MEMORANDUM
TO: 		Formaldehyde Work Group
FROM:	Rebecca Edelstein, EPA/OPPT/EETD
DATE:	February 23, 2011
SUBJECT:	List of Urea-Formaldehyde Resin Substitutes

The purpose of this document is to identify chemicals that should be assessed for hazard and exposure based on publicly available information and input from public meetings, the California Air Resource Board (CARB), and ANPR comments on potential substitutes.  Stakeholders from industry as well as CARB have stated that the CARB Air Toxics Control Measure (ATCM) is technology forcing; therefore, new technologies will likely be developed in the next few years that are not discussed in this document.

The type of resin used to manufacture pressed wood products greatly affects the amount of formaldehyde released.  Therefore, most technologies designed to limit formaldehyde emissions focus on alternative resins.  Different resins that are expected to be used to limit the emissions of formaldehyde from the three pressed-wood products regulated under the CARB ATCM are listed below:

   Hardwood Plywood (HWPW)
         * Urea-formaldehyde (UF) + Melamine (1,3,5-triazine-2,4,6-triamine)
         * Polyvinyl Acetate (PVA)
         * PVA-Soy
         * Phenol-formaldehyde (PF)
         * Polyamide-soy -- based on the combination of a polyamide epichlorohydrin combined with soy flour

   Particleboard (PB)
         * Urea-formaldehyde (UF) + Melamine
         * Urea-formaldehyde (UF) + Scavengers
         * Phenol-formaldehyde (PF)
         * Melamine-Formaldehyde (MF) + Scavengers
         * Cashew nut shell liquid resin

   Medium Density Fiberboard (MDF)
         * Urea-formaldehyde (UF) + Melamine
         * Urea-formaldehyde (UF) + Scavengers
         * Polymethylene diphenyl diisocyanate (pMDI)
         * Melamine-Formaldehyde (MF) + Scavengers

Likely scavengers, additives, and cross linking agents that may be added to the resins include: urea, ammonia, phenol, tannins, soy protein (hydrolysates and meal), melamine, hexamethylene tetraamine (commonly referred to as hexamine), sodium sulfate, sodium chloride, triacetin (glycerol triacetate), tris(hydroxymethyl) nitromethane, and chromium complexes.

Public comments from members of the pressed wood industry indicate that these substitutes have a number of limitations (both cost and performance), but that the industry is committed to meeting the CARB ATCM phase 2 limits and is working on resolving the cost and performance issues.  Information provided by CARB in a teleconference (July 29, 2009) and on its website on approved no added formaldehyde (NAF) and ultra-low emitting formaldehyde (ULEF) resins indicates that the alternative resins and scavengers listed above are consistent with what industry is currently using in certain products to meet the CARB ATCM limits.


Comment Info: =================

General Comment:A 75 day period of time to review the proposed regulations is insufficient.  I am requesting that the review period be extended to 180 days.

Thank you.


[Federal Register Volume 77, Number 181 (Tuesday, September 18, 2012)]
[Notices]
[Page 57566]
[FR Doc No: 2012-22965]

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ENVIRONMENTAL PROTECTION AGENCY

[EPA-HQ-OW-2012-0035; FRL-9730-7]

Announcement of Public Meeting on the Consumer Confidence Report
(CCR) Rule Retrospective Review and Request for Public Comment on
Potential Approaches to Electronic Delivery of the CCR; Correction

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice of a Public Meeting and Request for Public Comments;
correction.

-----------------------------------------------------------------------

SUMMARY: The U.S. Environmental Protection Agency (EPA) published a
document in the Federal Register of September 11, 2012, announcing a
public meeting listening session and a request for public comments. The
document contained an incorrect URL link for the pubic to use to
register for the meeting.

FOR FURTHER INFORMATION CONTACT: Adrienne Harris, Drinking Water
Protection Division, at<PHONE_NUMBER>.

Correction

    In the Federal Register of September 11, 2012, in FR Doc. FRL-9726-
8; on page 55833, in the third column, in the sixth paragraph, correct
the first sentence of the paragraph to read as follows:
    Public Meeting Registration: Individuals planning on participating
in the public meeting must register for the meeting at http://www.horsleywitten.com/ccrretroreview.

    Dated: September 12, 2012.
Pamela S. Barr,
Acting Office Director, Office of Ground Water and Drinking Water.
[FR Doc. 2012-22965 Filed 9-17-12; 8:45 am]
BILLING CODE 6560-50-P


[Federal Register: September 24, 2009 (Volume 74, Number 184)]
[Rules and Regulations]
[Page 48654-48657]
[DOCID:fr24se09-4]

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DEPARTMENT OF HOMELAND SECURITY

Coast Guard

33 CFR Part 165

[Docket No. USCG-2009-0755]
RIN 1625-AA00

Safety Zone: Robert Moses Causeway Bridge State Boat Channel,
Captree, NY

AGENCY: Coast Guard, DHS.

ACTION: Interim rule with request for comments.

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SUMMARY: The Coast Guard is establishing a temporary safety zone for
the waters of the State Boat Channel surrounding the Robert Moses
Causeway located in Captree, New York due to ongoing construction. This
rule is necessary to protect vessels transiting the area from hazards
imposed by construction barges and equipment; entry into this zone is
prohibited unless authorized by the Captain of the Port Long Island
Sound, New Haven, CT.

DATES: This interim rule is effective from September 24, 2009 until May
28th, 2010. The safety zone has been enforced with actual notice since
September 8, 2009. Comments and related material must reach the Coast
Guard on or before November 9, 2009. Requests for public meetings must
be received by the Coast Guard on or before October 1, 2009.

ADDRESSES: You may submit comments identified by docket number USCG-
2009-0755 using any one of the following methods:
    (1) Federal eRulemaking Portal: http://www.regulations.gov.
    (2) Fax:<PHONE_NUMBER>.
    (3) Mail: Docket Management Facility (M-30), U.S. Department of

Transportation, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue, SE., Washington, DC 20590-0001.
    (4) Hand delivery: Same as mail address above, between 9 a.m. and 5
p.m., Monday through Friday, except Federal holidays. The telephone
number is<PHONE_NUMBER>.
    To avoid duplication, please use only one of these four methods.
See the ``Public Participation and Request for Comments'' portion of
the SUPPLEMENTARY INFORMATION section below for instructions on
submitting comments.

FOR FURTHER INFORMATION CONTACT: If you have questions on this interim
rule, call or e-mail, Chief Petty Officer Christie Dixon, Waterways
Management, Coast Guard Sector Long Island Sound: telephone 203-468-
4459, e-mail<EMAIL_ADDRESS>If you have questions on
viewing the docket, call Renee V. Wright, Program Manager, Docket
Operations, telephone<PHONE_NUMBER>.

SUPPLEMENTARY INFORMATION:

Public Participation and Request for Comments

    We encourage you to participate in this rulemaking by submitting
comments and related materials. All comments received will be posted,
without change, to http://www.regulations.gov and will include any
personal information you have provided.

Submitting Comments

    If you submit a comment, please include the docket number for this
rulemaking (USCG-2009-0755), indicate the specific section of this
document to which each comment applies, and provide a reason for each
suggestion or recommendation. You may submit your comments and material
online (via http://www.regulations.gov) or by fax, mail or hand
delivery, but please use only one of these means. If you submit a
comment online via http://www.regulations.gov, it will be considered
received by the Coast Guard when you successfully transmit the comment.
If you fax, hand deliver, or mail your comment, it will be considered
as having been received by the Coast Guard when it is received at the
Docket Management Facility. We recommend that you include your name and
a mailing address, an e-mail address, or a telephone number in the body
of your document so that we can contact you if we have questions
regarding your submission.
    To submit your comment online, go to http://www.regulations.gov,
click on the ``submit a comment'' box, which will then become
highlighted in blue. In the ``Document Type'' drop down menu select
``Proposed Rule'' and insert ``USCG-2009-0755'' in the ``Keyword'' box.
Click ``Search'' then click on the balloon shape in the ``Actions''
column. If you submit comments by mail or hand delivery, submit them in
an unbound format, no larger than 8[frac12] by 11 inches, suitable for
copying and electronic filing. If you submit comments by mail and would
like to know that they reached the Facility, please enclose a stamped,
self-addressed postcard or envelope. We will consider all comments and
material received during the comment period and may change this rule
based on your comments.

