EVALUATION OF THE HARBOR GENERATING STATION

WITH RESPECT TO THE ENVIRONMENTAL PROTEC TION AGENCY’S 316(b)

RULES FOR EXISTING FACILITIES

Prepared by

Alden Research Laboratory, Inc.: Nathaniel Olken, Civil Engineer

Jonathan L. Black, Biologist Thomas C. Cook, Director, Environmental Engineering

Electric Power Research Institute: Douglas A. Dixon, Manager, Fish Protection Program

for Los Angeles Department of Water and Power

334-04/E400F December 2004EVALUATION OF THE HARBOR GENERATING STATION

WITH RESPECT TO THE ENVIRONMENTAL PROTEC TION AGENCY’S 316(b)

RULES FOR EXISTING FACILITIES

Prepared by

Alden Research Laboratory, Inc.: Nathaniel Olken, Civil Engineer

Jonathan L. Black, Biologist Thomas C. Cook, Director, Environmental Engineering

Electric Power Research Institute: Douglas A. Dixon, Manager, Fish Protection Program

for Los Angeles Department of Water and Power

December 2004

ALDEN RESEARCH LABORATORY, INC. ENVIRONMENTAL SERVICES 30 Shrewsbury Street Holden, MA 01520ES-1 EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) has promulgated guidelines for the implementation of section 316(b) of the Clean Wa ter Act (CWA) for Phase II Existing Facilities (the Rule). The Rule uses national performan ce standards (reduction in impingement mortality of 80-95% and, in some cases, a re duction in entrainment of 60-90% , compared to a baseline), as a metric for measuring the effectiveness of compliance options.

The Electric Power Research Institute (EPRI) and Alden Research Laboratory, Inc. (Alden) (collectively referred to as “The Team”) have assessed which alternative technologies, operational measures, and/or restoration measures are likely to meet the performance standards, and the monetary impact associated with both th e implementation and operation of the identified alternatives and the permitting and monitoring associ ated with compliance. Based on this review of the Rule and the available data, Los Ange les Department of Water and Power’s (LADWP) Harbor Generating Station’s (H arbor) cooling water intake st ructure (CWIS) may be in compliance with the Rule. If CalEPA does not be lieve that Harbor is already in compliance or proposes more stringent standard s then LADWP may need to implement changes in the design and/or operation of the CWIS.

EPA will require Harbor Unit 5 to meet both the impingement mortality and entrainment reduction (IM&E) standards because it withdraws water from a tidal embayment and has a capacity utilization rate s greater than 15% (Un its 1, 2 & 5). No other units at Harbor use circulating water and should therefore alr eady be in compliance with the Rule.

The Team believes the current configuration of Harbor’s CWIS along with the existing flow reductions may meet the performa nce standards. Since California EPA (CalEPA) can require LADWP to meet more stringent standard, LADWP should review technological, operational, and/or restoration measures that have the pot ential to reduce IM&E. Since Harbor’s existing National Pollution Discharge Elimination Sy stem (NPDES) permit expires June 30, 2008, less than 4 years after the Rule was published in th e Federal Register, LADWP should apply for an extended permitting application schedule. LADWP should also begin gathering the information EPA requires for the permit application.

Technological and operational options that have po tential to meet the pe rformance standards and are practicable for installation at Harbor were identified. Selected opti ons were developed toallow preliminary cost estimates to be generated. These cost estimates take into account sitespecific factors that potentially increase or de crease installation and operating and maintenance (O&M) costs at Harbor. In additi on, the costs developed in this repo rt were compared to the cost EPA used in developing the National Costs for the Rule.

Some key findings of our preliminary analysis include:

• The design and operation of Units 1&2, 5 a nd 10-14 may provide Harbor with an 84% reduction in flow from a theoretical baseline if all eight units were designed and operated as once-through units. If only Units 1, 2, & 5 are considered, then the existing operationsES-2 would result in a flow reduction of 68%. Because flow and entrainment are directly proportional (assuming equal distribution of organisms), this flow reduction should reduce entrainment by greater than the 60% required by the Rule.

• The existing through-screen velo city at the traveling water sc reens is less than 0.5 ft/sec during normal plant operations. Harbor shoul d automatically meet the IM reduction standard via Compliance Alterna tive 1due to this low velocity.

• Two technological (fine-mesh Ristroph screens and narrow-sl ot wedgewire screens) and two operational options (existing operations and closed-cycle cooling) were considered to have potential for meeting the impingement mortality and entrainment reduction standards and were deemed pr acticable from an engineeri ng standpoint. As the existing CWIS should already meet the IM reduction standard, technol ogies that reduce only IM were not evaluated.

• Of the four options that could meet the en trainment reduction sta ndard, Alden estimates the annualized costs range from $0 for to maintain current operations to $3,206,000 for closed-cycle cooling.

• If the existing operations at Harbor do not meet the IM&E standard, replacing the existing screens with fine-mesh Ristroph screen s or narrow-slot wedge wire screens have the greatest potential to meet the standards. The annualized costs for these technologies are $486,000 for fine-mesh Ristroph screen and $470,000 for narrow- slot wedge wire

screens.

• In Appendix A of the Rule, EPA provided an annualized cost of $62,942, for Harbor to upgrade its CWISs with a fish protection t echnology (EPA 2004a). This cost was for meeting only the IM reduction standard by the addition of fish handling and return system to an existing traveling screen system . Since the Team believes that Harbor will be required to meet both the IM&E reduction standards, the cost had to be corrected using EPA’s cost correction formulas, resul ting in an annualized cost of $130,007. While this cost is less than half the cost for bot h the fine-mesh Ristroph screens and narrow-slot wedge wire screens, EPA has not defined “significantly greater th an.” Therefore, it is not possible to determine, with any certainty, wh en the “significantly greater than” threshold has been exceeded.

• Calculation of benefits is beyond the scope of this analysis. In addition, the existing entrainment data and most of the existing im pingement data was collected in the late 1970’s and may not meet the standards necessa ry for inclusion in the IM&E Study. Until the completion of the IM&E study, benefits asso ciated with each alternative may not be possible to calculate. Therefore, The Alde n did not determine if Harbor would qualify for a site-specific BTA determination via the Cost-Benefit test. Data from the late-1970s indicate that impingement at Harbor was re latively low. The Team believes that if current levels of impingement continue to be low, then benefits of IM&E reduction technologies may not justify their costs.ES-3 • Compliance Alternative 1 (IM standard) a nd Compliance Alternative 2 (entrainment) appear to be the most likely tracks by which LADWP could achieve compliance at Harbor.

• Monitoring and re-permitting costs for Har bor could be as high as $700,000 depending on the compliance alternative se lected and the level of testing that is requested by the Director.

As cited in the Rule, LADWP should be prepared to:

1. Collect Source Water Physical Data– LADWP may need to supplement existing salinity and temperature gradients and determine the intake’s area of influence for the CWISs.

2. Collect Cooling Water Intake Data – Most of the necessary information is available in previous 316(b) filings. Ho wever, LADWP should confir m the existing configuration and operating conditions of Harbo r’s CWIS with plant operators.

3. Develop a Proposal for Information Collecti on – LADWP would have to submit to EPA the combination of intake technologies, opera tional methods, and/or restoration measures being evaluated, the information that is to be collected, and any sampling plans for field studies being proposed.

4. Conduct the Impingement Mortality and En trainment Characteri zation Study (IM&E Study) – LADWP would need to sample the current rate of entrainment and possibly impingement, as well as study the survival of impinged organisms. Sampling over 1-2 years may be required to adequately charac terize the populations of organisms impinged and entrained at Harbor’s CWIS. Since Harbor ’s CWIS is significantly different than the “calculation baseline”, LADWP may want to co nduct additional sampling in front of the intake, to determine if the existing design of the CWIS provides a reduction in IM&E from the “calculation baseline”. LADWP should identify available data from federal and state resource agencies, colleges and universitie s, or other facilities in the vicinity of Harbor which may be used in addition to or in lieu of any waterbody sampling. EPA estimated the cost for such studies could as high as $963,501. Site-specific factors may increase or decrease these costs depending upon the intensity and duration of monitoring approved by California Environmenta l Protection Agency (CalEPA).

Depending on the compliance alterna tive chosen, LADWP may have to collect some or all of the information required in the Comprehensive Dem onstration Study (CDS). As part of these efforts, LADWP may have to:

a) Design and Construction Technology Plan (D &C Technology Plan) – This study will be used to determine the applicability and costs of different technologica l, operational, and restoration measures at Harbor . This study can be used in examining the potential for applying for a site-specific BTA determination.

b) Supply EPA with the Information to Support a Site-Specific Determination of BTA:ES-4 i) Compare the cost EPA used for your facility to the site-specific costs for meeting the performance standards.

ii) Calculate the benefits of each potential alternative (this involves calculating annual equivalent adult and production foregone losses relative to impingement and entrainment).

iii) Perform detailed BTA analysis for options to reduce both IM&E per performance standard requirement. LADWP should esti mate costs of technologies and monetize the benefits of impingement mortality and entrainment reductions. Cost-Cost and Cost-Benefit tests should be applied and th e results assessed. If the requirements of either the Cost-Cost or Cost-Benefit test s are satisfied, LADWP should negotiate with CalEPA for a site-specific BTA determinati on. If the cost of retrofitting the CWIS technologies is not “significan tly greater than” either EPA’s cost estimate or the monetized benefits that will be attaine d, the following additional actions will be required:

(1) Compare technology options (efficacy and co sts) with restor ation options and decide which combination of options is most appropriate at Harbor.

(2) If restoration is determined to be a vi able option, initiate consultation with CalEPA and others. Costs range from as low as $1 million (the cost for initial construction and development of Mirant ’s Chalk Point hatchery) to $14-20 million, the current estimate for wetland restoration by Duke Energy North America for fish losses at their Morro Bay, California plant.

(3) Initiate actions to reduce entrainment and potentially impingement at Harbor, directly via technology/operational altern atives or indirectly via restoration

measures.
(4) Monitor for a minimum of two years following the implementation of the chosen alternative(s) to verify full-scale performance of technologies, operational measures, and/or restoration measures implemented at Harbor. The cost to adequately verify performance ma y be in the $200,000 to $600,000 range.i Table of Contents

EXECUTIVE SUMMARY .......................................................................................................ES-1

Section 1 INTRODUCTION ......................................................................................................... ..1

Section 2 DESCRIPTION OF HARBOR GENERATING STATION...........................................6

2.1 Plant Features............................................................................................................. ..... 6 2.2 Intake Structures .......................................................................................................... ... 6 2.3 Existing Hydraulic Conditions........................................................................................ 7 2.4 Biological Considerations............................................................................................... 7 2.4.1 Characterization of Impingement and Entrainment at Harbor.................................... 7 2.4.2 Threatened, Endangered, or Other Protected Species................................................. 8 2.5 Evaluation of Existing Information ................................................................................ 9 2.5.1 Applicability of the Rule at Harbor ............................................................................ 9 2.5.2 Baseline Characterization ........................................................................................... 9

Section 3 ASSESSMENT OF FISH PROTECTION TECHNOLOGIES.....................................23

3.1 Evaluation Criteria........................................................................................................ 23 3.2 Identification of Intake Alternatives with Potential for Application ............................ 24 3.3 Reduced Flow Alternatives Selected ............................................................................ 28

Section 4 DETAILED EVALUATION OF ALTERNATIVES....................................................32

4.1 Assessment of Alternatives with Potential for Application.......................................... 32 4.2 Add Fine Mesh Ristroph Screen s to the Existing Screenhouse.................................... 32 4.3 Retrofit Intake with 0.5 mm Wedge Wire Screens....................................................... 34 4.4 Existing Operations....................................................................................................... 3 5 4.5 Retrofit Plant with Closed-Cycle Cooling System ....................................................... 36 Section 5 RESTORATION AS A 316(B) COMPLIANCE OPTION AT LADWP’S HARBOR GENERATING STATIONS .............................................................................................42 5.1 What Are the Implications of the Recent Court Ruling Regarding the Use of Restoration in the EPA Phase I Rule to Their Use in Phase II? ............................................... 42 5.2 Why Should LADWP Consider Restoration?............................................................... 43 5.3 Types of Restoration Ap plicable to §316(b)................................................................. 44 5.4 Role of Restoration in the EPA Phase II Rule .............................................................. 45 5.5 Potential Restoration Measures for LADWP’s Haynes, Harbor, and Scattergood Generating Stations............................................................................................................ ....... 47 5.6 Implementing a Restoration Program for LADWP’s Haynes, Harbor, and Scattergood Generating Stations............................................................................................................ ....... 54 5.7 Information That LADWP Must Submit ...................................................................... 59 5.8 Summary.................................................................................................................... ... 59

Section 6 ESTIMATED COSTS ...................................................................................................64

6.1 EPA Costs .................................................................................................................. ... 64 6.2 Estimated Costs for Technology Intake Alternatives ................................................... 66 6.3 Permitting and Monitoring Costs.................................................................................. 67ii 6.4 Cost-Cost Test............................................................................................................. .. 68 6.5 Cost-Benefit Test .......................................................................................................... 69

Section 7 CONCLUSIONS.......................................................................................................... ..74 7.1 Phase II Facility Determination .................................................................................... 74 7.2 Applicability of Compliance Alternatives .................................................................... 74 7.3 Compliance Methods .................................................................................................... 75 7.3.1 Technologies and Operational Measures.................................................................. 75 7.3.2 Restoration .............................................................................................................. .. 76 7.4 Site-Specific Compliance Deadline .............................................................................. 77 7.5 Overview of Compliance Options ................................................................................ 77

Section 8 REFERENCES ........................................................................................................... ...79 Appendix A OVERVIEW OF THE RULE.............................................................A-1 Appendix B OVERVIEW OF INTAKE TEC HNOLOGIES AVAILABLE FOR FISH

PROTECTION......................................................................................B-1 Appendix C OVERVIEW OF REDUCED FLOW OPTIONS FOR FISH PROTECTION......C-1iii List of Tables

Table 1-1 Applicable Nationa l Performance Standards Based On Waterbody Type, Capacity Utilization Rate, and Design In take Flow (EPA 2004a)......................................................... 4 Table 1-2 Alternative Methods for Complying with the Rule....................................................... 5 Table 2-1 Pertinent Project Data – Harbor Generating Station ................................................... 10 Table 2-2 Family, Scientific Name and Comm on Name of Species Collected at Harbor Generating Station ............................................................................................................. ... 13 Table 2-3 Diel Larvae Size Entrained at Har bor Generating Station from October 1978 through November 1979.................................................................................................................. ... 13 Table 2-4 Abundant Species Collected in Impingement Samples from October 1978 through November 1979 at Harbor Generating Station ..................................................................... 14 Table 2-5 California Department of Fish and Game Listed Endangered and Threatened Species (http://www.dfg.ca.gov/whda b/pdfs/TEAnimals.pdf))......................................................... 15 Table 2-6 EPA Definition of “Phase II Existing Facility”........................................................... 16 Table 2-7 Criteria for Eliminating the Entrai nment Reduction Standard at Harbor Generating Station ........................................................................................................................ ........... 16 Table 2-8 Criteria for “Calculation Baseline” ............................................................................. 17 Table 3-1 Initial Screening of Fish Protection Alternatives at Harbor ........................................ 30 Table 5-1 EPA Requirements for the Content of Restoration Plans............................................. 61 Table 6-1 EPA Cost Modules ..................................................................................................... .. 70 Table 6-2 Cost EPA Estimated for Harbor Generating Station .................................................... 71 Table 6-3 Alden’s Appraisal Level Co sts of Evaluated Alternatives........................................... 72 Table 6-4 Comparison of Alden and EPA Permitting and Monitoring Costs .............................. 73iv List of Figures

Figure 2-1 Vicinity Map of th e Harbor Generating Station......................................................... 18 Figure 2-2 Aerial Photo of Harbor Ge nerating Station................................................................ 19 Figure 2-3 Harbor Ge nerating Station Intake Structure — Plan.................................................. 20 Figure 2-4 Harbor Generating St ation Screenhouse — Section .................................................. 21 Figure 2-5 Harbor Generating Station Screenhouse — Plan....................................................... 22 Figure 4-1 Typical Ristr oph Screen – Section............................................................................. 39 Figure 4-2 0.5 mm We dge Wire — Plan ..................................................................................... 40 Figure 4-3 0.5 mm Wedge Wire — Section ................................................................................ 411 Section 1 INTRODUCTION

Section 316(b) of the Clean Wa ter Act (CWA) requires that th e location, design, construction, and capacity of a cooling water intake structur e (CWIS) reflect the “best technology available” (BTA) for minimizing adverse environmental impact (AEI). AEI from CWISs occurs 1 as the result of entrainment of small aquatic organi sms through the CWIS and into the cooling water system and the impingement of larger organism s on traveling water screens. On July 9, 2004, EPA published the final rule for implementi ng §316(b) of the CWA for Phase II Existing Facilities (the Rule). The Rule dictates the use of technological, operational, or restoration measures to achieve an 80–95% reduction in impi ngement mortality at a ll Phase II facilities and a 60–90% reduction in entrainment from a “calculation baseline” at some Phase II Facilities. A summary of the Rule is provided in Appendix A.

As defined in the Rule, a Phase II Existing Facilit y is any point source facility that commenced construction before January 17, 2002; has a design flow of greater than 50 million gallons per day (MGD), at least 25% of which is used for cooling purposes; and generates electric power primarily for transmission or sale. The “calculation baseline” is an estimate of impingement and entrainment that a facility could expect if it ha d a shoreline intake, a capacity commensurate with a once-through cooling system, and no impingement or entrainment reduc ing technologies.

In response to the Rule, Electric Power Res earch Institute (EPRI) and Alden Research Laboratory, Inc., (Alden) collectiv ely referred to as “the Team ,” have conducted a strategic assessment for Los Angeles Department of Water and Power (LADWP) Harbor Generating Station (Harbor). This assessment evaluates the impact of the Rule on Harbor, including potential cost-effective compliance alternatives, additional information collection needs, and relative budget impacts as a resu lt of studies and compliance a lternatives. LADWP could use some of the information contained in this report in the Comprehensive Demonstration Study (CDS) the Rule requires for submittal.

The major component of this analysis is a prel iminary evaluation of alte rnative fish protection technologies (EPA’s “Design and Constructi on Technologies”) to meet the applicable performance standards for Harbor and our disc ussion of approximate co sts for the feasible alternatives. As part of this alternatives an alysis, the Team reviewed operational options for meeting the applicable performance standards. This alternatives analysis is the first step in developing a compliance strategy and provides a ba sis for preparing the Proposal for Information Collection (PIC). In addition, the adequacy of existing biological information is evaluated for its ability to support technol ogy selection and meet the requirements of the CDS.

This report addresses technologies , operational changes, and rest oration measures that LADWP can implement to meet the Rule. EPA’s currently favored approach is to reduce total fish losses, which does not address AEI at th e population and ecosystem levels. Therefore, the Team does not address traditional measures of population and ecosystem hea lth, such as species diversity

1 EPA has not defined AEI but has implicitly defined it as impingement mortality and entrainment2 and richness, in this report. Further, EPA does not consider f actors that influence populations such as compensatory mechanisms, species fecu ndity, and natural mortality. Therefore, these factors are not considered here. However, if LADWP determines that restoration is more feasible, cost-effective, or environmentally sound then any other alternative at Harbor, then ecosystem health, as well as the status of fish community and populations in the source waterbody would be considered.

EPA’s preferred alternative involv es the use of nationa l performance standards, i.e., a reduction in impingement mortality (IM) of all life stages of fish and shellfish of 80–95% from the “calculation baseline,” and at some facilities, a reduction in entrainm ent (E) of all life stages of fish and shellfish by 60–90% from the “calcu lation baseline” (EPA 2004a § 125.94[b]). Facilities that EPA requires to meet the entrainm ent reduction standard are those facilities that have a capacity utilization rate 2 of 15% or greater and withdraw water from a tidal river, estuary, ocean, or Great Lake. IM&E stan dards also apply to facilities that are located on a freshwater river and have a design intake fl ow greater than 5% of the mean annual river flow. Table 1-1 shows a summary of which performance standards apply to each waterbody. Conditions applicable to Harbor ar e identified in bold.

The “calculation baseline” is an estimate of impi ngement mortality and entrainment that would occur at a facility designed a nd operated in the following ways:

• The cooling water system has been designed as a once-through system;

• The opening of the cooling water intake struct ure is located at the shoreline and the face of the standard 3/8-inch mesh traveling screen is oriented parallel to the shoreline near the surface of the source waterbody;

• The baseline practices, procedures, and structur al configuration are t hose that a facility would maintain in the absence of any structur al or operational contro ls that would reduce IM&E, including flow or velocity reductions , implemented in whole or in part for the purposes of reducing impingement mortality and/or entrainment.

EPA has allowed for some flexibility in the “cal culation baseline” at the facility level. EPA permits a facility to use the current level of IM&E as the “calculation baseline.” This could potentially streamline the permit application since the facility could determine the baseline using

2 The capacity utilization rate is 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. In cases where a fac ility has more than one intake structur e, and each intake structure provides cooling water exclusively to one or more generating units, a facility can calculate the capacity utilization rate separately for each intake structure based on the capacity utilization of th e units it services. EPA would then determine applicable requirements under this subpart separately for each intake structure. The facility should measure the average annual net generatio n over a 5-year period (if data are available) of representative operating conditions, unless it makes a binding commitment to maintain capacity utilization below 15% for the life of the permit, in which case it may base the rate on this commitm ent. For purposes of this regulation, the capacity utilization rate applies to only that portion of the facility that generates electricity for transmission or sale using a thermal cycle employing the steam water system as the thermodynamic medium (EPA 2004a §125.93).3 data collected during the IM&E Study (a requirem ent of the CDS, described below). A facility may also request that EPA use an alternative intake location (e.g., at a depth other than at or near the surface or at a location other th an the shoreline) if the utility can demonstrate to the Director that the alternate locatio n would correspond to a higher baseline level of IM and/or entrainment.

A facility may estimate the calculation baseline using: 1) historical IM&E data from a facility; 2) IM&E data from another facility with comp arable design, operational, and environmental conditions; 3) current biological data collected in the waterbody near the CWIS; 4) or current IM&E data collected at a facility.

There are five compliance alternatives that EPA indicates a facility may use to comply with §316(b) of the Clean Water Act. All five co mpliance options, as EPA states, will achieve a reduction in impingement mortality by 80–95% a nd in entrainment (where applicable) by 60– 90% (or equivalent environmental benefit) fo r all Phase II Existing Facilities. The five Compliance Alternatives are outlined in Table 1-2. A full discussion of each of the Alternatives along with their required studies is provided in Appendix A.

This report is structured in the following way:

• Section 2 – provides a summary of existing engineering and biological information for Harbor and assesses the potential for the ex isting design and operation of the CWIS to meet EPA’s impingement mortality (IM)reduction standard

• Section 3 – defines criteria for sele cting alternative fish pr otection technologies and selects technologies that hold the greatest potential to meet EPA’s IM reduction standard for further evaluation

• Section 4 – provides preliminary engineering info rmation for selected alternatives

• Section 5 – discusses restoration as an op tion for complying with the Rule

• Section 6 – estimates potential compliance co sts, including permitting, technology, and EPA costs

• Section 7 – summarizes the key findings of the Team’s analysis.

• Appendix A – presents an overview of the Rule

• Appendix B – summarizes alternative fi sh protection technologies

• Appendix C – discusses reduced flow options4 Table 1-1 Applicable National Perfor mance Standards Based On Waterbody Type, Capacity Utilization Rate, and Design Intake Flow (EPA 2004a)

Waterbody Type Capacity Utilization Rate Design Intake Flow Type of Performance Standard Less than 15% N/A Impingement mortality only

5% or less of mean annual flow Impingement mortality only Freshwater river or
stream Equal to or greater than 15%

Greater than 5% of mean annual flow Impingement mortality and entrainment
Less than 15% N/A Impingement mortality only Tidal river, estuary,

or ocean

Equal to or greater than 15% N/A Impingement mortality and entrainment
Less than 15% N/A Impingement mortality only Great Lakes

Equal to or greater than 15% N/A Impingement mortality and entrainment
Lakes or reservoirs N/A Increase in design intake flow must not disrupt thermal stratification except where it does not adversely affect the management of fisheries. Impingement mortality only5 Table 1-2 Alternative Methods for Complying with the Rule

Alternative Description Alternative 1 Flow commensurate with closed cy cle cooling (meets both IM&E standards) or the design through-screen velocity is less than 0.5 ft/s (meets only the IM standard) Alternative 2 Existing CWIS uses BTA to meet the performance standards Alternative 3 Proposed technologies, operationa l changes, and/or restoration will meet the performance standards Alternative 4 Install, operate, and properl y maintain an EPA approved technology Alternative 5 Apply a site-specific BTA determina tion by satisfying the requirements of the CostCost or Cost-Benefit tests6 Section 2 DESCRIPTION OF HARBOR GENERATING STATION

2.1 Plant Features

Harbor Generating Station (Harbor) is locate d in the Inner Los Angeles Harbor Complex (ILAHC), in Wilmington, CA near Long Beach, as shown on Figure 2-1. Harbor has eight natural gas fired units, seven of which do not re quire circulating water; only Unit 5 requires using circulating water from the harbor. Units 1 & 2 are combined cycle combustion turbines with heat recovery steam generators. Unit 5 is a steam turbine with two circulating water pumps that provide 83.5 cfs (75,000 gpm) of circulating water at full load. Units 10 - 14 are gas turbines equipped with cooling towers.

The total plant output is 470 MW with Units 1 & 2 rated at 80 MW each, Unit 5 rated at 75 MW, and Units 10 - 14 each rated at 47 MW. Unit 5 has a capacity factor of 23% based upon an average of years 2002 - 2003. Table 2-1 presen ts a summary of pe rtinent plant data.

Cooling water for Unit 5 is withdrawn from th e ILAHC through an intake structure along the shore of Slip 5, as shown in Figure 2-2. The mean water depth in front of the intakes is 21 ft. Trash racks are installed across th e CWIS to prevent large debris from entering the intake bays. To further screen the intake water, vertical traveling screens are located in a separate screenhouse structure located inland of Slip 5. Water is transporte d from the intake structure to the screenhouse via a 1,095 ft long, 8 ft diameter pipe. Two circulating water pumps are located downstream of the traveling wate r screens to convey screened flow to the condensers. The remainder of the facility’s water needs is prov ided by municipal raw water. Cooling water is transported through a 1,393 ft long pipe to the disc harge structure in L.A. Harbor’s West Basin (Figure 2-2). The location and setup of the disc harge canal prevents discharged water from recirculating into the intake.

2.2 Intake Structures

Harbor is located about 23 miles south of downtown Los Angeles. The CWIS is located in the northwest corner of the Slip 5, and is surrounded by rip rap 25 feet below the water surface at the face of the intake. A plan showing the intake st ructures at Harbor is provided on Figure 2-3.

The Unit 5 CWIS is equipped with six vertical ba r racks to deflect large debris. The bar racks are made out of 3/8 in. by 3 in. bars spaced 4.5 in. on center. Cleaning of the bar racks is done on a weekly basis or as needed. The screenhouse is located onshor e, and connected to the intake structure by two, 8 ft diameter pipes, each 1,095 ft long. Two vert ical cooling water pumps and six screenbays with traveling wa ter screens are located within the screenhouse. Two of the screens are in continual use, tw o are permanently blocked with stop logs, and the remaining two are used during high flow conditions (both pumps in operation). The water is then discharged into the West Basin of L.A. Harbor.

The screen bays are about 8.0 ft wide , with the invert at El. -16.0 ft. All elevations in this report correspond to Mean Sea Level (MSL). The top of the intake pipes are at El. -8.0 ft when they7 enter the screenhouse. The trav eling water screen is located about 33.5 ft downstream where the intake pipes enter the screenhouse. A secti on and plan of the screenhouse are shown on Figure 2-4 and Figure 2-5, respectively. The screens are 6 ft wide and extend from the invert of the screenhouse to the top deck. The screen baskets have a 3/8 in. square bronze wire mesh. The screens they are rotated once every 8 hour shif t for thirty minutes. A back wash system providing up to 800 gpm of cleaning water at 70 psig is used to remove debris from the screens. Screenwash water and debris are collected in a rectangular trough that flows into the ILAHC near the face of the intake.

Circulating water to Unit 5 is pr ovided by two single stag e vertical mixed flow pumps. The inlet of these pumps is at El. -14.5 ft. Each of th e pumps is rated at 305 hp at 514 rpm and provides a flow of 83.5 cfs (37,500 gpm) each.

2.3 Existing Hydraulic Conditions

The ILAHC is a heavily industrialized area, wi th the intake and disc harge sites entirely surrounded by dockage, wharves and container termin als. The bottom of the ILAHC is mainly covered in about 3 ft of silt. Within the ship channels the bottom had been dredged to a depth of about 60 ft.

Velocities inside the circulati ng water system were calculated us ing the facility design flow of 83.5 cfs, flow through all four scre en bays, and the mean lower lo w water level (El. 0.0 ft). Under these conditions, the water velocity at the face of the CWIS was calculated to be 0.2 ft/sec. With both circulating water pumps are ope rating, this approach ve locity corresponds to a through-screen velocity of about 0.4 ft/sec, assu ming a 50% net flow area that is typical for traveling water screens.

