Eric Epstein, founder of the Rock the Capital, provided this question and answer document. This testimony relates to the York Haven Hydroelectric Project, and is included here in its entirety.
1) What are the consumptive and surface withdrawal parameters for York Haven?
York Haven does not consume or withdraw water as defined by SRBC.
2) What are the consumptive and surface withdrawal parameters for Three Mile Island Unit-1 when the plant was licensed to operate?
TMI Unit 1 is approved by SRBC to withdraw up to 122.8 million gallons per day (mgd) from the Susquehanna River and approved to consume up to 19.2 mgd.
3) What is the duration of TMI’s contract for water use with the SRBC?
The SRBC approvals were issued with expiration date of April 19, 2034, which coincides with the expiration of the US NRC operating license. The contract between SRBC and TMI for consumptive use mitigation water storage is effective for so long as they comply with the provisions of the contract.
4) What are the parameters of consumptive and surface withdrawal permits at Three Mile Island now that that the Nuclear Regulatory Commission has placed TMI into non-operating status?
The consumptive use and surface withdrawal approvals from SRBC have not changed yet as a result of the non-operating status. Commission staff is working with TMI operators to determine future operating parameters, and will modify the permits as appropriate.
5) What are the impacts on York Haven based Three Mile Island Unit 1’s new status?
SRBC has not been informed of any impacts of TMI’s new status on York Haven; see response to question #6 for specific information.
6) For example, how are York Hydro’s water level and temperatures impacted?
York Haven’s water level is primarily governed by natural river flow, the dam height, and York Haven’s generating schedule, so TMI’s change in status should not appreciably impact water level. The change in operating status at TMI has initially decreased the hot water discharged and will eventually eliminate the discharge of hot cooling water into Lake Frederic, so the local river temperature will likely decline slightly, to approach ambient river temperatures.
7) Has the MOU between the NRC and the SRBC been updated to reflect TMI’s new condition?
There is no MOU between NRC and SRBC. The two agencies have concurrent jurisdiction and coordinate accordingly.
8) Has this project also factored FirstEnergy’s proposal to move TMI-2 from a Possession Only License into DECON decommissioning mode?
Commission staff is unaware of any York Haven project impacts due to the change of status of TMI Unit 2’s license. The status of Unit 2 is immaterial for SRBC’s permits for Unit 1 or on York Haven’s operation.
9) What are the impacts on Lake Fredric’s water level and temperatures as a result of TMI’s reductions in consumptive and surface water?
See response to question #6.
10) What is the impact of this approval on the bog turtle project and shad ladder commitments?
No impact. Any condition of York Haven’s FERC license, including but not limited to the bog turtle project and shad ladder commitments, are enforced by FERC and incorporated by reference into SRBC’s Comprehensive Plan. York Haven Hydroelectric Station was incorporated into Comprehensive Plan in 2008. Fish Passage Facilities at York Haven were also incorporated into Comprehensive Plan in 2008. York Haven FERC license and conditions are not explicitly incorporated into Comprehensive Plan.
11) Will the fishway project continue after 2020?
SRBC fully expects that York Haven will comply with the fish ladder project requirement and all other FERC license requirements in 2020 and beyond. Any deviations would need to be approved by FERC and the intervening agencies such as the U.S. Fish and Wildlife Service, PA Fish and Boat Commission, and SRBC.
12) Will there be any changes in Cube Hydro Partners commitment, funding or operations of York Haven Project recreation facilities at the Historic Canal Lock, East Shore Boat Launch, Goosehorn Island Picnic Area, Shelley Island Recreation Area, Goodling Island Picnic Area, Beshore Island Recreation Area, Battery Island Recreation Area, Cly Shore recreational lot sites, York Haven Power Plant Recreation Area, and a Canoe Portage trail. These facilities are owned and operated by York Haven Power.
SRBC’s approval does not pertain to recreation commitments . York Haven FERC license and conditions are not explicitly incorporated into Comprehensive Plan.
13) What provisions have York Haven taken now that TMI has reduced its safety and security footprint?
Unknown. SRBC does not request or consider safety and security needs as part of its review and approval of hydroelectric, consumptive use or surface water withdrawal projects.