Water 2017 Information Request
CDP
Exelon Corporation
Module: Introduction
Page: W0. Introduction
W0.1
Introduction
Please give a general description and introduction to your organization
Exelon Corporation (NYSE: EXC), now including the Pepco Holdings utilities, is the nation’s leading competitive energy provider, with 2016 revenues of
approximately $31.4 billion. Headquartered in Chicago, Exelon does business in 48 states, the District of Columbia and Canada. Exelon is one of the largest
competitive U.S. power generators, with more than 32,700 megawatts of owned capacity comprising one of the nation’s cleanest and lowest-cost power generation
fleets. The company’s Constellation business unit provides energy products and services to approximately 2 million residential, public sector and business
customers, including more than two-thirds of the Fortune 100. Exelon’s six utilities deliver electricity and natural gas to approximately 10 million customers in
Delaware, the District of Columbia, Illinois, Maryland, New Jersey and Pennsylvania through its Atlantic City Electric, BGE, ComEd, Delmarva Power, PECO and
Pepco subsidiaries. Exelon is mindful that climate change may result in increased volatility in weather and demand, and believes that a reliable and resilient electric
grid requires fuel diversity and continued transmission and distribution investment. The company is making substantial investments to ensure that the electric grid is
more efficient and resilient for customers. Access to water is essential to Exelon’s production of energy from low-carbon generation and our other fossil generating
plants. We use approximately 36.9 billion gallons of water each day, and greater than 98% of it is returned to its source. We understand the importance of being
responsible stewards of this critical resource; water drives our hydroelectric facilities and cools our nuclear and fossil fuel steam generating power plants. While
access to affordable, reliable and adequate water supplies is imperative to our ability to deliver clean, low-cost energy, we recognize that water is a shared resource,
which supports the people, businesses and wildlife in the areas where we operate.
In 2013, we implemented a Water Resources Management Policy to help us continuously improve our water management practices. In 2014, we implemented our
Biodiversity and Habitat Policy, to help guide our efforts in activities ranging from avian protection to integrated vegetation management. We also instituted our
Greenhouse Gas Policy. In response to the effects of climate change we are monitoring watersheds to understand how these changes are impacting the water
resources we rely upon. We are developing tools to predict near and long-term fluctuations of our water resources. The ability to predict the effects of climate
change and other factors on long-term water availability at the local level has limitations and we are working to improve our ability to understand the impacts of
increased population density and upstream use. The regional nature of water resources necessitates strategically managing water use locally. In 2016, Exelon
contributed over $3.2 million in support of 349 watershed improvement, environmental education and sustainability initiatives.
Certain of the matters discussed in this survey are forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that are
subject to risks and uncertainties. The factors that could cause actual results to differ materially from the forward-looking statements include those factors discussed
herein, including those factors with respect to business strategy, potential risks and opportunities and financial statements or estimations associated with
management decisions and/or analysis or other factors discussed in filings with the SEC by Exelon and those of its subsidiaries that are registrants under the federal
securities laws (hereinafter collectively referred to as “Exelon”). Readers are cautioned not to place undue reliance on these forward-looking statements, which apply
only as of the date of this survey and to refer to filings made by Exelon with the U.S. Securities and Exchange Commission for further information. Exelon does not
undertake any obligation to publicly release any revision to its forward-looking statements to reflect events or circumstances after the date of this survey.
W0.2
Reporting year
Please state the start and end date of the year for which you are reporting data
Period for which data is reported
Fri 01 Jan 2016 - Sat 31 Dec 2016
W0.3
Reporting boundary
Please indicate the category that describes the reporting boundary for companies, entities, or groups for which water-related impacts are reported
Other: Companies, entities or groups that are owned and over which operational control is exercised.
W0.4
Exclusions
Are there any geographies, facilities or types of water inputs/outputs within this boundary which are not included in your disclosure?
Yes
W0.4a
Exclusions
Please report the exclusions in the following table
Exclusion
1. Ft. Calhoun, NE nuclear
power generating facility.
2. Upstream natural gas
exploration and production.
Please explain why you have made the exclusion
1. We have no ownership in the Fort Calhoun facility; we were contracted only as operators for the facility which ceased
operations on October 24, 2016. We report on facilities over which we have ownership and operational control.
2. Exelon sold its minority equity share in upstream natural gas in December 2016. Our limited minority share status limited
our ability to impact operations during our ownership.
Further Information
Exelon Corporation Sustainability Report: http://www.exeloncorp.com/sustainability/interactive-csr
Module: Current State
Page: W1. Context
W1.1
Please rate the importance (current and future) of water quality and water quantity to the success of your organization
Water quality and
quantity
Direct use
importance
rating
Indirect
use
importance
rating
Please explain
Water quality and
quantity
Direct use
importance
rating
Indirect
use
importance
rating
Sufficient amounts of
good quality freshwater
available for use
Vital for
operations
Neutral
Sufficient amounts of
recycled, brackish and/or
produced water available
for use
Vital for
operations
Neutral
Please explain
Access to affordable, reliable and adequate water supplies is imperative to the success of our
business; direct water access drives our hydroelectric facilities and cools our nuclear and fossil fuel
steam power plants. While water quality is a consideration, access to sufficient volume is more of a
concern. We use approximately 36.9 billion gallons of water each day, and greater than 98% of the
water is returned to its source. Water supply to support our direct operations has not been a
significant challenge to date; however, we continue to assess our risks, evaluate our impacts and
closely monitor our watersheds on an ongoing basis. We engage the communities in our watersheds’
improvement, environmental education and sustainability initiatives. Our supply chain managers use
a list of environmental criteria to evaluate products during the procurement process to understand
indirect water use and we provide sustainability consulting through our Constellation business unit.
Our nuclear and fossil plants located in Chesapeake Bay and Delaware River watersheds, as well as
Barnegat Bay depend directly on brackish water for cooling. Our Limerick nuclear plant collaborated
with regulatory agencies and environmental stakeholders to develop a flow augmentation alternative
that allows upriver mine water to supplement flow in the Schuylkill River. Adequate, affordable and
reliable water supplies to support our indirect operations have not been a challenge to date; however,
we continue to assess our risks, evaluate our impacts and closely monitor our watersheds on an
ongoing (in some cases hourly) basis. We engage the communities in our watersheds’ improvement,
environmental education and sustainability initiatives. Our supply chain managers use a list of
environmental criteria to evaluate products during the procurement process to understand indirect
water use and we provide sustainability consulting through our Constellation business unit.
