Case Studies
J.S. Held Acquires Element Forensic Engineering, Expanding Insurance-Focused Capabilities for Mid-Market and Large Loss Property Claims Across Canada
Read MoreThe US EPA under Section 316(b) of the Clean Water Act requires compliance from certain existing power generation and manufacturing facilities withdrawing cooling water from waters of the United States (WOUS) to reduce impingement/impingement mortality and entrainment of fish and other aquatic organisms at cooling water intake structures. The Rule applies if four requirements are met:
J.S. Held was asked to support a power generation client with meeting 316(b) compliance at a facility on the lower Mississippi River in Louisiana, to demonstrate effective and meaningful compliance without costly and time-consuming capital expenditures.
Their approach was to determine what equipment the facility currently had in place as well as how it was used, then to develop a strategy for enumerating how many fish were “not” entering the facility from impingement and entrainment. Our experts used a “systems of technologies” best technology available (BTA) compliance option allowed by the US EPA and implemented a novel “fisheries-based” approach instead of a costly engineered solution. This method included developing a rate of impingement into the system because what does not get into the system cannot become mortality from the system, thereby reducing impingement mortality and entrainment. As a result, the facility would be able to demonstrate compliance by determining fish reductions into the facility and calculating those credits for minimizing adverse environmental impact.
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