Wednesday, April 7, 2021

Response to Questions submitted March 12, 2021

                    Good morning, Eric.

This is in response to several of your questions regarding Exelon Generation Company, LLC’s (Exelon’s) Three Mile Island Generating Station, Units 1 and 2 (TMI-1 and 2 ) submitted on March 12, 2021.

Question 1: Provide the amount of water TMI can withdraw daily, and how much they pay for consumptive and surface water at TMI-1 and TMI-2.
As I stated previously, the consumptive use, surface withdrawal, and groundwater withdrawal approvals from SRBC have not changed yet as a result of the non-operating status. The docket approval for TMI-1 dates from 2011, and is attached for your review. SRBC does not have a docket approval for TMI-2.

The approved quantities at TMI-1 are:
Surface water withdrawal – up to 122.800 million gallons per day;
Groundwater withdrawal – 0.225 million gallons per day (as a 30-day average) from Wells A, B, and C;
Consumptive use – 19.200 million gallons per day (peak day).

The SRBC has no charges related to surface water withdrawals for any approved project. The project does not pay a consumptive use fee to the SRBC. The consumptive use is mitigated predominantly by releases of water stored in Cowanesque Reservoir during low flow periods, under an approved agreement (see Docket Section 7, no. 5).

Question 2:  Ask the NRC for the precise amount of water each reactor will need for decommissioning purposes, and inventorize the amount of water not used since TMI-1 no longer conveys heat from the reactor core to the steam turbine and there is no longer steam cycle heat transfers.

The SRBC has no information from the NRC at this time concerning the amount of water required for decommissioning.

The attached a spreadsheet shows SRBC’s data concerning the amount of recent water use at TMI-1. As you are aware, TMI-1 was taken offline and ceased operating for the purpose of generating electric power on September 20, 2019. The data brackets the time when operations ceased, containing reported daily water withdrawals from all sources and consumptive use from September 1, 2019 through December 31, 2020.

SRBC staff have not specific information at this time to answer your other questions regarding disposal of any radioactive wastewater. The SRBC will continue to coordinate with agencies of its member jurisdictions about all of the issues related to this project. 

Exelon staff indicated water withdrawal and consumptive use quantities are expected to continue to exceed Commission regulatory thresholds, but at a much lower magnitude due to cessation of power generation. As such, and recognizing the change in operations, Commission staff will review the water withdrawal and consumptive use demands, from all sources, based on the Facility’s reasonable and foreseeable need to adequately address ongoing decommissioning activities. Commission staff anticipate that this review will be done as part of the groundwater well renewal applications, required by May 26, 2021.

Thank you again for your patience as we work to obtain clarity on the key water issues related to decommissioning.

Best regards,

Paula Ballaron, P.G.
Manager, Policy Implementation & Outreach
Susquehanna River Basin Commission
4423 North Front Street
Harrisburg,  Pennsylvania 17110-1788
Office:717-238-0423 Ext - 1222
Mobile:  717-215-0455
Your River ~ Our Mission 

 Re: Before the SRBC, (Testimony of Eric J. Epstein, December 11, 2020)


          These questions were resubmitted at today's public hearing.
In our opinion, the initial responses were general  and vague.
I wrote the questions in the hope of providing clarity, and to
make sure you got the questions free from technical interference.

         In addition, to requesting more specific responses to the
January 27, 2021 requests, I also asked the SRBC  to:

1) Provide the amount of water TMI can withdraw daily, 
and how much they pay for consumptive and surface water
at TMI-1 and TMI-2;

2) Ask the NRC for the precise amount of water each reactor 
will need for  decommissioning purposes, and inventorize 
the amount of water not used since TMI-1  no longer coneys
heat from the reactor core to the steam turbine and there 
is no longer steam cycle heat transfers; 

3) Requests from the DEP and the NRC for TMI-1's and
TMI-2's plan(s) to dispose of radioactive water created 
by the decommissioning processes; and,

4) Identify CWA obligations as it pertains to what entity actually 
owns the water rights at TMI.

         Gene and Paula did contact me during the meeting, and Gene
reached out after the meeting. Unfortuantley, I've been in zoom
meetings all afternoon. I will return to the office on Monday.

Have a great weekend!

Eric Epstein

TMI Reporting Data.XLSX

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