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Defining and Assessing Adverse Environmental Impact
from Power Plant Impingement and Entrainment of
Aquatic Organisms 1st Edition D.A. Dixon Digital Instant
Download
Author(s): D.A. Dixon
ISBN(s): 9789058095176, 9058095177
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Year: 2003
Language: english
DEFINING AND ASSESSING ADVERSE ENVIRONMENTAL IMPACT
FROM POWER PLANT IMPINGEMENT AND ENTRAINMENT OF
AQUATIC ORGANISMS
Defining and Assessing Adverse
Environmental Impact from Power Plant
Impingement and Entrainment of
Aquatic Organisms

Editors:

Douglas A. Dixon
Electric Power Research Institute (EPRI), Palo Alto, CA, USA

John A. Veil
Argonne National Laboratory, Washington, DC, USA

Joe Wisniewski
Wisniewski & Associates, Inc., McLean, VA, USA

A.A. BALKEMA PUBLISHERS LISSE / ABINGDON / EXTON (PA) / TOKYO

This edition published in the Taylor & Francis e-Library, 2005.

“To purchase your own copy of this or any of Taylor & Francis or Routledge’s
collection of thousands of eBooks please go to www.eBookstore.tandf.co.uk.”
Copyright © 2003 Swets & Zeitlinger B.V., Lisse, The Netherlands

All rights reserved. No part of this publication or the information contained herein
may be reproduced, stored in a retrieval system, or transmitted in any form or by
any means, electronic, mechanical, by photocopying, recording or otherwise, without
written prior permission from the publisher.

Although all care is taken to ensure the integrity and quality of this publication and the
information herein, no responsibility is assumed by the publishers nor the author for
any damage to property or persons as a result of operation or use of this publication
and/or the information contained herein.

Published by: A.A. Balkema, a member of Swets & Zeitlinger Publishers

www.balkema.nl and www.szp.swets.nl
ISBN 0-203-97119-1 Master e-book ISBN

ISBN 90 5809 517 7

Table of Contents

PREFACE by Douglas A. Dixon and Kent D. Zammit VII

Maryland Power Plant Cooling-Water Intake Regulations and 1

their Application in Evaluation of Adverse Environmental Impact
R. McLean, W.A. Richkus, S.P. Schreiner, and D. Fluke
Scientific and Societal Considerations in Selecting Assessment 12
Endpoints for Environmental Decision Making
E.M. Strange, J. Lipton, D. Beltman, and B.D. Synder
Adverse Environmental Impact: 30-year Search for a Definition 21
D.A. Mayhew, P.H. Muessig, and L.D. Jensen
Uncertainty and Conservatism in Assessing Environmental 30
Impact under §316(b): Lessons from the Hudson River Case
J.R. Young, and W.P. Dey
A Holistic Look at Minimizing Adverse Environmental Impact 40
Under Section 316(b) of the Clean Water Act
J.A. Veil, M. G. Puder, D. J. Littleton, and N. Johnson
Modeling Possible Cooling-Water Intake System Impacts on Ohio 56
River Fish Populations
E. Perry, G. Seegert, J. Vondruska, T. Lohner, and R. Lewis
A Process for Evaluating Adverse Environmental Impact by 79
Cooling-Water System Entrainment at a California Power Plant
C.P. Ehrler, J.R. Steinbeck, E.A. Laman, J.B. Hedgepeth, J.R. Skalski,
and D.L. Mayer
Comparing Clean Water Act Section 316(b) Policy Options 103
J. Kadvany
Using Attainment of the Designated Aquatic Life use to Determine 136
Adverse Environmental Impact
G. Seegert
Defining “Adverse Environmental Impact” and Making §316(b) 143
Decisions: a Fisheries Management Approach
D.E. Bailey, and K.A.N. Bulleit
Indicators of AEI Applied to the Delaware Estuary 165
L.W. Barnthouse, D.G. Heimbuch, V.C. Anthony, R.W. Hilborn,
and R.A. Myers

V
Adverse Environmental Impact: a Consultant’s Perspective 185
A.W. Wells, and T.L. Englert

Proposed Methods and Endpoints for Defining and Assessing 198

Adverse Environmental Impact (AEI) on Fish Communities/
Populations in Tennessee River Reservoirs
G.D. Hickman, and M.L. Brown

