Tetra Tech, Inc.

10306 Eaton Place, Suite 340 Fairfax, VA 22030 phone 703 - 385 - 6000 fax 703 - 385 - 6007 TO : Paul Shriner and Jan Matuszko, EPA FROM : Kelly

Meadows, Tetra Tech DATE: September 10, 2008 SUBJECT: Phase II Facilities Tetra Tech was tasked with determining the number of facilities who are subject to thermal discharge limits in their NPDES permits. While summary is not readily

available, a query

of EPA’s Permit Com some insight to the issue. PCS was queried for all of the Phase II facilities (by NPDES permit number) and cooling water and temperature

- related fields were examined. Data was further screened by eliminating records that app ear to refer to permit conditions that are no longer contained in the facility ’s current permit (e.g., optional monitoring and deleted monitoring conditions fields). The table s facilities (of 544 o r 14%) appear to have thermal discharge limits of some type. Note that this analysis has significant limitations and likely represents an approximate number of facilities; most likely it represents the minimum number of facilities with thermal discharge c onditions. These limitations include:

 Several states do not submit information to PCS  Some states may

not input data to all fields  PCS may

not adequatel y display

narrative limits (thermal limits often narrative, such as a limit not to exceed 1



### MEMORANDUM 10306 Eaton Place, Suite 340

Paul Shriner and Jan Matuszko, EPA Kelly Meadows, Tetra Tech September 10, 2008 Phase II Facilities with Thermal Discharge Limits Tetra Tech was tasked with determining the number of facilities who are subject to thermal discharge limits in their NPDES permits. While summary

- level data of this ty pe is not readily

available, a query

of EPA’s Permit Com pliance System (PCS) provides PCS was queried for all of the Phase II facilities (by NPDES permit number) and cooling

related fields were examined. Data was further screened by ear to refer to permit conditions that are no longer contained in the facility ’s current permit (e.g., optional monitoring and deleted monitoring s below shows the results of the analysis: approximately 78 appear to have thermal discharge limits of some type. Note that this analysis has significant limitations and likely represents an approximate number of facilities; most likely it represents the minimum number of facilities with onditions. These limitations include: Several states do not submit information to PCS Some states may

not input data to all fields PCS may not adequatel y display

narrative limits (thermal limits often narrative, such as a limit not to exceed 1 ° C within a radius of 1000 meters of the discharge) Tetra Tech was tasked with determining the number of facilities who are subject to level data of this ty

pe pliance System (PCS) provides PCS was queried for all of the Phase II facilities (by NPDES permit number) and cooling

related fields were examined. Data was further screened by ear to refer to permit conditions that are no longer contained in the facility ’s current permit (e.g., optional monitoring and deleted monitoring shows the results of the analysis: approximately 78 appear to have thermal discharge limits of some type. Note that this analysis has significant limitations and likely represents an approximate number of facilities; most likely it represents the minimum number of facilities with

PCS may not adequatel y display

narrative limits (thermal limits often narrative, a radius of 1000 meters of the discharge)- 2

-

In short, a detailed review of each individual permit and fact sheet would be required to most accurately

assess the presence and scope of thermal discharge permit conditions at these facilities. Thermal Limits by Type Number of facilities Percent of total Wa ter Temperature 32 41.03% Te mp erature Difference between Sample and Upstream 4 5.13% BTUs/Heat Rejected 21 26.92% Combination of the Above 21 26.92% Total 78 Thermal Limits by Monitoring Frequency Number of facilities Percent of total Continuous 17 21.79% Monthly 3 3.85% Daily/W eek ly 37 47.44% Hourly 0 0.00% Combination 7 8.97% Not Specified 14 17.95% Total 78 Thermal L imits by EPA Region Number of facilities Percent of total Region 1 5 6.41% Region 2 9 11.54% Region 3 10 12.82% Region 4 17 21.79% Region 5 32 41.03% Region 6 1 1.28% Region 7 3 3.85% Region 8 1 1.28% Region 9 0 0.00% Region 10 0 0.00% Total 78