W1.2
For your total operations, please detail which of the following water aspects are regularly measured and monitored and provide an explanation as to why
or why not
Water aspect
% of
sites/facilities/operations
Please explain
Water aspect
Water withdrawals- total volumes
Water withdrawals- volume by sources
Water discharges- total volumes
Water discharges- volume by
destination
Water discharges- volume by treatment
method
Water discharge quality data- quality by
standard effluent parameters
Water consumption- total volume
Facilities providing fully-functioning
WASH services for all workers
% of
sites/facilities/operations
Please explain
76-100
76-100
76-100
Company policy and requirement of environmental permits
Company policy and requirement of environmental permits
Company policy and requirement of environmental permits
76-100
Company policy and requirement of some environmental permits
76-100
Requirement of environmental permits
76-100
Requirement of environmental permits
76-100
Company policy and requirement of environmental permits
This is a requirement of local health departments, county building codes and company
business continuity health initiatives – we comply with all of these standards.
76-100
W1.2a
Water withdrawals: for the reporting year, please provide total water withdrawal data by source, across your operations
Source
Fresh surface water
Brackish surface
water/seawater
Rainwater
Groundwater -
Quantity
(megaliters/year)
How does total
water withdrawals
for this source
compare to the
last reporting
year?
34772743.92
About the same
7215269.37
About the same
0.00
573029.07
Not applicable
About the same
Comment
Included in fresh water withdrawal in our watershed by watershed accounting
Source
renewable
Groundwater - nonrenewable
Produced/process
water
Municipal supply
Wastewater from
another organization
Total
Quantity
(megaliters/year)
How does total
water withdrawals
for this source
compare to the
last reporting
year?
0.00
Not applicable
Comment
8370760.33
About the same
5070.02
About the same
NOT typically included in surface water withdrawals in either fresh or brackish categories in
our watershed by watershed accounting. We typically account for recycled water under Total
Usage. Our overall total water usage remains the same; produced water reported for 2016
increased due to a correction in a calculation error for a facility which resulted in a 13.7%
underestimation of produced water for 2015.
Included in fresh water withdrawal in our watershed by watershed accounting
0.00
Not applicable
We do not use wastewater from another organization
50936872.72
About the same
W1.2b
Water discharges: for the reporting year, please provide total water discharge data by destination, across your operations
Destination
Fresh surface water
Brackish surface water/seawater
Groundwater
Municipal/industrial wastewater treatment
Quantity
(megaliters/year)
35050547.88
6627961.37
476.52
17.19
How does total water discharged
to this destination compare to the
last reporting year?
About the same
About the same
About the same
About the same
Comment
Quantity
(megaliters/year)
Destination
How does total water discharged
to this destination compare to the
last reporting year?
Comment
plant
Wastewater for another organization
0.00
Not applicable
Total
41679002.96
About the same
We do not use wastewater from another
organization
W1.2c
Water consumption: for the reporting year, please provide total water consumption data, across your operations
Consumption
(megaliters/year)
887109.43
How does this
consumption
figure compare to
the last reporting
year?
About the same
Comment
In 2016, we had about the same generation and technology, so water usage is about the same. We do not account for
the "water usage displacement" of our growing renewables fleet of wind and universal solar, or our fuel cell Bloom
boxes, LEED buildings, distributed generation or microgrids. All of these growing business lines, including
Constellation's consulting in water usage efficiency, result in less water usage for power. Exelon Generation is the12th
largest wind producer in the country with approximately 1,500 megawatts of wind generation in 11 states. Exelon
Generation is the nation’s largest producer of zero-carbon electricity, with a capacity of more than 23,000 megawatts of
zero-emissions generation.
W1.3
Do you request your suppliers to report on their water use, risks and/or management?
Yes
W1.3a
Please provide the proportion of suppliers you request to report on their water use, risks and/or management and the proportion of your procurement
spend this represents
Proportion
Total
of
procurement
suppliers
spend %
%
1-25
1-25
Rationale for this coverage
Our supply chain managers use a list of environmental criteria to evaluate products during the procurement process. Exelon
Supply Management incorporates environmental performance requirements and participation in voluntary pollution reduction
programs into the supply procurement process, including measures to address supplier water use. This has encouraged dialog
between suppliers and category managers leading to recommendation and procurement of some reduced water intense products.
We develop risk analyses of our suppliers in order to manage our own risks. Exelon is a member of the Electric Utility Sustainable
Supply Chain Alliance (www.euissca.org) which is developing voluntary procurement standards and promoting supply chain
environmental management practices, including environmental compliance, GHG emissions and water use. Finally, sustainability
is our business: our Constellation business unit publishes Seven Steps to Setting Sustainability Goals for Your Company, to
educate customers on how to set their own sustainability goals and to offer our sustainability services backed by our unique
expertise in energy and water efficiency.
W1.3b
Please choose the option that best explains why you do not request your suppliers to report on their water use, risks and/or management
Primary reason
Please explain
W1.4
Has your organization experienced any detrimental impacts related to water in the reporting year?
No
W1.4a
Please describe the detrimental impacts experienced by your organization related to water in the reporting year
Country
River basin
Impact driver
Impact
Description
of impact
Length of impact
Overall
financial
impact
Response
strategy
Description of
response
strategy
W1.4b
Please choose the option below that best explains why you do not know if your organization experienced any detrimental impacts related to water in the
reporting year and any plans you have to investigate this in the future
Primary reason
Future plans
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Module: Risk Assessment
Page: W2. Procedures and Requirements
W2.1
Does your organization undertake a water-related risk assessment?
Water risks are assessed
W2.2
Please select the options that best describe your procedures with regard to assessing water risks
Risk assessment
procedure
Comprehensive
company-wide risk
assessment
Coverage
Scale
Direct
operations and
supply chain
All
facilities
Please explain
Exelon has a formal program established for identifying, assessing, and managing risks as part of its
overall management model. Water-related risks at the local facility/watershed level are communicated
internally per the corporate policy for planning and risk abatement on the corporate level. Our Risk
Management Program supports: governance and oversight for risk management; identification,
Risk assessment
procedure
Coverage
Scale
Please explain
measurement, and prioritization of significant risks across Exelon on a periodic basis; management of
risks; communication of risk information to senior management and the board of directors; and evaluation
of compliance with risk policy and the effectiveness of the policy. Annual objectives and targets are
established in compliance with our certified ISO 14001 EMS for addressing environmental risks.