2.4 Biological Considerations

The selection of technologies for the protection of aquatic organisms at Harbor to meet the performance standard is based, in part, upon the species and life stages of fish in the vicinity of the intake, their temporal and spatial abundance, and their re lative hardiness. Since the performance standards are based upon a reduction over an existing baseline, some understanding of current fish and shellfish populations is requ ired to make predictions about the efficacy of potential technological options. Based on availa ble information, the species and life stages considered in this evaluation of alte rnatives are presented in Table 2-2.

2.4.1 Characterization of Impingemen t and Entrainment at Harbor

A complete year-long impingement and entrainment survey was conducted at Harbor by Intersea Research Corporation (Interse a) from October 1978 through N ovember 1979. A summary of fish species collected is pres ented in Table 2-2. During the study, entrainment samples were collected biweekly. Samples were collected wi th a 202 micron mesh plankton net at the intake conduit structure located w ithin slip number five along the East Basin Channel. Larvae and eggs washed from the nets were counted, preserved, and identified to the lowest possible taxonomic8 level. Larvae were measured to the nearest milli meter. Densities were measured in number of individuals per unit of vol ume of water sampled (m 3 ). The total annual entrainment of ichthyoplankton was calculated by multiplying biweek ly density estimates and the biweekly flow volumes then summing the results for the entire y ear. The most abundant eggs sampled were of the family Sciaenidae, with maximum density occurring from January to April. An estimated annual entrainment of 3.9 x 10 8 Sciaenidae eggs was determined. The most frequently entrained larvae were: anchovies (Engraulidae) — 1.0 x 10 8 , gobies (Gobiidae) — 5.2 x 10 8 , blenny ( Hypsoblennius spp

. ) — 1.9 x 10 7 , and white croaker ( Genyonemus lineatus) — 5.2 x 10 7 . The larvae entrained during the sample period were measured and placed into one of 4 size intervals with a percent composition being calculated fo r each interval and sp ecies, these data are presented in Table 2-3. The extent of the QA/QC that was applied to the entrainment data is not clear.

Impingement samples were collected over a to tal of 34, 24-hour samples collected weekly. Individuals were collected within debris baskets. Individuals co llected were weighted, measured to the nearest millimeter, and identified to the lowest possible taxonomic level. A total of 17,632 fish representing nine species were impinged during the study (Table 2-4). Four species comprise 86.7 % of the total impingement; Pacific pompano ( Peprilus simillimus ) 30.6 %, white croaker 28.9 %, queenfish 16.6 %, and shiner surfperch ( Cymatogaster aggregata ) 10.6 %. An estimated annual impingement of 164,225 was calculated for the 1978-79 study period.

Impingement samples were not collected in April or May of 1979. The reasoning for the absence of April and May impingement sample data is unknown. This missing data makes it difficult to demonstrate seasonal variability in im pingement. It is unclear as to what extent QA/QC was applied to the impingement data.

More recent biological information was gather ed at Harbor from September 2003 to January 2004. This four month study consisted of only th ree sample dates during which 52 fish were impinged. 90% of those impinged during the 2003-04 study consisted of ; Haller’s round ray ( Urolophus halleri ), giant kelpfish ( Heterostichus rostratus ), and black surfperch ( Embiotoca jacksoni ). These three species were not present among the most abundantly impinged species of the 1978-79 study. The limited sampling in 2003–2004 is insufficient to draw conclusions about the current species composition or abundance near Harbor. Harbor may need to monitor current levels of IM&E for a minimum of one year to determine if species composition and abundance has changed since the previous da ta were gathered. If I&E has changed substantially, a second year of sampling may be necessary to fulfill the requirement of the IM&E Study.

2.4.2 Threatened, Endangered, or Other Protected Species

As part of the IM&E stu dy, the Rule would require:

“Taxonomic identifications of all life stages of fish, shellfish, and any species protected under federal, state, or tribal law (includi ng threatened or endangered species) that are in the vicinity of the cooling water intake st ructure(s) and are susceptible to impingement and entrainment...” (§ 125.95 (b) (3) (1) EPA 2004a)9 Additionally, more stringen t requirements may be applied to a facility if any of these specified circumstances (e.g., located where additional prot ection is needed due to concerns regarding threatened, endangered, or protec ted species or habitat, or re garding migratory, sport, or commercial species) occur. The California Departme nt of Fish and Game maintains a list of the state’s threatened, endangered, a nd protected species (Table 2-5) . None of the species listed have appeared in entrainment or impinge ment samples collected at Harbor.

2.5 Evaluation of Existing Information

The current plant configuration plays an important role in determining what performance standard will apply to Harbor. If this configuration is not consistent with the “calculation baseline” then there may be potential to receive credit towards these standards.

2.5.1 Applicability of the Rule at Harbor

The Rule requires all Phase II Existing Facil ities to meet specific national performance standards, achieve an environmen tal benefit that is substantia lly similar to what would be achieved if a facility were to comply with the national performance standa rds, or, under certain circumstances, meet alternative, less restrictive, perf ormance standards. The requirements for a Phase II Existing Facility are listed in Table 2-6. Since Harbor meets all the criteria for a Phase II facility, it will be requi red to meet the applicable performance standards based on waterbody type and plant flow. The criteria used to dete rmine which performance standards are required for the CWIS are shown on Table 2-7. As Unit 5 withdraws water from the ILAHC, and has a capacity factor of greater than 15%, the current capacity factor is about 23% (Jan 2002 – Dec 2003), it would be required to meet both IM&E reduction standards.

2.5.2 Baseline Characterization

Harbor’s CWIS is not configured and/or ope rated in a manner consistent with EPA’s “calculation baseline” (Table 2-8). The top of the intake is located at El. -11.0 ft, which is 11 ft below the mean lower low water level, which causes water to be withdrawn from below the surface. The traveling screens also have a fi sh return which may offer some reduction in impingement mortality over what would be expected if Harbor were configured and operated in the “baseline” condition. The CWIS was designed to handle the flow for five units, as it is now only used buy one unit (Unit 5), which results in significantly less flow entering the CWIS. This reduced flow result in the velo cities within the CWIS and screenhouse being very low and may meet the IM reduction standard via Compliance A lternative 1. Any decrease in IM&E that can be attributed to these deviations from “calcula tion baseline” can be credited toward meeting the national performance standard.

Additional credit toward meeting th e standard can occur if a facil ity re-circulates a portion of its flow or has incorporated technolog ies, operational, or restoration measures specifically to reduce IM&E. From the information provided, the Harbor facility does not re-circulate any of the cooling water flow, does not have any other ope rational practices in place that may protect organisms susceptible to IM&E and has not enga ged in any restoration. Therefore, LADWP will be unable to take additional credit from these practices toward meeting the IM&E standards.10 Table 2-1 Pertinent Project Data – Harbor Generating Station

Location

161 Island Ave, Wilmington CA, 90774 Latitude: 33.7672 ° N Longitude: 118.2661 ° W Waterbody: L.A. Harbor Waterbody type: Tidal River
EPA ID #: DUT1138 NPDES ID #: CA0000361 Permit Expiration Date: June 10, 2008 Estimated project intake flow Maximum: 167 cfs (75,000 gpm) Minimum: 83.5 cfs (37,500 gpm) Plant Design: 167 cfs (75,000 gpm) Intake velocities: (approach) One Pump Trash racks: 0.2 ft/sec Screenbays: 0.4 ft/sec (2 screens in operation) Screenbays: 0.2 ft/sec (4 screens in operation) Two Pumps Trash racks: 0.3 ft/sec Screenbays: 0.4 ft/sec (4 screens in operation)

Water Level

Elevations HWL: El. 7.5 ft MLLW: El. 0.0 ft LWL: El. -1.7 ft MSL: El. 2.9 ft Water Depths

In front of CWIS Maximum: 42.5ft Minimum: 33.3ft MMLW: 35 ft MLS: 37.9 ft Project Structures

CWIS Location: Slip 5 L.A. Harbor Configuration: along shoreline Length: 56 ft Invert at face: El. -21.0 ft. Top: El: -11.0 ft Trash rack location: face of intake Trash rack material: 3/8 in. x 3 in. bars Trash rack spacing: 4.5 in. on-center Trash rack cleaning: weekly or when needed11 Table 2-1 Continued Intake Pipes Number: 2 Length: 1,095 ft Inner diameter: 8 ft Invert: El. -20.0 ft (CWIS) Invert: El. -16.0 ft ( screenhouse) Screenhouse Location: end of intake pipes Number of bays: 6 Bay width: 7 ft 11.5 in. Invert: El. -16.0 ft Top of structure: El. 12.0 ft Other info: 2 bays permanently blocked, 2 bays in use when one Circulating water Pump in use, 4 bays used when both pumps operating Traveling water screens Location: screenhouse Number: 6 Width: 6 ft Mesh material: bronze Mesh size and geometry: 3/8 in. sq. mesh Spray nozzle configuration: back wash Spray pressure: 70 psig Spray volume: 800 gpm (2pumps at 400gpm) Operation: rotated for 30 minutes every 8 hour shift Debris/fish return: rectangular trough Trough discharge: back into the ILAHC Circulating water pumps Number of pumps: 2 Types of pumps: vertical, single speed, mixed flow Pump inlet: El. -14.5 ft Invert: -19.0 ft Rating: 305 hp @ 514 rpm Flow per pump: 83.5 cfs (37,500 gpm) Flow with both pumps operating: 167 cfs (75,000 gpm) Cooling water discharge Location of discharge: Cooling water is transported th rough a 1,393 ft long pipe to the dischar g e structure in L.A. Harbor’s West Basin, p reventin g recirculation.12 Table 2-1 Continued

Power Generation

Fuel type: gas Facility output Units 1&2: 80 MW (each) Unit 5: 75 MW Unit 10-14: 47.5 MW (each) Facility total: 473 MW Operating mode: peaking Plant capacity factor: 32% (1999-2003 Units 1,2&5) Unit 1: 27% (Jan 02 – Dec 03) Unit 2: 28% (Jan 02 – Dec 03) Unit 5: 23% (Jan 02 – Dec 03) Estimated remaining plant life: 15 yrs Average annual energy: 658,458 MWh (gross) (1999-2003) 1,065945 MWh (net) (Jan 02 – Dec 03)13 Table 2-2 Family, Scientific Name and Co mmon Name of Species Collected at Harbor Generating Station

Family Scientific Name Common Name Blenniidae Hypsoblennius spp. Carangidae Trachurus symmetricus Pacific jack mackerel Embiotocidae Cymatogaster aggregata shiner surfperch Engraulis mordax northern anchovy Engraulidae Anchoa compressa deepbody anchovy Gobiidae Acanthogobies flavimanus yellowfin goby Genyonemus lineatus white croaker Sciaenidae Seriphus politus queenfish Stromateidae Peprilus simillimus Pacific pompano Urolophidae Urolophus halleri Haller's round ray

Table 2-3 Diel Larvae Size Entrained at Harbor Generating Station from October 1978 through November 1979

Percent Size Composition

Species Diel Mean Size (mm) Standard Deviation Total (No.Larvae/100

m 3 ) <5mm 5- 10mm 10- 15mm >15mm Day 15.6 8.2 139 3 25 42 30 anchovy Night 17.6 7.8 1,262 <1 10 52 38 Day 4.6 1.5 5,294 83 16 1 <1 gobies Night 4.4 1.4 18,159 92 7 2 <1 Day 4.3 1.0 136 90 10 0 0 blenny Night 4.3 1.0 118 91 9 0 0 Day 3.4 0.8 296 96 4 0 0 white croaker Night 4.2 2.2 369 81 15 4 014Table 2-4 Abundant Species Collected in Impingement Samples from October 1978 through November 1979 at HarborGenerating StationSpecies Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct NovTotalCollectedPercentCompositionPacificpompano274 689 1,902 2,104 94 - - 67 87 150 20 9 0 5,396 30.6whitecroaker177 140 100 2,223 498 - - 1,043 306 372 149 90 4 5,102 28.9queenfish 14 48 51 1,910 462 - - 248 103 70 17 12 0 2,935 16.6shinersurfperch79 138 36 660 183 - - 204 104 206 160 130 3 1,873 10.6yellowfingoby64 266 69 329 160 - - 84 26 46 26 58 2 1,130 6.4Pacific jackmackerel17 34 40 103 14 - - 5 5 4 11 4 0 237 1.3Haller’sround ray7 0 0 0 0 - - 3 41 48 42 22 0 163 0.9deepbodyanchovy4 8 0 57 33 - - 3 2 5 1 0 0 113 0.6northernanchovy1 2 8 0 0 - - 19 2 9 7 0 0 48 0.2Incidentalcatch31 92 16 273 67 - - 30 20 52 34 20 0 6353.9TotalNumberIndividuals668 1,417 2,222 7,659 1,511 - - 1,706 696 962 437 345 9 17,632 100PercentTotal Catch4%8%13%43%9%- -10%4%5%2%2%0%- April/ May data absent from survey15 Table 2-5 California Department of Fish and Game Listed Endangered and Threatened Species (http://www.dfg.ca.gov/ whdab/pdfs/TEAnimals.pdf) )

Family Scientific name Common name Salvelinus confluentus bull trout Oncorhynchus clarki henshawi Lahontan cutthroat trout Oncorhynchus mykiss whitei Little Kern golden trout Oncorhynchus tshawytscha Chinook salmon Oncorhynchus mykiss steelhead Oncorhynchus kisutch coho salmon Salmonidae

Oncorhynchus clarki seleniris Paiute cutthroat trout Deltistes luxatus Lost River sucker Catostomus microps Modoc sucker Xyrauchen texanus razorback sucker Catostomus santaanae Santa Ana sucker Catostomidae

Chasmistes brevirostris shortnose sucker Gila bicolor vaccaceps Cowhead Lake tui chub Gila bicolor mohavensis Mohave tui chub Gila bicolor snyderi Owens tui chub Cyrinidae

Gila elegans bonytail Cyprinodon salinus milleri Cottonball Marsh pupfish Cyprinodon macularius desert pupfish Cyprinodontidae

Cyprinodon radiosus owens pupfish Pogonichthys macrolepidotus Sacramento splittail Cyprinidae Ptylocheilus lucius Colorado squawfish Gobiidae Eucyclogobius newberryi tidewater goby Cottidae Cottus asperrimus rough sculpin Osmeridae Hypomesus transpacificus delta smelt Gasterosteidae Gasterosteus aculeatus williamsoni unarmored threespine stickleback16 Table 2-6 EPA Definition of “Phase II Existing Facility”

Rule Criteria Applicable to Harbor? point source that commenced construction before January 17, 2002 yes
generates electric power prim arily for transmission or sale yes

designed to withdraw ≥ 50 MGD a of water, at least 25% of which is used for cooling water yes

a MGD = millions of gallons per day

Table 2-7 Criteria for Eliminating the En trainment Reduction Standard at Harbor Generating Station

Rule Criteria Applicable to Harbor? facility is on a lake or reservoir (other than the Great Lakes) no

withdraws 5% or less of the mean annual flow of a freshwater river or stream 1 no

has a capacity utilizati on rate less than 15%. no

1. EPA requires percent of mean annual flow to be calcu lated on the facility level rather than for each individual CWIS17 Table 2-8 Criteria for “Calculation Baseline”

Rule Criteria Applicable to Harbor?The cooling water system has been designed as a oncethrough system yes

The face of the CWIS is located the shoreline and oriented parallel to the shoreline yes

The cooling water intake stru cture has standard 3/8-inch mesh yes

Traveling screen is oriented pa rallel to the shoreline near the surface of the source waterbody no
The cooling water intake st ructure does not have any modifications that woul d reduce IM&E (Ristroph screens, fish return) no

The facility does not have any operating controls to reduce IM&E (seasonal shut down, flow or velocity reduction) Unknown18Figure 2-1 Vicinity Map of the Harbor Generating Station19Figure 2-2 Aerial Photo ofHarbor Generating StationIntake StructureHarbor GeneratingStationDischarge Structure20Figure 2-3 Harbor GeneratingStation Intake Structure — Plan21Figure 2-4 Harbor GeneratingStation Screenhouse — Section22Figure 2-5 Harbor GeneratingStation Screenhouse — Plan23 Section 3 ASSESSMENT OF FISH PROT ECTION TECHNOLOGIES

3.1 Evaluation Criteria

EPA supports the adoption of national performa nce standards for existing CWISs (80-95% reduction in impingement mortality and 60-90% reduction in entrainment). Therefore, the primary criterion for evaluating alternative technol ogies is their ability to meet the performance standards. At Harbor, both impingement morta lity and entrainment reduction technologies were evaluated for the CWIS.

A summary of fish protec tion technologies available at water intakes is provided in Appendix B. An overview of modified circ ulating water pump operation opti ons and closed-cycle cooling systems is presented in Appendix C. Criteria used to evaluate alternatives that may be appropriate for application at Har bor are defined in this section. The screening process used for selecting alternatives for preliminary evalua tion is presented in Section 3.2 for intake technologies and Section 3.3 for reduced flow options.

The following general considerations were used to develop conceptual designs of alternative fish protection technologies for applicatio n at Harbor. The criteria were used to evaluate the relative advantages and disadvantages of ea ch fish protection alternative a nd to select for more detailed development those alternatives that have the greatest potential to effectively protect fish. The criteria represent key aspects to any ultimately successful protection strategy and are not listed in order of priority.

• Alternatives should be designed to redu ce impingement mortality of impingeable 3 fish by 80-95% from the “calculation baseline.”

• Alternatives should be desi gned to reduce entrainment by 60-90% from the “calculation baseline”.

• Alternatives should provide protection for species presen t in the harbor that are potentially susceptible to IM&E.

• The period of protection is y ear-round for impingement and 9 months for entrainment.

• Alternatives should take into considerat ion current project design features, as summarized in Table 2-1.

• Alternative designs should have suitable conditions for fish protection over the full range of intake flows and water depths at the CWIS.

3 EPA defines an entrainable organism as one that will pass through a 3/8 in. mesh. By contrast, an impingeable organism is one that will not pass through a 3/8 in. mesh.24 • Alternatives should provide effective protec tion throughout the entire water column such that they are effective with all spec ies potentially susceptible to IM&E.

• Alternatives should function under expected debris loadi ng and hydraulic conditions in the harbor (i.e., reasonable cleaning techniques are avai lable and demonstrated).

• Alternatives should preserve, to the extent possible, the exis ting civil/structural features.

• Alternatives should meet worker and public safety requirements.

• Alternatives should not a dversely impact navigation.

• Alternatives should be compatible with the ot her aesthetic and recreat ional features of the region.

3.2 Identification of Intake Alternativ es with Potential for Application

The available fish protection technologies were subjected to a screening process to determine which technologies offered the greatest potentia l for practical applica tion at Harbor. The screening identified those technologies that have potential for application, as presented below. Section 4 presents the development of the selected alternatives for proper installation at Harbor. The criteria used to screen the techno logies are discussed above in Section 3.1.

Table 3-1 summarizes results of th e preliminary screening of the fi sh protection technologies. A technology was considered to have poten tial for applicati on at Harbor if:

1. the technology has proven bi ological effectiveness,

2. the technology is available and does not requ ire further engineering development, and

3. the technology has engineering and/or biological advantages over the other technologies evaluated.

The screening process was as obj ective as possible. However, in assessing the potential for application of fish protection schemes under phy sical, hydraulic, and environmental conditions in which they may never before have been a pplied, The Team had to use best professional judgment based on experience.

A technology was deemed to have proven biological effectiveness if test data (preferably from full-scale application) were available that doc umented a technology’s effectiveness with one or more of the species present at that site. If engineering data exists in sufficient detail to develop a conceptual design and/or if the technology has been constructed at another site, it was judged to be an available technology. Each technology wa s qualitatively assessed to identify whether it had biological and/or engineering advantages over the other alternat ives. For example, an intake technology that has been proven effective at reducing losses for many species and under a variety of intake conditions ha s a biological advantage over one that has been proven effective with a few species or under limited intake cond itions. From an engineering perspective, one25 technology may hold an advantage over another if the civil/str uctural requirements for its installation are substantially less.

A few emerging technologies s how potential to meet the IM and potentially E reduction standards but have not been fully developed and/ or tested for biological effectiveness. These technologies include Beaudrey’s Fish Protection Solution (FPS TM ), Filtrex filter system, finemesh flat-panel screens with debris and organi sm collection (DOC) system, and Geiger’s Multi DiscTM Screening System.

• Beaudrey’s FPS TM system consists of a fine-mesh fixed screen with a fish collection scope positioned below the water’s surface. The collection scope tr avels along the screen face, collecting fish and debris, with suction provided by a fish pump.

• Filtrex filter system consists of filter “candles” approximate ly 5 inches long made of plastic wafers stacked and fastened togeth er with a central spring. Groves between stacked wafers provide filtration from 5 to 40 microns, and the flow capacity of each candle is approximately 10 gpm at a headloss of 4 feet. Filter candles are assembled together on 3 ft by 3 ft modules with filte r arrays on three sides and cleaned using a backwash system. During backwashing, the st acked wafers are allo wed to separate by compression of the central spring, and the back wash flow removes debris. Debris and fish then float downstream of the filter modules to a bypass pump and return system.

• Debris Organism Collection (DOC) System c onsists of flat panel 0.5 mm screens, a debris and organism collection nozzle, a fish pump, and fish return troughs and piping. The collection nozzle would be located close to the flat panel screen face just below the water’s surface and would remove debris and impinged fish from the screens. Submerged fish pumps would create sucti on for each nozzle. The fish pumps would discharge fish and debris through piping and/ or troughs back to the source waterbody. High-pressure spray wash headers and debris troughs would be locate d at deck level for additional debris removal for each screen.

• The Geiger Multi DiscTM Screening System cons ists of a single-pass, front-wash, vertical screen with fish handling capabilities. This design results in a “zero carryover” fish/debris condition. Mesh size and material (e.g. woven mesh or perforated plate) and screen rotation speed can be de signed for site-specific needs.

The technologies above could pr ove effective in meeting the IM&E reduction standard. However, the Team has not included them for fu rther evaluation because they have not been fully developed or have not been biologically proven.

Based on the literature summari zed in Appendix B, the following concepts are considered to have limited or no proven biological effectivenes s (i.e., they have not substantially reduced entrainment or impingement in past app lications as indicated in Table 3-1):

• Infrasound

• Mercury lights26 • Chemicals

• Electric screens

• Water jet curtains

• Hanging chains

• Visual keys

• Inclined plane screens

• Submerged traveling water screens

As discussed in Appendix B, other behavioral barri ers have been shown to repel or attract fish by eliciting a response to a particular stimulus. In particular, sound, str obe lights, and air bubble curtains have been shown to effectively repe l several species of fi sh. However, these technologies are only effective w ith fish in later life stages, since larval fish do not have sufficient motility to overcome the flow. Therefore, behavioral barriers ca nnot be considered as alternatives to address entrainment at Harbor.

Behavioral barriers to prot ect juvenile and adult fish have been the subject of extensive research. The use of strobe light to elic it a behavioral response is supported by the results of laboratory and cage test studies that have demonstrated stro ng avoidance by several fish species to strobe light. Strobe lights have been evaluated for repe lling or guiding juvenile and adult fish away from water intakes (EPRI 1994, 1999) and, in many cases, towards bypasses for transport to a safe release location. There is some evidence that combining strobe lights with an air bubble curtain can provide effective fish deterrence. However, results have been species- and sitespecific.

The focus of recent studies involving underwater sound technologies has been on the use of lowand high-frequency acoustic systems that were no t available for commercial use until the 1990s. High-frequency (120 kHz) sound has been shown to effectively and repeatedly repel members of the genus Alosa (American shad, alewife, and blueback herring) at sites throughout the U. S. (Ploskey et al. 1995; Dunning 1995; Consolidated Edison 1994). Ot her studies have not shown sound to be consistently effective in repelling species such as largemouth bass, smallmouth bass, yellow perch, walleye, rainbow trout (EPRI 1998) , gizzard shad, Atla ntic herring, and bay anchovy (Consolidated Edison 1994).

Based on the results of behavioral barrier st udies conducted over the past 30 years, a hybrid barrier consisting of light, sound, a nd air bubbles would be most eff ective on Alosids. Little or no information is available on the potential effect iveness of a hybrid barrier with several of the numerically dominant species at Harbor. Given that Alosids abse nt from the fish assemblage impinged at Harbor, a hybrid ba rrier would not reduce impingement to a level that meets the impingement mortality reduction standard and thus these types of barriers were removed from further consideration at Harbor.

The existing intake at Harbor incorporate 3/8 i n. square mesh traveling water screens that would be relatively easy to modify for installation of Ristroph screens. Ri stroph screens are very similar to conventional traveling water screens ex cept they are designed with extra features to collect and transport impinged organisms safely back to the waterbody. Fine-mesh Ristroph screens have the potential to meet both standard s, while coarse-mesh Ri stroph screens may meet27 only the impingement morality standard. In addition, Ristroph screens are designed for continuous operation to minimize impingement duration. Continuous rotation along with the associated spraywashes provides Ristroph screens with an automa tic screen-cleaning feature. This gives them an engineering advantage over fixed screens, barr ier nets, and bar rack barriers, all of which would require an additional cleani ng system. Fine mesh Ristroph screens can be considered a viable alterna tive for reducing both IM&E.

If only the entrainment standard needs to be met at Harbor fine mesh screen overlays could be used. These screens would be more cost effec tive than Ristroph screens as they would use the existing traveling water screens modified to accept a fine mesh screen material. However, these screens would not include the Ristroph fish handling and return components. Fine mesh traveling screens would meet the word of th e Rule by significantly reducing entrainment numbers. Impingement mortality of entrainable organisms off of fine mesh traveling screens, however, are expected to be near 100%, and w ould, therefore have no net benefit. The Team does not expect CalEPA would accept changing an entrainment issue into and impingement issue. As a result fine mesh traveling screens ar e not considered a viable option for Harbor.

Modification of the screenhouse to incorporate physical barriers or other diversion systems to prevent entrainment and impingement mortality w ould be difficult. Rotary drum screens and porous dikes require a much larger area than conv entional traveling screens because of the lower design velocity. Rotary drum sc reens are typically installed in channels where water elevations are relatively constant and water depths are less than 12 ft, whic h is less than the water depth near the Harbor intake. Bar rack barriers are typi cally designed to have spacing greater than 1 in. and would not be effective in preventing the entrainment of early life stages. They may, however, be effective at reducing impingement.

The Modular Inclined Screen (MIS) and Eicher screen have a biol ogical and engineering advantage over louvers, angled bar racks, and an gled screens in preventing impingement. Both screens offer the potential to effectively divert mo st species by using smaller structures than the other screen concepts. The MIS, for example, is designed to operate at ve locities up to 10 ft/sec. However, the MIS has not been shown to protect larval fish, and the Eich er screen is designed for installation in hydroelectric pr oject penstocks. Therefore, th ese diversion technologies are not applicable to Harbor where impingeme nt and entrainment are both of concern.

The existing intake could be modified to inco rporate cylindrical wedge wire screens, thus providing this technology with an engineering ad vantage over the porous di ke, infiltration intake, and bar rack barriers (Table 3-1). Wedge wire screens also have cl eaning features that give them an advantage over other fixed scr eens and barrier nets that are more difficult to maintain. This cleaning feature requires the presence of a sweepi ng current to be effective. Cylindrical wedge wire screens have a biological advantage in that they can exclude more life stages from intake water than conventional sc reens and bar racks. For this reas on, wedge wire screens have been included in the preliminary evaluation for Harbor.

Aquatic filter barriers (AFB) could perform a similar function to fine mesh traveling water screens. The AFB has an engineering advantag e over barrier nets rela tive to cleaning (Table 3-1). An AFB has two layers of material with an air purge system installe d between the layers to28 permit automatic cleaning of accumulated silt and debris. This cleaning system can also free impinged fish larvae and other non-motile life stag es. The flow approaching an AFB is currently limited to10 gpm/ft 2 . Harbor would require about 7,500 ft 2 of AFB to achieve this velocity. An AFB at Harbor would have to be approximately 225ft long, assuming a 33 ft average low water depth in front of the intake structure. Placing an AFB in the ILAH would interfere with shipping activities. Therefore, an AFB is not considered a viable alternative for preliminary evaluation for Harbor.

Fine mesh barrier nets (<0.5mm) are easily foul ed by silt and algae, require labor-intensive cleaning, and are considered expe rimental for reducing entrainment at this time. However, coarse mesh nets could reduce impingement if th ey were installed in a low velocity zone and periodically cleaned to remove debris accumulation and biofouling growth. A barrier net at Harbor, however, would have to be installed in the ILAHC and w ould interfere with shipping in the channel. Additionally the design through-screen velocity of the existing traveling water screens appears to be less than 0.5 ft/sec, ther efore automatically meeting the IM performance standard via Compliance Alterna tive 1. A barrier net is theref ore not considered a viable alternative for preliminary evaluation at Harbor.

The preliminary screening of in take technologies available for fish protection (Table 3-1) indicates that two intake alternatives have the greatest potential for a pplication to reduce fish impingement mortality and entrainment at Harbor:

• Expanded intakes with fine mesh 4 Ristroph screens

• Wedge wire screens with 0.5 mm openings

No technologies were evaluated to reduce only IM as Harbor should already meat the IM standard by having design through-screen velocities of le ss that 0.5 ft/sec

The two selected alternative technologies have proven biolog ical effectiveness and have advantages over other concepts, as presented in Table 3-1. All of these concepts have been previously developed to a level such that a conceptual design could be prepared for possible application of the technology at Harbor subs equent to this study. Therefore, these two alternatives have been carried fo rward to a preliminary evaluation, as presented in Section 4. In addition to these CWIS technology alternatives, fl ow reduction options th at are considered to have the potential for applicati on at Harbor to reduce entrainm ent are discussed in Section 3.3.