Viewing Comments and Documents

    To view comments, as well as documents mentioned in this preamble
as being available in the docket, go to http://www.regulations.gov,
click on the ``read comments'' box, which will then become highlighted
in blue. In the ``Keyword'' box insert ``USCG-2009-0755'' and click
``Search.'' Click the ``Open Docket Folder'' in the ``Actions'' column.
You may also visit the Docket Management Facility in Room W12-140 on
the ground floor of the Department of Transportation West Building,
1200 New Jersey Avenue, SE., Washington, DC 20590, between 9 a.m. and 5
p.m., Monday through Friday, except Federal holidays. We have an
agreement with the Department of Transportation to use the Docket
Management Facility.

Privacy Act

    Anyone can search the electronic form of comments received into any
of our dockets by the name of the individual submitting the comment (or
signing the comment, if submitted on behalf of an association,
business, labor union, etc.). You may review a Privacy Act notice
regarding our public dockets in the January 17, 2008, issue of the
Federal Register (73 FR 3316).

Public Meeting

    We do not now plan to hold a public meeting. But you may submit a
request for one on or before October 1, 2009, using one of the four
methods specified under ADDRESSES. Please explain why you believe a
public meeting would be beneficial. If we determine that one would aid
this rulemaking, we will hold one at a time and place announced by a
later notice in the Federal Register.
    For information on facilities or services for individuals with
disabilities or to request special assistance at the public meeting,
contact Chief Petty Officer Christie Dixon, Waterways Management, Coast
Guard Sector Long Island Sound at the telephone number or e-mail
address indicated under the FOR FURTHER INFORMATION CONTACT section of
this notice.

Regulatory Information

    The Coast Guard is issuing this interim rule without prior notice
and opportunity to comment pursuant to authority under section 4(a) of
the Administrative Procedure Act (APA) (5 U.S.C. 553(b)). This
provision authorizes an agency to issue a rule without prior notice and
opportunity to comment when the agency for good cause finds that those
procedures are ``impracticable, unnecessary, or contrary to the public
interest.'' Under 5 U.S.C. 553(b)(B), the Coast Guard finds that good
cause exists for not publishing a notice of proposed rulemaking (NPRM)
with respect to this rule because insufficient time exists prior to the
beginning of construction to allow for a full notice and comment
period. Further, any delay encountered in this regulation's effective
date would be contrary to the public's interest as immediate action is
needed to ensure the safety of vessels transiting in the State Boat
Channel in the vicinity of the Robert Moses Causeway Bridge during
construction.
    Under 5 U.S.C. 553(d)(3), the Coast Guard finds that good cause
exists for making this rule effective less than 30 days after
publication in the Federal Register. A delay or cancellation of this
ongoing construction project is not in the public interest and would
further disrupt the flow of vehicular and maritime traffic. In
addition, this safety zone is necessary to ensure the continued safety
of the maritime public and construction workers throughout the
completion of this essential repair project.

Background and Purpose

    The New York Department of Transportation has been rehabilitating
portions of the Robert Moses Causeway Bridge and recently determined
that additional work is needed and will be rehabilitating the
northbound section of the Robert Moses Causeway Bridge located over the
State Boat Channel in Captree, NY beginning on September 8th, 2009.
These repairs are needed to ensure the continued safe operation of the
bridge when being raised to accommodate vessel traffic. To complete the
repairs on the bridge, construction barges will need to block the
waterway throughout the course of the rehabilitation project. To ensure
the

continued safety of the boating community and the construction workers
during the completion of this project, the Coast Guard is establishing
a safety zone on the navigable waters of the State Boat Channel within
100-yards to either side of the Robert Moses Causeway Bridge. This
safety zone is necessary to protect boaters from the hazards posed by
construction equipment located on the waterway during the
rehabilitation work and to protect the construction workers from the
dangers caused by vessels and vessel wake near the barges. Vessels may
utilize the Great South Bay or Jones Inlet as an alternative route to
using the State Boat Channel, allowing vessels to avoid the safety zone
and construction while adding minimal additional transit time. Marine
traffic may also transit outside of the established safety zone during
the effective dates thus allowing navigation to continue in all other
areas of the State Boat Channel, except the portion delineated by this
rule.

Discussion of Rule

    This regulation establishes a temporary safety zone on the State
Boat Channel within 100-yards to either side of the Robert Moses
Causeway Bridge. This action is intended to prohibit all vessels from
entering the designated portion of the State Boat Channel unless prior
permission has been received from the Captain of the Port Long Island
Sound.
    The effective period of this safety zone is from September 8th,
2009 through May 28th, 2010, inclusive. Entry into this zone during the
effective period is prohibited unless authorized by the Captain of the
Port Long Island Sound. If construction is completed and the barges are
removed prior to May 28th, 2010, the safety zone will no longer be
enforced and the Coast Guard will advise the public of the cancellation
of the safety zone through marine information broadcasts and local
notice to mariners.
    Any violation of the safety zone described herein is punishable by,
among other things, civil and criminal penalties, in rem liability
against the offending vessel, and the initiation of suspension or
revocation proceedings against Coast Guard-issued merchant mariner
credentials.

Regulatory Analyses

    We developed this rule after considering numerous statutes and
executive orders related to rulemaking. Below we summarize our analyses
based on 13 of these statutes or executive orders.

Regulatory Planning and Review

    This rule is not a significant regulatory action under section 3(f)
of Executive Order 12866, Regulatory Planning and Review, and does not
require an assessment of potential costs and benefits under section
6(a)(3) of that Order. The Office of Management and Budget has not
reviewed it under that Order.
    This regulation may have some impact on the public, but the
potential impact will be minimized for the following reasons: Vessels
may transit in all areas of the State Boat Channel other than the area
of the safety zone, and may utilize other routes to transit around the
safety zone and construction with minimally increased transit time.

Small Entities

    Under the Regulatory Flexibility Act (5 U.S.C. 601-612), we have
considered whether this rule would have a significant economic impact
on a substantial number of small entities. The term ``small entities''
comprises small businesses, not-for-profit organizations that are
independently owned and operated and are not dominant in their fields,
and governmental jurisdictions with populations of less than 50,000.
    The Coast Guard certifies under 5 U.S.C. 605(b) that this rule will
not have a significant economic impact on a substantial number of small
entities. This rule may affect the following entities, some of which
may be small entities: The owners or operators of vessels intending to
transit in those portions of the State Boat Channel that are covered by
the safety zone. For the reasons outlined in the Regulatory Evaluation
section above, this rule will not have a significant impact on a
substantial number of small entities.
    If you think that your business, organization, or governmental
jurisdiction qualifies as a small entity and that this rule would have
a significant economic impact on it, please submit a comment (see
ADDRESSES) explaining why you think it qualifies and how and to what
degree this rule would economically affect it.