Operating companies, business units, and support groups are responsible for establishing their own risk
policies that satisfy the 2.1, and guiding principles of the Exelon Risk Policy (RK-AC-01).
W2.3
Please state how frequently you undertake water risk assessments, at what geographical scale and how far into the future you consider risks for each
assessment
Frequency
Geographic
scale
How far into the
future are risks
considered?
Six-monthly or
more frequently
Country
3 to 6 years
Six-monthly or
more frequently
River basin
Up to 1 year
Sporadically not
defined
River basin
>6 years
Annually
Country
Up to 1 year
Comment
Operating companies, business units, and support groups provide a Risk Inventory to the Exelon Chief
Risk Officer on a quarterly basis. Operating companies review their risk programs annually – evaluating
compliance with policy and effectiveness at satisfying the goals and guiding principles of the Exelon Risk
Management Program as identified in the Exelon Risk Policy (RK-AC-01).
Water supply data is managed in hourly increments with thermal models that use real-time data gathered
by telemetry in the watershed. The true value of the thermal models is their ability to evaluate different
weather scenarios and operational responses on water discharges. Our Drought Task Force looks ahead
from 3 days (weather forecast) to the seasonal climate forecast. Operationally, our thermal models update
12 times per day, incorporating approximately 30,000 hourly data points.
Our pilot hydrologic study linking potential climate impacts to a hydrologic model was undertaken for a
timeframe out to 2040.
The WRI Aqueduct global water risk mapping tool presents a composite water risk assessment of the
United States as an aggregated measure of 12 global water stress indicators weighted according to use
factors for the power industry, including water quantity and quality, as well as regulatory and reputational
Frequency
Six-monthly or
more frequently
Geographic
scale
River basin
How far into the
future are risks
considered?
Up to 1 year
Comment
risks. The risk analysis is based on historic trends over the past half-century and does not currently
consider forward-looking modelling of climate change effects.
Operationally, our thermal models update 12 times per day, incorporating approximately 30,000 hourly
data points from plant operating data, watershed telemetry and weather forecasts.
W2.4
Have you evaluated how water risks could affect the success (viability, constraints) of your organization's growth strategy?
Yes, evaluated over the next 10 years
W2.4a
Please explain how your organization evaluated the effects of water risks on the success (viability, constraints) of your organization's growth strategy?
Assessing the future of site-specific opportunities and risks is part of our internal environmental review and due diligence process for mergers and acquisitions as
well as organic growth. We are developing tools to predict near and long-term (decades) fluctuations of national water resources, including impacts linked to climatic
changes, increased population density and upstream use. We are making investments in renewable generation and energy/water efficiency measures and smart
usage awards. We are seeking growth opportunities related to water supply as part of our corporate strategy for pursuing sustainable energy solutions. Each of our
utilities and our Nuclear fleet has undertaken a flood risk analysis and is in the process of mitigation investment strategies. After evaluating water constraints, we
decided on air-cooled condensers for new generation assets in Texas. In 2016, our utilities invested $5.5 billion as part of a project to invest $25 billion from 2016 to
2020 in infrastructure, smart grid technology and other improvements to ensure stability of its electric grid.
W2.4b
What is the main reason for not having evaluated how water risks could affect the success (viability, constraints) of your organization's growth strategy,
and are there any plans in place to do so in the future?
Main reason
Current plans
Timeframe until evaluation
Comment
W2.5
Please state the methods used to assess water risks
Method
Internal
company
knowledge
Please explain how these methods are used in your risk assessment
In order to identify locations of our U.S. generation fleet with regard to water stress regions we used the World Resources Institute (WRI)
AqueDuct tool. The Executive Committee has established a Drought Monitoring Task Force that spans various business units. The Drought
Task Force recommends regulatory, operational, and technical solutions, and points out other regions of concern and potential impacts. In
order to address changing waterbody conditions due to climate change challenges, Exelon is installing monitoring systems in river bodies with
telemetry to increase data availability, trending and station response times. The Daily River Report based on our plant thermal modelling
telemetry of upstream river stage and temperature is circulated internally on a daily basis. Our thermal models update 12 times per day,
incorporating approximately 30,000 hourly data points. As part of our strategy to further assess water risk, Exelon completed a
hydrology/climate modelling study for our Braidwood facility in 2013. Exelon is continuing to pursue cutting-edge research with pre-eminent
researchers in an effort to better understand potential climate and water impacts and to help push the current limits of the state of art
modelling, by accessing both public and private institutions. Our pilot hydrologic study linked climate change impacts to a local hydrologic
model. The scenarios were run from retro-fitting of model outputs - out to a timeframe of 2040.
W2.6
Which of the following contextual issues are always factored into your organization's water risk assessments?
Issues
Choose
option
Current water availability and quality
parameters at a local level
Relevant,
included
Current water regulatory frameworks
and tariffs at a local level
Relevant,
included
Current stakeholder conflicts
concerning water resources at a local
level
Relevant,
included
Current implications of water on your
key commodities/raw materials
Relevant,
included
Current status of ecosystems and
habitats at a local level
Relevant,
included
Current river basin management plans
Relevant,
included
Please explain
Water drives our hydroelectric facilities and cools our nuclear and fossil fuel steam generating power
plants. Water supply risk data is managed in hourly increments with thermal models that use real-time
data gathered by telemetry in the watershed. Operationally, our thermal models updates 12 times per
day, incorporating approximately 30,000 hourly data points. The true value of the thermal models is their
ability to evaluate different weather scenarios and operational responses. Our Summer Readiness
Assessments evaluate potential issues such as drought risk. When a drought risk is identified, Exelon
Generation activates a Drought Monitoring Task Force that reports to the Executive Committee; this
group spans various business units and reports on an assessment of current drought conditions, the
impacts of the drought both historical and potential. Our Drought Task Force looks ahead from 3 days
(weather forecast) to the seasonal climate forecast. The Drought Task Force recommends regulatory,
operational, and technical solutions, identifies and assesses other regions of concern and potential
impacts, and reports on ongoing work and next steps.
Our business depends on reliable, affordable and adequate water supplies. We engage and contribute
our expertise and knowledge base at the local, state and federal levels in the legislative and regulatory
process. Exelon’s Water Resource Management Policy requires that all operations comply with
applicable environmental laws and regulations, and that voluntary commitments are fulfilled. Regulatory
compliance is an environmental policy requirement and corporate metric for all business units.