3.3 Reduced Flow Alternatives Selected

Two flow reduction options have be en identified to reduce entrainment and, to a lesser extent, impingement at Harbor:

4 The term “fine mesh,” as used in this document, refers to 0.5 mm (0.02 in.) square woven mesh.29 • Existing reduced flow operation

• Install an additional closed-loop cooling system

Harbor currently has only one unit, Unit 5 opera ting, with once-through cooling. Unit 5 operates off of waste heat from Units 1 & 2. Unit 3 a nd 4 have been retired and Units 10-14 are simple cycle turbines with cooling towers. Designing Units 1, 2 & 10-14 withou t once-through cooling may already result in a reduction in flow from a hypothetical baseline with all units operating as once-through that will meet the entrainment reduc tion standard. However, closed-cycle cooling could provide an even greater reduction in entrainment than the current plant design.

Mechanical or natural draft wet towers would require less modifica tion to the existing circulating water system piping and less real estate than dry cooling towers. The costs for construction of a wet mechanical cooling tower are about 60% less than the natural wet cooling tower. Natural wet cooling towers require less energy to ope rate and have lower annual costs than a wet mechanical draft tower. However, wet mechani cal draft tower generally have less aesthetic and air quality impacts than natura l draft wet towers. The area surrounding Harbor is heavily industrialized and would probably not be affect ed by compromised air quality, the site is however located near the city of Los Angeles. Since aesthetics and air quality issues would probably be greater for natural draft towers than for mechanical draft towers, wet mechanical draft towers were chosen as the closed-cycle cooling system option for preliminary evaluation.30 Table 3-1 Initial Screening of Fish Protection Alternatives at Harbor

Concept Biological Effectiveness Proven Engineering Alternative

Available Advantages Over Other

Concepts Potential for Application at Harbor

Behavioral Barriers

Sound Yes Yes No No

Infrasound No Yes Yes No
Strobe Lights Yes Yes No No
Mercury Lights No Yes Yes No

Chemicals No No No No

Electric Screens No Yes No No

Air Bubble Curtain Yes Yes No No

Water Jet Curtain No Yes No No
Hanging Chains No Yes No No
Visual Keys No Yes No No

Hybrid Barriers (e.g. strobe light / air bubble curtain) No No No No

Physical Barriers

Fixed Screens Yes Yes No No
Traveling Water Screens Yes Yes No No

Rotary Drum Screens Yes Yes No No

Barrier Net Yes No No No

Bar Rack Barrier Yes Yes No No

Infiltration Intakes Yes Yes No No

Porous Dike Yes Yes No No
Aquatic Filter Barrier Yes Yes No No
Cylindrical Wedge Wire Screen Intakes Yes Yes Yes Yes31 Table 3-1 (continued)

Concept Biological Effectiveness Proven Engineering Alternative

Available Advantages Over Other

Concepts Potential for Application at Harbor

Collection Systems

Modified Traveling (Ristroph) Screens Yes Yes Yes Yes

Fish Pumps Yes Yes No No

Diversion Systems

Louvers/Angled Bar Racks Yes Yes No No
Angled Screens (Fixed or Traveling) Yes Yes No No

Angled Rotary Drum Screens Yes Yes No No

Inclined Plane Screens No Yes No No

Eicher Screen Yes Yes No No

Modular Inclined Screens Yes Yes No No
Submerged Traveling Screens No Yes No No

Modifications to Reduce Intake Flow

Modified Pump Operation Yes Yes No No

Install Variable Speed Drivers Yes Yes No No

Install Closed-Loop Cooling System (Mechanical & Natural Draft and Dry Cooling Towers) Yes Yes Yes Yes32 Section 4 DETAILED EVALUATION OF ALTERNATIVES

4.1 Assessment of Alternatives wi th Potential for Application

Based on the screening of intake technologies and flow reduction options presented in Section 3, two alternatives utilizing intake technologies for fish protection and tw o flow reduction options were selected as having potential for effective application at Harbor. The alternatives selected for more detailed evaluation are:

Alternative 1 – Add Fine Mesh Ristr oph Screens to the Existing Screenhouse

Alternative 2 – Retrofit Intake with 0.5 mm Wedge Wire Screens

Alternative 3 – Existing Reduced Flow Operation

Alternative 4 – Retrofit Plant with Closed-Cycle Cooling System

Preliminary conceptual designs were prepared for each of these alternatives to serve as a basis for evaluation and cost estimates. The followi ng sections present for each option: (1) the technical considerations associated with the de sign, installation, operation, and maintenance, (2) estimated construction costs and operating and ma intenance costs, including replacement power, and (3) estimated biological effectiveness.

4.2 Add Fine Mesh Ristroph Screens to the Existing Screenhouse

Fine mesh Ristroph screens coul d be used to reduce both IM&E at Harbor. The velocity approaching the existing traveling screens was calc ulated to be 0.2 ft/sec, significantly less than 0.5 ft/sec, which is the design velocity Alden consid ers to be sufficiently pr otective of fish eggs and larvae. Therefore, the existing screenbays could be used and the screenhouse would not have to be expanded to lower the approach veloci ties to 0.5 ft/sec. This velocity assumes that equal flow is going through all four of the operati ng screens. If in f act flow is only passing through two of the operating travel ing screens the velocity would be about 0.4 ft/sec, which is still less than the Alden design value.

The screen baskets would have 0.5 mm mesh. Each screen basket would have a fish bucket to hold collected organisms in about 2 in. of water while they are lifted to the fish recovery system. A low pressure spray (10 psig) would be used to gently remove the fi sh from the fish holding buckets into a separate fish slui ce that would return fish to th e West Basin. A conventional high pressure wash would then remove debris into a separate debris sluice. A section of a typical Ristroph screen is shown on Figure 4-1.

New fish and debris troughs w ould be mounted above deck level on the descending side of the screens. These troughs would co mbine into a single trough and flow into the West Basin of the ILAH outside of the CWIS’ zone of influence. This trough would be about 2,500 ft long. The33 existing screenwash pumps would be used to provide water for the hi gh pressure spraywash headers. New screenwash pumps would be inst alled for the low pressure spraywash headers.

Removal of the existing traveli ng water screens and installation of the new Ristroph screens would require about two weeks per screen to remove the original screen, install the new screens, and complete mechanical and electrical work. The new fish and debris trough could be built simultaneously to the installation of the screens. These CWIS modifications would not require Harbor to be shutdown during the construction.

Operating and maintenance demands for the new screenhouse would be greater than the O&M requirements for the existing CWIS. Continuous operation of the fine mesh screens and operation of the screenwash pumps would require 1,050 MWh per year.

Fine mesh screens at Harbor would decrease the entrainment of larval fish through the circulating water system. The effectiveness of th is system would depend on the species of larvae and eggs currently present near the Harbor CWIS s. Retention can be estimated using the head capsule depth (HCD) (the widest non-compressi ble portion of the larval body). When head capsules are larger than the nominal opening size of a fine mesh screen, they will not be entrained. With larvae, the orient ation of the organism at the time they encounter the screen will also influence the likelihood of being retained. Based on the en trainment sampling conducted at Harbor in 1978-79, any fish prot ection technology that substantially reduces the entrainment of sciaenid eggs, larval gobies, and larval anchovies should prov ide sufficient protection to the potentially entrainable organisms at Harbor to meet the entrainment standard.

A second factor to consider with fine mesh screen s is that fish that we re previously entrained would be impinged. These screens are beneficial from an organism protection viewpoint only if impingement survival for important species and life stages is relatively high and exceeds entrainment survival levels. Post-impingement su rvival of fish is very species-specific. For example, past studies have show n that other gobies have had vari able survival when exposed to traveling screens. Reported extended survival of naked goby ( Gobiosoma bosc ) exposed to a standard screen was 18% (Oyster Creek, juveniles, Tatham et al. 1978) whereas the same species and life stage exposed to Ristr oph screens at Roseton Station had 100% survival. Reported survival of another goby sp ecies, the seaboard goby ( Gobiosoma ginsburgi ), was 74.5% when exposed to fine-mesh Ristroph screens (Oyster Cree k, juveniles, Davis et al. 1988). In contrast, engraulids (bay anchovy) have relatively lo w survival following impingement on fine mesh screens. Although there is no post-impingement survival data available for white croaker, extended survival of other juven ile Sciaenids (excluding freshwater drum) is moderate to high. The range of survival extends from 0 to 100% with a mean reported survival of 66.6% with a standard error of 4.2.

Use of fine mesh screens is therefore a tradeoff. Some species and life stages may benefit, while others may experience greater mortality than under existing conditions. From a compliance standpoint, the Rule considers entr ainable organisms to be those th at will pass through a standard 3/8 in. mesh. After a fine mesh screen is a dded to an intake, those organisms that were previously entrained are still considered to be “entrainable.” As such, the mortality of these impinged “entrainable” organisms is not considered. The Rule remains unclear about whether34 the survival of organisms prev ented from entrainment should be a concern. The Team believes that since EPA implies that impingement and entrainment are potential causes of AEI, entrainment survival must be considered.

4.3 Retrofit Intake with 0.5 mm Wedge Wire Screens

Fine mesh cylindrical wedge wire screens coul d be installed to reduce fish entrainment and impingement. Cooling water would be conveye d through submerged, cylindrical wedge wire screens mounted on a bulkhead wall in front of the existing CWIS. The bulkhead would be constructed to form a common plenum in front of the existing intakes. The existing trash racks and traveling water scre ens would no longer be needed with the option.

This bulkhead would be placed about 30 ft in front of the existing CWIS, within the area enclosed by the pile dolphins, as shown on Figur e 4-2. The screens would be mounted on this wall in three rows of 10 screens. The minimum water depth at the screen s has been assumed to be approximately 35 ft during mean lower low wate r levels. If the actual water depth in the vicinity of the screens is less than 28.5 ft, there would not be sufficient water depth for this configuration.

The screens would have a 0.5 mm screen slot si ze and would be designe d for a maximum slot velocity of 0.5 ft/sec. Thirty, T-36 screens, as shown on Figure 4-3, would be required to screen the entire facility flow. Each screen would be 3.0 ft in diameter and T-shaped, with an overall length of about 9.5 ft. Two screen sections, each about 3.0 ft long, would be located on each side of a 3.5 ft long T section. The outlet pipe would be 2.0 ft in diameter and located in the middle of the T section. The outlet of the T would be flanged for connection the bulkhead wall.

An air backwash system, complete with neces sary air compressors and controls, would be installed to clean the wedge wire screens. The air compressors a nd controls would be located in a new shelter near the existing CWIS. The air piping to each wedge wire screen would be installed along the top th e bulkhead wall. The air backwash system could be an effective method for maintaining the wedge wire screens at Harbor in a clean condition. The effectiveness of this cleaning would be contingent on th e local tidal currents ability to transport debris flushed away from the screens. Periodic manual cleaning fo r removal of biofouling agents would likely be
necessary.

Approach velocities at the wedge wire screens w ould be similar to curren ts in the area. The maximum through-slot velocity would not exceed 0.5 ft/sec. Therefore, the screens should be highly protective of juvenile and adult fish. Head losses through the screens should not exceed 1 ft (assuming biofouling would not be a significant problem). Except for the slightly lower water level, flow characteristics in the existing scre enbays would not change. Flow patterns to the pumps would not change from the existing conditions.

Shutdown of unit during construction would not be necessary. Unit 5 could operate fully during construction of the concrete bulkhead wall, as long as a section of the wall was left open to allow flow to the screenhouse. Once the wall was comp leted the screens could be installed and made operational one at a time.35 Installation of the cylindrical wedge wire scr eens would eliminate the need for operation and maintenance of the existing traveling water screen s. If the potential for wind-blown debris is high, then a roof could be installed over th e plenum. Maintenance requirements for the circulating water pumps with the wedge wire sc reens in place would not change. Additional operation and maintenance efforts associated with the wedge wire screens would entail approximately 43 MWh per year. Facility pers onnel would be require d to operate the air compressors and monitor backwashing operation to maintain the air supply equipment. Semiannual inspections by divers would be necessa ry to identify any damage or debris build up that could affect plant operati ons and to verify effective cleaning by the air backwash system. These inspections would take approximately 2 da ys using a three-man diving crew working from a workboat.

Physical size and behavior impact the effec tiveness of wedge wire screens to prevent the entrainment and impingement of the early life stages of fish. Physical exclus ion of fish with fine mesh screens is achieved when the openings to th e screen are smaller than the head capsule of the larvae being protected. Therefor e, head capsule depth can be used to determine if larvae can fit though an opening of a certain size. The slotte d wedge wire design is more conducive to fish passage than a woven mesh of th e same nominal opening size. Un like with fine mesh screens, however, hydraulic conditions in the vicinity of th e wedge wire screens may stimulate rheotactic responses in the larvae causing them to swim away from the screen s. Species-specific behavior will also impact the likelihood of entrainment a nd impingement. For example, Weisberg et al. (1984) observed that naked goby larvae were more susceptible to entrainment than bay anchovy, in part, due to their tendency to prefer structur es. Gobies were observed swimming very close to the screens and feeding on detritus drawn towards the screens.

This wedge wire screen option will meet the impingement mortality reduction standard, because the design through-screen velocity is 0.5 ft/sec. or less (Compliance Option 1). Their ability to meet the entrainment reduction standard will be based upon the results of verification monitoring required by the CDS.

Recent laboratory evaluations of wedge wire screens indicate that 0.5 mm screens can be effective in reducing entrainment and impingement of larval fish and eggs (EPRI 2003b). With the exception of rainbow smelt, 0.5 mm wedge wire screens configur ed for slot velocities of 0.15 m/sec, entrainment was 10.1% or less (alewife, winter flounder, white su cker, bluegill, striped bass, and yellow perch) when ambient curren ts were 0.15 m/sec or greater (EPRI 2003b). Rainbow smelt larval entrainment with a slot opening of 0.5 mm and slot velocity of 0.15 m/s was 75.0, 67.3, and 25.3% at channel velocities of 0.08, 0.15, and 0.30 m/s respectively. During the laboratory study, the eggs and larvae were re leased directly in front of the screens. Therefore, the entrainment rates observed are potent ially higher than what would be expected in the field. Therefore, the screens, as designe d, should be protective of fish at Harbor.

4.4 Existing Operations

Harbor currently has seven units in operation, only one requiring cooling water. Units 1&2 are combined cycle units, operating off of the wa ste heat from Unit 5 and do not require any additional cooling water. Unit 1&2 produce a co mbined total of 160 MW. Unit 5 is a 75 MW,36 steam turbine with once through cooling. Units 10 -14 are gas turbines with cooling towers and have a combined output of 240 MW . The total combined unit out put of Harbor is 473 MW. Assuming that flow is roughly pr oportion to generation, Alden be lieves that current facility operations reduce flow by 84% from a hypothetical baseline flow with a ll units operating with once-through cooling. If only Units 1, 2 & 5, the un its that make up the Harbor Steam Plant, are considered, Unit 5 flow would be about 32% of the total three unit flow, if all unit have oncethrough cooling, thereby reduc ing entrainment by 68%.

The CWIS and screenhouse at Harbor were desi gned for five units with once-through cooling. Since only Unit 5 currently withdraws water th rough the CWIS, the flow through the CWIS has been greatly reduced from its original desi gn flow. Under current operations only one circulating water pump is used during normal ope ration, with the second pump held on reserve for use if there are problems with the un it (e.g. vacuum problems). Based on one pump operation and flow through four screenbays, the through-screen velocity was estimated to be about 0.4 ft/sec . This velocity will meet th e IM standard via Compliance Alternative 1 (0.5 ft/sec through-screen velocity).

Continuing current operations would entail no construction activities or related outages. Operation and maintenance may incr ease as four traveling water sc reens would have to be used regularly. Maintaining current ope rating procedures with the exis ting intake structure would not create any additional adverse air, water, land, or energy resource impacts on the environment.

4.5 Retrofit Plant with Closed-Cycle Cooling System

Retrofitting the once-through coolin g water system with a closed -cycle cooling system would reduce water withdrawal from th e ILAHC for Harbor’s cooling sy stems. The average amount of make-up water for cooling towers would be appr oximately 5 cfs (about 3.0% of the once-through cooling water requirement), with a commensurate reduction in organism entrainment. As Harbor would be withdrawing saline wa ter the actual amount of water needed may be higher depending on the cycles or concentration required. Recl aimed water from a nearby LA City Publicly Owned Treatment Works (POTW) could also be used to provide makeup water for cooling towers. An evaluation of cooling tower cost s for retrofitting existing power facilities was provided in EPRI’s report entit led “Cooling System Retrofit Costs Analysis” prepared in July 2002. This report was prepared in response to the EPA Rulemaking. This study was conducted to provide generalized methods and supporting data for estimating the cost of retrofitting existing facilities with re-circula ting systems (EPRI 2002a).

The EPRI report (2002a) developed the likely costs for “all cooling towers.” To develop these costs, three assumptions were made:

1. The addition of a cooling tower would connect to the existing condenser so circulating water rates would not change.

2. Portions of the existing condenser conduit systems could be used, even though some modifications may be required.37 3. The cost methodology is based on new facilities and was adjusted using multiplying factors to determine the cost of retrofitting an existing facility.

Using these assumptions, the costs for retrofitting a cooling tower to an existing facility were broken down into easy, average, and difficult retrof itting costs. These three cost levels are based mainly on site-specific factors (EPRI 2002a).

A mechanical or natural draft c ooling tower could be retrofitted to meet the cooling requirements of Harbor. For the purpose of this evaluation, Alden has assumed that a mechanical draft tower would be installed at the site. Because Harbor is located near Los Angeles, plume abatement measures may be needed, and therefore the site ha s been classified as a difficult site to install cooling towers. This cost does not take into consideration costs associated with piping reclaimed water to the facility.

Most of the condenser and coo ling system components inside the turbine building would remain intact and would use approximately the same condens er flows. Cooling water, which is currently discharged into the West Basin, would be redire cted into a wet pit pump structure where booster pumps would convey cooling water to the coolin g tower spray deck and back to the existing intakes. There, the existing circulating water pumps would c onvey the cooling water through the condensers similar to the existing once-through sy stem. The existing CWISs would be isolated from the ILAHC by putting stoplogs in the CWIS. New, smaller pumps would be installed in the CWIS to supply makeup water for the closed-cycle cooling system.

Most of the construction efforts on the cooli ng tower would be indepe ndent of the existing circulating water system and woul d not affect facility operations. However, replacement power would be required to implement the intake modi fications and the final circulating water pipe modifications. These efforts would require Unit s 1, 2 &5 to be shut down for about 6 months, which could amount to a loss in generation of about 329,214 MWh.

The mechanical draft cooling to wer would require appr oximately 1.2% of th e total plant output for auxiliary power (EPRI 2002a). The extra powe r would be required to operate the additional cooling water supply pumps for the tower, the to wer fans, the blowdown facility equipment, and the makeup water pumps. Total auxiliary power would amount to 2,503 MWh per year. Since the temperature of the cold water produced by the tower would be proportional to approach temperature (local wet bulb temperature), the closed-cycle system would produce warmer water than the current once-through cooling water. All retrofitted closed-c ycle cooling system alternatives would cause a reduc tion in net generation and a corre sponding increase in the heat rate, except for periods when the turbine outpu t is limited by high backpressures. The higher water temperatures at the condenser inlet would reduce facility output by 1% of total facility capacity or about 2,107 MWh during the year (E PRI 2002a). The net loss of salable power would be about 4,610 MWh per year.

Annual maintenance is necessary on the mechani cal and electrical components of a mechanical draft tower and the other pumpi ng components for a closed-loop c ooling water system. Pumps, fans, motors, controls, fill sections, support st ructures, and the tower basin and hardware all38 require periodic inspections and maintenance. The EPRI study indicates that the operating and maintenance costs for a cooling tower retrofit would be 2% of the to tal construction costs.39 Figure 4-1 Typical Ristroph Screen – Section40Figure 4-2 0.5 mm Wedge Wire — Plan41Figure 4-3 0.5 mm Wedge Wire — Section42 Section 5 RESTORATION AS A 316(B) COMPLIANC E OPTION AT LADWP’S HARBOR GENERATING STATIONS

The EPA final Phase II Rule also provides that applicants may use restoration measures in addition to, or in lieu of, tec hnology measures to meet performan ce standards or in establishing best technology available (BTA) on a site-specific ba sis. Specifically, EPA’s final Phase II Rule states the following requirement relative to the use of the restoration approach:

Facilities that propose to use restoration me asures must demonstrate to the permitting authority that they evaluated the use of design and construction technologies and operational measures and determined that the use of restoration measures is appropriate because meeting the applicable pe rformance standards or requirements through the use of other technologies is le ss feasible, less cost-effective, or less environmentally desirable than meeting the standards in whole or in part through the use of restoration measures

.
The basic philosophy of restoration is mitig ation of fish losses at a CWIS via:

• Direct supplementation of a “species of con cern” (stocking) potent ially impacted by the CWIS; or

• Provision, protection, or restorati on of habitat that “p roduces” fish and thereby replaces those lost due to impingement and entrainment mortality.

Restoration efforts may be “in-kind” or “out-of- kind.” “In-kind” restor ation directly replaces (either via stocking or habitat) the fish and shel lfish species that are lost due to impingement mortality and entrainment. “Out-of-kind” restora tion replaces the fish and shellfish species lost with a different species mix as determined in consultation with the permitting authority and fish and wildlife resource agencies and tribes.

Restoration is a voluntary action offered by the applicant (LADWP) — the permitting agency or any other federal or state resource agency cannot request restoration as a mitigation approach. The following subsections discuss the basic ph ilosophy of restoration, the general types of restoration projects that a facility may develop th e role of restoration in EPA’s Phase II Rule, and filing requirements if the facility pursues this option. The revi ew also includes pot ential specific restoration measures for cons ideration by LADWP for proposal to California’s Environmental Protection Agency (CEPA) — State Water Reso urces Control Board (s pecifically, the Los Angeles Regional Water Quality Control Board or RWQCB). Restoration is state (permit authority) specific. The following discussion, therefore, applies to all of LADWP’s power plants in California (Haynes, Harbor and Scattergood).

5.1 What Are the Implications of the R ecent Court Ruling Regarding the Use of Restoration in the EPA Phase I Rule to Their Use in Phase II?

On February 3, 2004, the Second Circuit of the U. S. Court of Appeals, following consideration of the Riverkeeper Alliance pe tition of the EPA Phase I Rule (FR 66(No. 243), December 18,43 2001), found that EPA exceeded its authority re lative to allowing compliance with §316(b) through restoration methods. As a result of this finding, the Court remanded that aspect of the Phase I Rule. The Court’s decision, however, wa s clearly limited to Ph ase I by the following explicit footnote:

In remarking that one standard is app licable to new and existing structures, [the members of the Court] stress that this is one reasonable reading of the st atutory language. In no way [does the Court] mean to predetermine the factors and standar d applicable to the Phases II and III of the rulemaking.

Despite the Court’s ruling prior to the EPA Ad ministrator’s signing of the Phase II Rule, EPA decided to retain provision for restoration as di scussed herein. To addr ess many of the Court’s concerns, however, EPA strengthened the Rule’s language relative to restoration methods and explicitly noted the restoration approach as a cooling water intake structure “technology” option. Furthermore, EPA discussed how inclusion of this “technology” option provides the necessary flexibility that existing facilities will need to meet the performance requirements of the final Phase II Rule.

Following release of the final EPA Phase II Rule and despite EPA’s modi fied language relative to restoration, the Riverkeeper Alliance clearly si gnaled its intent to ag ain litigate the Phase II restoration provisions. Based on the fact that it took the Court nearly 2 years to reach its decision relative to Phase I, we can reasonably ex pect a similar time period to pass before the Court renders a decision on the EPA Phase II provisions for restoration methods.

The Team offers no prediction on the results of th e expected litigation other than to note that major investment in a restoration compliance strategy is an at risk approach . This risk, however, should not preclude c onsideration of rest oration measures as discussed herein, including preliminary planning fo r restoration implementation. Su ch consideration and planning will allow for effective implementation of restoration measures by SCE&G as a compliance approach should the Court reject the Ri verkeeper Alliance’s expected petition.

5.2 Why Should LADWP Consider Restoration?

Essentially, there are three reasons fo r considering a restoration approach:

1. Other technologies and operational measures, as noted by EPA, are less feasible, less costeffective, or less environmentally desirable.

2. Restoration is scalable according to the perf ormance requirement needed, unlike technologies that generally have a theoretical fixed level of performance. A facility can use a restoration project, therefore, to make up the differen ce when a technology only achieves some of the performance required. 5

5 For example, suppose a specific technology only achieves a 50% reduction in intake entrainment. A restoration project can be implemented to attain the remaining 10%+ reduction needed to meet the EPA’s proposed 60–90% entrainment reduction performance standard. Also, assume a site-specific performance standard much lower than44 3. Direct environmental and public relations benefits associated with restoration projects that the facility will not likely attain via an intake technology.

Minimizing “adverse environmental impact” (AEI), as measured at the population level, is not an explicit objective of the final Phase II Rule. In other words, direct reductions in impingement mortality and entrainment may not result in a ny type of net benefit to fish populations. Restoration measures, however, when properly designed and maintained, can offer direct benefits to the targeted species. Furthermore, an cillary benefits, when th e restoration measure is habitat-based, can also be significant (e.g., ripa rian erosion control a ssociated with wetland restoration) (EPRI 2003a). The publ ic relations benefits mentioned above may be in accord with corporate environmental stewardship goals, maki ng pursuit of restoration a worthy goal for this reason alone.

Similarly, we must also ask, Why should LADWP not consider restoration? A key reason for possibly not pursuing the restoration option is that a restoration proj ect may take several years, in some cases as many as 10 years, before it operate s at a level equivalent to natural production. For some projects, like fish stocking, it must be a continuous process during the life of the plant. There are also no guarantees that for some rest oration projects (e.g., fi sh passage), the “if you build it they will come” theory will apply. Long-term performance monitoring, many years longer than an intake technology would likely re quire, and other information requirements to address the uncertainties associ ated with restoration, may be burdensome and reasons for not considering the restoration opti on. Also, as previously noted, the recent Court ruling regards restoration in the Phase I Rule, and expected litigation over the restor ation provisions in the Phase II Rule creates significant uncertainties re lative to the legal standing of the restoration compliance option.

5.3 Types of Restoration Applicable to §316(b)

EPA does not specify the types of restoration m easures that can be us ed. This lack of specification provides flexibility in developing/proposi ng a restoration approach. Restoration measures that have been used at other power stations to meet §316(b) requirements include:

• Wetland restoration, e.g., Public Service El ectric & Gas (PSEG) Delaware Bay wetland restoration program for the Salem Generati ng Station (Weinstein et al. 2001). See http://www.pseg.com/c ompanies/nuclear/est uary/overview.html

.

• Fish stocking, e.g., Mirant (forme rly PEPCO) fish hatchery at the Chalk Point Station (Bailey et al. 2000); Exelon’s (formally Commonwealth Edison) walleye hatchery at Quad Cities Station on upper Mississippi River (LaJeone and Monzingo 2000); and Southern California Edison’s white sea bass hatche ry implemented, in part, fo r fish losses at SONGS (see subsequent SCE Web site address).

the EPA standards (e.g., a 25% reduction in impingement mortality rather than the required 80–95% standard) is established as a result of the outcome of one of the variance option tests. It may be much easier and a lower cost to scale a restoration project to this performance st andard rather than install an intake technology.45 • Submerged aquatic vegetation (SAV) restorati on, e.g., Southern California Edison’s kelp restoration for the San Onofre Nuclear Gene rating Station (Deysher et al. 2002). See http://www.sce.com/sc3/006_about_sce/006b_generation/ 006b1_songs/006b1c_env_prot/006b1c 3_songs_miti/default.htm

.

• Provision of fish passage (such as fish ladders or dam removal) at non-hydropower projects, e.g., PSEG fish ladders in Dela ware Bay tributaries for the Salem Generating Station. See http://www.pseg.com/c ompanies/nuclear/est uary/overview.html

.

• Contribution to, or maintenance of, a restor ation fund, e.g., Duke Energy North America’s contribution ($7 million) to the Elkhorn Slough Foundation to mitig ate for 316(b)-related impacts associated with th e re-powering of the Moss La nding Station on Elkhorn Slough near Monterrey Bay, California. See http://www.dukeenergy.com/businesses/plants/o wn/us/western/morrobay/reports/

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• Water quality improvements, e.g., riparian ar ea protection or implementation of non-point source best management practices, that minimi ze sediment/pollutant runoff, thereby resulting in fishery habitat improvements as well as prac tices that increase dissolved oxygen content in waterbodies, thereby increasing av ailable habitat for fish spawni ng and survival. While this approach is plausible, there are no known existing examples of such a 316(a & b) restoration project.

We describe the advantages and disadvantages , design considerations, and approximate unit costs of each of these restoration op tions in detail in EPRI (2003a).

