ML18283B597
| ML18283B597 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/10/2018 |
| From: | Eaby T D Susquehanna River Basin Commission |
| To: | Ma M S Office of Administration |
| References | |
| 83FR45692 00004, NRC-2018-0130 | |
| Download: ML18283B597 (4) | |
Text
PUBLIC SUBMISSION As of: 10/10/18 3:53 PM Received:
October 10, 2018 Status: Pending_Post Tracking No.
1k2-95wj-phsl Comments Due:
October 10, 2018
Submission Type:
Web Docket: NRC-2018-0130Exelon Generation Company, LLC; Peach Bottom Atomic Power Station Units 2 and 3 Comment On:
NRC-2018-0130-0003Exelon Generation Company, LLC; Peach Bottom Atomic Power Station, Units 2 and 3Document:
NRC-2018-0130-DRAFT-0005 Comment on FR Doc # 2018-19462 Submitter InformationName: Todd EabyAddress: Susquehanna River Basin Commission
4423 North Front Street
Harrisburg, PA, 17110Email: teaby@srbc.net General Comment Docket ID NRC-2018-0130: Scoping Comments of the Susquehanna River Basin Commission regarding the Subsequent License Renewal of the Operating Licenses for Peach Bottom Atomic Power St ation, Units 2 and 3 are provided with the attached file.
Attachments SRBC Comments Regarding Docket ID NRC-2018-0130 S ubsequent License Renewal Peach Bottom Atomic Power Station
October 10, 2018
Ms. May Ma, Director, Program Management, Announcements, and Editing Branch Office of Administration Mailstop: TWFN-7A6OM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Re: Docket ID NRC-2018-0130: Scoping Comments of the Susquehanna River Basin Commission regarding the Subsequent License Renewal of the Operating Licenses for Peach Bottom Atomic Power Station, Units 2 and 3
Dear Ms. Ma:
The Susquehanna River Basin Commission (SRBC) appreciates the opportunity to offer comments in response to the U.S. Nuclear Regulatory Commission's (NRC's) request for participation in the scoping process for the Subsequent License Renewal of the operating licenses for the Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom), in Drumore Township, Lancaster County, and Peach Bottom Township, York County, Pennsylvania.
The SRBC is a federal-interstate compact commission, created in 1971 by the passage of concurrent legislation by the General Assemblies of the three basin states, Pennsylvania, New York, and Maryland, and by the United States Congress. Under the terms of the Susquehanna River Basin Compact (Compact), SRBC is vested with very broad authority in the areas of water resources planning, management, conservation, development, utilization, and allocation within the jurisdictional area of the Susquehanna River Basin.
Concurrent with NRC's jurisdiction, SRBC regulates water withdrawals and the consumptive use of water pursuant to Article 3, Section 3.10, of the Compact, P.L.91-575, 84 Stat. 1509 et seq., and 18 CFR §§ 806.4 and 806.5. Furthermore, Peach Bottom is included in the SRBC's "Comprehensive Plan for the Water Resources of the Susquehanna River Basin" (Comprehensive Plan) as mandated by Article 14 of the Compact. The project has a significant effect on the Comprehensive Plan and could have an adverse or adverse cumulative effect on the water resources of the basin, if not properly regulated by SRBC. SRBC authorizes withdrawals and consumptive uses in accordance with its Comprehensive Plan, adopted on December 4, 2008, and as amended from time to time. See also 18 CFR §§ 806.4, 806.22, and 806.23.
Ms. May Ma October 10, 2018
Exelon Generation Company, LLC (Exelon), owner of Peach Bottom, currently has Docket No. 20061209-1 (Docket) with the SRBC approving a consumptive use of water of up to 49.000 million gallons per day (mgd) (peak day) and a surface water withdrawal of up to 2,363.620 mgd from the Susquehanna River for electric power generation. The Docket has an expiration date of July 3, 2034.
SCOPING COMMENTS Consumptive Use - Consumptive use is defined by SRBC as the loss of water withdrawn from the basin through a process by which the water is not returned to the waters of the basin undiminished in quantity, including but not limited to evaporation, transpiration by vegetation, incorporation in products during their manufacture, injection into a subsurface formation and diversion out of the basin. Pursuant to 18 CFR § 806.22, projects that consumptively use water must mitigate for the loss of water to the basin.
Peach Bottom currently satisfies SRBC's consumptive use mitigation requirement via releases from the Conowingo Hydroelectric Generating Station (Conowingo), also owned by Exelon. Conowingo has an estimated 800 cubic feet per second (cfs) of unmeasured leakage through the station. During low flow conditions, Exelon typically requests a waiver from the Federal Energy Regulatory Commission (FERC) to apply leakage toward Conowingo's minimum release requirements and help maintain Conowingo Pond levels. To provide consumptive use mitigation for Peach Bottom, Exelon reduces the Conowingo waiver request amount by 220 cfs during low flow conditions in the months of August, September, and October. However, Conowingo is presently undergoing FERC relicensing and future license conditions may impact the viability of Peach Bottom's current method of consumptive use mitigation.
SRBC, in collaboration with partner agencies, power companies, and water utilities, developed a Conowingo Pond Management Plan in 2006. The plan was formulated based on modeling of numerous operational alternatives aimed at balancing Conowingo Pond water demands, minimum flows, and reservoir levels, particularly during droughts. The selected alternative entails a credit for Conowingo leakage of up to 800 cfs when streamflow at the Susquehanna River at the Marietta, Pennsylvania, gage declines to within 1,000 cfs of Conowingo's FERC license minimum flow requirement. The plan also contains a series of recommended actions including ongoing evaluations of water use operations and consumptive uses affecting Conowingo Pond. This includes Peach Bottom operations and consumptive use, thus warranting that the Conowingo Pond Management Plan be carefully considered during the scoping process and preparation of the environmental impact statement.
Changes to operation and permitting of Peach Bottom, including but not limited to changes in mitigation and approval term, need to be included in the SRBC Comprehensive Plan. Additionally, Peach Bottom is only one of several water users operating within the Conowingo Pond, and a portion of SRBC review needs to consider any potential adverse cumulative effects on other users. Therefore, application for renewal of the Docket with the SRBC will need to be submitted by Exelon requesting approval of all withdrawals and consumptive use, any changes in water use and extension of the term from the current expiration date of July 3, 2034, to a term consistent with the NRC Subsequent License Renewal Term. 436412.1 Ms. May Ma October 10, 2018
The only source of water currently approved by SRBC by Peach Bottom is withdrawal from the Susquehanna River. SRBC staff attended the September 25, 2018, Subsequent License Renewal Scoping Meeting for Peach Bottom Units 1 and 2, where it was mentioned by NRC staff that Peach Bottom has wells that are used. Peach Bottom currently has no approval from the SRBC for groundwater withdrawal. The NRC should clearly identify all withdrawals including all groundwater sources, purpose and use of water from each withdrawal, and should evaluate if SRBC approval for the withdrawal or use of water from those sources is required.
SRBC appreciates the opportunity to provide scoping comments on Peach Bottom's application. If you have any questions regarding the above, please feel free to contact me at (717) 238-0423, extension 1234.
Sincerely,
Todd D. Eaby, P.G.
Manager, Project Review
436412.1