                                  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
DATE: 		April 22, 2010

SUBJECT:		Comparison of Cooling Tower Retrofit Costs to the Cost of New and Repowered Power Plants

EPA requested that Tt and SAIC compare the cost of retrofitting a facility with closed-cycle cooling to the cost of constructing a new power plant and to the cost to repower a plant.  This memo describes the results of the research.

Capital Costs for a New Plant

Table 1 presents a comparison of the capital costs of retrofitting a recirculating cooling tower at an existing power plant to the costs of building a new greenfield power plant with the same generating capacity.  A plant capacity of 1,000 MW was chosen as the size for both the existing and new plant.

Cooling tower retrofit costs are based on cost factors derived for EPA 316(b) compliance costs, which are based on the factors used in the EPRI Tower Calculation Worksheet.  Costs for "average" difficulty and "difficult" retrofits are presented, since the actual costs will vary depending on existing plant site conditions.  These cost factors use condenser flow rates as the basis, which have been estimated assuming a condenser delta T of 15[o]F and typical heat rates of 9,300 BTU/Kwh (plant efficiency = 37%) for an existing coal plant and 10,200 BTU/Kwh (plant efficiency = 33%) for an existing nuclear plant.

The new plant construction capital costs are based on cost assumptions used by EIA in developing economic data in their Annual Energy Outlook 2009.  These are overnight costs and do not include escalation or financing costs.  Other sources suggest that the estimates for construction costs of new nuclear power plants have increased in recent years and are very uncertain, with costs possibly being greater than those used by EIA.  A 2008 report stated that companies that were planning new nuclear units indicated that the total costs (including escalation and financing costs) would be in the range of $5,500/kW to $8,100/kW (Synapse 2008a).  To capture these higher costs, the "advanced nuclear  -  high" costs were added to Table 1 to reflect these higher estimates using the upper end of the range of costs that Florida Power & Light (FPL) projected in October 2007 for two new plants (Synapse 2008).  Interest and escalation may add between 35% and 75% to the costs.

Other sources indicate that the estimated costs of new coal plants have been increasing recently as well.  A 2008 report states that the estimated costs of building new coal plants has reached $3,500 per kW, not including financing costs (Synapse 2008b).  These cost increases are mostly due to a significant increase in the worldwide demand for power plant design and construction resources, commodities, and equipment.  This report was written in mid 2008, a time when commodity prices had increased rapidly and reached a peak and have subsequently dropped to lower levels due to the recent worldwide economic downturn.  However, high construction costs remain as a concern Table 2 provides some recent examples of capital cost estimates for both nuclear and coal-fired plants.  Two of the coal plants were cancelled in late 2008 and 2009 due to concerns about increased costs and greenhouse gas emissions.  Table 2 also shows that the estimated cost of the cooling tower and basin component are a small portion (<=2%) of total costs.  This is based on the assumption that cooling tower and basin costs are roughly $80/gpm (SAIC 2010).

In summary (as shown in Table 1), costs for construction of a conventional fossil fuel plant can be nearly 14 times higher than the cost to retrofit a closed-cycle cooling system at a comparable facility.  Costs for a new combined cycle plant can be nearly 7 times higher, while the costs for a new nuclear facility can be as much as 20 times higher.

Capital Costs for a Repowered Plant

While the costs in Table 1 reflect greenfield costs for a new plant, they can be viewed as indicative of the magnitude of costs for a full repowering at coal and combined cycle power plants as well.  The generating capacities of new repowered plants will in most cases be greater than those of the existing plants.  In the case of repowering of an existing steam plant to combined cycle, the repowered capacity could be as much as 200% greater than the existing plant, while producing the same amount of waste heat and requiring the same amount of cooling water as before.

On a non-incremental dollar/MW basis, fossil-fuel repowering projects can typically be implemented for about 70-80% of the cost of a greenfield plant in dollars/MW, because they are able to utilize existing infrastructure and steam turbines (ALSTOM Power Inc. 2003).