Assistance for Small Entities

    Under subsection 213(a) of the Small Business Regulatory
Enforcement Fairness Act of 1996 (Pub. L. 104-121), we offer to assist
small entities in understanding the rule so that they can better
evaluate its effects on them and participate in the rulemaking. Small
businesses may send comments on the actions of Federal employees who
enforce, or otherwise determine compliance with, Federal regulations to
the Small Business and Agriculture Regulatory Enforcement Ombudsman and
the Regional Small Business Regulatory Fairness Boards. The Ombudsman
evaluates these actions annually and rates each agency's responsiveness
to small business. If you wish to comment on actions by employees of
the Coast Guard, call 1-888-REG-FAIR (1-888-734-3247). The Coast Guard
will not retaliate against small entities that question or complain
about this rule or any policy or action of the Coast Guard.
    Small businesses may send comments on the actions of Federal
employees who enforce, or otherwise determine compliance with, Federal
regulations to the Small Business and Agriculture Regulatory
Enforcement Ombudsman and the Regional Small Business Regulatory
Fairness Boards. The Ombudsman evaluates these actions annually and
rates each agency's responsiveness to small business. If you wish to
comment on actions by employees of the Coast Guard, call 1-888-REG-FAIR
(1-888-734-3247). The Coast Guard will not retaliate against small
entities that question or complain about this rule or any policy or
action of the Coast Guard.

Collection of Information

    This rule calls for no new collection of information under the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520).

Federalism

    A rule has implications for federalism under Executive Order 13132,
Federalism, if it has a substantial direct effect on State or local
governments and would either preempt State law or impose a substantial
direct cost of compliance on them. We have analyzed this rule under
that Order and have determined that it does not have implications for
federalism.

Unfunded Mandates Reform Act

    The Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1531-1538)
requires Federal agencies to assess the effects of their discretionary
regulatory actions. In particular, the Act addresses actions that may
result in the expenditure by a State, local, or Tribal government, in
the aggregate, or by the private sector of $100,000,000 or more in any
one year. Though this rule will not result in such an expenditure, we
do discuss the effects of this rule elsewhere in this preamble.

Taking of Private Property

    This rule will not effect a taking of private property or otherwise
have taking implications under Executive Order 12630, Governmental
Actions and Interference with Constitutionally Protected Property
Rights.

Civil Justice Reform

    This rule meets applicable standards in sections 3(a) and 3(b)(2)
of Executive Order 12988, Civil Justice Reform, to minimize litigation,
eliminate ambiguity, and reduce burden.

Protection of Children

    We have analyzed this rule under Executive Order 13045, Protection
of Children from Environmental Health Risks and Safety Risks. This rule
is not an economically significant rule and does not create an
environmental risk to health or risk to safety that may
disproportionately affect children.

Indian Tribal Governments

    This rule does not have Tribal implications under Executive Order
13175, Consultation and Coordination with Indian Tribal Governments,
because it does not have a substantial direct effect on one or more
Indian Tribes, on the relationship between the Federal Government and
Indian Tribes, or on the distribution of power and responsibilities
between the Federal Government and Indian Tribes.

Energy Effects

    We have analyzed this rule under Executive Order 13211, Actions
Concerning Regulations That Significantly Affect Energy Supply,
Distribution, or Use. We have determined that it is not a ``significant
energy action'' under that order because it is not a ``significant
regulatory action'' under Executive Order 12866 and is not likely to
have a significant adverse effect on the supply, distribution, or use
of energy. The Administrator of the Office of Information and
Regulatory Affairs has not designated it as a significant energy
action. Therefore, it does not require a Statement of Energy Effects
under Executive Order 13211.

Technical Standards

    The National Technology Transfer and Advancement Act (NTTAA) (15
U.S.C. 272 note) directs agencies to use voluntary consensus standards
in their regulatory activities unless the agency provides Congress,
through the Office of Management and Budget, with an explanation of why
using these standards would be inconsistent with applicable law or
otherwise impractical. Voluntary consensus standards are technical
standards (e.g., specifications of materials, performance, design, or
operation; test methods; sampling procedures; and related management
systems practices) that are developed or adopted by voluntary consensus
standards bodies.
    This rule does not use technical standards. Therefore, we did not
consider the use of voluntary consensus standards.

Environment

    We have analyzed this rule under Department of Homeland Security
Management Directive 023-01 and Commandant Instruction M16475.lD, which
guide the Coast Guard in complying with the National Environmental
Policy Act of 1969 (NEPA) (42 U.S.C. 4321-4370f), and have concluded
this action is one of a category of actions which do not individually
or cumulatively have a significant effect on the human environment.
This rule is categorically excluded, under figure 2-1, paragraph
(34)(g), of the Instruction. This rule establishes a safety zone and
therefore falls under the categorical exclusion in paragraph (34)(g).
An environmental analysis checklist and a categorical exclusion
determination are available in the docket where indicated under
ADDRESSES.

List of Subjects in 33 CFR Part 165

    Harbors, Marine safety, Navigation (water), Reporting and
recordkeeping requirements, Security measures, Waterways.

0
For the reasons discussed in the preamble, the Coast Guard amends 33
CFR part 165 as follows:

PART 165--REGULATED NAVIGATION AREAS AND LIMITED ACCESS AREAS

0
1. The authority citation for part 165 continues to read as follows:

    Authority: 33 U.S.C. 1226, 1231; 46 U.S.C. Chapter 701, 3306,
3703; 50 U.S.C. 191, 195; 33 CFR 1.05-1, 6.04-1, 6.04-6, and 160.5;
Pub. L. 107-295, 116 Stat. 2064; Department of Homeland Security
Delegation No. 0170.1.

0
2. Add Sec.  165.T01-0755 to read as follows:

Sec.  165.T01-0755  Safety Zone: Robert Moses Causeway Bridge State
Boat Channel, Captree, New York.

    (a) Location. The following area is a safety zone: All navigable
waters of the Federal channel on the State Boat Channel in Captree, NY,
from surface to bottom, within 100 yards to either side of the Robert
Moses Causeway Bridge.
    (b) Definitions. The following definition applies to this section:
Designated on-scene patrol personnel, means any commissioned, warrant
and petty officers of the U.S. Coast Guard operating Coast Guard
vessels who have been authorized to act on the behalf of the Captain of
the Port Long Island Sound.
    (c) Regulations. (1) The general regulations contained in 33 CFR
165.23 apply.
    (2) In accordance with the general regulations in Sec.  165.23 of
this part, entry into or movement within this zone is prohibited unless
authorized by the Captain of the Port Long Island Sound.
    (3) All persons and vessels must comply with the Coast Guard
Captain of the Port or the designated on-scene patrol personnel.
    (4) Upon being hailed by a U.S. Coast Guard vessel by siren, radio,
flashing light or other means, the operator of the vessel must proceed
as directed.
    (5) Persons and vessels may request permission to enter the zone on
VHF-16 or via phone at<PHONE_NUMBER>.
    (d) Effective period. This rule is effective from September 8th,
2009, through May 28th, 2010, inclusive.

    Dated: September 4, 2009.
Kevin C. Burke,
Commander, U.S. Coast Guard, Acting Captain of the Port Long Island
Sound.
[FR Doc. E9-22981 Filed 9-23-09; 8:45 am]

BILLING CODE 4910-15-P


[Federal Register Volume 81, Number 78 (Friday, April 22, 2016)]
[Rules and Regulations]
[Pages 23639-23640]
[FR Doc No: 2016-09159]

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R04-OAR-2015-0618; FRL-9945-22-Region 4]

Air Plan Approval; Tennessee: Knox County VOC Limits Revision for
Permits

AGENCY: Environmental Protection Agency.

ACTION: Direct final rule.

