### MEMORANDUM

Tetra Tech, Inc. 10306 Eaton Place, Suite 340 Fairfax, VA 22030 phone 703 - 385 - 6000 fax 703 - 385 - 6007
TO : Record FROM : Christine Wong, Tetra Tech, Inc. DATE: August 28, 2008 SUBJECT: Notes from Beaudrey USA teleconference s To compleme nt existing information on cooling water intake structures and intake technologies, EPA directed Tetra Tech (Tt) to research and make contact with intake technology

manufacturers , specificall y international intake technology manufacturers

. Tt began b y searching the docket records and Internet for intake technology manufacturers. A 2007 Power

- Technology .com web article stated that over 90% of French nuclear plants use Beaudrey screens and the Beaudrey Web site stated that: Screens equipped with Beaudrey F PSTM will meet and/or exceed the 316b fish impingement criteria of 80 to 95% mortality reduction in almost all cases. System operational tests have demonstrated mean survival rates in excess of 90% across a range of fish species. Because Beaudrey , a Franc e - based compan y, also has an American office, Tt contacted the American office via email to discuss information on their sy stem operational tests

. On March 4, 2008, Tt spoke with Brian Hittle, Director of Beaudrey ’s USA projects, regarding the company ’s i ntake screening products and unusually large share of the French intake technology market. Tt learned that Beaudrey

was founded in France in 1982 to develop aquatic organism p rotection technologies for the Electricité de France , and that there are no nati onal regulation regarding aquatic organism protection in France, Belgium, or Portugal (the countries where Beaudrey has wo rked), or in the European Union. Mr. Hittle likened the European aquatic organism protection regulatory framework as similar to the U .S

. before the passage of the 316(b) regulations

– site

- specific, locall y - driven permits to protect aquatic organisms in specifi c, high

- value waterbodies

.While over 90% of France’s nuclear power plants use Beaudrey drum screens, only

two facilities use th e patented Fish Protection Sy stem ( FPS ) ; there are also s ys tems installed at facilities in Belgium and Portugal . The company , both in its European and American offices, remains extremely active in the in the intake technology market. Tt found that the or iginal Beaudrey screens were Ristroph screens equipped with fish buckets . The company ’s newest fish protection technology , the F PS , includes a Hidrostal® fish pumps and backwash screens and w orks with all ty pes of Beaudrey traveling screens, drum screens, and W Intake Protection (WI P) s creens . The FPS also works with fine mesh screens and can be installed at the same time as the screens or added/retrofit later

. Fish are impinged for a maximum of one minute, as the FPS operates at one revolution per minut e. W ith the FPS/WI P screen combination (rotating screening wheel with no chains or sprocket teeth), Beaudrey guarantees no carry
- over of debris or fish . The compan y has found that this sy stem works well for high, low, and mid

- range water levels

. Mr. Hittle explained that Beaudrey replaces other company ’s screens when installing its FPS; he did not specify

whether the FPS could be installed on or with other companies’ screens, onl y indicating that the Beaudrey doesn’ t , preferring instead to do a wholesale replacement

. He also noted that the Hidrostal® fish pump is the only technology approved b y the U.S. Bureau of Reclamation in California to move fish; there are man y papers available discussing this technology

. Mr. Hittle stated that r epresentatives fro m Beaudrey have previousl y met with Martha Segall (USEPA) to discuss the applicability of Beaudrey ’s technology for 316(b) requirements; the meeting took place after the Phase II Rule had been promulgated

. Mr. Hittle indicated that the company has y ears ’ worth of impingement and entrainment data at its French sites and is willing to share this data upon request. Mr. Hittle stated that Beaudrey has not had much presence in the U.S. market, but is working on market penetration

. Beaudrey is currently

runnin g an EPRI
- funded pilot study to test its FPS; the pilot test has been running since fall 2006. The pilot study has been collecting data on the effectiveness of the FPS on naturally

- occurring fish species; the pilot test move d on to introduced species in s pring 2008. The data collection include s both numbers and ty

pes of fish impinged . Mr. Hittle reported that i mpingement survival holds steady

at about 90% for the naturall y - occurring species, though the pilot study does not account for fish that were weak or dead prior to impingement. Beaudrey expect s to have even higher survival rates with the introduced fish

. Infollow

- up communications, Mr. Hittle indicated that Beaudrey conducted a series of native fish sampling events during March and early

April, and conduct ed the first of a series of hatchery fish introduction experiments (1,500 fish) on April 30th. Mr. Hittle reported that much of this research is sponsored or in partnership b y/with EPRI , and an EPRI r epresentative (Doug Dixon) was to be present to observe the introduction experiment. On May 13, 2008, Mr. Hittle reported on the preliminary mortality study results from the Beaudrey W IP screen fish introduction test after holding the fish for 48 hours (Table 1, below) and noted that afull statisti cal report will be issued upon completion of the summer warm water test with

more fish. Mr. Hittle conducts power plant inspections up and down the Mississippi River valley ; he commented that a common concern among plant operators is that a mandate for re circulating cooling towers will permanently lower water levels in the M ississippi River basin, or possibly , in the entire U.S., as large volumes of makeup water are taken up and never returned . M r. Hittle noted that a facility in Kansas City

has dug deep groundwater wells and begun using groundwater for cooling to avoid 316 intake water implications

. Table 1: Pilot Study Initial Results Fish Species Control Group Survival Test Group Survival Bluegill 101 live/101 total = 100.0% survival 197 live/199 tota l = 99.0% survival Fathead Minnows 81 live/100 total = 81.0% survival 165 live/208 total = 79.3% survival Channel Catfish 90 live/100 total = 90.0% survival 220 live/229 total = 96.1% survival