Minimizing Adverse Environmental Impact: How Murky the Waters? 213

R.W. Super, and D.K. Gordon

Measurement Error Affects Risk Estimates for Recruitment to the 231

Hudson River Stock of Striped Bass
D.J. Dunning, Q. E. Ross, S.B. Munch, and L.R. Ginzburg

Use of Equivalent Loss Models under Section 316(b) of the Clean 247
Water Act.
W.P. Dey

A Blueprint for the Problem Formulation Phase of EPA-Type 264

Ecological Risk Assessments for 316(b) Determinations
W. Van Winkle, W.P. Dey, S.M. Jinks, M.S. Bevelhimer,
and C.C. Coutant

Author index 291

VI
Preface

The Electric Power Research Institute (EPRI), headquartered in Palo Alto, California,
USA, is a non-profit energy research consortium for the benefit of the energy industry,
its customers, and society. The mission of EPRI’s Environment Sector is to be the pre-
mier provider of timely, credible scientific and technical knowledge, tools and services
to (1) inform critical policy and regulatory deliberations, (2) support cost-effective
compliance, stewardship, strategic issue management and business decision-making,
and (3) address longer-term sustainability issues.

A current issue of major importance to the U.S. electric power industry is the develop-
ment of regulations to address Section 316(b) of the Clean Water Act of 1972. Section
316(b) addresses the protection of aquatic life at power plant cooling water intake
structures (CWIS). CWIS affect fish and invertebrates via impingement of organisms
on intake screens and entrainment of organisms, particularly early life stages (eggs
and larvae), into the cooling system where they are exposed to physical, chemical
and thermal stress. Historical §316(b) demonstration studies have shown that billions
of aquatic organisms are annually exposed to these stresses. In accordance with our
mission, EPRI has a program dedicated to providing science and technology-based
solutions for aquatic life protection at CWIS.

Section 316(b) states:

Any standard established pursuant to section 301 or section 306 of this Act and
applicable to a point source shall require that the location, design, construction,
and capacity of cooling water intake structures reflect the best technology avail-
able for minimizing adverse environmental impact.

Over the 30 years since its enactment, there has been considerable discussion and
debate among stakeholders regarding the definition of terms and implementation proc-
ess for this section. Neither the legislation, nor its legislative history, defines “adverse
environmental impact (AEI).” In 1976, the U.S. Environmental Protection Agency
(USEPA) proposed regulations for implementing §316(b). However, these regulations
were challenged on procedural grounds and, subsequently, were formally withdrawn
by USEPA. Nevertheless, in the absence of formal regulations, permit applicants,
scientists, and regulators continued to rely on USEPA draft guidance publications, and
also on administrative decisions in several permit proceedings, to define the §316(b)
requirements for permitting CWIS during the 1970s, 1980s, and 1990s.

In the early 1990s, a coalition of U.S. environmental groups sued USEPA for failing
to promulgate §316(b) regulations. In 1995, the parties entered into a Consent Decree
directing USEPA to issue final regulations. USEPA divided the rulemaking process
into three phases. Regulations for new facilities were issued in November 2001; regu-
lations for power plants with intakes exceeding 50 MGD will be finalized in February

VII
of 2004; and regulations for CWIS at non-power plants with intake flows exceeding a
volume yet to be determined will be issued in June of 2006. The proposed regulations
are intended to minimize the potential AEI associated with CWIS. Minimizing AEI
may include requirements affecting the design, construction, location, and capacity of
CWIS that are determined to reflect the “best technology available” (BTA).

One central issue in the rule-making process is the definition of AEI, including how
it is assessed, endpoints for decision-making, and how it can be minimized. EPA has
not defined AEI, nor have they proposed an approach for assessing environmental
impact. Several alternative definitions and assessment approaches have been offered
for public consideration and comment.