Other Cost Considerations

There are many other cost considerations, in addition to differences in capital costs, that factor into the decision to construct new generating units either onsite or at a new location.  The decision to construct new generating units requires a detailed economic evaluation of all of these factors.  These cost factors include:
   * Plant efficiency and energy penalty - New power generating units can be designed to operate more efficiently than existing units that are retrofitted. Thus, new generating units will use less fuel and cost less to operate.  This increased efficiency results from the use of state-of-the-art power generation and cooling technology that is more efficient and designed for optimized performance. While the use of a recirculating cooling tower with the new unit may still experience some amount of both parasitic energy requirements and turbine efficiency reductions compared to a once-through system, there is a greater opportunity to design the system to optimize system performance plus in most cases the increased generating unit efficiency will be much greater than the energy penalty.
   * Changes in plant dispatch schedule and capacity utilization - A more cost efficient plant will tend to be dispatched more frequently resulting in a higher utilization rate affecting long term revenue estimates.
   * Fuel type  -  Changes in fuel type can also affect operating costs, dispatch rate, pollution emissions, and potential costs associated with carbon emissions.
   * Permitting  -  Existing generating units may require only minor modification to existing permits. New units may undergo an extensive, lengthy, and potentially restrictive permitting process.
   * Downtime costs  -  Offsite new generating units will have no downtime costs.  Onsite new generating units will result in minimal downtime, if any, depending on the need to tie into existing infrastructure such as water intakes or power distribution.
   * Timeframe  -  Cooling tower retrofits can be accomplished within a period of several years. New generating units require a long lead time of several years to plan plus up to seven years to obtain required permits.
   * Service life  -  New generating units will tend to have a much longer service life than retrofitted existing generating units. O&M costs of generating units tend to increase over time.
   * New generating unit tower costs  -  New units with recirculating cooling towers will completely avoid retrofit costs and may have lower capital costs than new units with once-through cooling systems. See SAIC memo: "Estimation of Net Difference in Capital and O&M Costs for Once-through Versus Closed Cycle Cooling for New Generating Units at Existing Power Plants and for Repowering of Existing Generating Units" March 5, 2010.
   * Flue gas disposal - New and repowered units requiring air pollution equipment upgrades where natural draft cooling towers (NDCT) are an available option can save costs of a new stack by disposing of flue gas through the NDCT.  See SAIC memo: "Technology Analysis for the Discharge of Power Plant Combustion Flue Gas Through Natural Draft Cooling Towers." March 12, 2010.
   * Future environmental requirements and regulations  -  Uncertainty about future regulation and associated costs regarding emission of carbon dioxide is clouding the current decision making process. Once these regulations are enacted, the associated costs and credits will factor in as well.

References

ALSTOM Power Inc. Schretter, J. Williams, S. Brandett, J.  Repowering: A Financially Compelling Method to Improve Existing Assets. Winter 2003.
http://beaconenergy.com/html/JSPF%20Repower%20Winter03%20article.pdf

EIA. Assumptions to the Annual Energy Outlook 2009. Table 8-2 Costs and Performance Characteristics of New Central station Electricity Generation technologies. 2009.

Synapse Energy Economics Inc. David Schlissel and Bruce Biewald. Nuclear Power Plant - Construction Costs. July 2008a.

Synapse Energy Economics Inc. David Schlissel, Allison Smith and Rachel Wilson. Coal-Fired Power Plant - Construction Costs. July 2008b.

AMP. News Release "AMP ANNOUNCES LIKELY CONVERSION OF AMPGS PROJECT" November 25, 2009. http://media.cleveland.com/business_impact/other/Project%20conversion%20release.pdf

Journal Sentinel. Milwaukee Wisconsin. PSC rejects Alliant Energy's proposed coal plant. Nov. 11, 2008
http://www.jsonline.com/business/34277094.html

Miami Herald "FPL suspends long-term projects, hints at job cuts" January 15, 2010.
http://www.miamiherald.com/2010/01/14/1426344/fpl-suspends-long-term-projects.html

Charlotte Business Journal. "Cost of Duke Energy's Cliffside project holding steady" March 19, 2010.

iStockAnalyst. "Federal loan guarantees encourages Levy County, Fla., plant construction" February 18, 2010.
http://www.istockanalyst.com/article/viewiStockNews/articleid/3880743

SAIC memo: "Estimation of Net Difference in Capital and O&M Costs for Once-through Versus Closed Cycle Cooling for New Generating Units at Existing Power Plants and for Repowering of Existing Generating Units" March 5, 2010.

