316(b) Compliance Planning and Implementation Webinar

Watch a video of this informative discussion

Additional resources:

    • PowerPoint presentation from the webinar  Download


About the Webinar

316b webinar

The webinar discusses the key considerations for evaluating and developing a compliance plan for Section 316(b) of the Clean Water Act. The presenters provide an overview of the rule, the requirements and timeline for each of the studies, and strategies for developing a successful compliance plan.

The webinar is hosted by Sargent & Lundy’s Environmental Services group and presented by Ken Snell and Joy Rooney. Other key contributors to the development of the webinar are Russ Light and Dr. Mehrdad Salehi.

Ken Snell is an environmental specialist with more than 30 years experience in environmental permitting, regulatory compliance, remediation, and pollution control. He is a registered professional engineer in the State of Illinois and licensed attorney, with degrees in Environmental Studies, Chemical Engineering, and Law. Ken is familiar with all substantive environmental regulations affecting the power generating and distribution industry, including the National Environmental Policy Act (NEPA), Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), and Endangered Species Act (ESA).

Since joining Sargent & Lundy, Ken’s work has focused on environmental issues affecting the power generating industry, including air pollutant emissions, wastewater treatment and discharge, cooling water intake rules, and solid waste management and disposal.  He has prepared numerous complex environmental permit applications, including New Source Review (NSR) construction air permit applications, National Pollutant Discharge Elimination System (NPDES) wastewater discharge applications, and U.S. Army Corps of Engineer permit applications required by Section 10 of the Rivers and Harbors Act of 1899 and Sections 401 and 404 of the CWA.  He has authored a number of articles focusing on environmental regulations affecting the power generating industry and has provided expert testimony before state and federal environmental and utility regulatory agencies.

A senior associate within the Environmental Services Group in Sargent & Lundy’s Fossil Power Technologies Division, Joy Rooney has over eight years of experience as a process engineer registered in Illinois. She has performed numerous studies to determine the impacts of regulations and legislation with respect to air and water quality control systems for new and existing power plants. Her responsibilities include following technological developments of water quality, SO2, NOx, mercury, particulate matter, and CO2 control technologies. Joy has performed specialized studies, including 316(b) cooling water intake compliance strategies for existing coal-fired power plants. Joy holds a B.S. in Chemical Engineering.

Russ Light is responsible for ensuring that Sargent & Lundy power generation and electric transmission projects are in compliance with applicable environmental requirements. He identifies the applicable requirements, whether state, local, federal, or international, and obtains the required environmental permits and licenses. He evaluates the potential environmental impacts of proposed power projects and prepares environmental impact assessments and mitigation plans. Russ prepares environmental management and compliance plans and assists in their implementation. He collects site-specific environmental information from published sources, government agencies, aerial photography, field reconnaissance, and field sampling. He prepares specifications and obtains services for specialized or complex field sampling, such as noise, emissions, or air quality sampling. As part of due diligence projects, Russ conducts environmental compliance audits for power plants in the United States and overseas. He also conducts or coordinates environmental site assessments for facilities and sites.

In addition to his academic credentials, Dr. Mehrdad Salehi has more than 10 years of industry experience in hydraulics, hydrology, and coastal engineering consulting and design, from planning to EPC stage. He has extensive practical experience in computer modeling and engineering studies related to hydrologic and hydraulic system design, flood hazard evaluation, and independent analysis and review. Mehrdad currently supports variety of power projects, including nuclear, fossil, and renewable, mainly focused on cooling water intake and discharge systems, power plant sitting, coastal engineering, specialized numerical / computational modeling, wave analysis, and thermal discharge modeling. He has published in several peer-reviewed journals and has presented aspects of his studies in national / international conferences. Mehrdad holds a B.S. in Civil Engineering, an M.S. in Hydraulic Structures / Fluid Mechanics, and a Ph.D. in Coastal / Hydraulic Engineering.

Environmental Services

Sargent & Lundy’s environmental services group supports the preparation of all required permit application material. In some cases, for example, the entrainment characterization study and benefits valuation study, the expertise of a biological consultant is required. Sargent & Lundy’s full-service support for 316(b) can start with the permit application phase and extend throughout project implementation.

Example Project: Riverside Combined-cycle Cooling Water Intake Modifications

  • Client Xcel Energy Services
  • Project Riverside Repowering
  • Location Minneapolis, MN
  • Size 466 MW
  • Fuel Coal-to-Gas Conversion
  • Configuration 2x2x1
  • CT Supplier/Type GE 7FA
  • Start 2006
  • Commercial Operation 2009


In 2003, Xcel Energy initiated implementation of the Metropolitan Emissions Reduction Project (MERP), with the twofold goal of significantly reducing flue gas emissions, while increasing the amount of electricity produced at three Twin Cities coal-fired power plants. MERP was a voluntary program pursued by Xcel Energy to convert two of the coal plants to natural gas combined-cycle arrangements (the Riverside and High Bridge plants) and to install emission control equipment on the third coal plant (the Allen S. King Plant).

Repowering of the Riverside plant required the project to reduce impingement by limiting the maximum through-screen design intake velocity to 0.5 ft/s or less, which could not be met by the existing traveling screens.

A study was performed to evaluate the technical acceptability and economics of the available technologies for intake screening. The number of available intake screening options was limited by the short timeframe allowed for actual construction of the intake. Installation of the new intake could not affect the operation of the plant until Unit 7 went into an extended outage starting in September of 2008, and had to be completed by the time the repowered plant initiated startup activities in January of 2009. Further, special consideration had to be taken to ensure all river work was completed before the river froze in November 2008.

Use of underwater wedge-wire screens was determined to be the best technically acceptable option. The versatility of the wedge-wire screens enabled them to be incorporated into the existing intake structure with relatively minor modifications. Five wedge-wire screens extend into the Mississippi River and are connected via an underwater pipe header to a new steel bulkhead installed at the existing Unit 7 intake screenhouse. A 3-D model view illustrating the new intake as designed is shown on page 6.

The river area in the vicinity of the Unit 7 intake was dredged and rip-rap was placed during a planned outage in the summer prior to installing the new intake. During the installation of the new intake, piles were driven into the river bottom to support the wedge-wire screens and the piping header. The new bulkhead and all underwater piping were shopprefabricated and modularized so that underwater installation involved only the setting of the pieces and bolting up the flanges. The intent of the design was to minimize the need for any underwater welding. The photo on page 6 shows one of the modular piping sections being lowered into the river.

Project-Unique Features

Challenges associated with the design of the new circulating water intake included the shallow river water depths in the vicinity of the existing intake, periods of heavy river debris and silting, incorporation of the wedge-wire screens into the existing intake structure, and avoiding the circulating water discharge pipe directly below the intake that extends to the middle of the river. Air burst, silt sluicing, and river warming systems were designed and installed to mitigate the varying types of screen fouling and keep the screens operating at peak performance.