To facilitate an exchange of information among all stakeholders in the §316(b) issue,

EPRI organized a national symposium to discuss the meaning of AEI and methods for
its assessment. The symposium was held in conjunction with the Annual Meeting of
the American Fisheries Society, August 23, 2001 in Phoenix, Arizona, USA. Techni-
cal experts in federal and state resource agencies, academia, industry, and non-govern-
mental organizations attended and made presentations on AEI issues including:

• Definition of AEI (including consideration of the full range of options such as indi-
vidual losses, population-level impacts, fishery opportunity foregone, and disruption
of aquatic community structure and function).
• AEI assessment endpoints and thresholds.
• Predictive and retrospective methods for assessing AEI (e.g., conditional mortality,
equivalent adult losses, production foregone, biocriteria, trend analysis of fishery-
independent and dependent data).
• Role of ecological risk assessment in assessing AEI.

The peer-reviewed accepted papers herein were presented at this symposium. EPRI
and the editors are making this information available to the scientific community and
specifically to the stakeholders in the §316(b) issue, particularly EPA, for considera-
tion during the rule development effort.

Finally, the symposium and papers reflect an enormous effort by many individuals and
organizations. For co-sponsorship of the original symposium, we express our appre-
ciation to the American Fisheries Society and its Western Division. Development of
the symposium objectives and selection of papers for presentation was supported by
John Veil, Argonne National Laboratory; William Richkus, Versar Inc.; and James
Wright, Tennessee Valley Authority. John Veil also served as symposium co-mod-
erator. Completion of this book involved sustained and extensive effort by all of the
authors, who were aided by the thoughtful and constructive reviews and comments
of many others. We are grateful to all these individuals for the diligence and patience
they have shown in bringing this project to fruition.

Douglas A. Dixon, Ph.D. and Kent D. Zammit

Managers, Fish Protection Research, EPRI

VIII
Maryland Power Plant Cooling-Water
Intake Regulations and their Application
in Evaluation of Adverse Environmental
Impact

Richard McLean1, William A. Richkus2,*, Stephen P. Schreiner2, and

David Fluke3
1Power Plant Research Program, Maryland Department of Natural
Resources, Annapolis, MD 21401; 2Versar, Inc., Columbia, MD 21045;
3Maryland Department of Environment, Baltimore, MD 21224

Received December 6, 2001; Revised January 28, 2002; Accepted February 19, 2002;
Published February, 2003

Maryland’s cooling-water intake and discharge regulations, the Code of Maryland

Regulations (COMAR) 26.08.03, stem from Sections 316(a) and (b) of the Clean Water
Act (CWA). COMAR 26.08.03.05 and litigative and administrative rulings stipulate that
the location, design, construction, and capability of cooling-water intake structures
must reflect the best technology available (BTA) for minimizing adverse environmen-
tal impacts (AEIs), providing that the costs of implementing the BTA are not wholly
disproportionate to the expected environmental benefits. Maryland law exempts
facilities that withdraw less than 10 million gallons/day (MGD) and less than 20% of
stream or net flow by the intake. If not exempt, BTA must be installed if the cost of
doing so is less than five times the value of fish impinged annually. Through site-
specific studies and the use of a Spawning and Nursery Area of Consequence (SNAC)
model applied to Representative Important Species, several power plants were evalu-
ated to determine if they have had an adverse effect on spawning and nursery areas
of consequence. Examples of application of the Maryland law to a number of power
plants in the state are presented, together with the outcome of their evaluation.

KEY WORDS: entrainment, impingement, environmental impact, cooling water regulation

DOMAINS: freshwater systems, marine systems, ecosystems and communities, environ-

mental monitoring

INTRODUCTION
Maryland takes pride in its strong commitment to environmental protection. A
cornerstone of this commitment has been the state’s efforts to restore and protect

Corresponding author. Email: [email protected]