 Table 1. Comparison of the Capital Costs for Closed-Cycle Cooling Tower Retrofit at an Existing Plant to the Capital Cost of a New Greenfield Power Plant of a Similar Size

                                      Old
                                      New
                                      Old
                                      New
Plant Type
Conventional Coal
Scrubbed New Coal[3]
Conventional Combined Cycle[3]
Conventional Nuclear
Advanced Nuclear (Low)[3]
Advanced Nuclear (High)[4]
Plant Capacity (MW)
1000
1000
1000
1000
1000
1000
Unit Cooling Flow1 (gpm/MW)
600

910

Existing Condenser Flow (gpm)
600,000

910,000

"Average" Difficulty Cooling Tower Retrofit Costs2 (million $)
$150

$228

"Difficult" Cooling Tower Retrofit Costs2 (million $)
$234

$355

Overnight Total Cost Factor ($2007/kw)

2,058
962

3,318
4,540
New Plant Overnight Capital Costs (million $)

$2,058
$962

$3,318
$4,540
All costs are in 2007 dollars.
1 Based on a delta T of 15°F and a heat rate of 9300 BTU/Kwh for coal and 10,200 BTU/Kwh for nuclear.
2 Based on EPRI Cooling Tower Retrofit Estimates.
3 Based on data in Table 8-2 of EIA Assumptions to Annual Energy Outlook 2009.
4 Based on FPL estimate in 2008 Synapse Report.

Table 2. Recent Capital Cost Estimates
                               Company and Plant
                                 Type of Unit

                                   Capacity
                             Total Plant Costs[1]
                 Wet Cooling Tower Costs as % of Project Total
               Florida Power and Light Turkey Point, Florida[1]
                                    Nuclear

                               2200 MW (2 units)
                               $12.1 billion to
                                $17.8 billion.
                                    <1%
                    Progress Energy Levy County, Florida[2]
                                    Nuclear
                               2200 MW (2 units)
     $10.5 billion with financing costs the total becomes $13-14 billion.
                                    <1%
                   Duke Energy Cliffside, North Carolina[3]
                             Coal - supercritical
                                    800 MW
                                 $1.8 billion
                                      2%
                        AMP-Ohio Meigs County, Ohio[4]
                            Coal  -  supercritical
                                    960 MW
                           $3 billion plus financing
                                    <2%
                       WPL Nelson Dewey 3, Wisconsin[5]
                   Coal and Biomass - Circulating Fluid Bed
                                    300 MW
                          $1.3 billion plus financing
                                    <1%
Costs are based on 2007/2008 estimates.
[1] FPL has suspended all long term capital projects for the next 5 years due to rejection of $1.3 billion rate increase in January 2010 but continue to seek nuclear licenses.
[2]   Plant construction originally scheduled to begin construction in 2010, will be delayed 20 to 36 months due to economic and regulatory problems including rejection of $500 million rate hike.
[3]  Plant was 55% complete at end of 2009 with projected costs remaining at $1.8 Billion
[4]  Plant was cancelled in 2009 when cost estimate increased 37% to $4 Billion. There are tentative plans for a smaller gas-fired combined cycle plant instead.
[5]  Unit 3 was rejected by state regulators in November 2008 citing concerns about increased total cost of $1.3 billion and greenhouse gas emissions.
Sources: Synapse 2008a; Synapse 2008b; AMP 2009; Journal Sentinel 2008; Miami Herald 2010; Charlotte Business Journal 2010; iStockAnalyst 2010.


[Federal Register Volume 86, Number 75 (Wednesday, April 21, 2021)]
[Notices]
[Pages 20787-20789]
[FR Doc No: 2021-08228]

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

DEPARTMENT OF TRANSPORTATION

Federal Railroad Administration

[Docket No. FRA-2021-0037]

Surface Transportation Project Delivery Program; California High-
Speed Rail Authority Audit Report

AGENCY: Federal Railroad Administration (FRA), U.S. Department of
Transportation (DOT).

ACTION: Notice; request for comment.

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

SUMMARY: The Surface Transportation Project Delivery Program (STPD
Program), often referred to as the ``NEPA Assignment Program,'' allows
a State to assume FRA's responsibilities for Federal environmental
review, consultation, and compliance under the National Environmental
Policy Act (NEPA), and other Federal environmental laws, for railroad
projects. When a State assumes these responsibilities, it carries out
the assigned environmental review process, in lieu of FRA. The STPD
Program requires annual audits for the first four years of the State's
lead role in the program to ensure compliance with program
requirements. This notice requests comments on FRA's first audit report
of the California High-Speed Rail Authority (CHSRA) under the STPD
Program.