Our ISO 14001 EMS mandates that we understand, review and address stakeholder concerns. As part of
the FERC relicensing process for Conowingo and Muddy Run projects, for example, Exelon Power has
been involved in an extensive stakeholder engagement process to identify and develop proposed
responses to stakeholder issues. We regularly attend environmental fora and presentations provided by
a wide range of stakeholders, and our corporate and business unit communications maintain a dialog in
various media.
Exelon is a member of the Electric Utility Sustainable Supply Chain Alliance (www.euissca.org) which is
developing voluntary procurement standards and promoting supply chain environmental management
practices, including environmental compliance, GHG emissions and water use. These best management
procurement practices have been implemented at Exelon voluntarily, with the expectation that our
suppliers will lessen their environmental impacts, including those related to water use.
We have a formal process for assessing ecosystem impact risks of our development investments, in the
earliest phases of planning. Our operating companies remain up to date on local endangered species
and habitat issues as part of their basic compliance obligations; but moreover as part of the corporate
Biodiversity and Habitat Policy (EN-AC-4) and stewardship. Our utility operations Avian Protection plans
inform daily activities on local species at risk. Local aquatic habitat risks are assessed through 316(a)
and (b) studies at plants.
Exelon has dockets with both the Susquehanna River and Delaware River Basin Commissions. Our
Limerick power station has an emergency mine water release agreement with the Delaware River Basin
Commission for drought conditions. Merrill Creek Reservoir, of which Exelon is an owner, provides flow
Issues
Choose
option
Current access to fully-functioning
WASH services for all employees
Relevant,
included
Estimates of future changes in water
availability at a local level
Relevant,
included
Estimates of future potential regulatory
changes at a local level
Relevant,
included
Estimates of future potential
stakeholder conflicts at a local level
Relevant,
included
Estimates of future implications of
water on your key commodities/raw
materials
Relevant,
included
Estimates of future potential changes
Relevant,
Please explain
augmentation to the Delaware River watershed and subsequently Exelon's facilities during drought
emergencies declared by the Delaware River Basin Commission.
These are basic requirements for Exelon’s internal company business continuity health initiatives, as well
as all US facilities according to health department regulations, building codes, and EPA regulations for
water supplies.
Our Summer Readiness Assessments evaluate potential issues such as drought risk. Exelon Generation
has established a Drought Monitoring Task Force that reports to the Executive Committee; this group
spans various business units and reports on an assessment of current drought conditions, the impacts of
the drought both historical and potential. Our Drought Task Force looks ahead from 3 days (weather
forecast) to the seasonal climate forecast. The Drought Task Force recommends regulatory, operational,
and technical solutions, identifies and assesses other regions of concern and potential impacts, and
reports on ongoing work and next steps. Exelon has joined the DOE Partnership for Energy Sector
Climate Resilience in order to better understand the impacts of climate change on our systems, and to
improve our resilience to climate change. Water use is a key challenge for the future; with changing
weather patterns and increases in competing water uses, the need for effective water management will
continue to grow. Increases in upstream use intensity through development and population growth could
impact water availability. We have modelled future scenarios of population growth and agricultural usage
at Quad Cities (Mississippi River) and Braidwood (Kankakee River) facilities, and use WRI’s AqueDuct
national risk map nationally.
For instance: certain of our facilities with once-through cooling water systems may be subject to
additional regulatory requirements as a result of the Clean Water Act (CWA) 316(b) regulations that
require them to apply Best Technology Available(BTA) to reduce effects of plant withdrawals on aquatic
biodiversity. We are evaluating available BTA alternatives and/or other regulatory compliance initiatives
that may be needed to comply with current regulations.
Our Water Resources Management Policy mandates that we engage local and other relevant
stakeholders when addressing water issues including those related to operational changes, development
of strategic plans, or public policy advocacy. Water use is a strategic issue for the future; with changing
weather patterns and increases in competing water uses, the need for effective water management will
continue to grow. Accordingly, we are committed to the long-term sustainability of water resources and
engagement at the local, state and federal levels.
Exelon is a member of the Electric Utility Sustainable Supply Chain Alliance (www.euissca.org) which is
developing voluntary procurement standards and promoting supply chain environmental management
practices, including environmental compliance, GHG emissions and water use. These best management
procurement practices have been implemented at Exelon voluntarily, with the expectation that our
suppliers will lessen their environmental impacts, including those related to water use.
Our business units perform significant aspects risk assessments annually; potential ecosystem changes,
Issues
in the status of ecosystems and
habitats at a local level
Choose
option
included
Scenario analysis of availability of
sufficient quantity and quality of water
relevant for your operations at a local
level
Relevant,
included
Scenario analysis of regulatory and/or
tariff changes at a local level
Relevant,
included
Scenario analysis of stakeholder
conflicts concerning water resources at
a local level
Relevant,
included
Scenario analysis of implications of
water on your key commodities/raw
materials
Relevant,
included
Scenario analysis of potential changes
in the status of ecosystems and
Relevant,
included
Please explain
concerns and issues that may pose impact risk would be communicated to management through
implementation of our EMS (ISO 14001) with appropriate responses required. Our Water Resources
Management Policy identifies key issues we are to be addressed including: ensuring adequate and
economical water supplies, enhancing water quality, preserving and restoring biodiversity, and
maintaining quality community recreational areas. In response to the effects of climate change we are
monitoring watersheds to understand how these changes are impacting water resources.
We are developing tools to predict near and long-term fluctuations of our water resources: those linked to
climatic changes, increased population density and upstream use. We are improving our ability to predict
the effects of climate change and other factors on long-term water availability at the local level. Our pilot
hydrologic/climate model ran risk scenarios based on climate models and bracketing weather scenarios,
changes in upstream water use, and watershed agriculture. On an ongoing basis our Annual Summer
Readiness Assessments evaluate water availability issues that could affect our ability to deliver power at
each of our facilities throughout the US, such as droughts. Our Drought Monitoring Task Force evaluates
changing conditions on a weekly basis and spans various business units including meteorologists,
trading floor and environmental strategy. Exelon has joined the DOE Partnership for Energy Sector
Climate Resilience in order to better understand the impacts of climate change on our systems, and to
improve our resilience to climate change. We have undertaken a Climate Change Vulnerability
Assessment intended to serve as a tool for communicating consistently and comprehensively about the
physical risks of climate change to Exelon and the steps the company has been taking to address these
risks. We endeavor to develop further understanding of future climate/water risks scenarios through
participation and support in programs of research institutions such as the Electric Power Research
Institute, MIT Center for Energy and Environmental Policy Research, World Resources Institute and
partnerships with DOE and national labs.