5.4 Role of Restoration in the EPA Phase II Rule

EPA’s final Phase II Rule provides that a facility can voluntarily implement restoration measures in lieu of, or in combination with, reductions in impingement mortality and entrainment. If a facility uses restoration measures, it must demonstrate to the permitting agency that the performance of the restoration measures (the prod uction of fish and shellfish in the facility’s waterbody or watershed, including the maintena nce of community structure and function) is substantially similar to that whic h it would have achieved if the facility met the standards with onsite technology and/or operational measures. The role of restoration in the final Rule is to provide additional flexibility to both permitting au thorities and facilities in complying with the Rule by eliminating or significantly offsetting what are, in EPA’s opinion, the AEI caused by the operation of a CWIS. EPA believes that restorat ion measures, such as fish stocking and wetland restoration, are “technologies” within the meaning of that term as used in §316(b) and, as such, are an appropriate means for meeting t echnology-based performance standards.

As previously discussed, facilities that propose to use restoration measures must demonstrate to the permitting authority that they evaluated the use of technologies and operational measures and determined that the use of restoration measures is appropriate because meeting the applicable performance standards through the use of other technologies is le ss feasible, less cost-effective, or less environmentally desirable than meeting the standards in whole or in part through the use of restoration measures. Facilities must also demonstrate that the restoration measures they plan to implement, alone or in combination with technologies and/or operational measures, will produce ecological benefits (production of fish and shellfish) at a level that is substantially similar to the level that a facility would achieve through compliance with the applicable46 performance standards or altern ative site-specific requirements that a facility attained from results of either the Cost-Cost test or Cost-Benef it test. In other words, restoration measures must replace the fish and shellfish lost to impingement mortality and entrainment, either as a substitute or as a supplement to reducing impingement mortality and entrainment through technologies and/or operational measures. Th e species makeup of the replacement fish and shellfish need not be exactly the same as that of the impingement mortality and entrainment losses (i.e., “out-of-kind” restoration). However, the facility must demonstrate to the permitting authority that the net effect of the restoration project will be th e production of fish and shellfish in the waterbody that is “substa ntially similar” to that whic h would result from meeting the performance standards vi a the technology approach.

The final Rule also requires that a facility use an adaptive management method for implementing restoration measures because the facility must regularly monitor the perfo rmance of restoration projects and potentially adjust them to ensure th e projects achieve their intended objectives. The final Rule also requires that restoration projects that replace the lost fi sh and shellfish with a different species mix (“out-of-ki nd” restoration) be ba sed on a watershed appr oach to restoration planning. The boundaries of a “watershed” shou ld be guided by the cataloging unit of the “Hydrologic Unit Map of the U.S.,” although it may be appropriate to use another watershed or waterbody classification system deve loped at the state or local leve l if such a system compares favorably in level of detail. EPA notes as an ex ample, in coastal systems that support migratory fish, a coastal waterbody that transects a number of watersheds may be the most appropriate unit for restoration planning.

Restoration must address the “s pecies of concern” identifi ed by the permit director in consultation with federal, state, and tribal fi sh and wildlife management agencies that have responsibility for aquatic species potentially affected by a facility’s CW IS. In California, this involves the federal Fish & Wildlife Service (F WS) and the National Mari ne Fisheries Service (NMFS), the state’s Regional Water Quality Control Board (RWQCB), California Energy Commission (CEC), and California Department of Fish & Game (CDFG). Native American Tribes in California will also have a role in id entifying “species of concern” and commenting on potential restoration proj ects. While the final Phase II Rule does not require collaboration with local non-governmental agencies, it is likely th at RWQCB and other reso urce agencies would require or strongly encourage such collaboration. “Species of con cern” is a new term specific to these regulations. The fact that a CWIS may onl y potentially have an impact on such species offers tremendous flexibility toward development of restoration measures. This is particularly relevant to endangered, threatened, and rare species (federal and st ate) that characteristically are not impacted by a CWIS (e.g., California green stur geon, protected California rockfish species, southern California steelhead), but may, however, be of high restoration inte rest to the federal, state, and tribal agencies.

EPA strongly encourages facilities w ith an interest in pur suing a restoration a pproach to initiate consultation with the fish and wildlife management agencies to:

• Identify the “species of concern”

• Identify the current status of “species of c oncern” located within the subject waterbody and provide general life history for those species, including preferred habitats for all life stages47 • Identify potential threats to “species of con cern” found within the wa terbody other than the CWIS (i.e., identify all additional stressors for the species of concern), appropriate restoration methods, and monitoring requireme nts to assess the ove rall effectiveness of proposed restoration projects.

EPA stresses the importance of consultation be cause it believes that natural resource management agencies typically have the most accu rate information available and thus are most knowledgeable about the status of the aquatic resour ce they manage.

5.5 Potential Restoration Measures for LADW P’s Haynes, Harbor, and Scattergood Generating Stations

LADWP may wish to consider the fo llowing example restoration projects 6 to attain the impingement mortality (and, if applicable, entrai nment) reduction performance standard or as part of a site-specific standa rd developed by the permit director. These projects are listed because of their known interest to fish and wild life agencies in California and because design and implementation informati on is readily available:

NOTE: Many of the following programs are vol untary collaborative efforts. They are not designed as regulatory option programs a nd some may not be directly receptive to regulatory involvement. 7 The programs do, however, offer valuable contacts for restoration information or for evaluating potential restoration approaches that are volunteered to meet the requirements of EPA’s Phase II §316(b) rule.

6 Projects listed are examples. Opportunities for creative restoration projects are un limited and depend upon corporate interests and negotiations with state and federal resource agencies.

7 Currently, there is only one restoration-based regulatory program in the U.S., NOAA’s Restoration Center Damage Assessment and Restoration Program (DARP) (see http://www.nmfs.noaa.gov/habitat/restora tion/projects_programs/darp/index.html ). NOAA established DARP in 1990 to fulfill natural resource trustee responsibilities assigned in the Clean Water Act (CWA), the Superfund Act, the Oil Pollution Act of 1990 (OPA), and the National Marine Sa nctuaries Act (NMSA). As a natural resource trustee, NOAA acts on behalf of the public to restore resources inju red by oil spills, releases of other hazardous substances, and vessel groundings. DARP collaborates with other fede ral, state, and tribal natural resource trustees in:

• Assessing and quantifying injuries to natural resources

• Seeking damages for those injuries

• Implementing restoration actions

• Monitoring progress to ensu re restoration goals are met It is possible that a similar federal program could develop in the future to support other Clean Water Act regulatory efforts such as those involved with §316(b) should there be sufficient demand for a consistent process.48 Fish stocking. 8 This involves the direct supplementation (s tocking) of a fish species of concern to aid restoration efforts for th at species. A facility generally pursues restoration stocking (as opposed to recreational gamefish stocking) where the species of interest has been completely extirpated or where associated habitat restorati on is unlikely to contribut e to stock restoration. For example, the Georgia Department of Natu ral Resources (GDNR), following 6 years of study, recently initiated a long-term effort to restor e lake sturgeon to the Coosa River system in Georgia/Alabama. This species is listed as threatened throughout the U.S. and has disappeared completely from much of its original range, in cluding the Coosa River. Through a collaborative effort between several state and federal agenci es, GDNR released 1,100 finge rlings to the Coosa River in December 2002 as the first step toward returning lake sturge on to a healthy, selfsustained population in the river (see
http://georgiawildlife.dnr.state.ga.us/c ontent/displaycontent. asp?txtDocument=305 ). A similar program may be of interest in California, particularly for the s outhern steelhead salmon or coastal rockfish ( Sebastes spp.), both of which are federal and state listed endangered and threaten ed species along the California coast (see http://ecos.fws.gov/te ss_public/TESSWebpageUsaLists?state=CA ). CDFG and RWQCB (and USFWS/NMFS) may support LADWP’s partic ipation in a program to restore rare, threatened, and endangered fish to native habitat. Mirant Mid-Atlantic Inc. currently raises and stocks Atlantic sturgeon at its Chalk Point Hatchery Facility on the Patuxent River for the State of Maryland, Department of Environmental Pr otection. American shad restoration to the Susquehanna River basin in Maryland/Pennsylvania has been accomplished in part via stocking of juvenile shad and via provi sion of fish passage (St. Pier re 2003; Hendricks 1995). LADWP could also combine restoration stocking (e.g., for southern steelhead) with provision of fish passage (i.e., dam removal or fish ladders). We discuss this form of restoration further below.

Fish stocking program support could be via hatchery operation developed on or off plant property (e.g., SCE funds the operation of a fish hatchery in Carlsbad, CA, for culturing and stocking California sea bass. See http://www.sce.com/sc3/006_about_sce/006b_generation/ 006b1_songs/006b1c_env_prot/006b1c 3_songs_miti/default.htm .) LADWP would operate and maintain such a ha tchery under state and federal oversight. Alternatively, LADWP could possibl y negotiate a direct annual c ontribution of f unds to a state and federal hatchery supplementation program or a private foundation. For example, the Hubbs/Sea World Research Institute operates th e SCE fish hatchery for SONGS mitigation. While hatchery or stock supplementation programs can be controversial due to concerns over protection of natural genetic inte grity, California resource agen cies, based on their approval and development of SCE’s SONGS Mitigation Project, supported stocking as compensation for fish losses. CDFG and NMFS also have a long-term fish hatchery program to support maintenance and restoration of anadromous salmonids in Ca lifornia coastal rivers (CDFG/NMFS 2001). California resource agencies’ experience with hatchery supplementation may mean that they

8 While forage species (e.g., gobies, anchovies, sardin es) are the most common species impacted at LADWP’s power plants, stocking of these species to compensate for the losses would not be of interest to any of the federal and state fish and wildlife agencies. The objective of a supplementation program would be to identify a “species of concern” the stocking of which would compensate (be “comparable to, or substantially similar to”) for the production foregone as measured by a gamefish’s consumption (e.g., X northern anchovy are equivalent in energy or food consumption to Y white sea bass or other recreational or commercial fish of concern). This is the approach used by Potomac Electric Power Company for estimating annual hatchery production of striped bass to compensate for bay anchovy (a forage species) losses at its Chalk Point Generating Station on the Patuxent River in Maryland.49 could be receptive to a hatchery progra m established by LADWP as compensation for impingement and entrainment losses at LADWP pow er plants in southern California. For example, when operating at design capacity, th e SCE-funded hatchery is expected to exceed compensation for the total SONGS fish losses es timated by an expert panel created by the California Coastal Commission.

For approximate cost references, SCE provide d $4.7 million in funding for the white sea bass hatchery which began operation in late 1996. Similarly, the Potomac Electric Power Company (PEPCO) established an aquacultur e facility at their Chalk Point Station at a capital cost (1990 dollars) of $1 million. Annual O&M has been approximately $175,000 to $250,000 depending on the species and number of organisms ra ised and stocked in Maryland waters.

Habitat Protection Program Participation. The importance of wetlands, in-stream habitat, and riparian areas as aquatic habitat for fish and inve rtebrates and as habitat fo r wildlife, is reviewed in EPRI (2003a). Wetland restoration or habitat restoration in general is becoming increasingly popular across the U.S., and there is a growing case history with use of ha bitat restoration as a 316(b) mitigation approach (EPRI 2003a). In Cali fornia, over 90% of its historic wetlands and 95% of historic streamside trees, shrubs, and ground vegetation has been lost from urbanization, agricultural conversion, logging, and flood cont rol (USFWS 2001). Habitat restoration, therefore, should be a major inte rest to federal and state resour ce agencies and non-governmental organizations (NGOs) in California. The follo wing identifies federal, state, and private restoration programs that provide information which LADWP may find of value for establishing their own restoration program or offer opportu nities to LADWP to co llaborate on potential restoration projects as compensation for impi ngement mortality and entrainment losses at LADWP power plants in southern Ca lifornia. Example programs include:

• Southern California Edison’s (SCE) Sa n Onofre Nuclear Generating Station (SONGS) Mitigation (see http://www.sce.com/sc3/006_about_sce/006b_generati on/006b1_songs/006b1c_env_prot/006b1c3_songs_miti/default.
htm ). The SONGS Marine Mitigation Program is a multifaceted environmental enhancement program intended to mitigate unavoidable impacts to the marine environment resulting from operation of the SO NGS Units 2 & 3 cooling water systems. The program includes: 1) Restoring 150 acres of degraded wetlands at San Dieguito Lagoon to mitigate impacts to marine fish populations caused by estimated mortality to fish eggs and larvae; 2) Improving the in-plant fish protection systems to increase survival of adult fish that enter the cooling water systems; 3) Constructing an artificial kelp reef to mitigate impacts to the San Onofre Kelp Bed; 4) Co-funding a marine fish hatchery program intended as supplementary mitigation for kelp impacts; and 5) Funding for Coastal Commission staff oversight and monitoring of these mitigation projects.50 SCE is managing the overall mitigation pr ogram. Through its Conservation Financing Corporation (CFC) subsidiary, the two larges t elements of the mitigation program — the wetlands restoration project at San Dieguito Lagoon and the artificial reef at San Clemente — are being addressed by an e quity alliance with an environmental management services consulting firm. CFC finances and oversees implementation of these two mitigation projects.

SCE is the plant operator and majority owne r of SONGS. SONGS is jointly owned by SCE, San Diego Gas and Electric, and the cities of Anaheim and Riverside, which are funding the mitigation work.

The owners of SONGS want to keep interested parties in formed about this program, which will significantly enhance the region's marine resources. Through meetings, discussions, newsletters, a Web site, and th e public hearing process, SCE expects to inform and involve the largest possible number of interested partie s in the development and implementation of the mitigation/enhancement plans. Detailed technical progress on implementing and monitoring the SONGS mitiga tion effort appears in the Proceedings from the Second Annual Public Workshop for the SONGS Mitigation Pr oject (Reed et al. 2002).

• Duke Energy’s Morro Bay Modernizatio n Project Habitat Enhancement Program (see http://www.duke-energy.com/ businesses/plants/own/us/western/morrobay/reports/ ). As part of the station modernization, Duke Energy has volunt eered to fund a program that would reduce sedimentation and the other major factor s undermining the Bay's productivity. The concerns for Morro Bay and the target of D uke’s proposal are the issues identified by the Morro Bay National Estuary Program's (MBNEP) Comprehensive Conservation Management Plan (CCMP). Those issues in clude sedimentation, loss of habitat, and nutrient pollution. Duke’s proposal is its pref erred alternative to the California Energy Commission’s (CEC) request for dry cooli ng operation. The Regional Water Quality Control Board (RWQCB) staff agrees with Duke’s proposal and believes that habitat enhancement would yield greater long-term benefits for the Bay.

Duke Energy's proposal would fund habitat enhancement projects authorized by the RWQCB and managed through pr ofessional groups like the MBNEP, which have plans and programs to reduce sedimentation and other factors undermining the Bay's productivity. The special value of habitat enhancement is that it not only addresses marine biology but also prot ects and enhances habitat fo r birds and other animals and sustains important recreational resources fo r the community. Documents describing the program in detail can be downloaded from th e Web site listed above. Because of recent economic conditions across the U.S., Duke ha s canceled plans for modernizing the Morro Bay Power Station and, as a result, it ha s not implemented its habitat enhancement project.

• PSEG’s Delaware Bay Estuary Enhancement Program (see http://www.pseg.com/c ompanies/nuclear/est uary/overview.html ) . This is the largest restoration program the U.S. implemented as compensation for impingement and entrainment losses at a power station. PSEG negotiate d this program, establishe d in 1995, with NJDEP as a51 mitigative action for fish losses at the Salem Nuclear Generating Station in lieu of implementing a closed-cycle cooling system. Principally focused on the restoration of approximately 10,000 acres of former salt hay fa rms to natural estuarine salt marsh in the lower Delaware Estuary, the program also includes provision of fish passage in combination with some limited fish stocki ng to support restoration of anadromous (American shad and river herring) fish st ocks. Details of the program appear in Weinstein et al. (2001). In a following sect ion, we demonstrate the method PSEG used to scale (i.e., convert fish loss to acres of equivalent wetland habita t) the size of the requisite restoration project. The PSEG incurred costs to date for the ongoing restoration project, including capital, O&M, and monito ring, exceed $100 million or $9,350/acre (EPRI 2003a).

• Santa Monica Bay Restoration Commission (see http://www.santamonicabay.org/s ite/aboutus/layout/index.jsp ). In recognition of the need to restore and protect the Santa Monica Bay and its resour ces, the State of California and the U.S. Environmental Protection Agency establishe d the Santa Monica Bay Restoration Project (SMBRP) as a National Estuary Program in December of 1988. The Project was formed to develop a plan that would ensure the long-term health of the 266 square mile Bay and its 400 square mile watershed, located in th e second most populous region in the United States. That plan, known as the Santa M onica Bay Restoration Plan, won state and federal approval in 1995. Since then, the SMBRP 's primary mission has been to facilitate and oversee the implementation of the Plan.

On January 1, 2003, the Santa Monica Bay Re storation Project formally became an independent state organization and is now known as the Santa Monica Bay Restoration Commission (SMBRC). The Santa Monica Ba y Restoration Commi ssion continues the mission of the Bay Restoration Project and th e collaborative approach of the National Estuary Program but with a greater ability to accelerate the pace and effectiveness of Bay restoration efforts. Restorat ion activities are based on a comp rehensive plan of action for Bay protection and management, known as the Bay Restoration Plan, which was approved by Governor Pete Wilson in D ecember of 1994 and by USEPA Administrator Carol Browner in 1995. The Plan identifies almost 250 actions, in cluding 74 priority actions, that address critical problems such as storm wa ter and urban runoff pollution, habitat loss and degradation, a nd public health risks associ ated with seafood consumption and swimming near storm drain outlets. The Plan outlines specific programs to address the environmental problems facing the Bay a nd identifies implementers, timelines, and funding needs.

Implementing the Plan is the focus of current efforts. Securing and leveraging funding to put solutions into action, building public-pri vate partnerships, pr omoting cutting-edge research and technology, facilitating a stakeh older-driven consensus process, and raising public awareness in order to restore and pres erve the Bay's many bene ficial uses are key objectives of the SMBRC.

• National Oceanic and Atmospheric Admi nistration (NOAA) Community-based Restoration Program (CRP ) (see52 http://www.nmfs.noaa.gov/habitat/restora tion/projects_programs/crp/index.html)

. This program applies a grass-roots approach to restoration by actively engaging communities in on-the-ground restoration of fishery habitats around the na tion. The CRP emphasizes partnerships and collaborative strategies built around restor ing NOAA trust resources and improving the environmental quality of local communities. The program is: (1) providing seed money and technical expertise to help communities restore degraded fishery habitats; (2) developing partnerships to accomplish sound coastal restoration projects; and (3) leveraging resources through national, regional, and local partnerships. This program is one of the services of the NOAA Restoration Ce nter. This Center’s mission is to enhance living marine resources to benefit the natio n’s fisheries by restoring their habitat. Working with others, the Cent er achieves its mission by (1) re storing degraded habitats; (2) advancing the science of coastal habitat restoration; (3) transferring restoration technology to the private sector, the public , and other government agencies; and (4) fostering habitat stewardship and a conserva tion ethic. Recently, under the communitybased program, NOAA awarded $250,000 to the Gulf of Mexi co Foundation for habitat restoration in the five states bordering the Gulf of Mexico. EPA, under NOAA’s Gulf of Mexico Program (see below) similarly awarded $90,000 to the Foundation. These awards launch a major new effort to reclaim e ssential fish habitats of the Gulf of Mexico by implementing field efforts to restore and impr ove marine and coastal habitats that have been degraded or lost.

• U.S. Fish & Wildlife Service Partnership for Fish & Wildlife (see http://partners.fws.gov/index.htm ). This program is supported by funds from federal and state agencies, private landowners, and non- governmental organizations (e.g., Ducks Unlimited, CDFG, the Nature Conservancy). The program is a voluntary partnership program with a goal to restore wetlands and ot her vital habitats on private land with 70% of the current funding coming from private sources. The remaining funds, along with restoration design and technical assistance, is provided by USFWS. State resource agencies, such as CDFG, work with the FWS to help establish priorities and identify focus areas. The restoration of degraded we tlands, native grasslands, streams, riparian areas, and other habitat to conditions as clos e as possible to natural is emphasized. The Partnership for Fish and Wildlife Program is im portant for restoration of critical habitats in California (USFWS 2001). LADWP could potentially negotiate to give financial support to the program and in-kind servic e could potentially as compensation for impingement mortality and entrainment at its power plants in southern California.

• Coastal America’s Corporate Wetla nd’s Restoration Partnership (CWRP) (see http://www.coastalamerica. gov/text/cwrpoperating.html ) is a program designed to foster collaboration between the federal government, state agenci es, and private corporations. Private corporations that participate in this nati onal program will donate funds for either sitespecific wetland or other aquatic habitat restoration projects or provide matching funds to a national or regional effort in support of a quatic ecosystem restora tion activities. All projects that will receive funds from the CWRP will be approved Coastal America projects, and federal agencies will assist in their proper execution. The Coastal America Partnership will coordinate among all of its Regional Implementation Teams to identify the appropriate private foundati on or state trust fund that wi ll receive funds from the53 CWRP. This organization will not likely accept support in response to regulatory requirements. However, the organization is a source of wetland restoration information and unique partnerships may be arranged.

Dam removal or fishway construction. An integral component to USFWS and NMFS anadromous fish restoration program is the provi sion of fish passage at existing artificial river obstructions. Passage can be obtained via dir ect dam removal or via the provision of fish passage. At the federal level, the key program is the National Fish Passage Program (see
http://fisheries.fws. gov/fwsma/fishpassage/ )

. In 1999, the U.S. Fish and Wildlife Service initiated the National Fish Passage Program. The Program uses a voluntary, non-regulatory approach to remove and bypass barriers. The Program addre sses the problem of fish barriers on a national level, working with local communities and partne r agencies to restore natural flows and fish migration. The Program is administered by Na tional and Regional Coordinators and delivered by Fish and Wildlife Management Assistance O ffices, with their 300 biologists located across the nation. Appropriations for the Program support the Coordinators , in-the-water fish passage projects, and the Fish Passage Decision S upport System (subsequently described). The Program’s goal is “ to restore native fish and other aquatic sp ecies to self-sustaining levels by reconnecting habitat that has been fragmented by barriers, wher e such re-connection would not result in a net negative ecological effect such as providing increased habita t to exotic species.”

The Fish Passage Decision Support System (see https://ecos.fws.gov/fpdss/index.do ) is a database of barriers preventing fish movement that is complemented by analyt ical tools (GIS software) for mapping and prioritizing fish pa ssage projects (calculating str eam mileage made available by providing fish passage at the barrier). Barrier information includes locat ion, type, size, owner, passage capabilities, associated fish species, and local habitat information.

CDFG and NMFS are actively involved in effo rts to restore anadromous salmonids in California’s coastal rivers. In the area of th e LADWP facilities, restor ation of the southern steelhead is a species of particul ar concern. While restoration effo rts to date have been largely based on hatchery supplementation, RWQCB or othe r state and federal res ource agencies may be receptive to the development of efforts to restore acce ss to historical spawning habitat via dam removal (e.g., see Pejchar and Warner 2001) and or fish laddering at river barriers. As mitigation for impingement mortality and entrainment impacts at LADWP’s power plants, LADWP could negotiate removal of one or more dams or provide fish passage where dam removal is not an option. Alaska Steeppass fish ladders offer an effective and moderate cost approach for fishway provision. PSEG of New Jersey has successfully installed such fishways in tributaries to the lower Delaware Bay to rest ore access to historical spawning habitat for American shad, alewife, and blueback herring. Dam removal, if LADWP pursued it, would focus on abandoned, non-hydropower projects, such as old low-head mill dams or flow control structures (river levees). The Rindge Dam on Malibu Creek (see
http://www.irn.org/revival/d ecom/alerts/rindgealert.html ), for example, is under strong consideration for removal. Consensus is building among local NGOs and federal and state resource agencies that this aging and silted-in dam should be removed to speed southern steelhead recovery efforts. Steelhead once spawned as far as 3 miles upstream. Removal of this structure would reopen the habitat to potential spaw ning by this endangered species. The major impediment to removal is a lack of funding. The California State Departme nt of Parks and Recreation is acting as the54 clearinghouse for securing the stat e’s share of the funding. Federa l efforts are being led by the U.S. Army Corps of Engineers. LADWP could combine fish passage programs with stocking to restore specific anadromous species of concern such as the southern steelhead. As we previously noted, such an approach was successful for restor ing American shad to the Susquehanna River in Pennsylvania and Maryland.

Alternative restoration measures. We have identified the measures discussed above as the most likely restoration approaches to appeal to RWQCB and other federal and stat e resource agencies. Other potential approaches include nonpoint source pollutant runoff abatement programs and contaminated sediments restoration. While these types of efforts focus on water quality improvements, the long-term benefit is improved fi sh and shellfish habitat. Such efforts would have to demonstrate a clear linkage between th e two as compensation for impingement mortality and entrainment losses at LADWP’s southern Calif ornia power stations. The California Coastal Commission is implementing a statewide Nonpoint Source (NPS) Program (see
http://www.coastal. ca.gov/nps/npsndx.html ). Elements of the plan include management measures for reducing runoff pollution from agriculture, silvic ulture, urban areas, marinas and recreational boating, and via hydromodification (i ncludes modification of stream and river channels, dams and water impoundments, and streambank/shoreline erosion). CCC, therefore, is a source of information for developing a potential nonpoi nt source runoff abatement program or implementing best management practices (BMPs) to meet the goals of the state’s plan in the Los Angeles urban and suburban areas. RWQCB ma y welcome direct support by LADWP toward implementing some of the BMPs as compensation for the impingement (and entrainment losses) at LADWP power plants.

5.6 Implementing a Restoration Program for LADWP’s Haynes, Harbor, and Scattergood Generating Stations

Estimating the size and cost of a potential restoration project is a complex process and beyond the scope of the current service. SCE’s and Duke Energy’s expe rience in California, however, provide valuable context. The size of a project and its cost are also the result of an iterative negotiation/investigation process with the resour ce agencies. If restor ation is of potential interest, LADWP should initiate appropriate pla nning and consultation with the agencies. We discuss information that LADWP must ultimately file below. However, there are a number of steps that we recommend prior to the developmen t of any specific restoration project plans. These steps are as follows: 9

1. Initiate preliminary consultation with the fe deral and state resource agencies to identify

9 There is no formal guidance from EPA or any other organization on planning restoration projects relative to meeting the requirements of the final Phase II §316(b) Rule. Procedures essentially are developed on a site-specific basis. LADWP can use procedures at other power plants as guidance. EPA is not expect ed to issue guidance of any type relative to the developing 316(b) rules until 2006 or even later. In late 2004, EPRI will deliver to its members a report that provides more definitive guidelines on planning restoration projects.55 “species of concern,” hab itat requirements, and potenti al restoration measures. 10

2. Impingement mortality and entrainment monitoring data at LADWP’s Haynes, Harbor ,and Scattergood Generating Stations are the re quisite data to s upport the baseline characterization, evaluation of technology options , cost-benefit calculations (i.e., benefit monetization), and initial input to calculating restoration goals (i.e., to support both “comparable performance” and estimate the requ isite size of the restoration project as subsequently discussed).

3. LADWP must convert data fr om impingement mortality and entrainment monitoring to annual “equivalent adult” (for recreational gamefish) and “p roduction foregone” (for forage fish) losses. EPRI will publish a report in la te 2003 describing in detail the procedures for both calculations. Existing literat ure that reviews each of thes e concepts appears in EPRI (2003a), Goodyear (1978), Rago (19 84), and Jensen et al. (1988).

4. Calculate requisite units of restoration that mitigate for CWIS impingement mortality and entrainment losses (or appropriately scale rest oration such that benefits are comparable 11 to what a facility could attain w ith technology or operational rest riction options). The science of restoration scaling is in its infancy, and EPA provides no guidelines, nor can we expect it to in the near future. Scaling that has been done has been negotiated with permit directors on a site-specific basis (e.g., PSEG for Delaware Estuary, DENA for Morro Bay Station). The new EPRI report on restoration science (EPRI 2003a) includes a chapter that summarizes the state of science (i.e., scaling methods, data needs, uncertainties) on appropriately scaling restoration to compensate for impingement mortality and entrainment losses at power stations (an example scaling approach is subs equently discussed). Scaling for hatchery supplementation is more direct: Fish are raised and stocked at a leve l slightly higher than that lost (per equivalent a dult and production foregone loss ca lculations) due to impingement mortality and entrainment. The slightly high er supplementation is a safety factor that addresses uncertainty in su rvival following stocking.

5. Present plan, including all requisite information noted in the following section , to SDRWQCB. Continue consultation and plan development until approved and formally included as a permit condition.

6. Implement restoration measure, maintain, and monitor performance per permit conditions.

10 Scientists at the Marine Science Institute of the Univer sity of California, Santa Barbara (e.g., Dan Reed, Steve Schroeter) have extensive experience working on the SONG S Mitigation Project. Independent, out-of-state experts include Drs. Kenneth Rose and James Cowan, Jr., at th e Louisiana State University Coastal Fisheries Research Center, both of whom have extensive experience in the development and implementation of restoration projects as mitigation for Clean Water Act §316(b). Each of these individuals is a valuable source of information to help LADWP in restoration planning should L ADWP decide to pursue such activities.