DATES: Comments must be received on or before May 21, 2021.

ADDRESSES: Comments related to Docket No. FRA-2021-0037 may be
submitted by going to http://www.regulations.gov and following the
online instructions for submitting comments.
    Instructions: All submissions must include the agency name and
docket number (docket #). All comments received will be posted without
change to https://www.regulations.gov; this includes any personal
information. Please see the Privacy Act heading in the SUPPLEMENTARY
INFORMATION section of this document for Privacy Act information
related to any submitted comments or materials.
    Docket: For access to the docket to read background documents or
comments received, go to https://www.regulations.gov and follow the
online instructions for accessing the docket.

FOR FURTHER INFORMATION CONTACT: Andr[eacute]a Martin, Senior
Environmental Protection Specialist, Office of Railroad Policy and
Development (RPD), telephone:<PHONE_NUMBER>, email:
<EMAIL_ADDRESS>or Marlys Osterhues, Chief Environment and
Project Engineering, RPD, telephone:<PHONE_NUMBER>, email:
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:
    Privacy Act Statement: FRA will post comments it receives without
edit, to www.regulations.gov, as described in the system of records
notice, DOT/ALL-14 FDMS, accessible through www.dot.gov/privacy. In
order to facilitate comment tracking and response, we encourage
commenters to provide their name, or the name of their organization;
however, inclusion of names is completely optional. Whether commenters
identify themselves or not, all timely comments will be fully
considered. If you wish to provide comments containing proprietary or
confidential information, please contact the agency for alternate
submission instructions.

Draft Surface Transportation Project Delivery Program Audit of the
California High-Speed Rail Authority: December 8-10, 2020

Executive Summary

    This report summarizes the results of FRA's first audit of CHSRA's
conduct of its environmental review responsibilities under 23 U.S.C.
327, in accordance with the July 23, 2019, memorandum of understanding
(section 327 MOU) between CHSRA and FRA.
    To carry out its audit responsibilities under the section 327 MOU,
FRA formed a team (Audit Team) in April 2020. The Audit Team consisted
of NEPA subject matter experts (SMEs) from FRA's environmental and
project management divisions and the John A. Volpe National
Transportation Systems Center. In addition, FRA designated a Senior
Environmental Protection Specialist to serve as a NEPA Assignment
Program liaison to CHSRA. The Audit Team reviewed certain NEPA project
documentation completed by CHSRA during the first year of the NEPA
Assignment Program, and CHSRA's self-assessment of its NEPA Assignment
Program. In addition, the Audit Team reviewed documents related to
quality assurance and quality control (QA/QC) and conducted interviews
with relevant CHSRA staff between December 8 and 10, 2020.
    Overall, the Audit Team found that CHSRA is carrying out the
responsibilities it has assumed and complies with the provisions of the
section 327 MOU.

Background

    The STPD Program allows a State to assume FRA's environmental
responsibilities for review, consultation, and compliance for railroad
projects.

When a State assumes these Federal responsibilities, the State becomes
solely liable for carrying out the responsibilities it has assumed, in
lieu of FRA. CHSRA published its application under the STPD Program on
November 9, 2017, and made it available for public comment for 30 days.
After considering public comments, CHSRA submitted its application to
FRA on January 31, 2018. The application served as the basis for
developing the section 327 MOU identifying the responsibilities and
obligations that CHSRA would assume.
    FRA published a notice of the draft MOU in the Federal Register on
May 2, 2018, with a 30-day comment period to solicit the views of the
public and Federal agencies. After the close of the comment period, FRA
considered comments received and proceeded to execute the MOU with
CHSRA. On July 23, 2019, CHSRA assumed FRA's responsibilities under
NEPA, and the responsibilities for NEPA-related Federal environmental
laws described in the section 327 MOU.
    Section 327(g) requires the Secretary of Transportation (Secretary)
to conduct annual audits during each of the first four years of State
participation. After the fourth year, the Secretary must monitor the
State's compliance with section 327 MOU, but no longer conducts audits.
The results of each audit must be made available for public comment.
    FRA's annual audits are the primary mechanism to (1) oversee the
State's compliance with this MOU and applicable Federal laws and
policies; (2) determine the State's attainment of the performance
measures identified in part 10 of the section 327 MOU; and (3) collect
information needed for the Secretary's annual report to Congress
pursuant to 23 U.S.C. 327(i). FRA will conduct three more annual audits
consistent with 23 U.S.C. 327(g) and part 11 of the section 327 MOU.
FRA must present the results of each audit in a report and make the
report available for public comment in the Federal Register, before
finalizing.

