Southern Company’s water-hogging Plant Vogtle aims to get even thirstier if the proposed two new nuclear reactors under construction receive approval from the Georgia Environmental Protection Division (EPD) for a large water withdrawal permit from the already imperiled Savannah River. The state agency is considering a permit request for up to 74 million gallons per day (mgd). This is in addition to the 127 mgd withdrawal permit from the Savannah for the existing two Vogtle reactors. Combine Vogtle’s current and predicted future water use with the antiquated coal-fired power plant downstream, Plant McIntosh, and Georgia Power (subsidiary of the Southern Company) clearly has the biggest straw in the Savannah River, much more than many cities combined, including upstream Augusta and downstream Savannah. This dire situation led the Georgia Water Coalition to twice pick this unacceptably large water withdrawal scenario as a “Dirty Dozen” culprit.
The Southern Alliance for Clean Energy (SACE) and our partners came together to highlight the serious concerns the proposed Plant Vogtle permit poses. Back in March, extensive written comments were filed on behalf of SACE and the Savannah Riverkeeper (SRK) by Emory’s Turner Environmental Law Clinic and the Southern Environmental Law Center (SELC) — and we also demanded a public hearing. EPD listened and granted a hearing, which was held in mid-May in Waynesboro, near Plant Vogtle in Burke County. I myself attended and provided comments. And though the location is not an easy trek and was held late in the evening, there was excellent turnout by a diverse set of interests both in Georgia and South Carolina — including upstream interests around Lake Hartwell, downstream residents of Savannah, local communities near the plant, and many concerned organizations from Atlanta and beyond, such as Georgia WAND, Concerned Citizens of Shell Bluff, BREDL, Center for a Sustainable Coast, Sierra Club, Nuclear Watch South, and the Lake Hartwell Association. (View videos of some of the commenters here.)
What are some of the concerns?
- There are many other outstanding issues that are of critical importance to the long-term health and sustainable management of the Savannah River, such as the long-awaited dissolved oxygen standard for the river and the long term drought management plan. These must be completed before can EPD meaningfully assess the impacts the proposed water withdrawal will have on the Savannah River.
- Plant Vogtle also requires a water discharge permit that is fundamentally intertwined with the withdrawal permit. EPD should consider the two permits together.
- The estimated consumptive loss for the proposed reactors, water that is never returned to the river, is significant with tens of millions of gallons lost per day. EPD has acknowledged a worst-case scenario of consumptive losses up to 88%. The existing reactors already have considerable consumptive loss, on average only returning one-third of what is withdrawn. This level of consumptive loss is extremely problematic during times of drought and low-flow periods for the fourth most toxic river in the country. And since no study of climate change has been included, it is unclear how much worse this situation could become decades into the future as the realities of global warming are realized across the region.
- The only mitigation measure proposed in the permit is to install untested “Speece” cones (often referred to as “bubblers”) far downstream of Vogtle, just north of the Savannah Harbor, to inject more oxygen into the river. No mitigation measures are proposed elsewhere, especially closer to the facility where serious impacts to aquatic species are most likely to occur.
Additional written comments were accepted by EPD for another week after the hearing. Once again, our team filed extensive technical comments backed by two experts. Professional Engineer and cooling technology expert Bill Powers filed an intriguing report, documenting that two feasible, cost-effective technologies are available to substantially reduce water usage by the proposed two Toshiba-Westinghouse AP1000 reactors at Plant Vogtle: indirect wet-dry cooling and zero liquid discharge (ZLD) from the cooling system. With these technologies, water use could be reduced by at least 70% at a reasonable cost.
Dr. Shawn Young, a fisheries biologist with extensive knowledge of the Savannah River, documented the unacceptable negative impacts the increased withdrawals would have on aquatic species dependent on a healthy river and the deficiencies in the current draft permit. He mentioned that if this permit is approved, Plant Vogtle would be “one of the largest sources of negative environmental effects on aquatic resources of the middle Savannah River, as surface water withdrawals have inherent negative impacts on aquatic biota.” Dr. Young highlighted that the Savannah River is one of Georgia’s and South Carolina’s most popular fishing spots, generating significant state revenue that is extremely beneficial to rural communities and thus, negative impacts on fish populations can have significant negative impacts on the economy and social values of both states. The middle Savannah River, where Vogtle is located, is home to numerous fish populations, including the endangered Atlantic and Shortnose Sturgeon, rare sucker species such as Robust Redhorse and Brassy Jumprock, Striped Bass, American Shad, American Eel, Largemouth Bass, catfish, and other fish that includes prey species such as blueback herring.
What’s next? We now wait while EPD reviews and replies to the comments presented at the public hearing and submitted in written form (over 250 were filed). We remain hopeful that if a thorough, proper review is conducted, EPD will, at a minimum, deny the permit in its current form. Stay tuned!
Find all comments and supporting materials filed on behalf of SACE and SRK by SELC and the Turner Environmental Law Clinic below:
- March 7, 2014 comments and Exhibit A;
- May 8, 2014 oral comments from SACE’s Sara Barczak; and
- May 15, 2014 supplemental comments, Exhibit 1 (Bill Power’s report), Exhibit 2 (Dr. Shawn Young’s comments), Exhibits 3, 4 (the Union of Concerned Scientists’ new report, Power Failure) & 5 (EPD’s draft recommendation for the permit from July 2012).