316(b) Rule Controlling Cooling Water Intakes
316(b) Rule Controlling Cooling Water Intakes
316(b) Rule Controlling Cooling Water Intakes
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Weaknesses<br />
• Doesn’t account for site specific costs for<br />
impingement<br />
– Offshore intakes<br />
• Doesn’t account for steps already taken<br />
– Ignores results of mandated monitoring programs<br />
• Impingement mortality of shellfish<br />
– Comparable to that achieved by barrier net<br />
– What’s a shellfish<br />
– Even for a few shellfish
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