ML19249F178
| ML19249F178 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/26/1973 |
| From: | Nash D US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19249F153 | List: |
| References | |
| NUDOCS 7910100588 | |
| Download: ML19249F178 (7) | |
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THREE MILE ISLAND NUCLEAR--DOCKET No. 50-289 SUPPLEMENTARY TESTIMONY ON WATER COSTS by Darrel A. Nash Contention 10 The extent to which the NEPA review concerning cost-benefit analysis and alternatives may not be complete in that the following point (s) have not been fully analyzed or included:
(c) The costs of water consumption Traditionally in the eastern U.S. there have been no charges for consumptive water use.
The Susquehanna River Basin, where the Three Mile Islcnd facility is located, is not an exception. Historically there has been no need for charges as an allocating mechanism for water because, except for brief periods, there has been a sufficient volume of flow to satisfy all users. Thus there is no direct way of obtaining water costs.
In the situation of normal supplies the cost should be quite low.
Costs can be imputed to a certain degree, such as by:
(1) the cost of supplying water, or (2) the value of the water in alternative uses, the so-called opportunity cost.
The concept of opportunity cost means that when a resource is used for one purpose its ' costs to society is the value which could have been produced if it were used for the next best use.
Generally speaking up to the present time the flow in the Susquehanna River Basin has been sufficient to meet all demands for consumptive use so that the value of the alternative use is low or zero.
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2 Thus, costs at the present time are reflected by the costs of supplying water which is included by the Applicant as a normal cost of operation.
The low flow levels are much more important in assessing demand for consumptive uses than is the mean flow. Various agencies are concerned with river flow in the basin and meeting future demand. The Susquehanna River Basin Commission was established nearly two years ago to make studies, develop plans, and review permit applications for water use.
The Commission is a result of a compact between the States of New Ycrk, Pennsylvania, Maryland and the Federal Government. The U.S. Army, Corps of Engineers, Baltimore District is concerned with facilities for water management in the Basin. Pennsylvania is responsible for issuing water use permits in the state and through its Department of Environmental Resources is also concerned with w ter uses and long range planning.
These organizations which have made substantial analyses of the River flow were consulted to make the following evaluation.
Although there is little runoff from Maryland into the Basin, the state has a vital interest in the river flow. The Susquehanna supplies some 85 percent of the fresh water into the upper Chesapeake Bay which preserves the ecological balance of the Bay.
Baltimore is also dependent upon the River for a substantial portion of its water supply.
Changing water use patterns in the Basin indicate that the future water supply and requirements should be anrlyzed from a short term and longer ter.n view.
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3-Short Term The consumptive use of approximately 15 million gallons per day for Unit 1 at Three Mile Island is classified by the Susquehanna River Basin Commiss'.on as a high volume use. At mean flow this is 0.1 percent of the River flow. However, at the 1964 minimum flow of 1,700 cfs this would utilize 1.3 percent of the flow. Although a flow of less than 2,000 cfs occurs _less than one percent of the time, low flow periods when they occur are likely to last for an extended period. The 1.3
.c cent of the use of the low flow by Three Mile Island has caused the Susquehanna River Basin Commission to be concerned about low flow augmentation.
The Applicants have not provided for low flow augmentation.
However, the U.S. Army Corps of Engineers is completing a storage facility upstream on the Raystown Branch of the Juniata River, a tributary of the Susquehanna. This dam is 120 miles upstream from Three Mile Island.
The facility is built at public expense to meet flood control and anti-cipated water dimands downstream so that the water cannot in any way be allocated to any one user. However, one method of estimating water cost for Three M,ile Island, Unit 1, is to attribute a portion of the cost of the Raystown dam to the Unit.
The facility on the Raystown Branch has a capacity to supply 300 million gpd for 40 days. Three Mile Island will consume 15 million gpd in the three cooling towers for Three Mile Island (Unit 1).
Thus, up to 5 percent per day of the Raystown storage may be needed to make up for consumptive water use of the Three Mile Island operation.
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. According to the U.S. Army Corps of Engineers, Baltimore District, construction costs of the Raystown facility if $69,400,000.
