A Peer Reviewer's Observations on Entrainment Characterization Study Plans

This talk will present observations from peer reviews of over a dozen site-specific Entrainment Characterization study plans (as of February 2016). Electricity generators using once-through cooling are actively responding to the current Environmental Protection Agency Rule for implementing Section 316(b) of the Clean Water Act. The Rule at 40 CFR 122.21(r)9 requires characterization of the entrainment of organisms by the intake, consisting largely of species, life stages and numbers of fish eggs and larvae. Accurate and representative entrainment characterization is fundamental to other sections of the Rule dealing with “Best Technology Available” entrainment-reduction options and analysis of benefits. Informal peer review of the (r)9 plan and reports is generally recommended but not required by the Rule. Issues include sampling location (in river, in intake, in plant piping, discharge), sampling gear, timing of samples to identify seasonal and daily changes, taxonomic identifications, year-to-year variations, acceptability of previous entrainment studies, what it means to be “representative” and quality assurance and control (QA/QC). Recommendations may vary according to specific circumstances. Companies and facilities will remain anonymous, but these general observations may be useful for others developing study plans and reports.