© 2002 with author. 1
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

the Chesapeake Bay and all of its diverse natural resources. One of the initial steps
toward protecting the bay was the creation in the early 1970s of the Power Plant
Research Program (PPRP). PPRP was created by legislation in response to public
controversy that arose when the Baltimore Gas and Electric Company (BG&E)
announced plans to construct the large Calvert Cliffs Nuclear Power Plant along
the shoreline of the bay. This plant would withdraw large volumes of cooling
water from the bay and discharge the heated water back into bay waters. The pub-
lic was concerned about the potential for the plant to adversely affect the bay and
its fisheries resources, and the state could not respond to these concerns because it
did not have adequate technical expertise with regard to the potential impact that
these power generating facilities might have on the bay.
As a result, the legislature created PPRP to ensure that, in the future, all exist-
ing and proposed power generating and transmission facilities in Maryland would
operate in a manner that ensured protection of the state’s natural resources and
at the same time made electric power available to the public at reasonable rates.
With regard to proposed new generating and transmission facilities, PPRP is
charged with assessing and advising the Maryland Public Service Commission on
the environmental and economic considerations associated with the siting, design,
and operation of the proposed facilities. For existing facilities, PPRP provides
technical assistance in permit review and evaluation to the Maryland Department
of Environment (MDE), which is the state’s permitting agency with responsibility
for writing national pollution discharge elimination system (NPDES) permits and
enforcing compliance with permit provisions.
Since its inception, PPRP has provided technical reviews of issues and devel-
oped recommendations concerning requirements associated with Maryland’s
regulations for cooling-water intake structures (CWIS) for all its generating sta-
tions. PPRP works cooperatively with MDE in reviewing all data and information
required from plant operators by MDE. In many instances, the state has conducted
research independent of permittees in order to assess impacts and technologies to
reduce those impacts. The information presented in this paper is based on PPRP’s
experience in addressing CWIS issues and on the results of the program’s very
diverse yet comprehensive studies of the manner in which cooling-water with-
drawals have impacted aquatic biota in Maryland’s waters.

MARYLAND REGULATIONS FOR CWIS

Impingement
As generating stations draw water in for the cooling cycle, aquatic organisms
near the intake can be caught in the suction and trapped (impinged) on the intake
screens. Large power plants often have systems that wash the screens and return
impinged organisms to the water thereby reducing injury and mortality. Injury
and mortality, however, can still be significant depending upon species, water
temperature, and other site-specific factors. The best technology available (BTA)
for impingement was deemed by Maryland to be the technology that was the most

2
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

cost effective for reducing the magnitude of impingement impact, as established

by the value of the fish lost to impingement. Thus, as established in the Code of
Maryland Regulations (COMAR) 26.08.03.05.D(1) and D(2), the dollar value of
the organisms killed by impingement is to be calculated, and the plant operator is
required to implement technologies to reduce impingement only to the extent that
the cost to the facility does not exceed the total value of lost organisms over a 5-
year period (in practice, generally five times the value of fish lost to impingement
in a single year). In essence, Maryland’s BTA is based on a simplified cost-benefit
assessment.
The technical basis for the regulation is not documented in the state’s regu-
latory records. We believe that the dollar values of fish presented in Section
08.02.09.01 of COMAR were taken from the American Fisheries Society’s (AFS)
listing of fish values at the time the regulation was promulgated. AFS has regu-
larly updated its fish values, and those values are used throughout the country to
establish the costs of fish kills due to many causes. Maryland’s regulation did not
specify changes of those values over time (for example, to account for inflation
or devaluation). Thus, the values in Section 08.02.09.01 have not been modified
since they were first promulgated. Plants using cooling water in the state have been
evaluated under these regulations since the 1970s. MDE and DNR reviewed the
issue of static fish values in their assessments throughout the period.

Entrainment
Aquatic organisms that are drawn through the generating facility through cooling
systems, intake valves, and turbines may be injured or killed as they are pulled
(entrained) through the station. The general concepts underlying a determination
of BTA for entrainment by Maryland are as follows:

• The evaluation of impact should be carried out to a specified level of biologi-

cal significance, i.e., representative important species (RIS) and spawning and
nursery areas of consequence for the RIS.
• The consequences of the cooling-water withdrawal effects should be based on
the extent to which they impact the viability of the RIS population and the eco-
system necessary to support its life history functions. The effect of the cooling-
water intake itself (i.e., the number of fish impinged or entrained) should not be
the major focus; it is the consequence of that effect to the biological entity of
concern, whether at the species or the ecosystem level, which establishes what
actions the state will take.

The state determined that a sequential approach to entrainment impact assessment

is a good, generic approach to the issues involved, with the steps in that sequence
being (1) to quantify the effects of the cooling-water withdrawal (i.e., estimate the
numbers of organisms lost to entrainment), (2) to establish the biological entity at
risk (i.e., select RIS), and (3) to assess the significance of the effects for causing
adverse harm to the target entity.

