Location:
Bridgman, Michigan

Clients:
American Electric Power (AEP) Donald C. Cook Nuclear Power Plant

Partners:
Arcadis Canada (SENES), Black&Veatch, GLEC, Veritas

Our Expert:

LimnoTech led a team of experts to assist a large Lake Michigan nuclear power plant with 316(b) Rule interpretation and permit deliverable development to comply with requirements for protecting aquatic organisms from impingement and entrainment.

The Challenge

USEPA published The Final 2014 Rule to update implementation of Section 316(b) of the Clean Water Act (CWA), which aims to reduce injury and death of fish and other aquatic life caused by cooling water intake structures at power plants and industrial facilities. The 316(b) Rule applies to existing facilities that use cooling water intake structures to withdraw greater than two million gallons per day from waters of the U.S. as authorized by a NPDES permit. The AEP Donald C. Cook Nuclear Plant relies on large quantities of water from Lake Michigan for once-through cooling water for its two nuclear reactors. To comply with the Rule, the plant was required to evaluate the technical feasibility and social cost of several alternatives (e.g., closed-cycle cooling, fine mesh intake screens, alternative water sources, etc.) that may provide benefits by reducing impingement and entrainment of aquatic organisms.

The Outcome

LimnoTech’s team developed an expedited planning and implementation strategy to meet the application and monitoring requirements of the Rule. We assembled and led a team of experts to plan and conduct aquatic studies as well as identify, review, and evaluate potential “best technologies available” (BTAs) for achieving compliance. The team completed and submitted application requirements (r)(2)-(r)(8) and conducted planning/strategy meetings with the Michigan Department of Environmental Quality (MDEQ). We developed a scientific basis and rationale for using existing monitoring data to fulfill year one of the required two years of monitoring. The LimnoTech team conducted six months of weekly entrainment sampling at the cooling water intake, background mortality sampling in Lake Michigan and a through plant survival study of entrained eggs. We developed the (r)(9)-(r)(12) materials, selected the peer review team (with MDEQ approval), and implemented a strategy for peer review engagement to fulfill the (r)(13) requirement of the rule.

Permit deliverables included a fish/larvae entrainment characterization study, and technical cost evaluations, social costs, and benefits for each relevant BTA. The technical support and project management provided by the LimnoTech team gave the plant a solid foundation to confidently recommend appropriate solutions for 316(b) Rule compliance. The LimnoTech team’s familiarity with the 316(b) Rule, the Great Lakes Region and the regulatory environment in Michigan has resulted in effective, efficient and successful implementation for the D.C. Cook Nuclear Plant.

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