tftD STA^ s U.S. Environmental Protection Agency 2007-P-00038 £ %M \ Office of Inspector General September 20,2007 / fi %; At a Glance Catalyst for Improving the Environment Why We Did This Review We conducted this review in response to a complaint from the Friends of Lake Anna (FOLA), a citizens group, alleging that the water discharge permit for the North Anna Power Station (NAPS) inappropriately allows the cooling lagoons to be designated a waste heat treatment facility exempt from the Clean Water Act. Background NAPS is located on Lake Anna, which has two parts: a 9,600 acre reservoir that provides water for the NAPS to operate, and 3,400 acres of lagoons to cool the water from the NAPS condensers before the water returns to the reservoir. Both parts of Lake Anna are used for recreation. By August 2005, FOLA identified concerns about the high water temperatures in the cooling lagoons. For further information, contact our Office of Congressional and Public Liaison at (202) 566-2391. To view the full report, click on the following link: www.epa.qov/oiq/reports/2007/ 20070920-2007-P-00038.pdf Decision Needed on Regulating the Cooling Lagoons at the North Anna Power Station What We Found NAPS has a water discharge permit allowing it to discharge water from the cooling lagoons into the Lake Anna reservoir. Lake Anna is classified as Class III waters. The Virginia water quality standards for Class III waters include, among other factors, that the maximum temperature cannot exceed 32° Celsius, which is about 90° Fahrenheit. The current (and all prior) water discharge permits, as well as the draft permit being processed by the Virginia Department of Environmental Quality, exempts the cooling lagoons from the water quality standards because they are considered a waste treatment facility. To protect those who use the cooling lagoons for recreational purposes, FOLA believes a water temperature limit should be placed on the cooling lagoons. For a variety of reasons, it believes the cooling lagoons are waters of the United States that can be regulated under the Clean Water Act. If so, the new water discharge permit can establish such limits. Although the U.S. Environmental Protection Agency (EPA) authorized Virginia to administer the water discharge permit program in 1975, it retained the authority to review and, if needed, object to permits proposed by Virginia. The NAPS permit is the type that must be reviewed by EPA Region 3. Based on its review of the proposed permit, Region 3 officials may: not respond, object, or make comments or recommendations. In view of the concerns raised by FOLA that the cooling lagoons should be designated waters of the United States, the permit review process by EPA is critical. What We Recommend We recommend that the Region 3 Regional Administrator: 1. Decide whether additional time should be requested for the Region's review of the proposed permit for NAPS, in order to consider whether the cooling lagoons should be classified as waters of the United States under the Clean Water Act. 2. Consider communicating to the public that this review was performed. ------- |