3
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

The CWIS operator is required to determine if the entrainment loss results in

a significant adverse environmental impact (AEI), which is defined as a statisti-
cally measurable effect outside the plant’s mixing zone. Entrainment evaluation
modeling has been applied in Maryland assessments[1,2].

WATER WITHDRAWAL RATE THRESHOLD

Maryland regulations also establish a water withdrawal rate threshold below which
impacts are assumed to be sufficiently small as to not require regulation for BTA.
The state defines that threshold as 10 million gallons/day (MGD), if that volume
of water is less than 20% of the defined flow for the providing water body: design
stream flow (7Q10) for nontidal waters (rivers), and the annual average net flow past
the point of discharge which is available for dilution for tidal waters. Note that this
exemption takes into account site specificity (i.e., the size of the body from which the
water is withdrawn), reinforcing the regulation’s intent that facilities be evaluated on
a site-specific basis. No documentation exists within Maryland’s regulatory archives
to explain the technical basis for the 10-MGD threshold. However, discussions with
individuals involved in the development of the regulation suggested that the thresh-
old value was selected based on knowledge of the various facilities in the state that
withdrew cooling water from the state’s surface waters; the status of the ecosystems
from which that water was being withdrawn; and the professional judgment of the
resource managers and permit regulators with management and regulatory author-
ity at that time. Since then, the state has not modified that threshold, and no impacts
have occurred that have supported the need for its reassessment.
Maryland CWIS regulations do not vary according to specific water body
type except with regard to the way in which the allowable percentage withdrawal
threshold is calculated. Two reasons underlie that decision. First, a site-specific
assessment approach was adopted, which makes generalizations related to water
body type moot. Second, a site-specific approach was established because the
potential for adverse impact was not consistent within each water body type. For
example, the regulation did not differentiate between estuarine and fresh waters,
recognizing that not all locations within an estuary or a freshwater body are
equally sensitive or productive.

IDENTIFYING AND ADDRESSING IMPACTS

Defining Adverse Environmental Impacts

Approaches to minimizing adverse impacts must be based on strong technical data
and information. Maryland regulations do not specify the types of studies required
to provide the data needed to comply with the regulations. However, because the
PPRP existed at the time the regulations were put in place, utility study designs
and results of studies were evaluated in a fairly consistent manner, and the state’s
approach to such evaluations was increasingly refined over time. Also, most of

4
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

the generating stations in the state were owned by two major utilities – BG&E and
Potomac Electric Power Company (PEPCo) – and the utility approach to satisfying
the state’s requirements became fairly standardized; the same utility staff worked
with the same state agency and contractor staff for more and more facilities.
Continued or periodic monitoring is required to measure the effectiveness of a
given technology’s performance. If the state’s CWIS determination required that
a facility take some action, monitoring of the required action was made a require-
ment of the permit issued. The performance measures that would be used to meas-
ure BTA effectiveness were made facility- and site-specific, and a function of the
type of action required. Thus, the state did not establish any type of standardized
monitoring requirement related to CWIS determinations.
Quantification of the effects of water withdrawal is necessary but not suffi-
cient to determine whether additional measures may be necessary to reduce these
effects. As noted above, the key is whether the effects caused by the water with-
drawal have significance to the biological entity of concern. If the effects are not
significant, existing structures and operations are sufficient since there is no truly
adverse impact to be minimized. Thus, clearly defining what constitutes adverse
impact is crucial. Maryland considers all costs to the citizens of the state in mak-
ing regulatory determinations, and factors include impacts to the state’s living
resources and economic costs to the utilities (and, beyond, to the consumers) of
measures that could be taken to reduce the effects of water withdrawal. Maryland’s
regulations thus balance these considerations so that any measures required of the
utilities are commensurate with the estimated significance of the effects being
reduced. We believe that as 316(b) rules are developed for the nation, the U.S.
Environmental Protection Agency should define AEI and place AEI into context
with the costs of protecting natural resources.