11 Under conditions of lack of guidance from EPA on dete rmining “comparability” of rest oration benefits to other technology options, final determination will reside with the permit director — relative to Haynes, Harbor, and Scattergood, LARWQCB. Lack of guid ance will allow considerab le flexibility in reaching these determinations. However, given California’s (Coastal Conservation Commission and RWQCB’s extensive experience in the design and implementation of DENA’s and SCE’s programs, LADWP should expect that it will likely require detailed comparability assessments.56 Historically, organizations have used two general approaches to implement restoration projects. These approaches are:

• Self-directed/managed projects . The power company identifies the restoration project, scales it accordingly, secures the property or access, designs the effort, manages implementation, and conducts monitoring to ensure design performance, then makes necessary adaptive management adjustments. This is the approach that PSEG has used for its Delaware Estuary Restoration Program for the Salem Nuclear St ation. Southern California Edison (SCE) is, through its Conservation Financ ing Corporation, similarly se lf-managing its restoration efforts (artificial reef, wetland restoration, and fish hatchery) for 316(a & b) impacts by the San Onofre Nuclear Generating Station (SONGS). Mirant Inc. (PEPCO) self-managed its fish hatchery as compensation for entrai nment impacts at its Chalk Point Station.

• Contribution to a restoration fund . The power company works with another entity to identify a project, scale it accordingly, and determine the funds necessary to implement, manage, and monitor. Funds are then provi ded to the third party, which may leverage such funds to further expand the restoration efforts. This is the approach that D uke Energy North America (DENA) has used for its Moss Landing Station a nd Morro Bay Station in California. In the former, DENA made a one-time contribution to the Elkhorn Slough Foundation of $7 million for its management of estuary restoration e fforts. For the latter, DENA attempted to negotiate a one-time contribution (~$14 to 21 million) to the Morro Bay Estuary Program to manage restoration projects in Morro Bay. Because plans to modernize the Morro Bay Power Plant have been put on hold, further negotiation with CEC and RWQCB have also been suspended.

EPA provides no guidance or recommendation relative to the preferred approach. Each approach has its limitations and advantages that are highly influenced by local non-governmental organizations, federal agencies, and state re source agencies, incl uding the permit issuing organization.

We present for consideration two methods for scal ing restoration projects that are similar in fundamental science: (1) PSEG’s approach for its Estuary Enhancement Program and (2) Duke Energy North America’s approach for its Morro Bay Power Station in California.

PSEG Scaling for the Salem Generati ng Station Fish & Shellfish Losses

The PSEG Estuary Enhancement Program is foun ded on the premise that primary production of salt marshes is linked to the production of marine transient taxa. PSEG needed two calculations to estimate the area of marsh needed to produ ce fish to offset losses at the power plant:

1. Annual fish biomass produced from De laware Bay marsh primary production 2. Annual fish biomass lost in on ce-through cooling at the plant.

PSEG then used the following formula to derive an estimate of wetland acreage for mitigation:57 wetland of acre per production biomass Fish operation plant power to due lost biomass Fish

= wetlands of Acres

PSEG based estimates of fish loss due to impingement and entrainment on sampling results as converted to annual losses usi ng the equivalent adult and pro duction foregone impact assessment methods as previously noted. For comparability with wetland productivity units in dry weight, fish biomass lost (BL) were converted to dr y weights by multiplying the BL by an appropriate wet weight to dry weight (DW) conversion factor . PSEG based its estimate of the fish biomass produced per wetland acre on an aggregated food chain model (AFCM) approach. The principle underlying this model is that biomass produced by wetlands vegetation is transferred through the food chain to higher level consumers including a ll five species at issue at Salem (bay anchovy weakfish, spot, white perch, and possum shrimp ). The model simplified complex food web interactions by aggregating sp ecies across trophic levels. In the AFCM, this biomass was calculated by multiplying wetland-based primary productivity ("PP") by appropriate conversion efficiency ("CE") factors betw een succeeding trophic levels (CE 0 , CE 1 , and CE 2 ). This biomass is then apportioned among indivi dual second-level consumer spec ies (including those species at issue) by multiplying the result of the AFCM by th e individual species' apportionment factor (A). These calculations are summarized in the equation below:

Fish production per acre of wetland = [ PP × CE 0 × CE 1 × CE 2 ] × A

where

PP = Primary productivity per acre of wetland (lb. dry weight/acre/year)

CE 0 = Efficiency of biomass conversion from primary productivity to the detrital complex

CE 1 = Efficiency of biomass conversion from the detrital complex to first level

consumers

CE 2 = Efficiency of biomass conversion from first level consumers to second level

consumers

A = Apportionment of the wetland-based secondary consumer productivity to the individual species at issue.

The original equation:

wetland of acre per production biomass Fish operation plant power to due lost biomass Fish

= wetlands of Acres

is now expressed as:58 A x ] CE x CE x CE x [PP DW x BL

= wetlands of Acres

2 1 0

PSEG derived the values for the parameters above from the literature or from monitoring surveys in Delaware Bay and environs. Details appear in Weinstein et al. (2001) and in the PSEG permit filings in NJDEP permit office. Using thes e formulas and input parameter values, PSEG estimated that approximately 2,500 acres of restored wetlands would mitigate for losses of key species at the Salem Station. Ho wever, in light of uncertainties and variability surrounding the assumptions and estimates used to construct th e model, PSEG used a ”s afety factor” of about four to achieve consensus among stakeholders , including NJDEP. Thus the final project involves restoring approximately 10,000 acres of wetlands along the New Jersey shore of the lower Delaware Estuary 12

. DENA Method for Morro Bay Station, California

Duke Energy North America (DENA) developed the following Habitat Equivalency Analysis (HEA) to determine requisite wetland restor ation to compensate for impingement and entrainment losses at the Morro Bay Power Pl ant in California (Duke Energy Morro Bay LLC 2002). HEA is an analytical method that Nati onal Oceanic and Atmo spheric Administration (NOAA) initially developed to quant ify natural resource and service reductions associated with oil spills and services gains associated with rest oration actions taken in response to those spills. More detailed information on HEA appear in NOAA (1997), Strange et al. (2002), and Duke Energy Morro Bay LLC (2002 — can be downloaded at http://www.dukeenergy.com/businesses/plants/o wn/us/western/morrobay/reports/ ). We provide this example 13 to illustrate a possible approach and the requisite data to suppo rt appropriate scaling.

Step 1: Convert estimated entrainment numbers of fish and crabs to biomass (debit) Summed entrainment losses of fish and crabs based on entrainment sampling to kg/year: 4,670 kg of fish/year and 2,983 kg of crabs/year

Step 2: Calculate discounted amount of entrained biomass over life of power plant (debit) Projected total biomass lost over 50 years at a discount rate of 3%: 120,167 kg of fish and 76,759 kg of crab

12 PSEG’s Salem Station is one of the larg est power stations in the U.S. and one of the largest daily withdrawals of estuarine water. The plant is also located in an estuarine zone, where entrainment of earl y life stages of fish is the greatest within Delaware Bay. As such, habitat equiva lency to compensate for entrainment losses are extremely large (~10,000 acres), particularly when compared to habitat equivalency calculated for the subsequent Morro Bay Power Plant example (~60 acres).

13 This example is superficial in presentation. It should al so be noted that not all parties (i.e., CEC and RWQCB) to Duke Energy’s Habitat Enhancement Plant concur with the application of HEA in relation to its traditional use by NOAA. The example is simply to illustrate the fundamenta l steps in scaling of fish losses to units of habitat restoration.59 Step 3: Estimate (from lite rature) habitat (e.g., eelgrass or salt marsh) produc tivity (credit) Marsh productivity in California based on th e scientific literatur e ~ 20,235 kg/acre/year

Step 4: Convert habitat productivity to fish and crab biomass (credit) Based on trophic transfer efficiencies fish and crab production was estimated at 0.4% and 4.0%/acrea: 80.96 kg of fish and 809 kg of crab

Step 5: Calculate discounted amount of fi sh and crab biomass (credit) Projected total biomass gained over 100 years ( lifetime of the restor ation project) at a discount rate of 3%: 2,231 kg/acre of fish and 22,319 kg/acre of crab

Step 6: Estimate habitat acres sufficient to eq uate the service “credit” to “debit” 120,167 kg fish loss/2,232 kg/acre = 53.8 acres of restored marsh to offset fish losses at the power plant 76,759 kg crab loss/22,319 kg/acre = 3.4 acres of restored marsh to offset crab losses at the power plant

TOTAL ACRES OF REQUIRED RESTORATION = 57.2

LADWP would need to submit considerable docum entation, as we subsequently discuss, to support such an accounting. Duke’s HEP (2002) is illustrative of the requisite breath of information that LADWP would need to provide and discuss.

5.7 Information That LADWP Must Submit

Table 5-1 lists the specifi c requirements of the required Restor ation Plan that LADWP must file if a facility proposes to use rest oration measures, in whole or in part, to meet the applicable requirements in §125.94 (compliance alternatives a nd performance standards) of the final Phase II Rule.

5.8 Summary

Proposal and implementation of a restoration meas ure offers LADWP an a lternative approach to compensate for impingement mortality and entrainment impacts at its Haynes, Harbor, and Scattergood facilities. In fact, restoration may be the most attractive approach toward meeting site-specific BTA standards under the Cost-B enefit variance should LADWP obtain a sitespecific determination. 14 Furthermore, LADWP may wish to c onsider one restoration effort that addresses the compliance requirement s of all its power plants in s outhern California. Under the waterbody/watershed approach required by EPA for the spatial context of a restoration effort, a

14 LADWP must volunteer restoration, it cannot be requested by SDRWQCB. Implementation of a successful restoration project may also provide mutual benefits to both LADWP and the State of California.60 facility may propose and implement such a sing le or unified effort. LADWP must perform considerable planning and consultation with RWQCB and fish and wildlife management agencies, as we discuss herein, to accomplish this.

This review and discussion of potential restor ation measures does not include a review of potential restoration costs for future budgeting. Restoration cost s are dependent upon units of restoration required (that compensate for fish loss es), the type of restor ation project, and land values in the area where a facili ty may implement a restoration pr oject. The experiences of SCE in compensating for fish losses at SONGS offer some insight into potential costs. LADWP should, however, view the costs incurred with the understanding that the SONGS program mitigates for total impacts associated with opera tion of its cooling system (intake and discharge effects) and impacts associated w ith construction of the intake and discharge system pipes. As noted herein, SCE provided $4.7 million in funding for a white sea bass hatchery. When operating at design capacity, the ha tchery is expected to produ ce 300,000 juvenile white sea bass per year. This white sea bass production is ex pected to exceed comp ensation for the total SONGS fish losses estimated by the CCC Marine Re view Committee (expert panel). In addition to these costs, SCE will be restoring 143 acres of wetlands in the San Die guito River Valley at a cost estimated at $86 million. Furthermore, in 2005, SCE will build out its experimental kelp reef to a full 150-acre required size at an estim ated cost, including post-construction monitoring, of $40 million. Monitoring of the experimental ke lp reef and wetlands currently costs SCE about $1.2 million annually.61 Table 5-1 EPA Requirements for th e Content of Restoration Plans

Final Phase II Rule Section Descriptive Requirement Comment

§125.95 (b)(5) Restoration Plan. If you propose to use restoration measures, in whole or in pa rt, to meet the applicable requirements in §125.94 [compliance alternatives and performance standards], you must submit the following information with your application for review and approval by the permitting authority. You must address species of concern identified in consultation with Federal, State, and Tribal fish and wildlife management agencies with the responsibility of fisheries and wildlife potentially affected by your cooling water intake structure(s). This plan would be filed as part of
your Comprehensive Demonstration Study (CDS). The CDS will be filed 6 months prior to expiration of the current facility permit. Your intent to examine restoration measures as a possible compliance approach would be noted in your Proposal for Information Collection (PIC) which will be due within the next 12 to 18 months. §125.95 (b)(5)(i) A demonstration to the permitting authority that you have evaluated the use of design and construction technologies and/or operat ional measures for your facility and an explanation of how you determinedthat restoration would be more feasible, costeffective, or environmentally desirable; The information contained in this report is the start of that process. Your PIC will list the technologies and operational measures that you plan on examining in a more detailed (BTA) process. This demonstration would be contained in your CDS

. §125.95 (b)(5)(ii) A narrative description of the design and operation of all restoration measures (existing and proposed) that you have in place or w ill use to produce fish and shellfish; §125.95 (b)(5)(iii) Quantification of the ecological benefits of the proposed restoration measures. You must use information from the required Impingement Mortality and/or Entrainment Characterization Study, and any other available and appropriate information, to estimate the reduction in fish and shellfish impingement mortality and/or entrainment that would be necessary for your facility to comply with §125.94(c)(2) [production of ecological benefits equivalent to meeting impingement and entrainment reduction requirements]. You must then calculate the production of fish and shellfish that will be achieved with the restoration measures you will or have already installed. You must include a discussion of the nature and magnitude of uncertainty associated with the performance of these restoration measures. You must also include a discussion of the time frame within which these ecological benefits are expected to accrue; “Scaling” addresses the quantification requirement. I&E losses, as documented in your Impingement Mortality and Entrainment Charact erization Study, is the starting point in the process. Scaling is accomplished based on a theoretical analysis using productivity values in the technical literature. Example scaling for wetlands is included herein.

Some recent key papers on restoration scaling include Peterson et al. (2003a), Peterson et al. (2003b), McCay and Rowe (2003), Powers et al. (2003), Kneib (2003), and Peterson and Lipcius (2003). §125.95 (b)(5)(iv) Design calculations, drawings, and estimates to document that your proposed restoration measures in combination with design and construction technologies and/or operational measures, or alone, will meet the requirements of §125.94(c)(2) [production of ecological benefits equivalent to There is some level of redundancy here with the previous requirementwith regards to scaling. “Out-ofkind” restoration gets at the previously footnoted issue that the resource agencies are not likely to62 meeting impingement and entrainment reduction requirements]. If the re storation measures address the same fish and shellfish species identified in the Impingement Mortality and/or Entrainment Characterization Study (in-kind restoration], you must demonstrate that the restoration measures will produce a level of these fish and shellfish substantially similar to that which would result from meeting applicable perf ormance standards in §125.94(b) [impingement mortality and entrainmentreduction standards], or that they will satisfy sitespecific requirements established pursuant to §125.94(a)(5) [cost-cost or cost-benefit tests]. If the restoration measures address fish and shellfish species different from those identified in the Impingement Mortality and/or Entrainment Characterization Study (out-of-kind restoration), you must demonstrate that the restoration measures produce ecological benefits substantially similar to or greater than those that would be realized through in-kind restoration. Such a demonstration should be based on a watershed approach to restoration planning and consider applicable multi-agencywatershed restoration plans, site-specific peerreviewed ecological studies, and/or consultation with appropriate Federal, Stat e, and Tribal fish and wildlife management agencies. look for replacement of lost forage fish (e.g., gizzard shad, threadfin shad, bay anchovy, or other ‘rough’ species). Instead, they would (assuming they support the restoration concept) prefer targeting the restoration at a gamefish or commercial fish or some other species of special concern. This ‘demonstration’ again is a theoretical analysis based on data in the technical literature.

The watershed approach provides great spatial flexibility toward implementing a project. For example, a restoration effort could be directed at the headwaters of the watershed in which the facility is located or within tributaries. Projects can also be implemented downstream of the facility.63 §125.95 (b)(5)(v) A plan using an adaptive management method for implementing, maintaining, and demonstrating the efficacy of the restoration measures you have selected and for determining the extent to which the restoration measures you have selected and for determining the extent to which the restoration measures, or the restoratio n measures in combination with design and construction technologies and operational measures, have met the applicable performance requirements of §125.94(c)(2) [production of ecological benefits equivalent to meeting impingement and entrainment reduction requirements]. The plan must include:

A. A monitoring plan that includes a list of the restoration parameters that will be monitored, the frequency at which you will monitor them, and success criteria for each parameter; B. A list of activities you will undertake to ensure the efficacy of the restoration measures, a description of the linkages between these activities and the items in paragraph (b)(5)(v)(A) of this section [above note on the required monitoring plan], and an implementation schedule; and C. A process for revising the Restoration Plan as new information, including monitoring data, becomes available, if the applicable requirements under §125.94(c)(2) [production of ecological benefits equivalent to meeting impingement and entrainment reduction requirements] are not being met. EPA defines adaptive management

as a type of project management method where a facility chooses an approach to meeting the project goal, monitors the effectiveness of that approach, and then based on monitoring and any other relevant information, makes any adjustments necessary to ensure continued progress toward the project’s goal. This cycle of activity is repeated as necessary to reach the project’s goal.

§125.95 (b)(5)(vi) A summary of past or ongoing consultation with appropriate Federal, Stat e, and Tribal fish and wildlife management agencies on your use of restoration measures including a copy of any written comments received as a result of such consultations; Consultation should begin prior to submitting the PIC (i.e., within the next 6 to 18 months). Consultation is necessary to obtain the resource agencies’ and permitting authority’s concurrence on the restoration concept and method, and in shaping reasonable expectations from the restoration effort. §125.95 (b)(5)(vii) If requested by the permitting authority, a peer review of the items you submit for the Restoration Plan. You must choose the peer reviewers in consultation with the permitting authority who may consult with EPA and Federal, State, and Tribal fish and wildlife management agencies with responsibility for fish and wildlife potentially affected by your cooling water intake structure(s). Peer reviewers must have appropriate qualifications (e.g., in the fields of geology, engineering, and/or biology, etc.) depending upon the materials to be reviewed; and University professors, such as those recommended herein, generally can offer unbiased peer review support, if it is requested.

§125.95 (b)(5)(viii) A description of the information to be included in a bi-annual status reports to the permitting authority.64 Section 6 ESTIMATED COSTS

The costs associated with meeting the Rule will likely determine the compliance strategy that is most desirable at Harbor. Preliminary installa tion and O&M costs associat ed with each of the alternatives identified in Section 3 and deve loped in Section 4 are presented below. The following costs are included:

• the costs that EPA assigned to a facility similar to your facility for the purpose of estimating the national costs for implementing the Rule;

• order of magnitude costs for selected tec hnologies based from hi storical data and Alden’s best professional judgment;

• costs associated with permitting and monitoring; and

• the potential for satisfying the Cost-Cost and Cost-Benefit tests to obtain a sitespecific BTA determination (Compliance Alternative 5)

6.1 EPA Costs

EPA costs are based on the Technology Cost M odules published in the Technical Development Document (TDD) (EPA 2004b). EPA developed costs for all Phase II facilities to estimate the total costs that the power industry will face as a result of implementi ng the Rule on a national level. To determine the costs for a facil ity, EPA determined which national performance standards apply and which technology would be best suited to each facility based upon either the long or short EPA questionnaires, and publicly ava ilable aerial photographs. EPA then estimated the costs for the selected technology using the appropr iate Cost Module for each Phase II facility.

There are 14 Cost Modules, one for each of EP A’s selected technologies (Table 6-1). The costing methodology of the Cost Modules is based on historical data from sites that already incorporate EPA approved techno logies, consultation with manuf actures of those technologies, and detailed design studies. Each of these modul es contains Capital and O&M costs, as well as costs associated with co nstruction shutdowns.

To assist facilities in understanding the costs EPA used in determining the national cost, EPA supplied two appendices with the Rule. Informa tion for Harbor from both these appendices is summarized in Table 6-2.

To annualize the Capital and O&M cost s, EPA made several assumptions

• All costs are based on 2002 dollars

• a discount rate of 7%,

• an amortization period of 10 years for the capital costs

• 30 year amortization period for the pilot study and downtime costs65 To determine the cost that EPA estimates Harbor will incur in order to meet the performance standards via a technology alte rnative, EPA provided a five step methodology. A summary of the methodology, and how to apply it to Harbor, is provided below.

Step 1: Determine which technology EPA se lected as the most appropriate compliance technology for Harbor

Step 2: Using the costs in Table 6-2, cal culate the annualized cap ital and net operation and maintenance costs for the facility using the following formula:

y f

= y epa + m ∗ (x f - x epa ),

where

y f = annualized capital and net O&M co sts using actual facility design intake flow,

x f = actual facility design intake flow (gpm),

x epa = EPA assumed facility de sign intake flow (gpm),

y epa = Annualized capital and net O&M costs using EPA design intake flow

and

m = design flow adjustment slope.

Step 3: Determine the annualized net re venue loss associated with construction downtime to install the t echnology and the annualized p ilot study costs that EPA selected for Harbor. The sum of these two costs is shown on the second to last row of Table 6-2.

Step 4: Add together the costs from Step 2 and 3 to get the prelim inary costs considered by EPA for Harbor.

Step 5: Determine if the performance sta ndard assigned by EPA for Harbor as reported in EPA’s Appendix A is in fact the perf ormance standard that applies to the facility. If EPA selected IM&E for a f acility, but only the impingement mortality reduction standard applies, then the cost in Step 4 should be di vided by a factor of 2.148 to get the final costs. If EPA selected only impingement mortality reduction standard for a facility, but bot h IM&E standards apply, then multiply the cost in Step 4 by a factor of 2.148 to get the final costs.

EPA estimated that Harbor would only have to m eet the IM reduction sta ndard and applied Cost Module 1 (Addition of fish handling and return syst em to an existing traveling screen system).66 As Harbor withdraws water from the ILAHC and has a capacity factor of greater than 15% the facility will be required to meet the IM&E standa rds. To compensate for this error the Team applied the five step adjustment described above. As a result the cost that LADWP would use if it were to apply for a site-speci fic BTA determination via the co st test is $130,007. This cost would not be affected if LADWP were to meet the IM standard due to the low through-screen velocity, as technologies used to meet the E standard would also meet the IM standard.

6.2 Estimated Costs for Technology Intake Alternatives

Appraisal level project costs were developed for the four alternatives discussed in Section 4. The costs were estimated using Alden’s cost databa se of alternatives fo r over 35 plants and a comparison of the conceptual designs for each of th e alternatives to adjust costs for identifiable differences in project sizes and operations. Due to the generalized nature of these costs appraisal level estimates are intended to identify the relati ve cost differences between alternatives and the cost of compliance in relation to the EPA selected technology for a facility. More detailed cost estimates based on detailed quantity takeoffs woul d be required if LADWP plans to apply one of these alternative tec hnologies at Harbor.

Costs in Alden’s historical database typically reflect the following assumptions:

• Present day prices and fully contracted labor rates;

• Forty-hour workweek with single shift opera tion for construction activities that do not impact facility operations and fifty-hour workweek with double shift operation for construction activities that impact facility operations;

• Direct costs for material a nd labor required for constructi on of all project features;

• Distributable costs for site non-manual supe rvision, temporary f acilities, equipment rental, and support services in curred during construction. Thes e costs are estimated to be 85-100% of the labor portion of the di rect costs for each alternative;

• Indirect costs for labor and re lated expenses for engineering services to prepare drawings, specifications, and design documents. The indi rect costs are estimated to be 10% of the direct costs for each alternative;

• Allowance for indeterminates to cover uncertainties in design and construction at this preliminary stage of study. An allowance for indeterminates is a judgment factor that is added to estimated figures to complete the final cost estimate, while still allowing for other uncertainties in the data used in de veloping these estimates. The allowance for indeterminates is estimated to be 10% of the direct, distri butable, and indirect costs of each alternative; and

• Contingency factor to account for possible additional costs th at might develop but cannot be predetermined (e.g., labor difficulties, deli very delays, weather) . The contingency factor is estimated to be 15% of the dire ct, distributable, indir ect, and allowance for indeterminate costs of each concept.

The costs do not include the following items that will affect estimates of the total capital costs:

• Costs to perform additional pilot studies incl uding laboratory or field studies that may be required;67 • Costs to dispose of any hazardous or non-hazardous materials that may be encountered during excavation and dredging activities;

• Costs for administration of project contra cts and for engineering and construction management incurred by LADWP.

• Escalation (increases in wages, materials, a nd other costs as a result of various economic factors)

• Permitting costs

For a closed-cycle cooling system alternative, EPRI’s estimated costs were used (EPRI 2002a). This study reflected retrofit cost data from 50 nuclear and fossil plants on fresh, brackish, and saline water sources. Facility sizes were 100 to 2,600 MW with cooling tower retrofit costs ranging between $11 million and $860 million. Costs are $125/gpm for “easy” projects, $200/gpm for “average” projects, and $250-$300/gpm for “difficult” projects (EPRI 2002a). Power to operate cooling towers is typically 1.0- 1.5% of the facility capacity and O&M costs are typically 1-2% of the tower capital costs (EPRI 2002a).

To allow Alden’s cost estimates to be directly co mparable to EPA’s cost for a like facility, Alden had to adjust its costs to be consistent w ith the methodology used by EPA in developing the national costs. Their adjustments are listed below:

• All costs are given in 2002 dollars

• At nuclear facilities, both the O&M and Capital costs for a given technology were multiplied by a cost factor to account for additional burdens as a result of added security and safety requirements.

• A cost factor ranging from 1.1 to 1.2 (based upon well depth) was added to the cost of Ristroph screens for the installa tion of dual flow screens.

• The cost for wedge wire screens was adjusted by a factor of 1.1 for facilities located on salt water or in a state with zebra mussels.

Costs for intake technologies and operational m easures based on Alden’s database are shown in Table 6-3. In addition to initia l capital costs and annual O&M cost s, this table includes costs (lost generation and potential lost revenue) asso ciated with constructi on shutdowns and energy penalties. Where applicable, costs were included for losses in generating cap acity as a result of the compliance option. For techno logies that do not re quire the use of the existing traveling screens, the annualized O&M cost s are the O&M costs for a give n alternative minus baseline O&M costs. Included in Table 6- 2 is EPA's estimated baseline O& M cost. The last column in this table is the total annualized cost for each alternative. To allow this cost to be compared to the cost of the EPA selected alternative, the same discount rate, amortization period, and durations described in Section 6.1 were used. As shown in Table 6-3, the annualized Alden costs for intake retrofit alternatives range from $0 for the exis ting operations to $486,000 for fine mesh Ristroph screens. Cooling to wer retrofit costs for Harbor would be about $3,206,000 annually.

6.3 Permitting and Monitoring Costs

The costs associated with completing the permit application and the asso ciated monitoring can be a substantial part of the total cost of comp liance. These costs are highly dependant on which68 performance standard(s) apply al ong with the costs for the select ed compliance alternative. Since Harbor is required to meet both the IM&E reduction standards, it would have to perform both IM&E monitoring. To account for some of the site-specific variability in these costs the Team provides cost ranges, the actual cost of permitting and monitoring would depend upon which compliance alternative LADWP chooses. The Team’s estimated cost ranges for permitting and monitoring are compared to the maxi mum cost EPA expects in Table 6-4. In the TDD, EPA based its costing methodology on the t ype of waterbody a facility withdraws from, not which standard applies. EPA also only provi ded costs for studies it ex pects most facilities will incur, and only the maximum burden cost for these studies, as a result some of the studies that the Team costed do not have comparable EPA costs. Total permitting costs for Harbor could be expected to range from $170,000 for one year of sampling and no pilot study costs up to $700,000 for two years of sampling and a one-year pi lot study with a Ristroph screen. These costs should only be used for preliminary budge ting; LADWP would have to do site-specific costing to determine the actual cost of the permitting and monitoring requirements.

6.4 Cost-Cost Test

A site-specific BTA determination (Complian ce Option 5) could be pursued by LADWP if Harbor satisfies the requirements of the Cost-C ost test. This test is a comparison of the annualized Capital and O&M costs for the EPA sele cted technology to the site-specific costs for a technology, operational measure, or restora tion alternative that has potential to meet the applicable performance standards. If the site-spe cific costs are “significantly greater than” those determined by EPA, then a site-specific dete rmination of BTA may be a viable compliance alternative at Harbor.

To determine the site-specific costs at a facility, a Comprehe nsive Cost Evaluation Study must be completed. This study includes a detailed engineering cost estimate of the technologies, operational measures, and/or restoration measur es that have been proposed to meet the applicable performance standards the facility. Once these costs have been calculated, they can be compared to the cost EPA selected to determ ine if the site-specific costs are “significantly greater than” EPA’s costs. It is important to note that EPA has not defined “significantly greater than,” so it is not possible at this time to determine conclusively if a facility will satisfy the requirements of the Cost-Cost test. The Co mprehensive Cost Evaluation Study should also include costs for other options included in the Site-Specific Technol ogy Plan that are not “significantly greater than” the costs EPA consid ered when formulating the Rule and that have potential for meeting a lesser standa rd as prescribed by the Director.

A preliminary evaluation of the applicability of the Cost-Cost test based on the Team’s rough costs can be made by comparing th e annualized costs in the last co lumn of Table 6-3 to the sum of the costs presented in th e last row of Table 6-2.69 6.5 Cost-Benefit Test

The Cost-Benefit test is the second method of obtaining a site-specific BTA determination (Compliance Alternative 5). This alternative is a comparison of the monetized benefits gained from complying with the Rule at a given faci lity to the site-speci fic costs for a technology, operational, or restoration alternat ive. If the site-specific costs are “significantly greater than” the benefits, then Harbor would be eligible for a site-specific determina tion of BTA based on the Cost-Benefit test.

To calculate the benefits of compliance with the Rule, a Benefits Valuation Study should be included in the CDS. The first step in the study is the completion of the IM&E Study. The results of this study are used as the basis for benefits monetization. This IM&E Study can be used to quantitatively determine if the Cost-Benefit test may be applicable at your facility.