Scope and Methodology

    Consistent with the section 327 MOU, the Audit Team examined a
sample of CHSRA's NEPA project files; CHSRA's self-assessment report;
and CHSRA policies, guidance, and manuals relating to NEPA
responsibilities. The scope of the project file portion of the audit
included a review of six reexaminations for previously approved Final
Environmental Impact Statements (EIS) and one Final EIS/Record of
Decision (ROD), representing all projects in process or initiated after
the section 327 MOU's effective date through June 30, 2020. In
conducting the audit, and to determine compliance with the section 327
MOU, the FRA Audit Team focused on objectives related to six NEPA
Assignment Program Elements: Program management, documentation and
records management, QA/QC, training, performance measurement, and legal
sufficiency. Each NEPA Assignment Program Element is described further
below.
    The Audit Team interviewed 11 CHSRA staff, in one of CHSRA's three
regional offices, and at its headquarters office. In addition, the
Audit Team interviewed one staff member from the U.S. Environmental
Protection Agency. The Audit Team invited CHSRA staff, middle
management, counsel, and executive management to participate in the
interview process to ensure representation of a diverse range of staff
expertise, experience, and program responsibility.
    To evaluate CHSRA's performance against its documented procedures,
the Audit Team compared the procedures outlined in CHSRA's
environmental manuals and policies to the information obtained during
staff interviews and project file reviews. The Audit Team documented
observations under the six NEPA Assignment Program Elements.

Audit Results

    Overall, CHSRA has carried out the environmental responsibilities
assumed through the section 327 MOU and the Audit Team found that CHSRA
is complying with the section 327 MOU.

Program Management

    Consistent with part 4 of the section 327 MOU, CHSRA has developed
and implemented the updated Environmental Policies and Procedures
Handbook, Environmental Compliance Program Manual, a QA/QC Plan, and
the NEPA Assignment Training Course. CHSRA has also conducted the
required self-assessment.
    CHSRA has incorporated the NEPA Assignment Program into its overall
project development process included in CHSRA's environmental manuals
and policies. CHSRA has also created a NEPA assignment team in the
CHSRA headquarters office to support the new responsibilities under the
NEPA Assignment Program. To ensure NEPA Assignment responsibilities are
fulfilled, CHSRA staff at the headquarters office review projects for
compliance with assigned environmental laws and regulations
independently from staff responsible for developing the NEPA and
related documentation, as required in part 3 of the section 327 MOU.
    CHSRA environmental staff at the three regional offices coordinate
their NEPA related project-work with headquarters staff through NEPA
Coordinators. Prior to assuming responsibilities under the NEPA
Assignment Program, CHSRA regional staff reported to their regional
office. However, following its assumption of FRA's NEPA
responsibilities, CHSRA hired a NEPA Assignment Manager in the
headquarters office who is responsible for overseeing CHSRA's policies,
manuals, guidance, and training under the NEPA Assignment Program.
CHSRA also has assigned a team of attorneys to advise on the
environmental review process. The legal team includes both CHSRA in-
house counsel and outside counsel, who advise on issues relate to the
assigned responsibilities.
    Since the NEPA Assignment Program became effective, CHSRA staff
noted that their relationship with resource agencies has not changed,
and the overall environmental and consultation process has continued
without significant change. FRA's Audit Team's review of project files
supports this conclusion.

Documentation and Records Management

    Between July 23, 2019, and June 30, 2020, CHSRA made 22 NEPA
auditable actions. Employing judgmental sampling, the Audit Team
reviewed seven NEPA project files; six were reexaminations of
previously approved Final EISs and one was a combined Final EIS/ROD.
These projects represented a sampling of CHSRA environmental review
efforts in process, or initiated after, the section 327 MOU's effective
date through June 30, 2020, covering a range of resource considerations
and agency coordination requirements. The Audit Team found that CHSRA
maintained a complete final electronic record, including all NEPA-
related documentation.
    The Audit Team recognized several CHSRA efforts to ensure
consistency of project documentation through CHSRA's use of an
accessible file database. Interviews with CHSRA staff indicated that
the regional staff consistently manage project files, including working
files. In addition, CHSRA uses a software program to document public
and resource agency comments, allowing CHSRA to track comments,
responses, and resolution.