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SUMMARY: The Environmental Protection Agency (EPA) is taking direct
final action to approve a portion of a revision to the Tennessee State
Implementation Plan (SIP) submitted on March 14, 2014, by the State of
Tennessee, through the Tennessee Department of Environmental
Conservation (TDEC) on behalf of the Knox County Department of Air
Quality Management (Knox County) to address changes to a Knox County
regulation regarding permits. EPA has determined that Tennessee's
requested SIP revision is consistent with the applicable provisions of
the Clean Air Act (CAA or Act).

DATES: This direct final rule is effective June 21, 2016 without
further notice, unless EPA receives adverse comment by May 23, 2016. If
EPA receives such comments, it will publish a timely withdrawal of the
direct final rule in the Federal Register informing the public that the
rule will not take effect.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-R04-
OAR-2015-0618 at http://www.regulations.gov. Follow the online
instructions for submitting comments. Once submitted, comments cannot
be edited or removed from Regulations.gov. EPA may publish any comment
received to its public docket. Do not submit electronically any
information you consider to be Confidential Business Information (CBI)
or other information whose disclosure is restricted by statute.
Multimedia submissions (audio, video, etc.) must be accompanied by a
written comment. The written comment is considered the official comment
and should include discussion of all points you wish to make. EPA will
generally not consider comments or comment contents located outside of
the primary submission (i.e. on the web, cloud, or other file sharing
system). For additional submission methods, the full EPA public comment
policy, information about CBI or multimedia submissions, and general
guidance on making effective comments, please visit http://www2.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT: Zuri Farngalo or D. Brad Akers, Air
Regulatory Management Section, Air Planning and Implementation Branch,
Air, Pesticides and Toxics Management Division, U.S. Environmental
Protection Agency, Region 4, 61 Forsyth Street SW., Atlanta, Georgia
30303-8960. Mr. Farngalo can be reached at<PHONE_NUMBER> and via
electronic mail at<EMAIL_ADDRESS>Mr. Akers can be reached at
(404) 562-9089 and via electronic mail at<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

I. Background

    On March 14, 2014, TDEC submitted to EPA several revisions to the
Knox County portion of the Tennessee SIP. At this time, EPA is acting
on one portion of the submittal: Section 25 of the Knox County Air
Quality Management Regulations, Permits, has been revised to add
regulations that streamline the permitting process for sources that
have the potential to emit volatile organic compounds (VOC), and EPA is
approving the incorporation of that revision into the Tennessee SIP.
The submittal also included revisions to section 25.6, adding a permit
exemption, and to section 26.5, adding a requirement that certain
sources of oxides of nitrogen and VOC submit an annual emissions
statement. The revision to section 25.6 was withdrawn from the
submittal in an August 7, 2015, letter sent to EPA by TDEC on behalf of
Knox County, a copy of which is included in the Docket for today's
action. EPA approved the revision to section 26.5 on November 5, 2015.
See 80 FR 68448. Therefore, today's final rule completes EPA's action
with respect to the March 14, 2014, submittal.

II. Analysis of Tennessee's Submittal

    The portion of Tennessee's March 14, 2014, SIP submittal that EPA
is approving today is the addition to the Knox County Air Quality
Management Regulations of section 25.11, Limiting a Source's Potential
to Emit of VOC by Recordkeeping, which sets forth recordkeeping and
reporting requirements for a source that has the potential to emit
above the major-source threshold but that prefers to be a synthetic
minor source (i.e., to accept limits lower than the major-source
threshold of 100 tons per year). Section 25.11 establishes a three-
tiered system of recordkeeping and reporting requirements, whereby
sources that elect to set their limits at the highest threshold have
the most stringent requirements and sources that opt for the lowest
threshold have the least stringent requirements. These changes are
consistent with ``Guidance for State Rules for Optional Federally-
Enforceable Emissions Limits Based on Volatile Organic Compound (VOC)
Use'' and ``Potential to Emit (PTE) Guidance for Specific Source
Categories,'' which are both EPA memoranda issued by the Office of Air
Quality Planning Standards. EPA has reviewed Tennessee's requested
changes to the Knox County Air Quality Management Regulations, and has
concluded that the addition of Section 25.11 is consistent with the
CAA.

III. Incorporation by Reference

    In this rule, EPA is finalizing regulatory text that includes
incorporation by reference. In accordance with requirements of 1 CFR
51.5, EPA is finalizing the incorporation by reference of Knox County
Air Quality Management Regulations section 25.11, Limiting a Source's
Potential to Emit of VOC by Recordkeeping. The EPA has made, and will
continue to make, these documents generally available electronically
through www.regulations.gov and/or in hard copy at the appropriate EPA
office (see the ADDRESSES section of this preamble for more
information).

IV. Final Action

    EPA is approving a portion of Tennessee's March 14, 2014, SIP
revision addressing changes to a Knox County regulation regarding
permits. EPA is publishing this rule without prior proposal because the
Agency views this as a noncontroversial submittal and anticipates no
adverse comments. However, in the proposed rules section of this
Federal Register publication, EPA is publishing a separate document
that will serve as the proposal to approve the SIP revision should
adverse comments be filed. This rule will be effective June 21, 2016
without further notice unless the Agency receives adverse comments by
May 23, 2016.
    If EPA receives such comments, then EPA will publish a document
withdrawing the final rule and informing the public that the rule will
not take effect. All public comments received will then be addressed in
a subsequent final rule based on the proposed rule. EPA will not
institute a second comment period. Parties interested in commenting
should do so at this time. If no such comments are received, the public
is advised that this rule will be effective on June 21, 2016 and no
further action will be taken on the proposed rule.

V. Statutory and Executive Order Reviews

    Under the CAA, the Administrator is required to approve a SIP
submission that complies with the provisions of the Act and applicable
federal regulations. See 42 U.S.C. 7410(k); 40 CFR 52.02(a). Thus, in
reviewing SIP submissions, EPA's role is to approve state choices,
provided that they meet the criteria of the CAA. Accordingly, this
action merely approves state law as meeting federal requirements and
does not impose additional requirements beyond those imposed by state
law. For that reason, this action:
     Is not a significant regulatory action subject to review
by the Office of Management and Budget under Executive Orders 12866 (58
FR 51735, October 4, 1993) and 13563 (76 FR 3821, January 21, 2011);
     Does not impose an information collection burden under the
provisions of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.);
     Is certified as not having a significant economic impact
on a substantial number of small entities under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.);
     Does not contain any unfunded mandate or significantly or
uniquely affect small governments, as described in the Unfunded
Mandates Reform Act of 1995 (Pub. L. 104-4);
     Does not have Federalism implications as specified in
Executive Order 13132 (64 FR 43255, August 10, 1999);
     Is not an economically significant regulatory action based
on health or safety risks subject to Executive Order 13045 (62 FR
19885, April 23, 1997);
     Is not a significant regulatory action subject to
Executive Order 13211 (66 FR 28355, May 22, 2001);
     Is not subject to requirements of Section 12(d) of the
National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272
note) because application of those requirements would be inconsistent
with the CAA; and
     Does not provide EPA with the discretionary authority to
address, as appropriate, disproportionate human health or environmental
effects, using practicable and legally permissible methods, under
Executive Order 12898 (59 FR 7629, February 16, 1994).
    The SIP is not approved to apply on any Indian reservation land or
in any other area where EPA or an Indian tribe has demonstrated that a
tribe has jurisdiction. In those areas of Indian country, the rule does
not have tribal implications as specified by Executive Order 13175 (65
FR 67249, November 9, 2000), nor will it impose substantial direct
costs on tribal governments or preempt tribal law.
    The Congressional Review Act, 5 U.S.C. 801 et seq., as added by the
Small Business Regulatory Enforcement Fairness Act of 1996, generally
provides that before a rule may take effect, the agency promulgating
the rule must submit a rule report, which includes a copy of the rule,
to each House of the Congress and to the Comptroller General of the
United States. EPA will submit a report containing this action and
other required information to the U.S. Senate, the U.S. House of
Representatives, and the Comptroller General of the United States prior
to publication of the rule in the Federal Register. A major rule cannot
take effect until 60 days after it is published in the Federal
Register. This action is not a ``major rule'' as defined by 5 U.S.C.
804(2).
    Under section 307(b)(1) of the CAA, petitions for judicial review
of this action must be filed in the United States Court of Appeals for
the appropriate circuit by June 21, 2016. Filing a petition for
reconsideration by the Administrator of this final rule does not affect
the finality of this action for the purposes of judicial review nor
does it extend the time within which a petition for judicial review may
be filed, and shall not postpone the effectiveness of such rule or
action. Parties with objections to this direct final rule are
encouraged to file a comment in response to the parallel notice of
proposed rulemaking for this action published in the proposed rules
section of today's Federal Register, rather than file an immediate
petition for judicial review of this direct final rule, so that EPA can
withdraw this direct final rule and address the comment in the proposed
rulemaking. This action may not be challenged later in proceedings to
enforce its requirements. See section 307(b)(2).