The requirements of the Benefits Valuation Stud y are outlined in Appendix A of this report. Valuation of the benefits is not wi thin the scope of this evaluation.70 Table 6-1 EPA Cost Modules

Cost Module Technology Description

1 Addition of fish handling and return system to an existing traveling screen system

2 Addition of fine-mesh screens to an existing traveling screen system

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 wedge wire ) 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 in the final rulemaking

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 wedge wire ) 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 mm71Table 6-2 Cost EPA Estimated for Harbor Generating StationFacility IDDUT1138Intake ID-Assumed design intake flow (gpm ) (Xepa)77,083Actual design intake flow (gpm) ((Xf)75,000Capital cost$264,532Baseline O&M annual cost$12,475Post construction O&M annual cost$37,753Annualized capital + net O&M using EPA design intake flow (Yepa)$62,942Net revenue losses from net construction down timePilot study costs-Annualized down time and pilot study costs-Performance standards on which EPA bases its cost estimatesIActual performance standard requiredI/EEPA-modeled technology1Design flow adjustment slope (m)1.1604EPA cost used as basis for rule (Yepa)$62,942Adjusted EPA costs for Compliance Alternative 5 (Yf)$130,00772Table 6-3 Alden’s Appraisal LevelCosts of Evaluated AlternativesEstimated from Alden DatabaseAlternativeConstructionCosts(2002 $)ReplacementPowerDuringShutdown(MWh)TotalCapital Cost( 2002 $)1O&MCosts(2002 $)LostGeneration(MWh)2AnnualizedCapitalCosts(2002 $)3AnnualizedO&M Costs(2002 $)1, 2TotalAnnualizedCosts(2002 $)Retrofit Screenhouse with Fine-MeshRistroph Screens$1,730,000 0 $1,730,000 $210,000 1,051 $246,000 $240,000 $486,000Install Narrow-Slot Wedge wire in frontof the Existing CWIS$3,100,000 0 $3,100,000 $40,000 43 $441,000 $29,000 $470,000Existing Operations $0 0 $0 $0 0 $0 $0 $0Retrofit Plant with Closed-CycleCooling System4$15,000,000 105,000 $19,200,000 $300,000 4,610 $2,734,000 $472,000 $3,206,0001.Based off a cost for lost generation of $40 per MWh2.Includes costs as a result of any power penalties associated with the technology3.Alden assumed a discount rate of 7%, and an amortization rate of 10 years for the capital costs and 30 years for the pilot study and downtime costs4.Cooling tower costs based off of EPRI study (EPRI 2002a).73 Table 6-4 Comparison of Alden and EP A Permitting and Monitoring Costs

Activity Alden (Entrainment) EPA ( Estuary/Tidal River ) Start-up activities $5,000–$15,000 $2,297 Source water physical data $1,000–$3,000 $11,105 Cooling water intake structure data $1,000–$3,000 Cooling water system data $2,000–$5,000 CDS Requirements Proposal for Information Collection $20,000–$35,000 $13,740 Source waterbody flow information $1,000–$2,000 $0 Impingement Mortality and/or Entrainment Characterization Study 1 $100,000–$200,000 $963,501 Technology and Compliance Assessment Information Design and Construction Technology Plan $10,000–$20,000 $6,751 Technology Installation and Operation Plan $10,000–$25,000

Pilot studies 2 $0–$350,000 $533,808 1 Restoration plan $10,000–$50,000 Information to Support Site-specific Determination of BTA Comprehensive Cost Evaluation Study $2,000–$4,000 Benefits Valuation Study $1,000–$2,000 Site-Specific Technology Plan $10,000–$25,000 Verification Monitoring Plan 3 $5,000–$15,000 $6,667

1. Minimum cost assumes 1 year of impingement and entrainment sampling. Maximum cost assumes two years of impingement and entrainment sampling. This does not include survival evaluations or waterbody characterization studies. 2. Minimum cost assumes that no pilo t studies would be required. Maxi mum cost assumes a one year pilot study with Ristroph screens. 3. Does not include actual verification monitoring.74 Section 7 CONCLUSIONS

7.1 Phase II Facility Determination

Harbor meets EPA’s definition of a Phase II Fa cility and will be subject to all the rules applicable to Phase II faciliti es. Harbor withdraws water from the ILAHC and has a capacity factor greater than 15%, therefor e the facility will be subject to both the impingement mortality and entrainment standards.

7.2 Applicability of Compliance Alternatives

Compliance Alternative 1

Harbor Units 10-14 are closed-cycle units a nd would therefore already meet the IM&E standard. Units 1&2 would also meet the IM &E standard as they do not require cooling water. If Unit 5 were to meet both the IM&E standards with closed-cycle cooling towers the annualized cost is estimated to be $3,206,000. The CWIS and screenhouse would already meet the IM standard as the existing through- screen velocity is less than 0.5 ft/sec

Compliance Alternative 2

The information provided to the Team indicat es that the current operation of Harbor may meet both performance standards. The current Unit 5 flow is only 16% of the hypothetical baseline flow that would occur if all operating units at ha rbor were designed as once-through units. This would result in a reduction in entrainment of about 84%, which meets the E reduction standard. The CWIS and screenhouse should meet the IM reduction standard by applying Compliance Alternative 1, as stated above.

Compliance Alternative 3

Harbor could achieve the perf ormance standard via a technol ogical, operational, and/or restoration measure used alone or in combin ation with existing technologies, operational measures, and/or restoration measures at the facility. Section 4summarizes the technological and operational options that ho ld the greatest pote ntial for meeting the performance standards. Restoration is summarized separately in Section 5.

Compliance Alternative 4

The existing pre-approved technology (submerge d cylindrical wedge wire screens) is preapproved for use in freshwater rivers or st reams only. Since Harbor is not located on a freshwater river or stream, this optio n is currently unavailable for Harbor.

Compliance Alternative 575 A Site-specific determination of BTA can be gr anted to any facility that passes either the Cost-Cost or the Cost-Benefit tests as disc ussed in Section 6.4 a nd 6.5. There is not sufficient information available at this time to determine if Harbor would pass either test. While the costs of the technologies Alden eval uated are at least two times the EPA cost, EPA has not defined “significantly greater th an.” Therefore, it is not possible to determine, with any certainty, when the “si gnificantly greater than” threshold has been exceeded.

The applicability of a site-specific BTA determination based on the Cost-Benefit test is out of the scope of this evaluation. LADWP should consider the applicability of the Cost-Benefit test following IM&E sampling. On ce current data are available, they can be used to estimate equivalent adults (EA) and production forgone (PF) losses.

7.3 Compliance Methods

The Team evaluated intake technologies, modifi ed operations, and restor ation alternatives for Harbor. A summary of these alte rnatives, along with expected e ffectiveness, is shown below.

7.3.1 Technologies and Operational Measures

A preliminary evaluation of alternative technolo gies and operational measures that could be considered by LADWP to meet the IM&E standard s at Harbor is presented in this report. Alden’s preliminary judgment on how likely thes e alternatives are to actually meet these standards is summarized as follows:

Alternative Will It Meet The Impingement Mortality

Reduction Standard? Will It Meet The Entrainment Reduction Standard? Fine Mesh Ristroph Screens Yes, provided that impingement survival of key species is at least 80% Yes.

Narrow-Slot Wedge Wire Screens Yes Yes Existing Facility Operations Yes, the through screen velocity is less than 0.5 ft/sec Yes, if the existing operations provide a flow reduction of greater than 60% from a hypothetical baseline flow. Closed-Cycle Cooling Yes Yes

The annualized costs of these alte rnatives as compared with the costs EPA used in developing the Rule are:76 Alternative Alden Annualized Costs EPA’s Annualized Costs Fine Mesh Ristroph Screens $486,000 Narrow-Slot Wedge Wire Screens $470,000

Existing Facility Operations $0 Closed-Cycle Cooling $3,206,000 $130,007

While Alden’s cost analysis was done on a prel iminary basis, the comparison of the costs indicates that if LADWP were to install a fish protection te chnology at Harbor the cost of installing fine-mesh Ristroph scr eens or narrow-slot wedge wire screens may be the most costeffective technologies to meet the IM&E standards.

7.3.2 Restoration

Based on available information, Alden cannot co mpare the costs of the various technology options to the costs for a rest oration project that would provi de comparable environmental benefits per EPA’s proposed criteria. This is b ecause the Team cannot estimate the requisite size (and associated costs) of the restoration pr oject since current annual fish losses due to impingement mortality and entrainment are not known. This lack of information should not preclude LADWP from consulting with the agencies if a restoration opti on may be of corporate interest. Information that must ultimately be filed has been previously noted. In addition to the agency consultation and data ga thering needs described in Appendix A, Alden recommends the following actions be taken prior to the development of any speci fic restoration project plans:

1. Calculate requisite units of restoration that would mitigate for CWIS impingement mortality and entrainment losses (or appropriate ly scale restoration such that benefits are “substantially similar” 15 to those which could be attained by meeting the applicable performance standard). 2. Develop a restoration plan and present, including all requisite information noted Section 6

, to CalEPA. Continue consultati on and plan development until approved and formally included as a permit condition. 3. Implement restoration measures- form an ad aptive management plan to monitor and refine the restoration measure.

The following information will have to be submitted to CalEPA for review and approval if LADWP wishes to include restoration measures as part of its demonstration of comparable performance to an intake technology:

15 EPA has not give guidance on the term “substa ntially similar” as it pertains to the Clean Water Act. On February 11, 1991, EPA released a ruling on the definition of “substantially similar” and its relation to the Clean Air Act (56 FR 5352). This definition indicates that in relation to the oxygen content in unleaded fuel, “substantia lly similar” is 2.7% by weight. How t his relates to section 316(b) of the Clean Water Act is not known.77 • A demonstration that LADWP evaluated other compliance measures at Harbor and concluded that restoration is a more feasible, cost-effective, or environmentally desirable alternative;

• A list and narrative description of any ex isting or proposed restoration measures;

• A quantification of the benefits resulti ng from implementation of a restoration measure along with any benefits associ ated with technology and/or operational controls. This should also include an y uncertainties in the calculation of the benefits;

• Design calculations, drawings, and estimat es to document that the proposed restoration measures in combination with design and construction technologies and/or operational measures, or alone, will meet the requirements of the Rule;

• An adaptive management plan for implementing and maintaining the efficacy of selected restoration measures used al one or in combination with control technologies and operational measures that have met the applicable requirements of the Rule;

• A summary of any past or voluntary consultation with a ppropriate federal, state, and tribal fish and wildlife management agencies related to proposed restoration measures and a copy of any written comments received as a result of consultations;

• A peer review of information submitted with the Restoration Plan. This would need to be requested by CalEPA; and

• A description of the information to be in cluded in a bi-annual status report to CalEPA

7.4 Site-Specific Compliance Deadline

Harbor’s permit expires on (June 10, 2008) which is less than four years af ter the finalization of the Rule. Therefore, LADWP should to request an extension to its submission schedule.

Based on EPA’s compliance timeline, LADWP would need to submit the Proposal for Information Collection twenty-one months prior to the permit expiration date. Once comments are received, LADWP can proceed with the remain ing application materials including: 1) Source Water Physical Characterization Study, 2) Cool ing Water Intake Structure Data, 3) Cooling System Data, and 4) CDS. This information is due 180 days prior to the permit expiration date. Alden believes that this sche dule is somewhat idealistic as IM&E sampling would require several years of data to pr operly conduct the study. Ther efore, LADWP should start the permitting process as soon as possible.

7.5 Overview of Compliance Options

If LADWP chooses not to apply Compliance Alternative 1 via closed-cycle cooling at Harbor, then it should prepare the Proposal for Inform ation Collection, included in the study should be the details of an IM&E sampling program. This sampling program should collect 1-2 years of data. These data could be used to help LADW P determine which of the compliance alternatives are applicable to Harbor. Depending on whic h compliance alternative LADWP selects for78 Harbor, the permitting and monitoring costs could vary significantly. The following table represents EPA’s Permitting and Monitoring Cost for an estuary site versus Alden’s estimated Permitting and Monitoring Cost ranges for different compliance alternatives. The EPA cost does not take into consideration cost s for several of the studies that LADWP may face at Harbor, including: Cooling Water Intake Structure Data , Cooling Water System Data, the TIOP, pilot study costs, a Restoration Plan, Comprehensiv e Cost Evaluation Study, Benefits Valuation Study, Site-Specific Technology Plan.

Compliance Alternative Alden Cost Range EPA Maximum Expected Cost

1 $10,000 - $30,000

2 $170,000 - $700,000
3 $170,000 - $700,000

4 N/A
5 $170,000 - $270,000 $1,004,061

From this preliminary analysis it appears that the ex isting operation of Harbor should meet the performance standard via Compliance Alternativ e 2. However, EPA allows states to set alternative regulatory requirements that are as stri ct or stricter then those required by the Rule. CalEPA may impose additional requirements at Harbor beyond what would be required by EPA under Compliance Alternative 2.79 Section 8 REFERENCES

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EPRI. 2002b. Guidelines for Selection of 316(b) Assessment Method or Model. Report 1005176, May 2002. Palo Alto, CA.80 EPRI. 2003a. Enhancement Strategies for Mitigati ng Potential Operational Impacts of Cooling Water Intake Structures: Final Technical Re port. Report 1007454. June 2003. Palo Alto, CA.

EPRI. 2003b. Laboratory Evaluations of Wedgewire Screens for Protecting Early Life Stages of Fish at Cooling Water Intakes, EPRI, Palo Alto, CA: 2003. 1005339.

Fox, D. A., J. E. Hightower, and F. M. Parauka . 2002. Estuarine and nearshore marine habitat use by Gulf sturgeon from the Choctawhatchee Rive r System, Florida. Pages 111-126 in W. Van Winkle, P. Anders, D. Secor, and D. Dixon, ed itors. Biology, Management, and Protection of North American Sturgeon. American Fish eries Society Symposium 28, Bethesda, MD.

Goodyear, C. P. 1978. Entrainment impact estimates using the equivalent adult approach. Report No. FWS/OBS-78/65. U.S. Fish a nd Wildlife Service, Washington, D.C.

Hendricks, M. L. 1995. The contribution of hatchery fish to the restoration of American shad in the Susquehanna River. Pages 329-336 in H. L. Sc hramm, Jr. and R. G. Piper, editors. Uses and effects of cultured fishes in aquatic ecosys tems. American Fisheries Society Symposium 15, Bethesda, Maryland, USA

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Weisberg, SB., et al. 1984. The effects of screen slot size, screen diam eter, and through-slot velocity on entrainment of es tuarine ichthyoplankton through wedgewire screens. Martin Marietta Environmental Systems. August 1984.A-1 APPENDIX A OVERVIEW OF THE RULE

A.2 Basic Requirements

Recently promulgated guidance for the implementa tion of Section 316(b) of the Clean Water Act set national performance standard s to minimize adverse environmental impacts caused by water withdrawals. This report addresses the Phase II Existing Facilities portion of the Rule.

A.2.1 Applicability of the Rule

The Rule applies to existing Phase II facilitie s. EPA defines “existing facility” and “Phase II facility” separately. Both definitions appear in Section 125.93 of the Rule. EPA defines an existing facility as:

• Any facility that commenced cons truction before January 17, 2002;

• Any modification of such a facili ty or any addition of a unit at such a facility that does not meet the definition of a new facility as outlined in §125.83 of the Rule;

• Any addition of a unit at such a facility fo r purposes of the same industrial operation;

• Any addition of a unit at such a facility for purposes of a different industrial operation, if the additional unit uses an existing cooling wa ter intake structure a nd the design capacity of the intake structure is not increased; or

• Any facility constructed in place of such a fac ility if the newly constructed facility uses an existing cooling water intake structure whose design intake flow is not increased to accommodate the intake of additional cooling water. EPA defines a Phase II facility as a point source where the primary activity is to generate and transmit electric power or generate electric power for sale to anot her entity for transmission; that uses or proposes to use one or more cooling wa ter intake structures (CWISs) with a total design intake flow of 50 million gallons per day (MGD) or more to withdraw cooling water from waters of the United States; and that uses at least 25% of water withdrawn exclusively for cooling
purposes.

A.2.2 Core Requirements

EPA’s preferred alternative invo lves the use of national perfor mance standards (i.e., a reduction in impingement mortality (IM) of all life stages of fish and shellfish of 80–95% from the “calculation baseline” and at some facilities, a reduction in entrainm ent of all life stages of fish and shellfish by 60–90% from the “calculation baseline” (EPA 2004a § 125.94[b]). Facilities that EPA requires to meet the en trainment reduction standard are those facilities that have aA-2 capacity utilization rate 1 of 15% or greater and withdraw wate r from a tidal river, estuary, ocean, or Great Lake. Both the IM and entrainment stan dards apply to facilities that are located on a freshwater river and have a design intake flow greater than 5% of the mean annual river flow. A summary of which performance standards a pply to each waterbody appears in Table A-1.

The “calculation baseline” is an estimate of IM&E that would occur at a facility if it were designed and operated in the following ways:

• The cooling water system is de signed as a once-through system.

• The opening of the cooling water intake stru cture is located at the shoreline near the surface of the source waterbody and the face of the standard 3/8-inch mesh traveling screen is oriented parallel to it.

• The baseline practices, procedures, and structur al configuration are t hose that a facility would maintain in the absence of any structur al or operational contro ls that would reduce IM&E, including flow or velocity reductions , implemented in whole or in part for the purposes of reducing IM&E.

EPA has allowed for some flexibility in the “cal culation baseline” at the facility level. EPA allows a facility to use the current level of IM &E as the “calculation baseline.” This could potentially streamline the permit application since the facility could determine the baseline using data collected during the IM&E St udy (a requirement of the CDS, as we describe below). A facility may also request that an alternative intake location be us ed (e.g., at a depth other than at or near the surface or at a locati on other than the shorel ine) if the utility ca n demonstrate to the Director that the alternate loca tion would correspond to a higher baseline level of IM and/or entrainment.

A facility may estimate the “calculation baseline” us ing: 1) historical IM&E data from a facility; 2) IM&E data from another facility with co mparable design, operational, and environmental conditions; 3) current biological data collected in the waterbody near the CWIS; or 4) current IM&E data collected at a facility.

1 Capacity utilization rate is the ratio between the aver age 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. 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 facility may calculate the capacity utilization rate separately for each intake structure based on the cap acity utilization of the units it servi ces. The EPA would then determine applicable requirements under this subpart separately for each intake structure. The facility should measure the average annual net generation over a 5-year period (if available) of representative operating conditions, unless the facility makes a binding commitment to maintain capacity utilization below 15% for the life of the permit, in which case it may base the rate on this commitment. For purposes of this regulation, the capacity utilization rate applies to only that portion of the facility that generates electricity for transmission or sale using a thermal cycle employing the steam water system as the thermodynamic medium (EPA 2004a § 125.93).A-3 A.2.3 Alternate/Amended Requirements

Under special circumstances, a regulatory agency may apply alternative regulatory requirements to a facility. A state that oversees St ate Pollutant Discharge Elimination System ( SPDES) permits may apply alternative standa rds that are equal to or more stringent than those in the Rule. Agencies may also impose alterna tive regulatory requirements at a nuc lear facility if the facility can demonstrate to the Director, based on cons ultation with the Nuclear Regulatory Commission (NRC), that compliance with the performance standards could compromise safety requirements established by the NRC. The Director woul d then have to make a site-specific BTA determination that would not result in a conflict with the NRC’s safety requirements. EPA also allows states to establish progr ams for the trading of compliance credits within a watershed that would result in an environmental performance that compares to the reductions of IM&E that a facility would otherwise achieve under the Rule. EPA recommends that states base their trading programs on an organism-for-organism basis rath er then an organism-f or-pollutant reduction basis. Currently, no establishe d trading programs exist. The Administrator would need to approve any trading program.

A.3 Methods for Compliance

There are five compliance alternatives that EPA indicates a facility may use to comply with §316(b) of the Clean Water Act. All five complia nce options, as stated by EPA, will achieve a reduction in impingement mortality by 80–95% a nd entrainment (where applicable) by 60–90% (or equivalent environmental benefit) for all Phas e II Existing Facilities. We present the five compliance options in §125.94 of the Rule and de scribe it in detail in Sections 2.2.1 through 2.2.5

A.3.1 Flow Commensurate with Closed-Cycle Cooling or 0.5 ft/sec Through-Screen Velocity (Compliance Alternative 1)

Two methods exist for complying with Complia nce Alternative 1. The first method is to demonstrate that a facility has or will reduce intake flow comm ensurate with a closed-cycle system. Using closed-cycle cooling reduces intake flow by 70–98% compared to a once-through system, depending on the cycles of concentratio n of the cooling system. EPA assumes that impingement mortality and entrainment would be reduced by the same amount. EPA deems such a reduction in flow as satisfying the appli cable IM&E performance standard for all waterbodies. EPA will not require a facility that has installed or will install a closed-cycle system to submit a CDS. A second method fo r complying using Comp liance Alternative 1 allows a facility to meet the IM standard by having or reducing design intake velocity 2 to 0.5 ft/sec or less. A facility that reduces the desi gn intake velocity would not have to submit CDS

2 EPA defines design intake velocity as the value assigned (during the design of a CWIS) to the average speed at which intake water passes through the open area of the intake screen (or other device) against which organismsmight be impinged or through which they might be entrained. Alden believes that this synonymous with throughscreen velocity.A-4 information pertaining to IM. However, if th e facility has to comply with both the IM and entrainment standards, EPA would require all th e CDS information pertaining to entrainment.

A.3.2 Existing Intake Meets the Standa rds (Compliance Alternative 2)

Under the second Compliance Alte rnative, a facility may meet the performance standards by demonstrating that existing design and constr uction (D&C) technologies and/or restoration measures meet the applicable performance standards.

A.3.3 Proposed Technology, Operation, and/or Restoration to Meet the Standard (Compliance Alternative 3)

The third Compliance Alternative allows a utility to comply by demonstrating that the facility in question will meet the applicable performa nce standards by implementing D&C technologies and/or restoration measures. EP A defines technologies as physic al modifications to the intake (e.g., fine mesh screens, wedge wi re screens, fish handling and return systems, aquatic filter barrier systems, etc.). Examples of operationa l measures include season al flow reductions, a reduction in velocity, installation of variable speed pumps, and adjustment of maintenance shutdowns, etc. Finally, a facility may use restor ation that produces a level of organisms in the waterbody that is “substantially si milar” to that which would resu lt from meeting the applicable performance standards. A facility could use all three of these methods alone or in conjunction with each other to meet the performance standards.

A.3.4 EPA-Approved Technology (Compliance Alternative 4)

The Rule states that a facility may demonstrate to the Director that it has installed and is properly operating and maintaining a Rule -specified and approved D&C t echnology in accordance with §125.99(a).

EPA currently has one pre-approved technology fo r compliance: submerged cylindrical wedge wire screens in freshwater rivers or streams. The Director may approve additional technologies if it is demonstrated that the technology in que stion can “consistently meet” the performance standards.

A facility may use submerged cylindrical wedge wire screens when its CWIS is located in a freshwater river or stream, where there is a sufficient ambient current to properly clean the screens, where the maximum through-slot velocity is 0.5 ft/sec, where the sl ot size is protective of all the species and life stag es that require protection, and where all the condenser cooling water flows through the wedge wire screens. A facility can use th is alternative to meet both the IM and entrainment standards. If a facility ne ed only meet the IM standard, then wedge wire screens would meet the requirements of Comp liance Alternative 1 ( 0.5 ft/sec through-screen velocity). Facilities where both the IM&E st andards apply would need to conduct verification monitoring of entrainable organisms.A-5 In addition, under this Compliance A lternative, a facility or othe r interested persons may submit a request to the Director for a pproval of a different technology. If the Director approves the technology, all facilities w ith similar site conditions under his or her jurisdiction may use it, if the State’s administrative procedures allow it . Requests for approval of a technology submitted to the Director must include a detailed descriptio n of the technology, a list of design criteria for the technology and site characteristics, and conditi ons that each facility must possess in order to ensure that the technology can consistently meet the performance standards at any facility with applicable design criteria, site characteristic s, and conditions. Prio r to approving a technology, the Director must allow public notice and opportunity for co mments on the approval of the technology.

A.3.5 Site-Specific BTA (Compliance Alternative 5)

The Rule includes two methods fo r a facility to obtai n a site-specific BTA determination: the Cost-Cost and Cost-Benefit tests. Both tests are fundamentally similar in that they compare the site-specific costs necessary to meet the applicab le national performance standards to either the costs that EPA estimated for a like facility in calc ulating the national costs or the benefits that a facility would achieve by comply ing with the performance standard s. If the site-specific costs are “significantly greater than” EPA’s costs or the benefits that a facility would attain, then the Director can make a site-specific BTA determina tion. EPA, however, has not explicitly defined “significantly greater than.” Therefore, until additional guidance is provided by EPA, it may be difficult, if not impossible, to determine if a facility satisfies the requirements of the Cost-Cost or Cost-Benefit tests.

If a facility chooses to use th e Cost-Cost test, EPA will require it to submit two additional studies with the CDS. These studies are the Comprehe nsive Cost Evaluation Study and a Site-Specific Technology Plan. For a facility choosing to use the Co st-Benefit test, a th ird study would need to be included: the Benefits Valuation Study. A summary of th ese studies appear in Section 2.3.2.

A.4 Information Requirements

The Rule requires substantial engineering and biol ogical information to establish a baseline; to determine which of the performance standards are applicable; to justify the selection of BTA; and, subsequently, to monitor the performance of the selected opera tional, technological, and/or restoration measure the facility w ill use to meet the performance stan dards. A utility will need to develop and present considerable data and studies dur ing the permit renewal process and must maintain extensive ongoing manageme nt of selected alternatives.

A.4.1 Date Required Prior to the Expiration of the Current Permit

To determine which standards will apply at a given facility, EPA requires the permittee to submit, 180 days prior to expiration of a permit, the following three study components: 1) Source Water Physical Characterization Study, 2) Cooli ng Water Intake Structure Data, and 3) Cooling System Data as we summarize in Table A-2.A-6 A.4.2 Comprehensive Demonstration Study (CDS)

EPA requires all facilities, except those th at meet BTA requirements by having flow commensurate with closed-cycle cooling, to s ubmit a CDS. The CDS may include the following informational and study components:

• Proposal for Information Collection

• Source Waterbody Flow Information

• Impingement Mortality and/or En trainment Characterization Study

• Technology and Compliance Assessment Information 3⁄4 Design and Construction Technology Plan 3⁄4 Technology Installation and Operation Plan

• Restoration Plan

• Information to Support a Site-Specific Determination of BTA 3⁄4 Comprehensive Cost Evaluation Study (Cost-Cost and Cost-Benefit test) 3⁄4 Valuation of Monetized Benefits of Re ducing IM&E (Cost-Benefit test only) 3⁄4 Site-Specific Technology Plan

• Verification Monitoring Plan

The purpose of the CDS is to characterize the curr ent level of IM&E, to de scribe the operation of the CWIS, and to confirm that the current configur ation and operation or options a facility selects and installs meet the applicable national performance standards or those the Director requires for a site-specific BTA determination. The requi rements of the CDS would vary depending upon which Compliance Alternative the facility pursue s (Table A-3). We describe the individual components of the CDS below.

Proposal for Information Collection

The Proposal for Information Coll ection (PIC) is a description of the information necessary to support the CDS and the methods used to gather any additional information. This study includes:

• A description of the proposed and/or impl emented technologies, operational measures, and/or restoration measures evaluated in the CDS;

• A list and description of any historical studies characteri zing IM&E and/or the physical and biological conditions in the vicinity of the CWIS and their relevance to the CDS;

• A summary of any past or ongoing consultations with appropriate federal, state, and tribal fish and wildlife agencies that are releva nt to the CDS, including a copy of written comments received as a result of such consultations; and

• A sampling plan for any new field studies the facility will conduct in order to ensure sufficient data exists to develop a scientifically valid estimate of IM&E at a facility.A-7 Source Waterbody Flow Information

The information necessary for the Source Wate rbody Flow Information would depend upon the waterbody from which the CWIS withdraws water:

If the CWIS located on a freshwater river or st ream, the following information is necessary:

• The mean annual flow of the waterbody (fro m a period of time up to 10 years, if available).

• Supporting documentation and engineering calcu lations necessary to determine if the design intake flow of the CWIS is greater than 5% of the mean annual flow of the river or stream for purposes of determining applicable performance standard s (the facility may use data from USGS gaging st ation or actual instream flow monitoring by the facility).

If the CWIS is located in a reservoir or lake (other th an one of the Great Lakes), 3 the following information is necessary:

• Where the facility proposes an increase in th e CWIS design intake flow, it must describe the thermal stratification in the waterbody and provide any supporti ng documentation and engineering calculations to dem onstrate that the total design intake flow after the increase will not disrupt the natural thermal stratifi cation and turnover patte rn in a way that adversely impacts fisheries. This includes the results of any consultations with federal, state, or tribal fish and wildlife management agencies. If the CWIS is located on an ocean or estuary, EPA does not require it to submit any source waterbody flow information.

Impingement Mortality and/or Entrainmen t Characterization Study (IM&E Study)

If EPA requires a facility to meet the IM re duction standard but not the entrainment reduction standard, the facility must submit only those com ponents of the IM&E Study that directly relate to IM.