Exelon’s Environmental Regulatory & Policy Group tracks environmental regulatory developments and
updates the Environmental Review Council and the Executive Committee as needed. Engineering cost
studies are conducted as warranted evaluating business risks and response options.
Plants, business units, corporate legislative affairs and environmental strategy all track scenarios of
changes in stakeholder conflicts related to water availability and use, with regular reporting to the
executive level. Our pilot hydrologic/climate model enables stakeholder engagement from a technically
enlightened perspective.
Exelon performs evaluations of supplier risks, including water treatment chemicals, including the risk to
Exelon if suppliers were to experience business interruption, compliance issues, operations disruptions
and other types of risks, as well as mitigation strategy and a risk measurement metric. Suppliers are
evaluated for their risk and resilience to various impacts including extreme weather events including
snow, ice, hurricanes and floods.
Exelon has joined the DOE Partnership for Energy Sector Climate Resilience in order to better
understand the impacts of climate change on our systems, and to improve our resilience to climate
Choose
option
Issues
habitats at a local level
Relevant,
included
Other
Please explain
change. We use WRI’s AqueDuct indicator species maps to assess potential risks to ecosystems at the
local level. Scenarios and sensitivities Exelon explored in our hydrology/climate change study included
potential changes in ecosystems (watersheds) upstream of our facility during typical low-flow months of
the year with a 50 percent increase in water use, which is reasonable given the currently projected
growth in agriculture and urban development.
In 2014, Exelon participated in the launch of the DOE Partnership for Energy Sector Climate Resilience
in order to better understand the impacts of climate change on our systems and to improve our resilience
to climate change, and extreme weather and climate change impacts. The goal is to accelerate
investment in technologies, practices, and policies that will enable a resilient 21st century energy system.
The Partnership seeks to facilitate risk-based decisions and greater investment in cost-effective
strategies for a more climate-resilient power sector. Exelon has undertaken a Climate Change
Vulnerability Assessment intended to serve as a tool to assess the physical impacts of climate change on
Exelon and the steps the company is taking to address these risks. The physical changes that are
projected to affect weather patterns that will most impact the electric energy provider sector relate to:
•Increasing air temperatures - increasing summer peak and average temperatures and more mild winter
temperatures (but with occasional extreme temperature lows, i.e. polar vortexes); •Increasing storm
event intensity and frequency – increased physical damage causing impacts on reliability of service for
T&D and potential impacts on the availability of power plants; •Sea level rise – increased risk of coastal
flooding that could impact T&D infrastructure, the reliability of power delivery and potential impacts on
power plant availability; and •Changes in precipitation and water availability – increased risk of flooding,
water supply shortages and extreme precipitation events including snow fall and ice storms.
W2.7
Which of the following stakeholders are always factored into your organization's water risk assessments?
Stakeholder
Customers
Choose
option
Relevant,
included
Please explain
We provide sustainability consulting through our Constellation and utility business units (such as PECO’s Energy Audits
and BGE’s Quick Home Energy Check-up). Constellation’s core business is assisting customers to assess risk and
Stakeholder
Choose
option
Employees
Relevant,
included
Investors
Relevant,
included
Local communities
Relevant,
included
NGOs
Relevant,
included
Other water users at a
local level
Relevant,
included
Please explain
manage energy-related issues that reduce energy consumption, water use and cost, while improving reliability. We are
accredited by the National Association of Energy Service Companies (NAESCO) as an “Energy Services Provider” and
hold a number of IDIQ contracts with DOE, GSA and DOD and various state governments. The majority of our clean
energy production for our customers is provided by nuclear fleet, which in turn relies on reliable, affordable and adequate
water supplies. Two way communication with customers allows us to innovate new products, improve customer service
and maintain our “license to operate” and grow. We regularly engage with our customers and community members
through a variety of existing channels including: customer surveys, customer service calls, and community meetings,
among others.
Exelon 360 is a series of quarterly meetings with our employees, CEO and senior team providing an opportunity to
discuss our environmental performance. An open Q&A session follows brief executive updates on the state of the
company. An Employee Survey includes questions to gather employee input evaluating environmental performance.
Exelon’s water management policy calls for raising the awareness of employees of the strategic importance of water and
the need for effective water management. Environmental performance is discussed in regular Management Review
Meetings.
Exelon’s nuclear facilities produce a significant percentage of earnings; access to water resources which are reliable,
affordable and adequate is key to sustaining their value. We engage investors in our quarterly earnings calls and analyst
meetings, as well as investor surveys such as the DJSI and CDP. Exelon is committed to the Ceres Principles and
annually Ceres facilitates a corporate level review of Exelon’s material sustainability issues and performance with a group
of interested stakeholders including investors. Water resource issues and the company’s response are addressed as part
of the review. Exelon also publishes an annual report on its environmental performance which includes a discussion of
water use and issues, our 2016 Corporate Social Responsibility Report (CSR) to be published in June 2017.
Two-way communication allows us to maintain our license to operate and grow. Our Water Resources Policy mandates
that we engage local communities. Example: Conowingo & Muddy Run relicensing using the FERC Integrated Licensing
Process which incorporates consultation with regulatory and other interested stakeholders. In support of this process,
forty-seven (47) studies designed with input from stakeholders were conducted and the results of the studies were
included in the final license applications. Exelon continues to work with the State of Maryland and FERC to relicense
Conowingo. In April of 2016, Exelon and the US Fish and Wildlife Service announced an agreement to restore American
Shad and river herring by improving fish passage facilities at Conowingo. The license for the Muddy Run Pumped
Storage Facility was issued on December 22, 2015. Exelon continues to work with stakeholders to implement
requirement of the new license.
Exelon collaborates with environmental NGOs and wildlife organizations to preserve, protect and restore sensitive
habitats (e.g., Wildlife Habitat Council, Ducks Unlimited, Partnership for the Delaware Estuary, Trout Unlimited, Water
Resources Association for the Delaware River Basin, The Nature Conservancy, American Rivers, , Lower Susquehanna
Heritage Greenway, Alliance for the Chesapeake Bay, Chesapeake Bay Trust, Waterfront Partnership of Baltimore, Blue
Water Baltimore, and over 100 others.