Quality Assurance/Quality Control

    Under part 10.2.B of the section 327 MOU, CHSRA has agreed to carry
out regular QA/QC activities to ensure the assumed responsibilities are
conducted in accordance with applicable law and the section 327 MOU.
The Audit Team noted that CHSRA has implemented a QA/QC program where
environmental staff in the three regions coordinate with the NEPA
assignment team within the headquarters office. The NEPA assignment
team is responsible for reviewing all NEPA documentation and technical
reports to ensure compliance. CHSRA staff also have access to SMEs for
various environmental resources and regulations. During interviews,
CHSRA staff noted that the NEPA assignment team acts independently to
provide unbiased and objective reviews of work products. The Audit Team
also found that regional staff understands how to implement the QA/QC
process throughout the environmental review process.
    During subsequent audits, the FRA Audit Team will require that
CHSRA provide FRA with supporting QA/QC documentation associated with
project files. This will allow the Audit Team to confirm QA/QC measures
are being fully implemented for the projects under review. The Audit
Team also recommends that CHSRA review a judgmental or random sampling
of projects between FRA's annual audits to check compliance and
identify potential improvements that can be made to the QA/QC process.

Training Program

    CHSRA committed to implementing training necessary to meet its
environmental obligations under the section 327 MOU. CHSRA developed
its NEPA Assignment Training Plan to fulfill the requirements of part
12 of the section 327 MOU. The training covers all topics related to
CHSRA's responsibilities under NEPA assignment. Based on interviews and
a review of training documentation and records, all CHSRA staff
received the training in accordance with the training plan after the
MOU was executed.
    The FRA Audit Team recommends that CHSRA expand its training plan
to include additional training opportunities. This training could
include formal or informal training with State and Federal resource
agencies, in addition to the regularly scheduled agency coordination
meetings.

Performance Measures

    In accordance with part 10.1.1 of the section 327 MOU, FRA and
CHSRA have established performance measures that CHSRA will seek to
attain and that FRA will consider during FRA's audits.
    CHSRA is still in the early stages of developing metrics to track
attainment of performance measures outlined in the section 327 MOU.
However, based on the results of the audit review and interviews, the
FRA Audit Team found that CHSRA is implementing the performances
measures. CHSRA environmental leadership staff indicated they will
continue to implement the performance measures in part 10 of the
section 327 MOU.

Legal Sufficiency

    CHSRA conducts a legal sufficiency review at various stages of the
environmental review process, consistent with existing internal
procedures. This review is generally conducted by outside counsel and
CHSRA attorneys. CHSRA attorneys are responsible for making the final
written determination regarding legal sufficiency of EISs prior to
their publication.

Next Steps

    FRA provided this draft audit report to CHSRA for a 21-day review
and comment period. The FRA Audit Team considered CHSRA comments in
developing this draft audit report. This draft audit report is
available for public review for a 30-day comment period in accordance
with 23 U.S.C. 327(g). No later than 60 days after the close of the
comment period, FRA will respond to all comments submitted to finalize
this draft audit report pursuant to 23 U.S.C. 327(g)(B). FRA will
publish the final audit report in the Federal Register.

    Issued in Washington, DC, on April 16, 2021.
Jamie P. Rennert,
Director, Office of Infrastructure Investment.
[FR Doc. 2021-08228 Filed 4-20-21; 8:45 am]
BILLING CODE 4910-06-P


P-19-0161 Sanitized Support Documents Index:
 P-19-0161 Sanitized Determination Document (linked)
 P-19-0161 Sanitized CHEM Report (attached)
 P-19-0161 Sanitized ECO Report (attached)
 P-19-0161 Sanitized ENG Report (attached)
 P-19-0161 Sanitized EXP Report (attached)
 P-19-0161 Sanitized Fate Report (attached)
 P-19-0161 Sanitized HLTH Report_POST-FOCUS FINAL (attached)