Operations and maintenance costs are quite low and can reasonably be ignored. This is a multipurpose facility although an important, if not the primary, purpose is for low flow augmentation.
It is intended for flood control and recreation as well. Eight million dollars of the cost is directly attributable to providing recreational facilities.
Thus a maximum of $61.4 million is attributable to flood control and low flow aupnentation. The individual cost of each of these uses is essentially inseparable. Thus a maximum of 5 percent or $3.07 million may be attributed to low flow augmentation as a result of Three Mile Island, Unit 1.
This is a cost of $3.75 per net kilowatt of capacity compared to construction cost of Unit 1, not inclading water of appro-ximately $450 per net kilowatt. Thus the short term cost, even if not borne by the Applicant, is not of great consequence.
Long Term Increasing uses of the River flow and plans now under way for future withdrawals has precipitated the need for long range planning for flow maintenance.
This will likely lead to water allocation and water charges after a period of time.
From the standpoint of water flow management, there are three types of uses in increasing order of concern, (1) use and return at the same point, (2) withdrawal, i.e. use and return at a downstream point, and (3) consumptive use.
The Susquehanna River Basin Co==ission is considering a Comprehensive Plan for the Basin. An important function of the Commission is in regard 14ii 26i
-S-to the management of water supply shortage emergencies.
It will establish priorities for use and the principal of user charges.
The guidelines the Susquehanna River Basin Commission is seeking to establish is that those who use the water must pay for it, either by providing storage or through direct cash payments.
It is expected that there will'be provisions for " grandfather rights," meaning that current users will not be subject to these provisions. Three Mile Island Unit I will probably not be subject to any charges unless additional r,uantities are used after charges are instituted.
No estimate is available on what amount or kind of water charger may be instituted.
Strictly for illustration, water charges by the Delaware River Basin Commission are given to show the dimensions of one possible system in the Susquehanna Basin. The Delaware Basin has water charges and legal entitlement. Their charges are $0.04 per thousand gallons. They also have grandfather clauses for uses before charges were instituted. At this rate, and i f all water used by Three Mile Island were subject to charges, this would amount to less thaa a half million dollars per year. However, the demand for consumptive water uses relative to supply 1s more favorable in the Susquehanna R.ver Basin than the Delaware River Basin which would indicate that lower user rates might be justified for the Susquehanna River Basin.
Even if charges are instituted, the full cost of water may not be reflected due to the opportunity costs as mentioned above.
If uses increase so that all requirements are not met, the opportunity costs
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. could be substantial.
The future needs for consumptive uses in the Basin are not well established.
It is helpful to point out problems and opportunities as various agencies view the situation. The Corps of Engineers foresees the fewest problems on future water availability. Generally the most significant problem is viewed in terms of proper water management.
By flood control and low flow augmentation they expect relatively few prob-lems for managing an adequate flow at the points of use through 1990. The Susquehanna River Basin Commission expresses less optimism.
It pointed out that the number of suitable sites for large storage facilities in the Basin is restricted. Acceptable sites in New York State are being opposed by local residents who see no benefit of the facilities to themselves. The Commission has surveyed potential users and found that there are current plans for consumptive use of an additional 120 million gpd by power plants by 1980.
This figure may be altered as plans are dropped or added. Baltimore has the op ion of requesting additional amounts if needed.
The Commonwealth of Pennsylvania, Department of Natural Resources has a " low flow criteria" for which they are seeking to establish a level.
This would establish some minimum flow where no further con-su=ptive use is permitted. On that basis, the percent of permitted withdrawal from the Basin would not be calculated from total flow, but only the flow in excess of the minimum flow criteria.
This would make the low flow more critical in terms of the flow to be allocated to consumptive uses.
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7-In su= nary, the cost of water at the Three Mile Island Generating Station for the near term is quite low. At most it is 5 percent of the cost wt ich the Corps of Engineers has borne to build the Raystown Bra.:h storage facility.
In the longer term, the Applicant may be subject to water use charges of a modest amount.
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