List of Subjects in 40 CFR Part 52

    Environmental protection, Air pollution control, Incorporation by
reference, Intergovernmental relations, Reporting and recordkeeping
requirements, Volatile organic compounds.

    Dated: April 6, 2016.
Heather McTeer Toney,
Regional Administrator, Region 4.

    40 CFR part 52 is amended as follows:

PART 52--APPROVAL AND PROMULGATION OF IMPLEMENTATION PLANS

0
1. The authority citation for part 52 continues to read as follows:

    Authority:  42 U.S.C. 7401 et seq.

Subpart RR--Tennessee

0
2. In Sec.  52.2220, table 3 in paragraph (c) is amended by revising
the entry for ``Section 25.0'' to read as follows:

Sec.  52.2220  Identification of plan.

* * * * *
    (c) * * *

                                 Table 3--EPA Approved Knox County, Regulations
----------------------------------------------------------------------------------------------------------------
                                                       State
      State section            Title/subject      effective date     EPA approval date          Explanation
----------------------------------------------------------------------------------------------------------------

                                                  * * * * * * *
25.0....................  Permits...............       3/12/2014  4/22/2016 [Insert       ......................
                                                                   Federal Register
                                                                   citation].

                                                  * * * * * * *
----------------------------------------------------------------------------------------------------------------

* * * * *
[FR Doc. 2016-09159 Filed 4-21-16; 8:45 am]
 BILLING CODE 6560-50-P


                                  MEMORANDUM

Tetra Tech, Inc.
10306 Eaton Place, Suite 340
Fairfax, VA 22030
phone<PHONE_NUMBER>
fax<PHONE_NUMBER>

TO:			Paul Shriner and Jan Matuszko, EPA
FROM:		John Sunda, SAIC and Kelly Meadows, Tetra Tech
DATE: 		April 17, 2009

SUBJECT:	Modular Cooling Tower Technology and Costs

Closed-cycle cooling (in the form of cooling towers) is one form of flow reduction.  However, in estimating compliance costs associated with closed-cycle cooling, EPA has typically only considered permanently-built onsite structures with concrete cold water basins.  Closed-cycle cooling may also be achieved through the use of modular cooling towers.  Modular cooling towers are portable cooling units that can supplement or even replace once-through cooling water flows at electric generators and other significant users of cooling water.  While this alternative technology offers a number of benefits over permanent cooling towers and could significantly reduce facility downtime, EPA does not presently have enough information to assess the widespread applicability of this technology.

Typical Modular Tower System

Much of the technical information below was obtained through correspondence with Blue Stream Services, which has partnered with the modular tower manufacturer Varitech Equipment Company.  The services provided by the vendors primarily involve short-term and long-term rentals, especially for systems that may require use during only a portion of the year.

System Operation

Modular cooling towers are typically used in either a helper mode or a recirculating mode.  In the recirculating mode, hot water can be withdrawn directly from the hot water discharge channel, cooled and then returned to the intake channel upstream of the intake pumps or in the intake pump well.  The modular tower system can recirculate all or only a portion of the total cooling system flow requirements.  To recirculate all of the flow, the modular cooling tower pumping rate is matched to the associated condenser cooling water pumping rate through the use of float controls in the intake channel.

System Set-Up

The simplest installation is to withdraw water from the facility's effluent channel and pump the water through the towers, where it then flows by gravity to the existing intake channels or cooling water pump wells.  The upstream portion of the intake can then be blocked off so that the existing recirculation pumps remain functional while intake construction occurs.  Other engineering solutions for cooling water pump and piping configurations are possible.  In some cases, there may be challenges in finding a suitable path for the placement of the temporary cooling water recirculation pipes, but engineering solutions should be available in most circumstances.

Modular towers can be installed while the plant is in operation and can be operated on an as-needed basis.  The installation can be done quickly; once the units are trucked in-place, it takes approximately one day per unit to complete the installation.  This allows modular towers to be used as a temporary source of cooling water during the period when an intake must be shut down, such as allowing for the retrofit of 316(b) compliance technology.

The Varitech units are transported to the site on a truck trailer bed.  In earlier designs prior to this one, the modular units either remained on the truck trailer or were removed using a crane.  One advantage of the newer Varitech units is that they can be trucked onsite, jacked up so that the truck trailer can move out, and then the tower height can be adjusted using built-in legs that are easily leveled.  No crane is necessary, thus reducing mobilization and demobilization costs.  These towers require very little site preparation as long as the site is moderately level.

System Design

The basic modular cooling tower configuration uses PVC pipes running along the ground to and from the towers, skid-mounted pumping units that pump water through the towers, and the tower units themselves.  The vendor typically provides all the necessary equipment, including pumps, piping, control system, electrical cable and transformers.  The vendor can also provide all necessary services, including engineering design, mobilization/installation, contract operation and maintenance, and removal/demobilization.  In short, the vendor can provide all necessary equipment and services with the exception of permitting activities.  In many respects, operation and maintenance activities for modular towers will be similar to those for permanent towers, except that these tasks would be performed by the vendor.  One benefit of modular towers is that it will be easier to perform maintenance on the modular units while maintaining generation at near full capacity, since the temporary loss of the flow from one unit at a time represents only a small component of total cooling water flow.

In the past, large portable towers generally ranged in size from 500 ton to 2,000 ton capacities.  Recently, however, Varitech has begun manufacturing portable 3,000 ton units capable of handling up to 10,000 gpm of cooling water.  A typical design flow for these units is 10 MGD or 6,945 gpm (Blue Stream 2008b).  These units are the largest portable units available and provide the most efficient use of available space.

With the use of multiple side-by-side tower units, a cooling system of any size capacity can be assembled.  For example, Blue Stream recently worked on a system for the 2,600 MW Cumberland Plant in Cumberland City, Tennessee, operated by the TVA (see below).  This plant requires cooling tower flow capacity of 500,000 gpm.  In this case, the towers have been installed in a helper tower configuration to eliminate the need to derate (reduce plant generation) during summer source water low-flow conditions that have been exacerbated by recent drought.

The specifications for the 3,000 ton units are:

      Flow Range:		5,000  -  10,000 gpm
      Design Flow:		6,945 gpm (10 MGD)
      Tower Width:		12 ft
      Tower Length:		50 ft
      Tower Height:		15 ft excluding ground clearance
      Fans:			20 direct drive at 15 Hp each
      Fan Energy Req.:	300 Hp
      Shipping Weight:	56,000 lbs
      Operating Weight:	88,000 lbs
      Source: Varitech 2008.

The towers are constructed of fiberglass-reinforced plastic, stainless steel, and PVC components to prevent corrosion.  The towers contain high efficiency cellular sheet PVC drift eliminators.