Defining Best Technology Available

Based on extensive research and data, Maryland has determined that the extent of
impacts of cooling-water withdrawal is site specific, as are the need for and the
nature of various ameliorating intake technologies. Factors that directly affect the
decisions on what constitutes BTA at a particular facility include a determination
of an impact, the nature of that impact, the design and location of the facility on
the water body, and life stages of affected species. Maryland’s regulations do not
specify a design intake velocity; Maryland facilities generally have a 1 to 2 ft/s
screen face velocity. Impingement rates at Maryland plants with similar intake
designs within the Chesapeake Bay have varied widely, and they appear to be
related more to the plant’s location and the location of the intake than to intake
velocity or volume of water withdrawn.
Our assessments of generating facilities in Maryland resulted in BTA deter-
minations that ranged from a decision that the existing intake structure is BTA to
recommending mitigative technologies such as wedgewire screens, modifications
to intake structures, and installation of barrier nets. Therefore, we believe there is
no single technology or suite of technologies that can be applied on a state-wide

5
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

or nation-wide basis. We believe, however, that it is important to have a consistent

national process for identifying BTA at the site-specific level.

Cumulative Impacts
Cumulative effects of impingement and entrainment are not specifically addressed
in the regulations, but they have been evaluated in Maryland in a limited and
somewhat cursory manner. Most Maryland facilities are relatively far apart spa-
tially, and the biological populations exposed to the effects of these widespread
plants are often distinct, with only some intermingling. For example, the major
tributaries of the Chesapeake Bay support their own spawning populations of
striped bass (Morone saxatilis), and impacts to the Potomac River stock would
have no significance to the Nanticoke River stock. Maryland has tracked cumula-
tive impingement losses across all power plants for some species, such as Atlan-
tic Menhaden (Brevortia tyrannus), that may occur over a wide range of salinity
regimes and are thus exposed to the effects of all of the power plants located on
tidal waters of the state. These assessments have suggested that the cumulative
magnitude of impingement is a small fraction of the commercial harvest of the
species and a small fraction of the amount of the species consumed by predators.
On that basis, the state concluded that the levels of impingement by Maryland’s
power plants do not represent a significant adverse impact to important resource
species in the bay. With regard to Maryland’s experience, long-term monitoring
of the status of important resource species have temporally addressed cumulative
impacts. None of these diverse monitoring programs has suggested any adverse
cumulative impact from the power plants operating in Maryland[3,4].

Mitigation
While mitigation is not identified or mentioned in Maryland’s regulations, out-of-
kind mitigation has been incorporated into some state NPDES permits issued after
a CWIS evaluation, as is discussed further below. The state believes that mitiga-
tion can play a valuable role in the resolution of 316(b) issues on a site-specific
basis. The term mitigation as used here refers to actions aside from alternative
intake technologies or operating strategies that might be used to minimize ultimate
impacts of cooling-water intakes to the state’s resources. Mitigation may include
alternative measures that can indirectly compensate the public for resource losses
due to CWIS effects.

DISCUSSION

Maryland Facilities’ Regulation Compliance

Before reviewing the permitting actions at various facilities, some general obser-
vations can be made about how facility permitting often proceeded. COMAR
26.08.03.05D addresses impingement and requires a facility owner to estimate the
value of fish lost to impingement over a 5-year period as a basis for determining

