EPA CWA Section 316(b): The Challenges Multiply when they are Nuclear

With the issuance of the final EPA Clean Water Act (CWA), Section 316(b) rule, several existing
manufacturing, industrial and power plant facilities that intake more than 2 million gallons per day
(MGD) of water are faced with several challenges ahead. To address the rule, each affected facility will
have varying degrees of required effort depending on the design intake flow of the facility, the
ecosystem in the intake waterbody, the existing configuration of the facility, the existing impingement
and/or entrainment reduction technologies employed at the facility, public opinion in the region, etc. In
addition to the challenges faced by all facilities impacted by the rule, nuclear power facilities have
unique considerations and burden. The unique considerations at a nuclear power plant include topics
associated with security, the effect on safety-related systems, defense-in-depth, and greater relative
construction costs.
This paper will discuss topics related to the unique considerations to address Section 316(b) of the CWA
at nuclear power plants. Specific challenges will be identified and expanded on such as technologies
crossing security boundaries, tie-in and/or construction impact to safety-related systems, impact to a
plants probabilistic risk assessment (PRA) model (defense-in-depth), and higher relative construction
costs due to the level of training, quality control, security, etc. The topics of discussion will be
supplemented with case studies from Section 316(b) studies, environmental regulatory-driven
modification work, and other relevant projects at existing nuclear power plants.
Notes:
1. Introduction
2. Security
a. Fish-return systems exiting protected area.
3. Construction Costs
a. RSMeans comparison between safety-related steel and industrial facility costs.
b. Refer to the additional couple of papers we have.
4. Safety-Related Tie-Ins
a. FitzPatrick and/or Indian Point construction around service water system.
5. Defense-in-Depth
a. SONGS fragility assessment.