System Requirements

The system requirements are available space for placement of the towers and a route for the piping from the warm water discharge channel to the towers and then from the tower cold water outlet to the intake channel.  Each unit is 12 ft wide by 50 ft long and requires a side clearance of 12 ft between units placed side-by side and 24 to 36 ft between rows to allow for proper air circulation (Blue Stream 2008b).  The result is that, for each 10 MGD of design flow volume, an area of approximately 2,000 sq ft including the side clearance is required.  Looking at the tower footprint alone, these 3000 ton units can cool 11.6 gpm/sq ft.  The footprint size of the permanent cooling towers derived using the EPRI cost methodology (as described in Chapter 8 of the TDD) indicates they cool only 3.4 gpm/sq ft.  Thus, the modular towers are more compact and should require less space.  The reason for this is the higher fan energy requirement (see discussion below) and high efficiency design of the units and fill material.

Assuming that the total side clearance for both sides for permanent cooling towers is equal to the tower width, a similarly sized permanent cooling tower would require about 4,000 sq ft.  The difference in space requirements may be somewhat less than the factor of 2 that is implied by the above estimates, since the smaller modular units will have plumes that may be more prone to recirculation, especially if they are placed in arrays of multiple rows and close together using minimum clearance.  A 10,000 gpm skid-mounted pump requires a space of 6 ft by 6 ft (Blue Stream 2008a).

Another system requirement is a power source.  The fan energy requirements for modular towers are about 50% higher than the fan energy requirements estimated using EPRI's methodology for a similar design flow.  The higher fan energy is part of the modular tower design that allows for the towers to be more compact, taking up less space than permanent towers.

A comparison of the total pump and fan energy requirements reported by the vendor to estimates derived from EPRI's methodology indicates that the modular towers may require about 70% more electrical energy than equivalent permanent towers to operate.  That means that pumping energy requirements may also be higher for modular towers.  This may be due to the fact that modular towers use multiple pumps and pipes that are smaller in size than those used in permanent towers.  The use of smaller pipes and pumps tends to result in greater friction losses and less efficient pump operation.

Non-Water Quality Impacts

In general, non-water quality impacts (e.g., noise, drift, water consumption, plume) should be similar for both modular and permanent cooling towers.

Example Installations

The largest example facility provided by the vendor is the 2,600 MW Cumberland Plant in Cumberland City Tennessee (operated by the TVA).  The facility's design intake flow (DIF) is over 2 billion gallons per day (BGD).  This plant operates the towers in a helper mode due to problems with low river flow, which have led to problems in meeting the facility's 316(a) discharge limits.

Another facility is the 370 MW WS Lee Steam Station in Anderson County, South Carolina (operated by Duke Energy).  The facility recently purchased modular towers and is using them in a recirculating mode to reduce intake flow volume.  Existing permanent cooling towers already located onsite are operated in as helper towers; the new modular towers are operated in a recirculating mode during the summer because the river level drops too far.  The modular tower recirculating flow volume is approximately 100,000 gpm, which is close to the facility's actually intake flow (AIF).   So during the summer, the facility routes the helper tower effluent to the modular towers, recirculating the water back to the intake and thus running water through two sets of towers.

System Costs

Table 1 below presents the rental costs and total energy requirements for modular towers (as supplied by the vendor).  These costs require a minimum rental period of four months per year but facilities are only charged for the period the towers remain in use in excess of 4 months each year after that (i.e., beyond the minimum 4 month rental, a facility is only charged for time the towers are in use; if they are idle, there is no additional fee).  The rental costs include the tower units, pumps, piping, controls, and maintenance.  These costs do not include items such as site preparation, freight, installation labor, electrical supply equipment, electricity to operate the pumps and fans, or system removal labor and freight (Blue Stream 2008b).  The vendor noted that since the clients are power companies, they usually provide the electrical supply components using their own resources.
                                  Table 1.

Cost of Modular Towers Compared to Permanent Towers

For comparison, Table 1 also includes the capital and O&M costs and the energy requirements for a permanent cooling tower system, as derived from the EPRI methodology.  A present-value calculation using an interest rate of 5% and the assumption that the towers will operate for four months per year indicates that the break-even time period is about 14 years (see below for a detailed discussion).  This means that if the modular towers are used for 4 months or less each year, they will be more economical than permanent towers if they are needed for a period of less than 14 years.  If the duration of tower operation is extended to 12 months/year, the break-even time period is less than four years.  The break-even calculation takes into consideration the costs presented in Tables 1 though 4 below (including estimated cost of energy requirements), but assumes that the non-power O&M costs for permanent towers (Table 1, Column 7  --  EPRI O&M) are the same for both 4 and 12 months of operation.  The energy costs are a large component of O&M costs.  For permanent towers operated continuously throughout the year, energy requirements can represent up to 90% of total O&M costs.  The results of the break-even analysis demonstrate that modular towers may be more financially advantageous for facilities that require flow reduction for only a portion of the year and for facilities in which the cooling tower technology will not be needed for the full service-life of permanent towers constructed onsite.

Estimation of Costs for Temporary Use During Construction Downtime

The temporary installation of modular cooling towers is an available technology option for minimizing construction downtime costs.  This approach also has the added benefit of maintaining generating capacity at baseload plants which may be important in regions or time periods where extended facility downtime would be detrimental to maintaining reliable generation.  Below is an estimate of the costs for a typical temporary rental tower installation.  For each facility with an estimated net downtime period (due to installing a compliance technology as a result of the proposed rule), the equations below can be used to estimate the cost of this downtime technology option.  These costs can then be compared to the lost generation costs of shutting down the generating units.  EPA could then identify the facilities that could benefit economically from employing this option and adjust the downtime costs accordingly.

Each project will have a minimum cost associated with installation and demobilization costs plus rental costs (minimum four months for Blue Stream).  The decision to utilize modular towers to reduce downtime costs will be somewhat dependent on whether the estimated lost generation costs for the net downtime period exceeds the total cost for tower rental by a large enough margin to make it economically worthwhile.  Lost generation costs will also be dependent on both the downtime duration and facility's capacity utilization rate (CUR) during the downtime period.  Due to the installation and minimum rental period costs, this technology will likely be more attractive to facilities that expect longer downtime requirements and a high CUR during the outage.  The decision to use temporary cooling towers may not be limited to just economic considerations for the facility, as the need to maintain minimum regional generating capacity and the cost of replacement power generation may also factor into the decision.

Table 2 presents the estimated one-time installation and demobilization costs that are not covered by the vendor rental costs.  The total costs apply to all applications regardless of duration.  The shipping, installation, power supply, demobilization, and other costs not covered by the vendor fees are derived using the assumptions below:

 Freight  -  transportation costs per tower (each way) is $6,000 including shipping of towers and ancillary equipment.
 Installation labor  -  installation time of one day per tower is assumed to require six persons for two 8-hr shifts per tower.
 Demobilization labor - same as for installation.
 Labor Rate - $50/hr ($38/hr in 2002 adjusted for inflation to 2009).
 Site Preparation - assumed as $4,000 per unit (estimate based on BPJ).
 Electrical hookup  -  material and labor cost is assumed to be $20,000 per unit (estimate based on BPJ).
 Allowance  -  additional costs equal to 50% of total for above items (freight, labor, site preparation, and electrical) to account for all other costs.
 Power  -  cost estimate for power to operate pumps and fans are based on a CUR of 85% and an average wholesale power cost of $65/Mwh.

                                    Table 2

Table 3 presents the tower rental costs based on the data in Tables 1 and 2 and includes the total costs for a rental duration of up to 16 weeks, the weekly rental costs for periods exceeding 16 weeks, and power costs which are shown separately.  Note that the tower rental costs already include tower O&M for labor and materials, with the exception of the cost of power to operate pumps and fans.