6
McLean et al.: Cooling-Water Intake Regulations © 2003 Swets & Zeitlinger B.V.

if modification of the CWIS to achieve BTA would be required. As a result,

some quantification of magnitude and composition of impinged organisms was
performed at all Maryland plants at which the water withdrawal rate exceeded
the 10-MGD threshold. For those facilities where impingement was anticipated
or known to be low, a relatively limited sampling effort was often sufficient
to confirm that judgment. Conversely, at large plants where very substantial
numbers of organisms were expected or known to be impinged, impingement
studies in a number of cases were conducted over many years (e.g., 21 years at
Calvert Cliffs) to ensure that an accurate characterization of impingement was
made[4].
COMAR 26.08.03.05E, which addresses entrainment, does not provide guid-
ance and requirements as detailed as those specified for impingement. Also, data
and information that would be required for a rigorous empirical quantification
of entrainment impact was most often unavailable and frequently was costly
to acquire. For these reasons, initial estimation of whether a facility impacted
a Spawning or Nursery Area of Consequence (SNAC) was often done through
modeling. PPRP developed a SNAC model for that purpose that was used to
estimate entrainment losses of vulnerable RIS, the consequences of those losses
to the ecosystem, and the economic value of those losses[1]. An overview of that
model was presented by Richkus and McLean[3]. PPRP applied the SNAC model
to many of the generating stations in Maryland, and decisions on permitting and
permit conditions were often based on the model outcomes. In many cases, results
of the SNAC model suggested that impacts were not significant and that existing
CWIS could be considered to be BTA. In cases where the SNAC model results
suggested that significant impact might be occurring, but where the modeling
was conducted using limited data or information from the literature, permits were
issued that required the facility owner to conduct studies sufficient to reliably
estimate entrainment impacts. Results of such studies were then used as a basis
for subsequent permitting decisions.
PPRP assessments of the type just described established that many of the power
plants in Maryland were causing minimal impacts due to entrainment and impinge-
ment. For example, at the R.P. Smith plant, which is located on the mainstem of
the nontidal portion of the Potomac River, annual impingement losses were val-
ued at $90 using COMAR-specified values, and the overall projected ecological
impact from entrainment was estimated at less than 0.1% of system net primary
production. Small impacts were also estimated for the Dickerson plant, which is
also located on the nontidal Potomac River. Similarly minor impacts were found
for some of the smaller facilities located on estuarine waters (Baltimore City),
such as the Baltimore Refuse Energy Systems Company (BRESCO) waste-to-
energy incinerator and the Gould Street Plant, an older facility seldom run at full
capacity. For these types of projects, the existing plant CWIS was determined to
be BTA and no CWIS modifications or other 316(b) action by the facility owner
were required in the permit.
At some facilities, initial estimates of entrainment impacts, derived from SNAC
modeling, suggested that significant impacts may be occurring, but no data were

7
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different content
 Physical Education - Study Plan
Summer 2023 - Research Center