Our Wolf Hollow facility in Texas withdraws cooling water from Lake Granbury. The lake has a variety of water users and
has experienced reduced water levels in the past; however, since the 2015 and subsequent rainfall events, the lake levels
Stakeholder
Choose
option
Regulators
Relevant,
included
River basin
management
authorities
Relevant,
included
Statutory special
interest groups at a
local level
Relevant,
included
Suppliers
Relevant,
included
Water utilities at a
local level
Relevant,
included
Other
Relevant,
included
Please explain
have remained at 95%. The recently completed intake extension project at Wolf Hollow will ensure the facility has access
to the cooling water needed for continued operations. Exelon has engaged the controlling Brazos River Authority to
discuss near and long-term impacts. The likelihood of an event restricting Wolf Hollow operations in the near-term is low,
given the Authority’s forecasts that no curtailment of water service is expected.
Environmental risk assessment is included as part of facility permitting and relicensing activities, as well as public policy
advocacy. Exelon engages with regulators and public policy makers in assessing water risk. For example, as part of the
relicensing process for Conowingo and Muddy Run hydropower projects, Exelon completed 47 studies concerning
assessment of water and natural resource related risks, and has committed to supporting up to $3.5 million in additional
studies of sediment and nutrient transport in support of relicensing.
Exelon has dockets with both the Susquehanna River and Delaware River Commissions. Our Limerick power station has
an emergency mine water release agreement with the Delaware River Basin Commission for drought conditions. Merrill
Creek Reservoir, of which Exelon is an owner, provides flow augmentation to the Delaware River watershed and
subsequently Exelon's facilities during drought emergencies declared by the Delaware River Basin Commission. We also
participate in local watershed advisory committees and boards to assist external stakeholders with sustainability
management.
Relicensing Conowingo and Muddy Run hydro projects required identification of stakeholders of record; over 47 studies
were completed with input from stakeholders. At our Limerick nuclear facility, Exelon collaborated with numerous
regulatory agencies and environmental stakeholders to develop a flow augmentation alternative to be used to supplement
flow in the Schuylkill River. We also participate in local watershed advisory committees and boards to assist external
stakeholders with sustainability management.
As a large purchaser with the potential to influence the sustainability practices of our suppliers, we are active in industry
and government efforts to improve supply chain operations. As one of the founders of the Electric Utility Industry
Sustainable Supply Chain Alliance (www.euissca.org), Exelon has helped develop industry standards for evaluating the
environmental impacts of key materials and services as well as performance metrics for suppliers. Exelon performs
evaluations of supplier risks, including water treatment chemicals, including the risk to Exelon if suppliers were to
experience business interruption, compliance issues, operations disruptions and other types of risks, as well as mitigation
strategy and a risk measurement metric. Suppliers are evaluated for their risk and resilience to various impacts including
extreme weather events including snow, ice, hurricanes and floods.
Constellation, an Exelon business, is working with water utilities to assess their risk and address energy efficiency and
resilience issues through our water and energy efficiency, renewables and load management products and services. For
example: constellation has entered into an agreement with the City of Los Angeles (with Exelon Power as EPC and
operator) for a 27-megawatt (MW) renewable energy power plant at L.A. Sanitation’s Hyperion Water Treatment Plant.
This facility was placed in service on April 29, 2017.
Constellation’s core business is assisting customers to assess risk and manage energy-related issues that reduce energy
consumption and cost, while improving reliability. We are accredited by the National Association of Energy Service
Companies (NAESCO) as an “Energy Services Provider” and hold a number of IDIQ contracts with DOE, GSA and DOD
Stakeholder
Choose
option
Please explain
and various state governments.
W2.8
Please choose the option that best explains why your organisation does not undertake a water-related risk assessment
Primary reason
Please explain
Further Information
Hyperion Water Treatment Plant information: http://www.constellation.com/about-us/news/archive/2014/constellation-to-develop-biogas-power-plant-city-la-bureausanitation.html http://www.exeloncorp.com/sustainability/interactive-csr
Module: Implications
Page: W3. Water Risks
W3.1
Is your organization exposed to water risks, either current and/or future, that could generate a substantive change in your business, operations, revenue
or expenditure?
Yes, direct operations only
W3.2
Please provide details as to how your organization defines substantive change in your business, operations, revenue or expenditure from water risk
Substantive change would be one that significantly impacts operations or has a material financial impact such as a cooling water system retrofit, if mandated by the
permitting authority, or it could also be the potential for shareholder or customer concern, or a combination resulting in a larger impact. The basis for expressing the
percentage of operation affected is based on plants identified using WRI AqueDuct risk mapping plus our own plant specific information. The calculation is: total net
generation MWh of the facilities located in water stress regions divided by the total net generation MWh produced by the generation facilities over which Exelon has
operational control. This percentage does not include operations related to the marketing and distribution of energy or natural gas, which have less significant water
uses. Exelon Corporation compiles an enterprise-wide inventory of water withdrawals and associated discharges annually. Exelon used the WRI AqueDuct to screen
for potential geographic water scarcity. All facilities identified in the screening process as being potentially located in water scarce areas were further evaluated using
internal company knowledge and regional basin management information to confirm the model output. The WRI AqueDuct uses twelve global maps grouped into
physical, quantity, quality, and regulatory and reputational risk. The seven physical quantity risks include: baseline water stress; inter-annual variability; seasonal
variability; floods; drought severity; upstream storage and groundwater. Physical water quality risks include return flow ratio and upstream protected land. The three
regulatory and reputational risks include media coverage, access to water and threatened amphibians. Overall water risk assessment identifies areas with higher
exposure to these water-related risks and is an aggregated measure. In the past Exelon used the UNEP water stress map:
http://www.unep.org/dewa/vitalwater/jpg/0221-waterstress-EN.jpg which shows that Exelon has no operations in water stressed areas based on the UNEP definition
(less than 1700 cubic meters per person per year). WRI’s new AqueDuct assessment tool is far broader in its definition of water stress, and therefore identifies some
areas where we operate that are subject to water stress as defined in the multivariate analyses in the WRI AqueDuct tool.