                                    Table 3

The total downtime for all cost modules ranges from <4 weeks to 15 weeks, with the exception of installing cooling towers at nuclear facilities which has a relatively high downtime value of 32 weeks.  In the 2004 Phase II rule, the total downtime values were converted to net downtime by subtracting 4 weeks of routine maintenance downtime. A second possible approach to consider downtime is to use facility-specific data to calculate facility-specific estimated routine maintenance durations ranging from 1 to 8 weeks.  Using this approach, the calculated net downtime periods for any facility could range from 0 to 14 weeks.  Since both of these approaches would yield outages that are less than the minimum four-month (16 weeks) rental period, the minimum cost will apply to most technology modules at non-nuclear facilities.  The only variable cost is the power to operate the pumps and fans.

The costs shown in Table 3 were plotted against the recirculating flow rate and the data were fitted to straight lines.  Table 4 presents cost estimation equations derived from this data.  Equations for O&M costs for pump and fan energy are presented in both megawatts at full capacity and in dollars per week assuming that the energy usage will be 85% of full capacity over the operating period and the average wholesale cost of electricity is $65/Mwh.

                                    Table 4

Additional Cost Information

The rental fee is charged only for the months the towers are used; the equipment can stay onsite the remainder of the year at no extra charge.  Thus, installation/demobilization costs can be amortized over the entire rental contract period.  As a result, modular cooling towers are often rented for periods of several years or more.  Another benefit is that rental towers can be financed through the facility's operating budget, thus avoiding the time-consuming planning and approval requirements for such a major capital expenditure as a cooling tower.

Modular towers may be capable of producing colder water than permanent cooling towers, which in turn could offset a portion of the extra power requirements through a reduction in the turbine efficiency energy penalty.  The vendor stated that the modular towers had an approach of 7 to 10 F, while the EPRI documentation specified an approach of 10 F for permanent towers (Blue Stream 2009).  The approach is the difference between the temperature of the cold water exiting the tower and the wet bulb temperature of the air and thus, towers with lower approach values will produce colder water.  The modular tower cited here is designed to be efficient and compact and accomplishes this, in part, by using a higher fan power and thus may produce colder water.

Cooling towers can be designed with different approach values, generally ranging from 5 to 15 F with 10 F being a typical design value.  In general, a tower with a lower approach will cost more and in the case of permanent towers will be larger in size.  The 316(b) Phase I Rule based cooling tower costs on a vendor-supplied tower sizing factor of $30/gpm for a cooling tower with an approach of 10 F and a sizing factor of $50/gpm for a tower with an approach of 5 F.  (USEPA 2000)  Thus, based on these sizing factors, it is estimated that a reduction of the approach from 10 F to 5 F would result in an increase in capital costs for a permanent tower of approximately 67%.

It is estimated that a 1.0 C reduction in the cooling water temperature can decrease the heat rate of a thermal power plant by 5 Kcal/KWh.  (National Productivity Council of India (NPCI) 2009)  Using this factor, a coal-fired plant with a heat rate of 9,000 BTU/KWh (thermal efficiency = 37.9%) would increase its output by 0.12% for each 1.0 F reduction in cooling water temperature during warmer periods of the years.  Another analysis of a theoretical pressurized water nuclear reactor predicted that an increase in cooling water temperature by 1.0 C would decrease output by 0.45%. (Durmayaz and Sogut 2006)  This is equivalent to a change in output of 0.25% for a 1.0 F change in cooling water temperature, or roughly double the NPCI-based estimate.  Note that an approach of 5 F is generally considered the lower limit for tower design, due to the fact that the tower size will increase exponentially as the approach decreases, resulting in greatly diminishing returns in terms of performance versus costs.

The quality of the water being circulated through the towers (e.g., concentration of suspended of solids) may affect the type of tower fill that can be used, which can in turn affect the efficiency of the tower and the approach value.  The modular towers use a film fill that is more susceptible to plugging and fouling than splash fill.  Film fills come in different designs that can be tailored to the water quality.  If the water contains solids or is susceptible to biofouling that could plug the smaller holes/channels, then a fill with larger holes/channels must be used, which will reduce the efficiency of the tower.

Applicability for 316(b)

Modular cooling tower systems would be most useful for projects requiring a temporary source of cooling water during major repairs or construction at existing once-through intakes and cooling tower systems, such as during the downtime associated with retrofitting a new intake technology or closed-cycle cooling system (although there are limitations on the latter, as discussed below).  The modular towers would be available to those facilities with sufficient space for the towers and where the existing cooling water pumps and pump wells or intake channels can be blocked off (see Figure 1).  Modular towers require somewhat less space than permanent towers and, since the modular cooling towers consist of many individual units, they can also be placed in configurations that allow for efficient use of available space, including space that might not otherwise be useful for conventional multi-cell cooling towers.

Potential Sites for Modular Towers

Modular towers may provide a significant reduction in downtime and the associated costs at some facilities.  In some cases, especially those where the interruption period is fairly long or if the facility is a baseload facility, the downtime costs (due to lost generation) can be much higher than the tower rental costs, resulting in substantial overall savings for the project when modular cooling towers are used.  As described in Chapter 8 of the Technical Development Document (TDD), EPA estimated that 100% of normal generating revenue will be lost during net construction downtime; however, in cases where modular towers are compatible with site conditions, this is likely an overestimate for facilities with long downtime periods, since it does not consider modular towers as an available cost-saving option.  The actual downtime costs would simply be the modular cooling tower rental costs for the period, including mobilization/demobilization costs.

Modular cooling towers are also useful at facilities that are subject to periodic interruptions or reductions in the quantity of water withdrawn for cooling purposes, and can be a cost-effective option for facilities that require supplemental cooling or flow reduction for only a portion of the year.

Limitations on Applicability

This technology is most appropriate for compliance technologies that involve major modifications to the intake structure or relocation of the intake inlet.  There are limitations regarding the use of modular cooling towers at nuclear facilities and in conjunction with the installation of new cooling towers.

At nuclear plants, the service water may be pumped from a combined service water and condenser cooling water intake, or it may be from a separate intake.  Nuclear facilities have more stringent safety requirements for the service water system than for the condenser cooling water system.  The service water system is considered part of the emergency and safety system, which has very rigorous certification requirements regarding the manufacturing, installation, and maintenance of each component.  Obtaining certification for a new technology can be a rather involved process with no guarantee that the technology will become certified.

During intake construction downtime, the intake no longer functions as a cooling water source and thus, when modular towers are used during construction downtime to replace this cooling water, they become the sole source.  For this reason, it is unlikely that modular towers would be considered for situations where they would become at any time during plant operation the sole source of cooling water for the service water system at a nuclear facility.

At nuclear facilities where the condenser cooling water has a separate intake, the installation of modular towers would still be required to meet rigorous seismic and fire control requirements.  Even if these requirements were met, there may be a perception of modular towers as a "temporary technology" that could influence the Nuclear Regulatory Agency's decision to permit such a technology application.

For the reasons discussed above, modular towers are not likely to be used as an alternate cooling water source to keep a nuclear plant operating during construction activities.  It may, however, be possible to use them in situations where they function as an alternate source of cooling water where once-though operation can be maintained as a backup, provided the technology can meet the technical requirements.

For facilities installing new (permanent) cooling towers, modular towers are also unlikely to prove useful.  In order for modular towers to be used as an alternate source of cooling water during the construction downtime, space must be available for the towers and piping for both the permanent and modular towers.  This essentially doubles the space required; most facilities would be unlikely to have this much available space.

