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Meeting the Clean Water Act Challenge: L-Reactor Thermal Effluent Management

This case study examines the L-Reactor's compliance challenges with the Clean Water Act (CWA) regarding thermal effluent discharges into the Savannah River. Initiated by the Department of Energy in March 1981, the renovation involved significant thermal variance issues with the National Pollutant Discharge Elimination System (NPDES) permit, impacting aquatic life severely. The study discusses various thermal mitigation strategies, the construction of cooling facilities, and the eventual shutdown due to safety concerns amid ongoing compliance pressures.

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Meeting the Clean Water Act Challenge: L-Reactor Thermal Effluent Management

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  1. Case Study 5:L-Reactor Thermal Effluent Case S-5_L-Reactor

  2. Meeting the CWA Challenge • The Clean Water Act (CWA) established a comprehensive Federal/State scheme for controlling the introduction of pollutants into the Nation’s water. Case S-5_L-Reactor

  3. Meeting the CWA Challenge • A number of comprehensive acts were subsequently designed to control discharges into: • Surface water bodies and waterways • Publicly owned treatment works (POTWs) Case S-5_L-Reactor

  4. Case Study 5: L-Reactor • March 1981 -- the DOE initiated activities to renovate and upgrade L-Reactor • The SRS utilized water from the Savannah River for secondary cooling purposes (as it had in the past) • Water was discharged back to the Savannah River via Steel Creek • Discharge temperature (effluent canal and immediate vicinity) ranged from 170 to 180 0F Case S-5_L-Reactor

  5. Case Study 5: L-Reactor • Initial NPDES permit: • Issued by the EPA in 1976 • Contained a thermal variance statement • Onsite streams did not have to meet thermal standards until they reached the Savannah River (offsite) Case S-5_L-Reactor

  6. L-Reactor Case S-5_L-Reactor

  7. Case Study 5: L-Reactor • NPDES permit renewal: • The SRS submitted a renewal application to the State in June 1981 • NPDES authority for Federal facilities was transferred from the EPA to the State of South Carolina in 1980 • The State issued the SRS a draft permit that did not contain thermal variance language Case S-5_L-Reactor

  8. Case Study 5: L-Reactor • Discussion ensued between the SRS and the State • Each side reviewed and discussed the series of events relating to the thermal variance issue • The State eventually issued the SRS a NPDES permit that required thermal compliance at the point of discharge Case S-5_L-Reactor

  9. Case Study 5: L-Reactor • The SRS found the standards set in the permit impossible to meet through then current procedures • The SRS entered into a consent order to undertake thermal mitigation studies Case S-5_L-Reactor

  10. Case Study 5: L-Reactor • Possible solutions for compliance: • Construct off-stream cooling facilities • Obtain a thermal variance (through CWA Section 316(a) study) • Request that the State change the classification of the onsite streams Case S-5_L-Reactor

  11. Case Study 5: L-Reactor • The SRS explored thermal mitigative procedures: • Once-through cooling water systems • Recirculating cooling water systems Case S-5_L-Reactor

  12. Case Study 5: L-Reactor • Due to restart schedule pressure: • Lake construction was begun before the NPDES permit was finalized • Complete permit limitations and restrictions were yet to be spelled out in final form Case S-5_L-Reactor

  13. Graphic of L-Lake Case S-5_L-Reactor

  14. Case Study 5: L-Reactor • Once the permit was finalized: • The SRS discovered that the lake acreage planned as a cooling area was reduced (by the SCDHEC) by approximately 50 percent • The south end of the lake’s surface needed to be kept at 90 0F or less Case S-5_L-Reactor

  15. Case Study 5: L-Reactor • Lake size: • Could no longer support year-round reactor operation • Surface temperature of the lake would approach permissible limits during summer months • The SRS needed: • A larger lake, or • Additional cooling measures Case S-5_L-Reactor

  16. Savannah River Paddle-Wheel Sampler Case S-5_L-Reactor

  17. Case Study 5: L-Reactor • Impact on the lake’s aquatic life: • Reactor restart affected fish that resided in the lake • Massive fish kills were reported in 1986, 1987, and 1988 • The SRS entered into a resultant settlement agreement with the State that mandated fish-kill mitigation efforts Case S-5_L-Reactor

  18. Case Study 5: L-Reactor • Shutdown: • Reactor shut down was initiated in 1988 due to safety issues • During this time, the SRS was actively pursuing mitigative efforts to alleviate/ eliminate the fish-kill problem • Shut down was not related to the NPDES permit/thermal effluent issue Case S-5_L-Reactor

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