### 316B RULE **TELEPHONE LOG** Name of Caller: John Sunda, SAI C Date: January 15 , 2010 Company Name: SPX Cooling Technologies, Inc. Street Address: 7401 W 129 Street City /State/ZIP: Overland Park, KS 66213 Person Contacted: Kent A. Martens, P. E. Title : Chief Technical Advisor
- Evaporative Cooling Contact Info: Tel: 913/664
- 7501

Fax: 913/693
- 9522 Cell: 913/302
- 7234 kent.martens@spx.com Questions: In quired about plume and noise abatement cooling towers including questions about operating problems cited by others with the plume abated towers at Newington Energy

Facility The Newington plume abatement cooling tower is an obsolete cooling tower design called “Clear Flow ” that they no longer sell. The dry

cooling portion of this design used corrugated PVC sheets with air and water flowing between alternating sheets. He was not sure of the problem but thinks it involved some leaking of cooling water in this part of the sy stem. This design of corrugated PVC sheets and alternating flow is s omewhat similar in design to their new Clear Skies technology but in this case the alternating flow is ambient air and wet cooling exhaust. This technology was originally

designed as a water conservation technology but has demonstrated an ability to functi on as plume abatement as well. He agreed that it may take some time for this technology to acquire more public acceptance. They have performed a successful full scale demonstration in New Mexico. Regardless, they

do have plume abatement towers that use conventional coils that are suitable for saltwater applications. He suggested they would need to be constructed using high grade stainless steel or titanium. I asked about cycles of concentration for saltwater sy stems and he said that ty picall y the y operate in the range of 1.3 to 1.7. Imentioned that the Newington NPDES permit fact sheet indicated that the tower could operate at a COC of 2.0 and he said that 2.0 was possible but it was pushing the limit.Regarding increased energy usage for plume abate ment

– although the dry coils are higher than the wet tower spray nozzles , once the system fills up with water the head loss is primarily

due to friction losses and the increase in pumping head will range from 5 to 10 ft with 8 ft being a ty

pical value. T here will also be a slight fan energy increase on the order of about 5 to 10%. This is due to the fact that the sy stem needs to account for some damper air leakage. Dampers are used to close off the dry cooling coil portion in winter when it is not needed
. He said that an increase in capital costs for a plume abated tower of 2.5 to 3.5 can be expected. Regarding the ability

to use plume abatement in back
- to - back configurations, it isn’t that it can’t be done but rather that since the coils must be placed in a vertical configuration, it is difficult to get full mixing of the dry cooling airflow coming in on one side with the wet cooling airflow. So you don’t get sufficient dryer airflow mixing towards the back side resulting in partial plume abatement ( i.e. only front half of plume is fully abated). Regarding noise att enuation, he though that a 10% increase in capital costs might be low especiall y if the noise abatement requirements are aggressive. I suggested an aggressive design target of 50 dBA at 50 0 ft. He did a quick calculation of an 18 cell back
- to - back tower showing the non
- abated design producing 63.3 dBA at 500 ft and the same abated tower producing 47 dBA at 500 ft using numerous additional features resulting in nearl y double the cost of the towers. I requested that he provide me with some design and cost estimates for comparable towers with different features including aggressive noise abatement, moderate noise, and plume abatement. Some noise abatement points he made:  Noise abatement requ ires a sophisticated anal ys is by a specialist.  Some of the additional technologies may onl y be necessary

on one side of the tower limiting costs.  Low noise fans can cost orders of magnitude more than conventional fans  Barrier walls work well for close up receptors but not as well for far off receptors  They have an array

of technologies such as splash baffle, inlet and outlet attenuators, aluminum frame baffles, etc. **Follow -**  **up on May 5, 2010** Inquired about degree of increase in O&M costs for plume abatem ent. I said that my calculations showed a total fan & pump power increase of about 15% and he said that would be a reasonable estimate. Inoted that our cooling tower and basin capital costs were about $80/gpm. He said that his quick calculation was $40/gp m but if you included installation, controls, mechanical & electrical equipment that this figure was reasonable. I then noted that using a factor of 2.5 resulted in a capital cost increase of $200/gpm for plume abatement.
. I then noted that O&M costs for conventional towers was often cited as 1%
- 2% and that our EPA cost estimate includes about $1.25/gpm (about 1.5% of $80) for non

- powermaintenance and another $1.25 for chemicals to operate at high COC. He said that there

would also be an increase in non
- power O&M c osts due to the larger tower and maintenance of coils and dampers. He said a 50% to 100% increase in the non
- power O&M over that for the conventional tower would be reasonable
.