Implications for EPA's Engineering Costs

One difficulty of incorporating this potential construction cost-saving option into the compliance technology economic analysis is that there is insufficient information to determine for which facilities and construction projects this technology would be viable.  The primary obstacle that may limit the technology viability is the availability of sufficient space to place the modular cooling towers.  However, this technology should be viable for more facilities than conventional permanent cooling towers because modular towers require somewhat less space and also allow for more flexibility in the placement of individual units, including the availability of alternatives such as placing some or all of the units on barges.  Conventional cooling towers are generally too large to be installed on floating barges.

In general, limitations on the availability of sufficient space for modular towers will be greatest at facilities that are located in higher density urban areas, where there is insufficient available space within the plant property boundaries as well as there being no undeveloped land adjacent to the plant that could be purchased and used for siting cooling towers.

Also, the elevation of the available land is an important consideration.  Optimal locations for cooling towers should be at elevations that are not much higher than those of the generating unit condensers to ensure that pumping costs are economically acceptable.

Summary of Advantages and Disadvantages

The advantages and disadvantages of modular cooling towers (as compared to permanent cooling towers) are summarized below.

Advantages include:

          Can be more economical than permanent towers where requirements for use are temporary or seasonal
          Can be installed quickly
          Can be installed with minimal site preparation
          Can be installed without use of explosives that might be necessary for permanent tower concrete basins
          May be available to more facilities because they require less space than conventional cooling towers
          Can be installed in almost any configuration
          Can be installed on barges
          Can be used to provide temporary supply of cooling when existing intake is being modified
          Rental cost includes equipment maintenance and repair
          Can be paid for using facility operating budget

Disadvantages include:

          Economic benefit over permanent towers diminishes or disappears as period of use per year or number of years in use increase
          Energy requirements (and thus operating costs) are higher than for permanent towers

Analysis

The CUR at which the plant would have otherwise been operating during the downtime is an important factor in determining whether the lost generation cost would be high enough to justify using this technology option during construction downtime.  To analyze how capacity utilization could affect this decision, the lost generation costs and total tower rental costs were calculated and then compared for different CUR values and different net downtime durations in weeks.  The typical generating capacity associated with each recirculating flow rate was calculated using the average cooling water requirement of 707 gpm per MW.  Lost revenue was assumed to be $45/Mwh, based on an assumed wholesale value of $65/Mwh minus an assumed fuel cost of $20/Mwh.  The tower costs and lost generation costs were then calculated for different downtime durations in weeks and CUR values in increments of 10%.  The data were then reviewed to determine the minimum number of weeks for assumed CUR values at which the lost generation cost exceeded the tower rental costs.

Using an assumed value for cooling water requirements of 707 gpm/MW, a facility requiring 400 MGD of recirculating cooling water (last row in Tables 1-3) would generate approximately 400 MW of electricity at full power.  Lost generation costs for the loss of 400 MW of electric power generation are estimated to be approximate $18,000/hr using the assumed value for lost revenue of $45/ MWh.  This is equivalent to a loss of $2.4 million dollars per week if the capacity utilization rate (CUR) is 80%.  Using this example, at $65/MWh, a reduction in the approach of 1.0 F (increase in efficiency of 0.12%) will increase revenue by $3,120/hr or $419,000 per week at 80% CUR.

Table 5 presents the results of the analysis and indicates that the use of temporary cooling towers to reduce downtime costs will not likely be cost-effective for construction projects with net downtime durations of less than 6 weeks for facilities with a high CUR during the downtime period.  Nor would temporary towers be economical for facilities with CUR values of <40% for the range of estimated construction downtime durations for most of the technology cost modules considered by EPA.  Since most facilities would likely schedule the construction downtime to coincide with a period of time where power demand is lower, the CUR during the downtime period will likely be lower than the annual average CUR for the plant.

                                    Table 5

Table 6 presents a comparison of estimated downtime costs for a 400 MW and a 1000 MW power plant, assuming two different capacity utilization rates:  one for a baseload plant (80%) and one for an intermediate load plant (60%).  The net downtimes are based on EPA estimates for cost modules 4, 7, 12, and 14, and are associated with relocation of intakes to a submerged offshore location.  These net downtimes are the net values after subtracting out a four-week concurrent scheduled maintenance downtime event.  Table 6 shows that downtime cost for longer durations can be reduced substantially by use of modular towers, especially at baseload facilities.  The last column is the break-even point for these examples, similar to that shown in Table 5.

                                    Table 6
                  Comparison of Estimated Downtime Costs for
                  Use of Modular Tower Versus Plant Shut Down

As an example of the potential benefits of a lower tower design approach value, if the example 400 MW facility in row one of Table 5 is used along with the 0.12% (output increase /1.0 F) factor described above, the effect of reducing the cold water temperature by 1.0 F would be to increase plant revenue by up to $3,800,000 for the nine-week period if this were to occur during a period of continuously elevated air temperatures.  Note that the benefit of increased generating efficiency is only available during periods when the wet bulb temperature is high enough to result in a turbine back-pressure that is well above the design back-pressure of the turbine.

Conclusions

In summary, modular towers are a technology that offers a potentially significant reduction in facility downtime related to compliance with the proposed rule.  Facilities that are able to install the modular towers may actually face no downtime at all, which would eliminate a significant component of the costs of the proposed rule and replace it with the smaller, temporary cost of modular tower rentals.  (See the Environmental and Economics Benefit Analysis for a discussion of the role of downtime costs in EPA's estimation of national economic impacts.)  However, EPA is not able to estimate how many facilities would be able to employ these modular towers, nor has it attempted to estimate the overall cost savings of using them.  As a result, EPA has not adjusted its national cost estimates to include the use of modular cooling towers.
References

Blue Stream Inc., Richard Brister.  Telephone contact record by John Sunda, SAIC.  Regarding technical requirements and costs of modular cooling towers.  May 30, 2008a.

Blue Stream Inc. Email from Richard Brister to John Sunda, SAIC.  Re:  Request for Modular Cooling Tower Cost Information In Support of EPA 316(b) Rule.  May 30, 2008b.

Blue Stream Inc.  "Estimated Cooling Cost Chart" (attachment to May 30, 2008 email from Richard Brister to John Sunda, SAIC).

Blue Stream Inc., Richard Brister.  Telephone contact record by John Sunda, SAIC.  Regarding technical requirements and costs of modular cooling towers.  June 10, 2008c.

Blue Stream Inc., Richard Brister.  Telephone contact record by John Sunda, SAIC.  Regarding modular tower energy requirements and approach.  March 25, 2009.

Durmayaz, Ahmet and Sogut, Oguz.  Influence of Cooling Water Temperature on the Efficiency of Pressurized-Water Reactor Nuclear-Power Plant.  International Journal of Energy Research.  Vol. 30 No. 10. pp 799-810.  2006.

National Productivity Council of India (NPCI).  Guide Book 3  -  Energy Efficiency in Electric Utilities.  Chapter 7  -  Cooling Towers.  No Date.  Accessed on March 25, 2009 at website:  http://www.em-ea.org/Guide%20Books/book-3/Chapter%203.7%20Cooling%20Tower.pdf.

EPA.  316(b) Phase I  -  Proposed Rule.  Economic and Engineering Analyses of the Proposed Rule.  Appendix A.  August 2000.

EPRI.  Tower Calculation Worksheet.  September 17, 2007.

Varitech Equipment Company.  Fact Sheet:  VTECT-ID3000 Portable Cooling Tower (equipment specifications).  Accessed on May 30, 2008 at website:  http://www.rentalcoolingtowers.com/product-specifications.htm

Figure 1. Intake Canal with Sheet Pile Wall, Forming a Closed Loop System

Figure 2. Example of Flexible Configuration