ECT has provided comprehensive Clean Water Act (CWA) Section 316(a) and Section 316(b) compliance support to an electric utility developer for its multiple coal-fired generating facilities, addressing regulatory requirements for thermal discharges and cooling water intake structures. This work was conducted in coordination with state environmental agencies and the U.S. Environmental Protection Agency as part of state pollutant discharge elimination system (PDES) permitting and related reviews.
For Section 316(b), ECT performed third-party reviews of compliance submittals for multiple facilities, including evaluation of materials prepared by other consultants and development of comments on draft discharge permits. This work included evaluation of facility-specific intake configurations, refinement of compliance strategies, and coordination with the client to address regulator comments. ECT also prepared requests for reduced 316(b) information requirements, which were accepted by the state agency, resulting in minimal information needs for permit renewal.
For Section 316(a), ECT supported the client with thermal discharge evaluations and permit support activities at one facility. Work included review of thermal mixing zone and variance requirements, evaluation of operational and ambient temperature data, completion of a focused thermal study supporting alternative limits, and preparation of responses to agency comments. ECT also prepared a request for reduced 316(a) information requirements, which was accepted by the state agency.
Across both programs, ECT emphasized practical, defensible compliance strategies that balance regulatory requirements with facility operations, while maintaining a clear administrative record to support permitting decisions and long-term regulatory certainty for the client.