W3.2a
Please provide the number of facilities* per river basin exposed to water risks that could generate a substantive change in your business, operations,
revenue or expenditure; and the proportion of company-widefacilities this represents
Country
United States of
America
United States of
America
United States of
River basin
Number of facilities
exposed to water
risk
Proportion of companywide facilities that this
represents (%)
Other: Barnegat Bay
1
1-5
Mississippi River
1
1-5
Delaware River
3
6-10
Comment
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
Country
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
River basin
Number of facilities
exposed to water
risk
Proportion of companywide facilities that this
represents (%)
Other: Chesapeake Bay
2
1-5
Other: Colorado River
(Texas)
1
1-5
Trinity River (Texas)
2
1-5
Other: Massachusetts Bay
1
1-5
Susquehanna River
2
1-5
Other: Lake Ontario
2
1-5
Other: Kankakee River
1
1-5
Brazos River
1
1-5
Comment
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
W3.2b
For each river basin mentioned in W3.2a, please provide the proportion of the company's total financial value that could be affected by water risks
Country
United States of
America
River basin
Other: Barnegat Bay
Financial reporting metric
% generation capacity
Proportion of chosen
metric that could be
affected
1-5
Comment
metric: power capacity facilities exposed/ power
capacity Exelon
Country
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
River basin
Financial reporting metric
Proportion of chosen
metric that could be
affected
Mississippi River
% generation capacity
6-10
Delaware River
% generation capacity
11-20
Other: Chesapeake Bay
% generation capacity
1-5
Other: Colorado River
(Texas)
% generation capacity
1-5
Trinity River (Texas)
% generation capacity
1-5
Other: Massachusetts Bay
% generation capacity
1-5
Susquehanna River
% generation capacity
6-10
Other: Lake Ontario
% generation capacity
6-10
Other: Kankakee River
% generation capacity
6-10
Brazos River
% generation capacity
1-5
Comment
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
metric: power capacity facilities exposed/ power
capacity Exelon
W3.2c
Please list the inherent water risks that could generate a substantive change in your business, operations, revenue or expenditure, the potential impact
to your direct operations and the strategies to mitigate them
Countr
y
United
States
of
Americ
a
River basin
Other:
Mississippi
River, Salt
Creek,
Illinois River,
Kankakee
River,
Susquehann
a River,
Chesapeake
Bay,
Delaware
River,
Colorado
River (TX),
Trinity River
(TX),
Massachuse
tts Bay, Lake
Ontario
Risk driver
PhysicalEcosystem
vulnerability
RegulatoryMandatory water
efficiency,
conservation,
recycling or
process standards
Other: Regulation
leading to higher
capital and
operating costs
Potential
impact
Higher
operating
costs
Description
of
potential imp
act
Retrofitting
cooling water
intake
structures.
Implementing
potential
operational
and design
changes at
affected
Exelon power
plants to meet
the regulatory
changes could
result in
material costs
for
compliance.
Timefra
me
>6 years
Likeliho
od
Probable
Magnitu
de of
potential
financial
impact
Medium
Response
strategy
Alignment
of public
policy
positions
with water
stewardshi
p goals
Engageme
nt with
public
policy
makers
Engageme
nt with
other
stakeholde
rs in the
river basin
Increased
investment
in new
technology
River basin
restoration
Strengthen
links with
local
community
Other:
Implement
regulatory
requiremen
ts
Costs of
response
strategy
Unknown at
this time
Details of
strategy and
costs
The US EPA
issued the
Clean Water
Act 316 (b)
Phase II
cooling water
intake rule in
May, 2014.
Those facilities
most affected
are Calvert
Cliffs, Dresden
(partially
closed cycle),
Quad Cities,
Eddystone,
Fairless Hills,
Handley,
Mountain
Creek, Peach
Bottom, Ginna,
, Nine Mile
Point, Gould
Street Mystic
7,andWolf
Hollow.
Exelon is in
various stages
of
implementing
the rule at the
affected
facilities. The
316(b) Rule is
Countr
y
United
States
River basin
Other:
Barnegat
Risk driver
PhysicalEcosystem
Potential
impact
Higher
operating
Description
of
potential imp
act
Retrofitting
cooling water
Timefra
me
1-3 years
Likeliho
od
Highly
probable
Magnitu
de of
potential
financial
impact
High
Response
strategy
Engageme
nt with
Costs of
response
strategy
Details of
strategy and
costs
plant closure
10 years prior
complex and
relates in many
different ways
to our affected
facilities
compliance
options are
dependent on
site-specific
factors. We
are evaluating
the
requirements
and
compliance
options and
will engage in
environmental
studies and
engineering
analyses as
determined by
our
assessment.
Certain parties
are pursuing
legal
challenges to
the final rule in
the federal
court system.
On December
8, 2010,
Countr
y
River basin
of
Americ
a
Bay
United
States
of
Americ
a
Delaware
River
Risk driver
vulnerability
Other: Regulation
leading to higher
costs
Physical-Increased
water scarcity
Physical-Projected
water scarcity
Potential
impact
costs
Plant/producti
on disruption
leading to
reduced
output
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
intake
structures.
Implementing
potential
operational
and design
changes would
result in
material costs
for
compliance.
community
Engageme
nt with
public
policy
makers
Other:
Implement
regulatory
requiremen
ts
to expiration
of NRC
operating
license
At Limerick
nuclear
generating
facility in
Pennsylvania,
seasonal
variations of
temperature
and river flow
Engageme
nt with
community
Engageme
nt with
public
policy
makers
Infrastructu
Costs
included
environmenta
l studies,
legal
representatio
n,
engineering
and project
Currentup to 1
year
Highly
probable
Lowmedium
Details of
strategy and
costs
pursuant to
discussions
with the
NJDEP
regarding the
application of
Section 316(b)
of the Clean
Water Act to
Oyster Creek,
Exelon
announced
that Exelon will
permanently
cease
generation
operations at
Oyster Creek
in 2019, ten
years prior to
the expiration
of its NRC
operating
license.
Seasonal
variations of
temperature
and river flow
rate could
potentially limit
water intake
needed by the
Limerick plant.
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
rate could
potentially limit
water intake
needed by the
plant.
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
re
investment
Strengthen
links with
local
community
Costs of
response
strategy
Details of
strategy and
costs
implementati
on.
To address
these
limitations,
Exelon
collaborated
with numerous
regulatory
agencies and
environmental
stakeholders to
develop a flow
augmentation
alternative that
allows mine
water to be
used to
supplement
flow in the
Schuylkill
River, allowing
the plant to
continue to use
the Schuylkill
rather than the
Delaware
River as its
primary source
for non-contact
cooling water.
This project
has
demonstrated
that mine
water can be a
Countr
y
United
States
of
Americ
a
River basin
Other:
Mississippi
River,
Kankakee
River, Salt
Creek,
Illinois River
Risk driver
Physical-Climate
change
Physical-Drought
Physical-Increased
water scarcity
Physical-Increased
water stress
Physical-Projected
water scarcity
Physical-Projected
water stress
Potential
impact
Plant/producti
on disruption
leading to
reduced
output
Description
of
potential imp
act
Thermal
Discharges
Risk
Reduction.