Prepared by: Instructor Brown

Date: July 28, 2025

Background 1: Statistical analysis and interpretation

Learning Objective 1: Case studies and real-world applications
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Learning Objective 2: Case studies and real-world applications
• Fundamental concepts and principles
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Learning Objective 3: Study tips and learning strategies
• Best practices and recommendations
- Sub-point: Additional details and explanations
- Example: Practical application scenario
[Figure 3: Diagram/Chart/Graph]
Learning Objective 4: Study tips and learning strategies
• Critical analysis and evaluation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Learning Objective 5: Historical development and evolution
• Key terms and definitions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 5: Diagram/Chart/Graph]
Definition: Historical development and evolution
• Comparative analysis and synthesis
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Assessment criteria and rubrics
• Research findings and conclusions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Assessment criteria and rubrics
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Assessment criteria and rubrics
• Statistical analysis and interpretation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Practice Problem 9: Interdisciplinary approaches
• Historical development and evolution
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Formula: [Mathematical expression or equation]
Results 2: Statistical analysis and interpretation
Example 10: Historical development and evolution
• Literature review and discussion
- Sub-point: Additional details and explanations
- Example: Practical application scenario
[Figure 11: Diagram/Chart/Graph]
Important: Theoretical framework and methodology
• Key terms and definitions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Comparative analysis and synthesis
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 13: Diagram/Chart/Graph]
Important: Theoretical framework and methodology
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Key Concept: Practical applications and examples
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Note: Fundamental concepts and principles
• Case studies and real-world applications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Example 16: Experimental procedures and results
• Case studies and real-world applications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Note: Assessment criteria and rubrics
• Literature review and discussion
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 18: Diagram/Chart/Graph]
Example 18: Current trends and future directions
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 19: Diagram/Chart/Graph]
Remember: Key terms and definitions
• Ethical considerations and implications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Formula: [Mathematical expression or equation]
[Figure 20: Diagram/Chart/Graph]
Module 3: Key terms and definitions
Key Concept: Study tips and learning strategies
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
[Figure 21: Diagram/Chart/Graph]
Important: Critical analysis and evaluation
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Remember: Key terms and definitions
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
[Figure 23: Diagram/Chart/Graph]
Key Concept: Problem-solving strategies and techniques
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Practice Problem 24: Critical analysis and evaluation
• Critical analysis and evaluation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Problem-solving strategies and techniques
• Ethical considerations and implications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
[Figure 26: Diagram/Chart/Graph]
Definition: Best practices and recommendations
• Fundamental concepts and principles
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Interdisciplinary approaches
• Critical analysis and evaluation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Problem-solving strategies and techniques
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Important: Comparative analysis and synthesis
• Best practices and recommendations
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Section 4: Fundamental concepts and principles
Definition: Ethical considerations and implications
• Assessment criteria and rubrics
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Important: Interdisciplinary approaches
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Remember: Theoretical framework and methodology
• Critical analysis and evaluation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Best practices and recommendations
• Theoretical framework and methodology
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Research findings and conclusions
• Case studies and real-world applications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Remember: Study tips and learning strategies
• Assessment criteria and rubrics
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 36: Diagram/Chart/Graph]
Remember: Case studies and real-world applications
• Key terms and definitions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Historical development and evolution
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 38: Diagram/Chart/Graph]
Practice Problem 38: Theoretical framework and methodology
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Definition: Fundamental concepts and principles
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Practice 5: Practical applications and examples
Note: Study tips and learning strategies
• Assessment criteria and rubrics
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
[Figure 41: Diagram/Chart/Graph]
Definition: Case studies and real-world applications
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Key Concept: Ethical considerations and implications
• Theoretical framework and methodology
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 43: Diagram/Chart/Graph]
Important: Comparative analysis and synthesis
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Key Concept: Historical development and evolution
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Note: Fundamental concepts and principles
• Practical applications and examples
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Learning outcomes and objectives
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Remember: Key terms and definitions
• Case studies and real-world applications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Remember: Ethical considerations and implications
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Example 49: Fundamental concepts and principles
• Literature review and discussion
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Introduction 6: Comparative analysis and synthesis
Key Concept: Research findings and conclusions
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Definition: Experimental procedures and results
• Comparative analysis and synthesis
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Fundamental concepts and principles
• Comparative analysis and synthesis
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Formula: [Mathematical expression or equation]
Definition: Comparative analysis and synthesis
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 54: Diagram/Chart/Graph]
Important: Ethical considerations and implications
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Key Concept: Research findings and conclusions
• Learning outcomes and objectives
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Key Concept: Research findings and conclusions
• Historical development and evolution
- Sub-point: Additional details and explanations
- Example: Practical application scenario
[Figure 57: Diagram/Chart/Graph]
Example 57: Interdisciplinary approaches
• Interdisciplinary approaches
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
[Figure 58: Diagram/Chart/Graph]
Example 58: Practical applications and examples
• Statistical analysis and interpretation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Important: Ethical considerations and implications
• Ethical considerations and implications
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 60: Diagram/Chart/Graph]
Unit 7: Case studies and real-world applications
Important: Assessment criteria and rubrics
• Comparative analysis and synthesis
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Remember: Comparative analysis and synthesis
• Research findings and conclusions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Remember: Ethical considerations and implications
• Practical applications and examples
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
[Figure 63: Diagram/Chart/Graph]
Note: Interdisciplinary approaches
• Literature review and discussion
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Example 64: Experimental procedures and results
• Statistical analysis and interpretation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 65: Diagram/Chart/Graph]
Definition: Statistical analysis and interpretation
• Practical applications and examples
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Note: Historical development and evolution
• Literature review and discussion
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Practice Problem 67: Assessment criteria and rubrics
• Study tips and learning strategies
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Definition: Interdisciplinary approaches
• Statistical analysis and interpretation
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
[Figure 69: Diagram/Chart/Graph]
Note: Theoretical framework and methodology
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
[Figure 70: Diagram/Chart/Graph]
Summary 8: Practical applications and examples
Note: Case studies and real-world applications
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Definition: Learning outcomes and objectives
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Important: Assessment criteria and rubrics
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Important: Critical analysis and evaluation
• Experimental procedures and results
- Sub-point: Additional details and explanations
- Example: Practical application scenario
Key Concept: Study tips and learning strategies
• Assessment criteria and rubrics
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Practice Problem 75: Critical analysis and evaluation
• Historical development and evolution
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Important: Fundamental concepts and principles
• Historical development and evolution
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
Formula: [Mathematical expression or equation]
Example 77: Problem-solving strategies and techniques
• Current trends and future directions
- Sub-point: Additional details and explanations
- Example: Practical application scenario
- Note: Important consideration
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