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s	U.S. Environmental Protection Agency	2007-P-00038
£ %M \ Office of Inspector General	September 20,2007
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%; 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.

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