• Taxonomic identification of all life stages of fish, shellfis h, and any species protected under federal, state, or tribal law (including th reatened or endangered species) that are in the vicinity of the CWIS and are susceptible to IM& E.

• A characterization of all life stages of fish, shellfish, a nd any species protected under federal, state, or tribal la w (including threatened or e ndangered species) identified above,

3 EPA did not request supporting documentati on or engineering calculations necessary to determine if a facility withdraws from a river or a reservoir (i.e., retention time). To calculate retention time, Alden expects a facility must de termine annual mean flow through the waterbody along with the current storage volume of the waterbody. If the waterbody is a controlled reservoir, then EPA may allow the facility to use the average seasonal retention time. EPA, however, has not given any guidance on this issue.A-8 including a description of thei r abundance and temporal and sp atial characteristics in the vicinity of the CWIS. The facility must base this information on sufficient data to characterize annual, seasonal, and diel variations in IM&E (e.g., related to climate and weather differences, spawning, feeding, and wa ter column migration) . The facility may use historical data that are re presentative of the current oper ation of the facility and of biological conditions at th e site if appropriate.

• Documentation of the current IM &E of all life stages of fish, shellfish, and any species protected under federal, state, or tribal law (including thr eatened or endangered species) identified above and an estimate of IM&E fo r the facility to use as the “calculation baseline.” The facility may use historical data that are representative of the current operation of the facility and of biological conditions at the site if appropriate. The facility must collect the data during periods of repr esentative operational flows for the CWIS and must document the flows associated with the samples.

Technology and Compliance Assessment Information

Design and Construction Technol ogy Plan (D&C Technology Plan)

Design and construction (D&C) technologies in clude both fish protec tion technologies and operational changes designed to reduce IM&E. D& C technologies do not include restoration. The D&C Technology Plan provides EPA with in formation on the fish protection technologies and/or operational measures the facility is currently using or planning to use to meet the national performance standards at each CWIS.

• The D&C Technology Plan must include all the data and engineering calculations necessary to calculate the cap acity utilization rate for a facility (or individual CWIS where applicable), including average a nnual net generation (MWh) (averaged over 5 years, if available) and total net capacity of facility (MW). In addition, the plan must explain the technologies and/or operational measures that the f acility is currently using or planning to use to meet the na tional performance standards.

• A narrative description of the design and operation of all design and construction technologies and/or operational measures (existing and proposed), including fish handling and return systems that the facility uses or will use to meet the requirements to reduce IM of those species the facility expect s to be most susceptible to impingement. This should include information that demonstr ates the efficacy of th e technologies and/or operational measures for those species.

• A narrative description of the design and operation of all D&C technologies and/or operational measures (existing and proposed) that a facility is curren tly using or planning to use to meet the requirements to reduce entr ainment of those species the facility expects to be the most susceptible to entrainment, if applicable. In addition, the facility must provide information that demonstrates the e fficacy of the technologies and/or operational measures for those species.

• Calculations of the reduction in IM&E of all life stages of fish and shellfish that the facility would achieve by implementing the selected technologies and/or operationalA-9 measures based on the IM&E Study. The fac ility should add reductions in IM&E from this “calculation baseline” as a result of any D&C technologies and/or operational measures (recirculation of some flow) it has already implemented at the facility to the reductions the facility expect s to achieve by any additiona l design and/or construction technologies and operational measures that it will implement. This should include any increases in fish and shellfish within the wa terbody attributable to restoration measures.

• Design and engineering calcula tions, drawings, and estimates prepared by a qualified professional to support the descriptions.

If a facility has multiple intake structures and dedicates each to the cooling water needs of one of more generating units, the facility may calculate the capacity utilization rate separately for each structure for purposes of determining whether entrainment reduction performance standard apply. The facility should use the total design intake flow at all structures combined in determining whether the design inta ke flow exceeds 5% of the mean annual flow of a freshwater river or stream. If the capacity utilization rate for either a single intake st ructure, or the facility as a whole is 15% or greater based on the histor ical 5-year annual averag e, but the facility has made a binding commitment to the Director to ma intain that rate below 15% for the duration of the permit, then the facility can base the cap acity utilization rate determination on that commitment.

Technology Installation and Operation Plan (TIOP)

If a facility chooses Complian ce Alternatives 2, 3, 4, or 5 an d uses design and construction technologies and/or operational measures in whole or in part to comply with the applicable requirements of the Rule, it must submit the following information:

• A schedule for the installation and maintena nce of any new D&C technologies. This includes any required down time.

• A list of operational and other parameters it will monitor and the location and frequency with which that monitoring will occur.

• A list of activities that the facility will unde rtake to ensure, to the degree practicable, the efficacy of D&C technologies and operational measures the facility will implement and a schedule for implementing them.

• A schedule and methodology for assessing the efficacy of any installed D&C technologies and operational measures in mee ting applicable perfor mance standards or site-specific requirements.

• Documentation that the appropria te site conditions exist at the facility if it chooses Compliance Alternative 4 (EPA-approved technology).

Restoration Plan

If the facility plans to use restoration measures in whole or in part to meet the applicable performance standards, it must submit the followi ng information with the application for reviewA-10 and approval by the Director. (R estoration is part of the “d esign” of the CWIS, and EPA considers it one of several technolog y options available to a facility.)

• A demonstration to the Director that th e facility has evaluated the use of D&C technologies and/or operational measures for th e facility and an e xplanation of how the facility determined that restoration woul d be more feasible, cost-effective, or environmentally desirable.

• A narrative description of the design and operation of all re storation measures that the facility is using or will use to produce fish and shellfish. If the facility uses existing restoration to compensate for environmental impacts other than the impacts from IM&E, then the facility cannot count these benefits toward meeting the applicable performance standards.

• Quantification of the ecologica l benefits of the proposed restoration measures. The facility must use information from the IM&E Study and describe the production of fish and shellfish that the restoration measures will achieve or are al ready achieving. This must include a discussion of the nature and magnitude of uncertainty associated with the performance of these restoration measures.

• Design calculations, drawings, and estimates to document that the proposed restoration measures, in combination with D&C technolog ies and/or operational measures or alone, will meet the requirements of the Rule. If th e restoration measures address the same fish and shellfish species identified in the IM&E St udy (in-kind restoration), then the facility must demonstrate that the restoration measures will produce a level of these fish and shellfish substantially similar to that wh ich would result from meeting applicable performance standards. The facility can alternately dem onstrate that the restoration measures will satisfy site-specific requirem ents established by the Director. If the restoration measures address fish and shellfis h species different from those identified in the IM&E Study (out-of-kind rest oration), then the facility must demonstrate that the restoration measures produce ecological benefits substantially similar to or greater than those that in-kind re storation would produce.

• A plan utilizing an adaptive management method for implemen ting, maintaining, and demonstrating the efficacy of the selected restoration measures and for determining the extent to which the restoration measures, al one or in combination with D&C technologies and/or operational measures, have met the appli cable requirements of the Rule. The plan must include:
3⁄4 A monitoring plan that includes a list of th e restoration parameters that the facility will monitor, the frequency with which the facility will monitor them, and successful criteria for each parameter.
3⁄4 A list of activities that the facility will undertake to ensure the efficacy of the restoration measures and a description of the linkages between these activities and the monitoring plan, including an implementation schedule.
3⁄4 A process for revising the Restoration Plan as ne w information, including monitoring data, becomes availa ble, or if the facility is not meeting the applicable Rule requirements.A-11 • A summary of any past or ongoing consultation with appropriate federal, state, and tribal fish and wildlife management agencies on th e use of restoration measures, including a copy of any written comments received as a result of such consultations.

• If requested by the Director, a peer review of the items submitted for the Restoration Plan. The facility will chose the peer revi ewers in consultation with the Director, who may consult with EPA and federal, state, and tribal fish and wildlife management agencies with responsibility for fish and w ildlife potentially affected by cooling water intake structure(s). Peer revi ewers must have appropriate quali fications (e.g., in the fields of geology, engineering, and/ or biology, etc.) depending upon the materials they will review.

• A description of the informati on the facility will include in a biannual status report to the Director.

Information to Support Site-Specific Determ ination of Best Technology Available for Minimizing Adverse Environmental Impact

The component studies the Director requires to support a site-specific BTA determination would depend upon which variance test the facilit y is using to estab lish the alternative standards. All facilities that are seeking a site-specific BTA determination must submit the Comprehensive Cost Evaluation Study and the Site-Specific Technology Plan. Those facilities that are seeking a site-specific BT A determination based on the Cost-Benefit test must also submit a Benefits Va luation Study. We discuss the re quirements of each of these studies below.

Comprehensive Cost Evaluation Study The facility must provide engine ering cost estimates in sufficient detail to document the costs of implementing D&C technologies, operational measures, and/or restoration measures necessary to meet the appli cable performance standards.

• A demonstration that the costs in the D& C technology plan significantly exceed either those considered by the Director for a simila r facility in establishing the applicable performance standards or the be nefits of meeting the appli cable performance standards.

• Engineering cost estimates in sufficient deta il to document the costs of implementing the D&C technologies, operational measures, and/or restoration measures in a Site-Specific Technology Plan.

Benefits Valuation Study

• A description of the methodology (or met hodologies) the facility uses to value commercial, recreational, and ecological be nefits (including any non-use benefits, if applicable).

• Monetized non-use benefits where the IM&E Study indicates substantial harm to threatened or endangered species; the sustaina bility of populations of important species of fish, shellfish, and wildlife; or the ma intenance of the community structure and function in a facility’s waterbody or watershed.A-12 • Documentation of the basis for any assumptions and quantitative estimates. If the facility is using an entrainment survival rate other than zero, it must submit a determination of entrainment survival based on a study approved by the Director.

• An analysis of the effects of significant sources of uncerta inty on the results of the study.

• If requested by the Director, a peer review of the items submitted in the Benefits Valuation Study. The facility must choose th e peer reviewers in consultation with the Director, who may consult with EPA and fede ral, state, and tribal fish and wildlife management agencies with responsibility for fish and wildlife potentially affected by cooling water intake structures. Peer revi ewers must have appropr iate qualifications depending upon the materials they will review.

• A narrative description of any non-monetized benefits that the facility would realize if it were to meet the applicable performance st andards and a qualitative assessment of their magnitude and significance.

Site-Specific Technology Plan Based on the results of the Comprehensive Cost Evaluation Study and th e Benefits Valuation Study if applicable, the facility must submit a Site-Specifi c Technology Plan to the Director for review and approval. The plan mu st contain the following information:

• A narrative description of th e design and operation of all existing and proposed design and construction technologies, operational measur es, and/or restorati on measures that the facility has selected.

• An engineering estimate of the efficacy of the proposed and/or implemented design and construction technologies or ope rational measures and/or re storation measures. This estimate must include a site-specific evaluati on of the suitability of the technologies or operational measures for reducing IM and/or en trainment (as applicable) of all life stages of fish and shellfish based on representati ve studies (e.g., studies that have been conducted at cooling water intake structures located in the same waterbody type with similar biological characteristic s) and, if applicable, site-s pecific technolog y prototype or pilot studies. If the facility will use restor ation measures, it must provide a Restoration Plan.

• A demonstration that the proposed and/or implemented D&C technologies, operational measures, and/or restoration measures achieve an efficacy that is as close as practicable to the applicable performance standards wit hout resulting in costs “significantly greater than” either the costs considered by the Admini strator for a similar facility in establishing the applicable performance standards, or as appropriate, the benefits of complying with the applicable performance standards at a facility.

• Design and engineering calcula tions, drawings, and estimates prepared by a qualified professional to support the elements of the Plan.

Verification Monitoring Plan

If a facility applies Compliance Alternatives 2, 3, 4, or 5 using D& C technologies and/or operational measures, it must submit a plan to co nduct, at a minimum, 2 years of monitoring toA-13 verify the full-scale performance of the proposed or already implemented technologies and/or operational measures. The plan must provide the following:

• A description of the frequency and duration of monitoring, the parameters the facility will monitor, and the basis for determining the pa rameters and the fre quency and duration for monitoring. The parameters selected and dur ation and frequency of monitoring must be consistent with any methodology for assessing success in meeting applicable performance standards in the TIOP.

• A proposal on how the facility would identify naturally moribund fish and shellfish that enter the cooling water intake structure and ta ke them into account in assessing success in meeting the performance standards.

• A description of the informati on the facility will include in a biannual status report to the Director.

A.5 Compliance Determination & Timeline

In the preamble to the Rule, EPA provides a sugges ted timeline for facilities to file the required permit application. We show this timeline in Fi gure A-1. Most of the information in the permit application is due 180 days prior to the end of the current permit term or the extended submission schedule, including the Source Water P hysical Data, Cooling Water Intake Structure Data, Cooling Water System Data, and the CDS. If a facility’s permit expires within 4 years after the Rule is published in the Federal Register (July 9, 2008), then the facility may request a submission schedule that is as expeditious as it is practicable but does not exceed 3 years and 180 days after the Rule is published in th e Federal Register (January 7, 2008).

Facilities that plan to impl ement a technology alternative for compliance should submit the PIC 15 months prior to submission of the remainder of required application materials. The director will then review and comment on the proposal and re turn it to the facility as expeditiously as possible (i.e., within 60 days) to allow the fac ility to address any comments and to implement any required study modifications.

EPA estimates that it will take approximately 1 y ear for a facility to complete all of the studies outlined in the Proposal for Information Collection. This number may be an understatement of the actual time required. The IM&E Study indi cates that sampling should be sufficient to characterize annual, seasonal, and diel variations in IM&E. This indicates that more than one year of sampling may be required. Therefore, Alden believes that a facility should submit the PIC ahead of the EPA’s suggested schedule to allow adequate time for the IM&E study.

For a facility to come into compliance, it mu st submit all of the application information (including the required components of the CDS), it must demonstrat e compliance with one of the alternatives, and it must monitor compliance with the performance standard as prescribed by the Director. A facility may also illustrate co mpliance by showing that it has compiled all the requirements of the Technology Installation and Op eration Plan or Restoration Plan and is assessing the success of the plan to allow for an adaptive management process to further refine the plan.A-14 Table A-1 Applicable National Performa nce Standards Based on Waterbody Type,

Capacity Utilization Rate, and Design Intake Flow ((Exhibit V–1 – EPA 2004a))

Waterbody Type Capacity Utilization Rate Design Intake Flow Applicable Performance Standard Less than 15% N/A 1 Impingement mortality only

5% or less of mean annual flow Impingement mortality only Freshwater river or
stream Equal to or greater than 15% Greater than 5% of mean annual flow Impingement mortality and entrainment
Less than 15% N/A 1 Impingement mortality only Tidal river, estuary, or

ocean Equal to or greater than 15% N/A Impingement mortality and entrainment

Less than 15% N/A Impingement mortality only Great Lakes Equal to or greater than 15% N/A Impingement mortality and entrainment

Lakes or reservoirs N/A Increase in design intake flow must not disrupt thermal stratification except where it does not adversely affect the management of fisheries Impingement mortality only

1. Determination of appropriate compliance reductions in not applicableA-15 Table A-2 Information Required 180 Days Prior to Permit Expiration (§ 122.21 (r) (2), (3), and (5) (EPA 2004a)

Data Type Source Water Physical Characterization Study Narrative description and scaled drawings of source waterbodies:

• Aerial dimensions

• Depths

• Salinity

• Temperature regimes

• Other documentation to support waterbody type
Identification and characterization of hydrological and geomorphological features of the waterbody:

• Methods and results of physical studies to determ ine the intake’s area of influence within the waterbody

• Locational maps Cooling Water Intake Structure (CWIS) Data Narrative description of the CWIS configurati on, including location on waterbody and depth Geographic position: degrees, minutes, and seconds of each CWIS Narrative description of the operation of the cooling water intake system:

• Design intake flow

• Daily hours of operation

• Days per year of operation

• Any seasonal variations in operation Flow distribution and water balance diagram (sources, recirculation, and discharges) Engineering drawings of the CWIS Cooling Water System Data Narrative description of the cooling water system in relation to the CWIS: proportion of design intake flow that the system uses, the number of days of the year the system operates, seasonal changes in operation, and the engineering calculations the facility used to derive these resultsA-16 Table A-3 Comprehensive Demonstration Study (CDS) Requirements for Each Compliance Alternative (Exhibit V-2 – EPA 2004a)

Compliance Alternative Comprehensive Demonstration Study Requirements 1. Demonstrate facility has reduced flow commensurate with closed cycle recirculating system. None

1. Demonstrate facility has reduced design intake velocity to ≤ 0.5 ft/sec No requirements relative to impingement mortality reduction. If subject to entrainment performance standard, the facility must only address entrainment in the applicable components of its Comprehensive Demonstration Study, based on the compliance option selected for entrainment reduction. 2. Demonstrate that existing design and construction technologies, operational measures, and/or restoration measures meet the performance standards Proposal for Information Collection Source Waterbody Flow Information Impingement Mortality and/or Entrainment Characterization Study (as appropriate) Technology and Compliance Assessment Information

• Design and Construction Technology Plan

• Technology Installation and Operation Plan Restoration Plan (if appropriate) Verification Monitoring Plan 3. Demonstrate that facility has selected design and construction technologies, operational measures, and/or restoration measures that will, in combination with any existing design and construction technologies, operational measures, and/or restoration measures, meet the performance standards. Proposal for Information Collection Source Waterbody Flow Information Impingement Mortality and/or Entrainment Characterization Study (as appropriate) Technology and Compliance Assessment Information

• Design and Construction Technology Plan

• Technology Installation and Operation Plan Restoration Plan (if appropriate) Verification Monitoring Plan

4. Demonstrate that facility has installed and properly operates and maintains an approved technology Technology Installation and Operation Plan Verification Monitoring PlanA-17 Table A

- 3 Continued

5. demonstrate that a sitespecific determination of BTA is appropriate Proposal for Information Collection Source Waterbody Flow Information Impingement Mortality and/or Entrainment Characterization Study (as appropriate) Technology Installation and Operation Plan Restoration Plan (if appropriate) Information to Support Site Specific Determination of BTA including:

• Comprehensive Cost Evaluation Study (Cost-Cost test and Cost-Benefit test);

• Valuation of Monetized Benefits of Reducing IM&E (CostBenefit test only);

• Site-Specific Technology Plan (Cost-Cost test and CostBenefit test); Verification Monitoring PlanA-18Figure A-1 Sample Compliance Timeline (Figure 1 – EPA 2004a)A-19 References

United States Environmental Protection Agency (EPA). 2004a. National Pollutant Discharge Elimination System - Final Regulations to Es tablish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities. July 9, 2004 Federal Register: Vol. 69, No. 131 Pg 41576-41693B-1 APPENDIX B OVERVIEW OF INTAKE TECHNOLOGIES AVAILABLE FOR FISH PROTECTION

Overview of Intake Technologies

Depending on their mode of action, available fish protection systems fall into one of four categories: behavioral barriers, which alter or take advantage of natural behavior patterns to attract or repel fish; physical ba rriers, which physically block fi sh passage; collection systems, which actively collect fish for their return to a safe release location; and diversion systems, which divert fish to bypasses for return to a sa fe release location. A re view of the biological effectiveness, engineering practicability, and cost s of these systems and de vices is presented in detail in three Electric Power Research Inst itute (EPRI) reports prepared in 1986, 1994 and 1999 (EPRI 1986, 1994b, 1999). The EPRI reports, along with results of recent research, provide the basis for screening alternatives for potential us e at the Station, as pres ented in this appendix.

Extensive research has been conducted since the early 1970s in an attempt to develop technologies that will minimize entrainment and impingement. As a result, a suite of technologies is available that can be considered for application as BTA at CWISs. The ability of a given technology to meet BTA requirements is influenced by a wide variety of biological, environmental and engineering factors that mu st be evaluated on a site-specific basis.

Technology Category Mode of Action System/Technology Physical Barriers Physically block fish passage (usually in combination with low water velocity) Traveling screens Stationary screens Drum screens Cylindrical wedge wire screens Barrier nets Aquatic filter barrier Rock Structures Infiltration Intakes Rotary drum screens Collection Systems Actively or passively collect fish for transport through a return system Modified traveling screens Fish pumps

Diversion Systems Divert fish to a return system or safe area Angled screens Modular Inclined Screen Eicher Screen Angled rotary drum screens Louvers/Angled bar racks Inclined plane screens Vertical/Horizontal traveling

screensB-2 Technology Category Mode of Action System/Technology Behavioral Barriers Alter or take advantage of natural behavior patterns to repel or attract fish Strobe light Mercury light Other light sources Acoustic systems Infrasound Air bubble curtains Hybrid systems Velocity Caps Other behavioral technologies

As support for the screening pro cess and selection of alternativ es for further evaluation, the following is a brief summary of the status of av ailable fish protection technologies by category.

PHYSICAL BARRIERS

Traveling Screens (Through flow, Dual flow, Center flow, Drum, etc) . The traveling water screen is a standard feature at most CWISs. The ability of traveling screens to act as a barrier to fish, while not resulting in impingement, is depend ent on many site-specific factors such as size of fish, flow velocity, location of screens, and presence of escap e routes. As barrier devices, traveling screens cannot be considered for protec tion of early life stages or aquatic organisms that have little or no motility.

Cylindrical Wedge Wire Screens . Wedge wire screens have the potential to reduce both entrainment and impingement at water intakes. In order to effectively reduce impingement and entrainment, the following conditions must exist:

• sufficiently small screen slot si ze to physically block passage of the smallest life stage to be protected (typically 0.5 to 1.0 mm for egg and larval life stages);

• low through-slot velocity (on th e order of 0.5 to 1.0 ft/s); and

• an ambient current cross-flow to carry or ganisms and debris around and away from the screen);

To date, large-scale CWIS applic ations of wedge wire screens have been limited to two plants (J.H. Campbell Unit 3 and Eddystone Station) wh ere relatively large slot openings have been used (i.e., they have not been ta rgeted specifically to prevent entr ainment of early life stages). These screens have been biologically effective in preventing impingement of larger fish and have not caused any unusual maintenance problems.

EPRI and the U. S. Environmental Protection Ag ency (EPA) sponsored laboratory evaluations of wedge wire screens with eggs and/or larvae of nine fish species commonly entrained at CWISs (EPRI 2003, in press). General entrainment a nd impingement trends observed in the dataB-3 collected included: 1) impingeme nt decreased with increases in slot size; 2) entrainment increased with increases in slot size; 3) entrai nment and impingement increased with increases in through-slot velocities; 4) entrainment and impi ngement decreased with increases in channel velocity, and 5) within a species, larval fish length did not app ear to be a factor, although the lengths of most species evaluated were within a narrow size range.

Wedge wire screens can generally be considered for application at CWISs. Since the only two large CWISs to employ wedge wire screens to date use 6.4 and 10.0 mm slot openings, the potential for clogging and fouling w ith slot sizes as small as 0.5 to 1.0 mm (as would be required for protection of many entrainabl e life stages) is unknown. In ge neral, consideration of wedge wire screens with small slot dimensio ns for CWIS application should include in situ prototype scale studies to determine potential biological e ffectiveness and identify the ability to control clogging and fouling in a way that do es not impact station operation.

Aquatic Filter Barrier (AFB) . The aquatic filter ba rrier is a relatively re cent technology for the protection of all life stages of fish at water intakes. As a result, there are limited data available on their deployment for this purpose. The AFB consists of polyester fiber strands that are pressed into a water-permeable fabric mat. Beginning in 1995, Mirant, New York, LLC. has sponsored an evaluation of the AFB to dete rmine its ability to minimize ichthyoplankton entrainment at the Lovett Generating Stati on on the Hudson River (ASA 1999, 2001). Despite difficulties in keeping the boom deployed and pr oviding adequate cleaning in 1995-1997, results of studies in 1998 show a large reduction in entrainment and it appears that deployment and cleaning problems may have been resolved for this site. Results analyzing the rate of ichthyoplankton entrainment between two side-by-si de water intakes (one protected by an AFB and the other unprotected) have shown the potentia l biological effectiveness of this technology (ASA 1999; 2001).

Laboratory studies on retention and survival of the early life stag es of five species of fish exposed to aquatic filter barrier fa bric were conducted in 2002 (Black et al., in press). Results of testing with three perforation sizes (0.5, 1.0, and 1.5 mm) and two flow rates (10 gpm/ft 2 and 20 gpm/ft 2 ) indicate that, in general, survival of orga nisms was not significantly correlated to either flow rate or perforation size. Retention of organisms, ho wever, appeared to decrease significantly with increasing flow rate for one species of fish (rainbow smelt). In addition, increasing perforation sizes appeared to significantly decrease rete ntion of three species of fish tested (common carp, rainbow smelt, and striped bass), which potentially limits the effectiveness of larger perforation sizes in protecting th e earliest life stages of these species.

At this time, the AFB system is considered to be experimental despite its potential biological effectiveness. However, continued improvements in anchoring and cleaning systems make AFBs a technology to be considered when evaluating fish prot ection alternatives.

Infiltration Intakes . Radial wells and artificial filter beds have been successfully used to supply small quantities of water. While such systems ha ve little if any biological impact, they have not been developed for screening large fl ow volumes or for CWIS application.B-4 Rock Structures . Rock structures such as rock cribs and porous dikes allow water to pass while preventing passage of juvenile and adult fish. Su ch structures have been shown to be effective on an experimental basis. Rock structures ha ve been used on a limited basis to filter large quantities of water but should be considered a potentially viable option for use at a CWIS depending upon the species and life stages to be protected and th e presence of suitable hydraulic conditions.

Barrier Nets . Under the proper hydraulic conditions (pri marily low velocity ) and without heavy debris loading, barrier nets have been effective in blocking fish passage into water intakes. There have been several recent applications of barrier nets in the Midwest (Michaud and Taft 1999). At the Ludington Pumped St orage Plant on Lake Michigan, a 2.5-mile long barrier net, set in open water around the intake jetties, has b een successful in reducing entrainment of all fish species occurring in the vi cinity of the intake (Reider et al. 1997). The net was first deployed in 1989. Modifications to the design in subsequent years have led to a net effectiveness for target species (five salmonid species, yellow perch, ra inbow smelt, alewife and chub) of over 80% since 1991, with an overall effectiveness of 96% in 1995 and 1996.

In 1993 and 1994, Orange and Rockland Utilities, In c. sponsored a study of a 3.0-mm, fine mesh net at its Bowline Point Generating Station on the Hudson River (LMS 1 996). In 1993, clogging with fine suspended silt caused the net to cl og and sink. In 1994, spraying was not effective in cleaning the net when it became fouled by the algae Ectocarpus . Excessive fouling caused two of the support piles to snap, e nding the evaluation (LMS 1996). In both years, abundance of the target ichthyoplankton species , bay anchovy, was too low to determine the biological effectiveness of the net. On th e basis of studies to date, the re searchers concluded that a fine mesh net may be a potentially effective method for preventing entrainm ent at Bowline Point (LMS 1996). However, pending further evalua tion, this concept is considered to be experimental.

In conclusion, barrier nets can be considered a viable option fo r protecting fish provided that relatively low velocities (generally less than 1 ft/s ec) can be achieved and debris loading is light. A thorough evaluation of site-specific environmen tal and operational conditions is generally recommended. At this time, barrier nets can on ly be considered for reducing impingement of larger fish at CWIS.

FISH COLLECTION SYSTEMS

Modified Traveling Water Screens . Conventional traveling water screens have been altered to incorporate modifications that improve survival of impinged fish. Su ch state-of-the-art modifications minimize fish mortality associat ed with screen impingement and spraywash removal. Screens modified in this manner are commonly called “Ristroph screens.” Each screen basket is equipped with a water filled lifting bucket that safely contains collected organisms as they are carried upward with the rotation of the screen. The screens typically operate continuously to minimize impingement time. As each bucket passes over th e top of the screen, fish are rinsed into a collection trough by a low pressure spraywash system. Once collected, theB-5 fish are transported back to a safe release locatio n. Such features have been incorporated into through flow, dual flow, and center flow screens.

Ristroph screens have been shown to improve fish survival and have been installed and evaluated at a number of power plants. Improvements have recently been made to the Ristroph screen design that have resulted in increased fish surviv al. The most important advancement in state-ofthe-art Ristroph screen design was devel oped through extensive laboratory and field experimentation. A series of studies conducted by Fletcher (1990) indicated that substantial injury associated with these tr aveling screens was due to repeated buffeting of fish inside the lifting buckets as a result of undesirable hydrauli c conditions. To eliminate these conditions, a number of alternative bucket c onfigurations were developed to create a sheltered area in which fish could safely reside during screen rotation. After several attempts, a bucket configuration was developed that achieved the desire d conditions (ENVIREX 1996). In 1995, PSE&G performed a biological evaluation of the improve d screening system installed at the Salem Generating Station in the De laware River (PSE&G 1999; R onafalvy 1999). The reported survival rates for this instal lation are among the highest for any traveling screen system. (PSE&G 1999).

Modified traveling water screens continue to be an available technology that can reduce fish losses due to impingement. Unless modified to in corporate fine mesh, as discussed below, these screens do not reduce entrainment losses.

Fine-mesh Traveling Screens . In addition to the fish handli ng provisions noted above, traveling water screens have been further modified to inco rporate screen mesh with openings as small as 0.5 mm to collect fish eggs and larvae and re turn them to the source water body. For many species and early life stages, mesh sizes of 0.5 to 1.0 mm are required for effective screening. Various types of traveling screens, such as thro ugh flow, dual flow, and center flow screens, can be fitted with fine mesh screen material.

