Client: GenCo Nuclear
Project Highlights: Normandeau’s history with Peach Bottom Atomic Power Station pre-dates its construction through a variety of environmental consulting services—particularly related to compliance with the Clean Water Act.
Services Provided:
- Regulatory Research and Interpretation
- Strategic Planning
- Environmental Support
- Ecosystem Services Analysis
- Biological Surveys
- Performing Terrestrial and Aquatic Biological Surveys and Inventories
- Sample Collection and Testing
Normandeau Associates, Inc. (Normandeau) has worked with Exelon Generating Company and its predecessor since the 1960s at Peach Bottom Atomic Power Station (PBAPS) on a variety of environmental issues including the §316(b) rule of the Clean Water Act (CWA), which regulates impingement and entrainment of fish and other aquatic organisms at cooling water intake structures (CWISs).
Peach Bottom Atomic Power Station is a two-unit, power generating station in York County, Pennsylvania. The Station operates under PADEP administered NPDES Permit which, in part, requires compliance with CWA §316(b). The updated §316(b) regulation requires establishment of the best technology available (BTA) for minimizing adverse environmental impacts associated with the use of cooling water intake structures.
In 2015, Normandeau was contracted by Exelon to provide §316(b) related services. Normandeau was tasked with evaluating PBAPS CWIS and determining an appropriate path for compliance with the §316(b) requirement. This included evaluating existing information, development of site-specific standard operating procedures, and design and installation of sampling equipment.
In March 2016, Normandeau began a one-year entrainment abundance sampling program for PBAPS to provide a portion of the information to fulfill the requirements of §122.21(r)(9) of the §316(b) regulations for CWIS at existing facilities. The objective of this one-year entrainment study was to obtain weekly, monthly, and annual density data describing the number of fish eggs and larvae per unit volume of cooling water sampled at PBAPS. A previous entrainment abundance study was performed in 2012 by Normandeau.
Simultaneous to the entrainment program, a one-year latent impingement mortality characterization sampling program was developed. The impingement sampling program was proposed for PBAPS beginning in May 2016 and continuing through April 2017 to provide a portion of the information for use in determining a compliance strategy for satisfying the requirements of §122.21(r)(6) of the CWA §316(b) regulations.
No previous latent impingement mortality studies have been performed at PBAPS. The objective of this one-year latent impingement mortality study at the outer intake structure of PBAPS was intended to evaluate a specific compliance option in the Rule. Latent impingement mortality characterization data was obtained to describe the latent mortality of non-fragile fish impinged on the traveling screens of the PBAPS outer intake structure on a biweekly, monthly, and annual basis. These latent mortality data were applied to previous impingement abundance data from a 2005-2006 study performed by Normandeau to determine total annual latent impingement mortality of the existing traveling screens and screenwash system. Total annual latent impingement mortality was evaluated in regard to specific performance standards outlined in the §316(b) regulation.