A number of fine mesh screen in stallations have been evaluated for biological effectiveness. Results of these studies indicate that survival is highly species-specific and life stage-specific. Species such as bay anchovy and Alosa spp. have shown low survival while other species, such as striped bass, white perch, yellow perch, and inve rtebrates, show moderate to high survival. Therefore, evaluating fine mesh screens for pot ential application at a CWIS requires careful review of all available data on th e survival potential of the specie s and life stages to be protected as well as non-target species.

In addition to these field applications, survival data on a variety of species and life stages following impingement on fine-mesh screens is available from extensive laboratory studies (ESSERCO 1981). In these studies, larval life stages of striped bass, winter flounder, alewife, yellow perch, walleye, channel catfish, and blueg ill were impinged on a 0.5 mm screen mesh at velocities ranging from 0.5 to 3.0 ft/s ec and for durations of 2, 4, 8 or 16 minutes. As in the field evaluations, survival was variable between sp ecies, larval stages, impingement duration, and velocity.B-6 The primary concern with fine mesh screens is that they function by impinging early organism life stages that are entr ained through coarse mesh screens. Depending on species and life stage, mortality from impingement can exceed entrainment mortality. In order for fine mesh screens to provide a meaningful benefit in protecting fish, impingement survival of target species and life stages must be substantially greater than surv ival levels when pulled through the circulating water system.

Fish Pumps

. Several pumps have demonstrated an abil ity to transfer fish with little or no mortality. These include the Hidrostal and Archimedes screw pumps that have undergone extensive research (Liston et al. 1993). These pumps by themselves do not represent a technology for protecting fish. However, when c oupled with fish bypass systems such as angled screens and louvers, fish pump s are biologically effective.

FISH DIVERSION SYSTEMS

Angled Screens

. A variety of species have been show n to guide effectively on screens given suitable hydraulic conditions. Angled screens requi re uniform flow conditi ons, a fairly constant approach velocity, and a low through-screen velocity to be biologically eff ective. Angled screen systems have been installed and biologically eval uated at a number of cooling water intakes on a prototype and full scale basis. Angled screen diversion effici ency varies by species, but is generally quite high for most species evaluated. Survival following dive rsion and pumping (as required to return fish to thei r natural environment) has been more variable. Overall survival rates of relatively fragile species following diversion can be low. Heartier species exhibit higher survival rates resulting in overall system effici ency values (diversion and survival) ranging from 50 to nearly 100%.

In addition to the CWIS applications, angled fi sh diversion screens lead ing to bypass and return pipelines are being used extens ively for guiding salmonids in th e Pacific Northwest. These screens are mostly of the rota ry drum or vertical, flat pa nel (non-moving) types and have provided effective downstream protection for juvenile salmonids at several diversion projects in the Pacific Northwest (Neitzel et al. 1991; EPRI 1998). Li ke other angled screens, suitable hydraulic conditions at the screen face and a safe bypass system are required for the screens to effectively protect fish from entrainment and im pingement and to divert them to a bypass for return to the source wate r body (Pearce and Lee 1991).

Angled screens can be considered a viable option for protecting juvenile and adult life stages provided that proper hydraulic conditions can be maintained and debris can be effectively removed. To date, all angled sc reen applications at cooling wa ter intakes have involved the use of conventional traveling water screens modified to provide a flush surface on which fish can guide to a bypass. Fish eggs, larvae, and small invertebrates w ould not be protected by angled screens unless fine mesh screening was used.

Eicher Screen

. The Eicher screen is a passive pressu re screen that has proven effective in diverting salmon at hydroelectric projects. The first prototype of an Eicher Screen wasB-7 constructed and installed in a 9- ft diameter penstock at a hydro electric project in the Pacific Northwest. Field testing of the screen conduc ted in 1990 and 1991 demonstrated that the Eicher screen effectively diverted over 98% of the steelhead, coho, and chinook smolts (EPRI 1992). The first full-scale Eicher screen installation (two screens in two, 10-ft diameter penstocks; total flow of 1,000 cfs) at B. C. Hydro's Puntledge Project has shown similar results. Survival of chinook and coho salmon smolts exceeded 99%, and survival of steelhead, sockeye, and chum salmon fry was 100%, 96%, and 96%, respectively, at penstock velocities up to 6 ft/sec (Smith 1997). While biologically effective, the Eicher Sc reen was not designed for use at steam electric station cooling water intakes.

Modular Inclined Screens

. The Modular Inclined Screen (MIS ) has recently been developed and tested by the Electric Power Research Institut e (EPRI 1994a; EPRI 1996; Taft et al. 1997). The MIS is intended to protect juvenile and adult life st ages of fish at all types of water intakes. An MIS module consists of an entrance with trash ra cks, dewatering stoplogs in slots, an inclined screen set at a shallow angle (10 to 20 degrees ) to the flow, and a bypass for directing diverted fish to a transport pipe. The module is comple tely enclosed and is designed to operate at relatively high water velocities ranging from 2 to 10 ft/sec, depending on the species and life stages to be protected.

The MIS was evaluated in laboratory studies to determine the design configuration which yielded the best hydraulic conditions for safe fish passage, and the biological effectiveness of the optimal design in diverting selected fish specie s to a bypass (EPRI 1994a). Biological tests were conducted in a large flume with juvenile walle ye, bluegill, channel ca tfish, American shad, blueback herring, golden shiner, rainbow trout (two size classe s), brown trout, chinook salmon, coho salmon, and Atlantic salmon. Screen eff ectiveness (diversion efficiency and latent mortality) was evaluated at water velocities ra nging from 2 ft/sec to 10 ft /sec. Diversion rates approached 100% for all species ex cept American shad and blueb ack herring at water velocities up to at least 6 ft/sec. Generally, latent morta lity of test fish that was adjusted for control mortality was low (0 to 5%).

Based on the laboratory results, a pilot scale evaluation of the MIS was conducted at Niagara Mohawk Power Corporation’s Green Island Hydr oelectric Project on th e Hudson River near Albany, NY (EPRI 1996). The results obtained in this field evaluation with rainbow trout, largemouth and smallmouth bass, yellow perch, bluegill, and golden shiners were similar to those obtained in laboratory studies (Taft et al. 1997).

The combined results of laboratory and field evalua tions of the MIS have de monstrated that this screen is an effective fish diversion device that has the potential for protecting fish at water intakes. Studies to date have only evaluated possible application at hyd roelectric projects. Further, no full-scale MIS facility has been constr ucted and evaluated. As a result, the potential for effective use at cooling water intakes is unknown. Any consideration of the MIS for CWIS application should be based on future large-scale, prot otype evaluations.

Louvers . A louver system consists of an array of evenly spaced, vertical slats aligned across a channel at a specified angle and leading to a bypa ss. Bar racks can also be angled to act as louvers. Results of louver studie s to date have varied by specie s and site. Most of the louverB-8 installations in the U.S. are in the Pacific Nort hwest at water supply inta kes. Louvers generally are not considered acceptable by the fishery resour ce agencies in that region since they do not meet the current 100% effectiveness criterion. However, numerous studies have demonstrated that louvers can be on the order of 70 to 95% effective in diverti ng a wide variety of species over a wide range of conditions (EPRI 1986; Stira and Robinson 1997; LMS 1997).

Until recently, the effectiveness of diversion devi ces for non-anadromous fish has been largely unknown. Recent studies by the Electric Power Res earch Institute (EPRI) evaluated the potential for 15 and 45 degree louvers for guiding riverine species (smallmouth bass, largemouth bass, walleye, channel catfish, and golden shiner) and others (l ake sturgeon, shortnose sturgeon, and American eel) (EPRI 2001, Amaral et al ., 2002). Results indicate that 15-degree structures have considerable potential for guiding fish to a bypass.

Most of the louver applications to date have been with migratory species in riverine environments. The ability of louvers to protect species commonly impinged at CWISs is largely unknown because there have been so few louvers inst alled at CWISs. A system of guiding vanes and louvers has been installed at San Onofre Nuclear Generating Station (EPRI 1986) to direct fish away from the traveling sc reens into a collection area. Biological effectiveness of these louvers is unknown.

Due to the large spacing of the louver slats, louver systems do not protect ear ly life stages of fish. Future consideration of louver systems for protec ting fish at cooling wate r intakes is warranted but will require large-scale evaluations.

BEHAVIORAL BARRIERS

Strobe Lights . The use of strobe lights to elicit a behavioral respons e is supported by the results of laboratory and cage test studies that have demonstrated strong avoi dance by several fish species to strobe light. Strobe has been evaluated for repelli ng or guiding fish away from water intakes and, in some cases, towards bypasses fo r transport to a safe release location (EPRI 1994b, 1999). Early studies with light examined th e response of salmonids to both flashing and continuous sources (Brett and MacKinnon 1953; Cr addock 1956). The results from these studies indicated that flashing light produc ed stronger avoidance reactions than continuous light and that responses appeared to be affect ed by species tested, developmen tal stage (i.e., age or size of fish), and light adaptation level (Feist and A nderson 1991). More recent studies with salmonids have corroborated these findings (Pucke tt and Anderson 1987; EPRI 1990; Nemeth and Anderson 1992).

Research examining the potential for strobe light to be used as a fish deterrent expanded considerably in the 1980s, incl uding laboratory studies with an adromous salmonids and Alosa species, several riverine and estuarine species, an d the catadromous American eel. These studies involved both controlled experime nts (laboratory and cage tests) and field studies. Extensive research with strobe lights has continued in th e 1990s, including laborato ry and/or cage testB-9 evaluations with Pacific salmon, American eel, and several freshwa ter species, open water tests with kokanee salmon, and field tests with freshwater species and Atlantic salmon.

Although many studies have evaluate d strobe lights as a primary ba rrier system, strobes are often evaluated as part of an integrat ed fish protection and passage sy stem that includes other devices such as screens, narrow-spaced bar racks, bypa sses, and/or other behavioral systems (EPRI 1994b, 1999). As a secondary system, strobe lights have the potential to incrementally increase fish protection effectiveness.

Air Bubble Curtains . These curtains generally have been ineffective in blocking or diverting fish in a variety of field applications. Air bubble curtains have been evaluated at number of sites on the Great Lakes with a variety of species. A ll air bubble curtains at these sites have been removed from service.

Sound . The focus of recent fish protection studies involving underwater sound technologies has been on the use of new types of low and hi gh frequency acoustic systems that have not previously been available for commercial use. High frequency (120kHz) sound has shown to effectively and repeatedly repel members of the Genus Alosa (American shad, alewife and blueback herring) at sites throughout the U. S. (Ploskey et al. 1995; Dunning 1995; Consolidated Edison 1994). Other studies have not shown sound to be consistently ef fective in repelling species such as largemouth bass, smallmouth bass, yellow perch, walleye, rainbow trout (EPRI 1998), gizzard shad, Atlantic herring, and bay anchovy (Consolidated Edison 1994).

Given the species-specific responses to different frequencies that have been evaluated and the variable results that often have been produced, additional research is warranted at any sites where there is little or no da ta to indicate that the species of concern may respond to sound.

Infrasound . In the first practical application of infrasound (frequencies below 100 Hz) for repelling fish, Knudsen and colleagues (Knudsen et al. 1992; 1994) found a piston-type particle motion generator operating at 10 Hz to be effectiv e in repelling Atlantic salmon smolts in a tank and in a small diversion channel. Following th is success, there was a general belief in the scientific community that infras ound could represent an effective fi sh repellent since there was a physiological basis for understandin g the response of fish to pa rticle motion. The potential for currently available infrasound sources to effectivel y repel fish has been brought into question by the results of more recent studies (e.g., Amaral et al. 1998; Lakeside E ngineering, 1996). Given these results, it appears that infrasound sources need to be further developed and evaluated before they can be considered an availa ble technology for application at CWISs.

Mercury Light . Response to mercury light has been s hown to be species-specific; some fish species are attracted, others re pelled, and others have demons trated no obvious response (e.g., GNPC 1995, 1998; Hadderingh and Smyt he 1997; EPRI 1990). Therefore, careful consideration must be given for any application of mercury lights to avoid increasi ng impingement of some species while reducing impingement of others.

Electric Screens . Electric barriers have been shown to effectively prevent the upstream passage of fish. However, attempts to divert or dete r the downstream movement of fish have met withB-10 limited success (Bengeyfield 1990; Kynard and O’ Leary 1990). Consequen tly, past evaluations have not lead to permanent applications. Electric screens that use DC current have been used to prevent passage of fish at relatively low flow intakes (e.g. irrigation canals) and to prevent upstream passage of invasive fish species. The potential effectiveness of these barriers for application at CWISs is unknown. Gi ven their past ineffectiveness and hazard potential, electric screens are not considered a viable technology for application at CWISs.

Velocity Caps

. Velocity caps are a common feature at many submerged intakes. They offer some degree of protection to juve nile and adult fish by acting as a behavioral barrier. While there is little available data to quantify the effect that velocity caps have on fish behavior, it is generally believed that a cap on a submerged intake provides horizontal velocity cues to approaching fish. In some instances, reporte d reductions in entrainment and impingement associated with velocity caps have been the resu lt of the location of the intake in deeper, less productive zones.

Other behavioral barriers

. Devices such as water jet curtains , hanging chains, visual cues, and chemicals have been suggested, and in some cases evaluated, as fish protection measures. However, no practical application of these de vices has been developed, and they are not considered available technologies for application at CWISs.B-11 References

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Ronafalvy, J. P. 1999. Circulating Water Trave ling Screen Modifications to Improve Impinged Fish Survival and Debris Handling at Salem Ge nerating Station. Proceedings of the EPRI/DOE Power Generation Impacts on Aquatic Re sources Conference, Atlanta, GA.

Smith, H. 1997. Operating History of the Puntledge River Eicher Screen Facility. Proceedings of Fish Passage Workshop, Milwaukee, Wi sconsin, May 6-8, 1997. Sponsored by Alden Research Laboratory, Conte Anadromous Fish Re search Laboratory, Electric Power Research Institute, and Wisconsin Electric Power Company.

Stira, R. J. and D. A. Robinson. 1997. “E ffectiveness of a Louver Bypass System for Downstream Passage of Atlantic Salmon smolts and Juvenile Clupeids in the Holyoke Canal, Connecticut River, Holyoke, Massachusetts.” Proceedings of Fish Passage Workshop, Milwaukee, Wisconsin, May 6-8, 1997. Spons ored by Alden Research Laboratory, Conte Anadromous Fish Research Laboratory, Electric Power Research Institute, and Wisconsin Electric Power Company (1997).

Taft, E. P., A. W. Plizga, E. M. Paolini, and C. W. Sullivan. 1997. Protecting Fish with the New Modular Inclined Screen. The Envi ronmental Professional 19(1):185-191.C-1 APPENDIX C OVERVIEW OF REDUCED FLOW OP TIONS FOR FISH PROTECTION

Reducing flow into power plant in takes can reduce fish entrainment. Flow can be reduced by: 1) modifying existing pump operations by reducing the number of operating pumps or throttling valves, 2) installing variable sp eed drives on the circulation wate r pumps, or by 3) retrofitting the plant with a closed-cycle cooling system. Reduc tion in entrainment for all three options would be roughly proportional to the fl ow reduction. Operating fewer pumps or installing variable speed motors on the existing circulating water pumps would allow opera tion at reduced flow rates during periods of high entrainment. A lower pump capacity would reduce the screen approach velocity, thereby potentially reducing impingement as well as entrainment. Make-up water for closed loop cooling systems can be as little as 2% of the flow into a once-through cooling system, thereby greatly reducing entrainmen t potential. However, the reduced effects of closed-cycle cooling systems on the aquatic e nvironment resulting from small makeup water requirements can be countered by major airborne impacts such as noise impacts, aesthetic impacts, icing of roads and streets, reduced visibility from the tower vapor plume, and drift dispersion.

Modified pump operation options and closed-loop c ooling water alternatives that are available to reduce intake flow and fish entrainment are discussed in the following sections.

MODIFIED PUMP OPERATION

Reducing circulating water could be accomplishe d by reducing the number of operating pumps or by reducing the flow from each pump. If mul tiple circulating water pumps discharge into a common pipe to convey water to the plant conden sers, operating fewer pumps would be possible. If pumps can not be shut off because of the piping configuration, throttling of discharge valves or variable speed drivers (power fr equency or eddy current couplings) could be used to reduce flow. In any case, reduced flow would result in higher discharge water temperatures for the same heat transfer and, in some cases, pl ant output might have to be limited to meet permit requirements for thermal discharges.

Estimates of the amount of flow reduction that is acceptable for satisfactory condenser performance are needed to evaluate modified pump operation alternatives . Pump performance characteristics must be reviewed to define opera ting limits if discharge va lves are used to reduce flow. Throttling valves could re quire more power to operate the pump with less flow. Hydraulic grade lines must be developed to determine if negative pressures at the condenser outlet water boxes will be a problem. Installation or modifi cations of vacuum priming systems may be necessary to assure that the structural integrity and performance of the condenser is maintained.

Important considerations that have to be addres sed relative to backfitting motors with variable speed drivers are:C-2 • Eddy current couplings are large and the size increases with lower speed requirements. Large eddy current couplings that would be necessary for large ci rculation water pumps are as big as the pump motors.

• Voltage spikes from a variable frequency drive (VFD) can cause damage to the motor insulation. A reactor on the incoming line or between the VFD and the motor may be necessary to prevent damage to the insulation.

• At slower speeds, existing mo tor cooling fans may not be able to remove the heat. Additional fans may be needed to cool th e motor and prevent damage to the motor insulation.

• Harmonics from a VFD may backfeed into the incoming power line affecting other power users. This problem has been eliminated with the newer VFD designs.

All of the above issues should be discussed with the existing pu mp and motor manufacturers and variable speed drive suppliers to full y evaluate reduced flow alternatives.

CLOSED-CYCLE COOLING SYSTEMS

Cooling towers and cooling reservoirs are the primary closed-cycle cooling systems that are employed at power plants. Cooling reservoirs generally have very large surface areas, on the order of 4,000 to 10,000 acres, depending on the plant design. Cooling towe rs require less area than reservoirs, and for the purpose of this st udy, cooling towers are c onsidered to be better suited for potential retrofit at existing plants than cooling reservoirs . Therefore, cooling reservoirs have not been included in this eval uation as a potential alternative to reduce fish entrainment.

Wet and dry cooling towers are the two types of cooling towers that are typically used. Wet towers are the most common and reduce cooling wa ter temperatures by dir ect contact with large volumes of air. Wet towers are classified as natural or mechanical draft, depending on how the airflow is induced through the tower. Cooling water in dry towers does not come in direct contact with air. Where plumes from towers ar e a concern, hybrid wet-dr y towers can be used (EPA 2002). Wet-dry towers combine dry heat ex change surfaces with c onventional wet cooling
towers.

Retrofitting any closed-cycle cooli ng system to an existing power pl ant is a difficult engineering, scheduling, and construction effort because mo st plants are not originally designed to accommodate unusual modifications (Burns et al, 1994b). Th e complexity and high costs associated with retrofitting a cooling to wer to an existing plant are due to:

• Permanence of existing site features and structures.

• Fundamental design differences between once-through cooling systems and any alternative closed-cycle cooling technologies.

• New construction must acco mmodate existing plant operational requirements and regulatory restrictions.

• Installation of the tower f acilities and long, underground, larg e diameter piping runs to and from the towers are difficult without cont acting buried obstructi ons or contaminated soils.C-3 Each of the retrofitted closed-cycle cooling systems, if installed, would reduce net generation because of design differences between closed- loop and once-through cooling systems. Reasons why retrofit of closed-cycle co oling at once-through plants ca use reduced generation include (Parsons 2002):

1. Turbine exhaust pressures are higher with a closed-loop cooling system than with a oncethrough system because of the seasonally higher water temperatures that the closed-loop system delivers to the condenser inlet. Higher turbine back pressure penalizes the unit heat rate and reduces power output. 2. Cooling water has to be pumped to and up into cooling towers, requiring significantly more power than a once-through system. 3. Except in the case of the natural draft towe r, major amounts of energy are consumed in conveying the necessary fresh air through closed -cycle cooling equipment with the fans. 4. Water flow through the condensers desi gned for once-though cooling must be appreciably reduced for closed-loop cooling to utilize cooling towers that are of a costeffective size. In the case of a natural draf t towers, reduced flow is sometimes necessary to develop suitable draft. To be compatible w ith the required heat transfer conditions in a condenser with lower cooling water flow than the once-through design, the turbine backpressure must correspondingly rise wh ich further reduces the plant output.

Mechanical draft and natural dr aft cooling towers both have vi sible plumes that can cause concern. During periods of cool er weather, high relative humi dity, and low winds, a visible plume out of the top of the towers is evident be cause the exit air temperature is higher than the ambient air temperature and is essentially at 100 % relative humidity. As the air cools down to ambient conditions, the water vapo r in the air becomes visible.

A brief description of natural dr aft and mechanical dr aft wet cooling towers, dry cooling towers, hybrid wet-dry towers, and design cons iderations are presented below.

Natural Draft Cooling Tower. A natural draft cooling tower tr ansfers heat in the condenser closed-loop cooling water to ambient air that is induced to flow through the tower by the chimney effect (i.e., the density difference betw een the exhaust air inside the shell and the ambient air density surrounding the shell). Warm water from the condenser is distributed uniformly to the top of the fill section, which is located near the base of the tower. The fill section disperses the water into small droplets and thin sheets as it falls by gravity through the fill into the basin. The cooling effect provided in the fill section is mostly by the evaporation of a small percentage of the heated discharge wate r as it contacts the cooling air (Brocard and Burns, 1985). The remaining cooled water is re cycled back through the condenser. The cooling (heat transfer) section of the na tural draft tower is the fill whic h is typically an anti-fouling, nonclogging, plastic PVC material.

Important environmental considerations associated with natural draft cooling towers are effects on air quality, ambient noise, and aesthetics. Natu ral draft cooling towers are large and, because of their size, the towers and their plumes ha ve a major visual and aesthetic impact on the surrounding area. Natural draft towers overshado w all the surrounding struct ures and are visible from several miles away. The vapor plumes can also be considered obtrusive because duringC-4 ambient conditions that are stable , cold, and humid with little wind, the plumes extend far from the plant and with a variable trajectory. Because of the height of the towers, ground fog does not occur with natural draft towers. The falling wate r in a natural draft c ooling tower creates sound levels that are typically less than 45 A-weighted decibels (dba) with in 3,000 ft of the base of the tower. Noise attenuation measures can be inco rporated into a natura l draft tower design, but these measures could increase the to wer costs by up to 15% (EPA 2002)

Natural draft cooling towers typically concentr ate the chemical and minerals in the makeup water drawn from the water body about five times. Concentration of the water is an inherent, natural consequence of the evaporation pro cess for all types of wet cooling towers

Mechanical Draft Cooling Towers. In a mechanical draft wet c ooling tower, heat in the discharged warm condenser water is transferred to ambient air that is induced to flow through the tower by large, slow speed fans. The warm water is distributed uniformly to the top of the fill section of each cell of the tower a nd is dispersed into small droplets and thin sheets as it falls by gravity through the fill into the basin. The coolin g effect provided in the fill section is mostly by the evaporation, similar to the natural draft coolin g tower. The fill sectio n is similar to natural draft towers and consists of anti-f ouling, non-clogging, plas tic PVC material.

Environmental considerations associated with mech anical draft cooling towers are similar to the considerations for natural draft cooling towers. An opaque plume can be expected to occur and can extend downwind 500 to 1000 feet from the c ooling tower, especially during the colder seasons. This may lead to icing of the roads under certain conditions. Drift dispersion from a mechanical draft tower is very local because the exhaust is clos e to the ground. Modern drift eliminator designs can limit drift to less than 6 gpm during normal operatio n. The usual dispersion pattern results in salt deposition and saline air concentrati ons that are relative ly small and remain mostly within the site boundaries. At a 2-to-1 concentration level, the drift droplets would be comprised of a maximum of 40,000 ppm of salt and could cause some surface corrosion to the tower components and may damage vegetation in th e area. To prevent the release of potentially harmful leacheate from the fill material, fiberglass fill is often used.

Noise as high as 50 dba typically occurs within 3,000 ft of the tower. Similar to natural draft towers, noise attenuation treatments can reduce th ese effects, but would increase the tower costs by up to 25 percent.

Blowdown from the closed-loop cool ing system would have water qua lity constituent s concentrated at twice the natural water body chemistry levels and slightly elevated in temperature. The cooling system blowdown would have to be treated and cooled to comply with applicable EPA and state mandated guidelines and regulatio ns before being discharged.

Dry Cooling Towers. A dry cooling tower rejects heat to the atmosphere in manner similar to the steam turbine condenser. Water or steam from the condenser is pumped through finned tubes, and large diameter fans force cooling air ov er the tube surface and the heat of the water or steam inside the tubes is transfer red to the cooling air. There ar e two important differences in the heat transfer process between dry and wet coo ling towers. The first is that the dry tower transfers the rejected plant heat in proportion to the difference between its operating temperatureC-5 and the ambient dry bulb temperature. Depe nding on the relative humidity, the dry bulb temperature can be 15°F to 20°F warmer than the wet bulb temperature and so the dry tower usually produces a warmer return to the plant. The second difference is that dry towers require about four times the air quantity needed by wet towers because the evaporative heat transfer process that occurs in wet cool ing towers essentially humidifies the cooling air. This higher airflow in dry towers must be created by fans resulting in a significantly higher operating cost than mechanical wet draft towers.

Dry towers do not require any water use except for a very small amount that compensates for piping, tubing, and pump seal leakag e. Installation of dry cooling towers at an existing plant would virtually eliminate all environmental effects relative to the water b ody and air quality. No makeup water or blowdown discharges are necessary with a dry tower and the plume is invisible. However, dry cooling towers have never been retr ofitted to an electric utility generating unit. High capital costs, high pumping and fan power requirements, extremely poor performance during the warm weather months , potential for freezing in wint er, potential for high noise emissions, and high maintenance requirements make dry cooling towers imprac tical to retrofit at existing plants (Brocard and Burns, 1985).

There are two general types of dry cooling towers, direct and indir ect. As the name implies, the direct dry cooling tower direc tly condenses the steam from the turbine. A large steam duct carries the sub-atmospheric turbine exhaust stea m from the turbine exit inside the power block area to a location outside the building at the dry cooling tower. Here, th e turbine exhaust steam condenses inside finned round, square , or elliptically shaped tubi ng. The direct dry tower design replaces the condenser. To produce the transfer of the heat of c ondensation from the steam in the tubes to the ambient cooling air, a relatively la rge number of fans is required. The non-contact heat transfer coefficient of the finned tube surface is very low, and this has a significant effect that increases the dry direct tower size. In a ddition, the quantity of cooling air required is much greater than other types of towe rs. As a result, direct dry co oling towers are very large and require significant auxiliary power from the plan t. In a direct dry cooling tower, after condensation, the condensate of th e steam is collected and pump ed back to the conventionalplant feedwater system equipment where the steam power cycle repeats. Air in-leakage and noncondensable gases are removed from the condens ation process and compressed to atmospheric pressure by relatively large capacity steam jet air ejectors or vacuum pumps.

An indirect dry cooling system would use a water cooled cond enser, and the heat of the condensing turbine exhaust steam is transferred into the cooling water within the condenser. The circulating water pumps typically pump the coo ling water through the conde nser to the cooling tower supply basin. Booster pumps convey the heat ed water to the dry cooling tower where it is cooled within a finned tube surface and returned again to the circulating water pumps and the condenser. The indirect dry tower can be more flexibly sited than the direct dry towers. Indirect dry towers avoid the use of th e large reinforced steam duct fr om the turbine that would be difficult to route through the existing turbin e building. However, the indirect dry tower introduces an intermediate heat transfer step that further decreases the co oling efficiency of the system.C-6 Relative to the wet cooling tower, both the direct and indirect dry towers require significantly more attention and maintenance during the winter months in cold climates to prevent freezing. Furthermore, the dry tower designs and housings must incorporate feat ures for operation at below freezing temperatures.

Hybrid Wet-Dry Cooling Towers. Hybrid wet-dry towers utili ze closed-loop air cooling systems for the turbine steam condensers and a separate closed-loop cooling water system with a wet tower to transfer heat from the condenser cool ing system to the atmosphere. Concerns with retrofitting a hybrid wet-dry cooling tower at a plant with a once-through cooling system are similar to the concerns discussed above for natu ral and mechanical draft wet cooling towers and for dry cooling towers.C-7 REFERENCES

Brocard D., and J. M. Burns. 1985. Cooling Towers. In : Handbook of Energy Systems Engineering. J. Wiley & Sons, NY.

Burns, J. M., J. M. Nicholson, J. H. Annet, and D. N. Alexander. 1994b. The Impacts of Retrofitting Cooling Towers at a Large Powe r Station. EPRI Cooling Tower Conference.

Parsons Infrastructure and Technology Group, Inc. (Parsons) 2002. An I nvestigation of SiteSpecific Factors for Retrofitting Recirculating Cooling Towers at Existing Power Plants.

United States Environmental Protection Agen cy (EPA). 2002. Technical Development Document for the Proposed Secti on 316(b) Phase II Existing Faciliti es Rule. Office of Science and Technology, Engineering and Analysis Divi sion and the Office of Water. EPA 821-R-02- 003.