Exelon
operates
thermal power
generation
facilities that
depend on
adequate and
reliable water
resources for
condenser
cooling.
Climate
change and
drought may
challenge the
availability and
adequacy of
these
resources.
Timefra
me
Currentup to 1
year
Likeliho
od
Unlikely
Magnitu
de of
potential
financial
impact
Medium
Response
strategy
Engageme
nt with
public
policy
makers
Engageme
nt with
other
stakeholde
rs in the
river basin
River basin
restoration
Strengthen
links with
local
community
Other:
Comply
with local
legal
requiremen
ts or
company
Costs of
response
strategy
Low to
medium
Details of
strategy and
costs
viable option.
It has been
made part of
the facility’s
water use
docket with the
Delaware
River Basin
Commission.
Exelon has
joined the DOE
Partnership for
Energy Sector
Climate
Resilience in
order to better
understand the
impacts of
climate change
on our
systems, and
to improve our
resilience to
climate
change. In
order to
identify
locations of our
U. S.
generation
fleet with
regard to water
stress regions
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
own
internal
standards,
whichever
is more
stringent
Costs of
response
strategy
Details of
strategy and
costs
we used the
World
Resources
Institute (WRI)
AqueDuct tool.
The Executive
Committee has
established a
Drought
Monitoring
Task Force
that spans
various
business units
and reports on
an assessment
of current
drought
conditions and
the impacts of
the drought,
both historical
and potential.
The Drought
Task Force
recommends
regulatory,
operational,
and technical
solutions, and
points out
other regions
of concern and
potential
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
impacts. In
order to
address
changing
waterbody
conditions due
to climate
change
challenges,
Exelon has
installed
monitoring
systems in
river bodies
with telemetry
to increase
data
availability,
trending and
station
response
times. A Daily
River Report
based on our
plant thermal
modelling
telemetry of
upstream river
stage and
temperature is
circulated
internally on a
daily basis.
Our thermal
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
models update
12 times per
day,
incorporating
approximately
30,000 hourly
data points.
Exelon
completed a
hydrology/clim
ate modelling
study for our
Braidwood
facility in 2014.
Exelon is
continuing to
pursue cuttingedge research
with preeminent
researchers in
an effort to
better
understand
potential
climate and
water impacts
and to help
push the
current limits of
the state of art
modelling in
the most
efficient and
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
effective
manner by
accessing
both public and
private
institutions.
Our pilot
hydrologic
study linking
climate change
impacts to a
local
hydrologic
model
evaluated
potential
impacts to the
watershed
including
climate
change,
population
growth,
development,
and potential
changes in
environmental
protection
regulations.
The scenarios
were run from
retro-fitting of
model outputs
- out to a
Countr
y
United
States
of
Americ
a
River basin
Susquehann
a River
Risk driver
Physical-Climate
change
Physical-Drought
PhysicalEcosystem
vulnerability
Physical-Increased
water stress
RegulatoryIncreased difficulty
in obtaining
withdrawals/operati
ons permit
Potential
impact
Higher
operating
costs
Description
of
potential imp
act
Thermal
discharges
impacts on
indigenous
aquatic
populations, to
assess the
impacts of a
plant uprate.
Should the
permit require
operation of
the
supplemental
cooling towers
to limit
discharge
water
temperature,
additional
operational
costs and
reduced
generation
output would
result, with the
possibility of a
temporary derate of plant
operations. It
could also
Timefra
me
Currentup to 1
year
Likeliho
od
Probable
Magnitu
de of
potential
financial
impact
Low
Response
strategy
Alignment
of public
policy
positions
with water
stewardshi
p goals
Costs of
response
strategy
Low
Details of
strategy and
costs
timeframe of
2040.
At Peach
Bottom nuclear
generating
facility, Exelon
is working with
the state
environmental
agency to
establish an
acceptable
compliance
solution for the
NPDES permit
renewal. The
plant’s
previous
NPDES permit
required that a
thermal study
be conducted,
to include an
assessment of
the operation
of the
refurbished
cooling towers
on the
increased
thermal
discharge
resulting from
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
adversely
affect the
ability of the
plant to obtain
the NPDES
permit
modifications
necessary for
nuclear uprate
projects.
United
States
of
Americ
a
Susquehann
a River
RegulatoryIncreased difficulty
in obtaining
withdrawals/operati
ons permit
Higher
operating
costs
Exelon’s
Conowingo
hydroelectric
generating
station has a
Federal
Energy
Regulatory
Commission
(FERC)
license that
allows the
company to
operate this
generation
asset through
August 2014,
and the facility
is currently in
the relicensing
process. The
Currentup to 1
year
Probable
Lowmedium
Alignment
of public
policy
positions
with water
stewardshi
p goals
Engageme
nt with
community
Engageme
nt with
public
policy
makers
Engageme
nt with
other
stakeholde
rs in the
river basin
Unknown
Details of
strategy and
costs
the uprate. The
study was
complete in
2014, and the
permit has
been renewed.
The cooling
towers will run
less than
previously
used during
the study.
Exelon
continues to
work with the
State of
Maryland and
FERC
regarding
relicensing of
Conowingo. In
April of 2016,
Exelon and the
US Fish and
Wildlife
Service
announced an
agreement to
restore
American
Shad and river
herring by
improving fish
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
project will
continue
operating
under annual
license
renewals from
the FERC until
the relicensing
process is
complete. The
relicensing
process
requires a
review of all
operational
and permit
conditions
based on
results of
studies
completed by
Exelon Power,
and receipt of
a 401 Water
Quality
Certification
from Maryland
for
Conowingo.
FERC issued
a 40-year
operating
license for
Muddy Run on
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
River basin
restoration
Strengthen
links with
local
community
Costs of
response
strategy
Details of
strategy and
costs
passage
facilities at
Conowingo.
The license for
the Muddy Run
Pumped
Storage
Facility was
issued on
December 22,
2015. Exelon
continues to
work with
stakeholders to
implement
requirements
of the new
license.
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
Low-medium
Illinois has
discontinued
the use of
Provisional
Thermal
Variances. In
its place is a
rule
promulgated
by the Illinois
Pollution
Control Board
and
administered
by IEPA under
Clean Water
Act Section
316(a) to
provide
thermal relief
to a permit
holder with
thermal limits
that vary from
the state’s
water quality
standards after
submitting
December 22,
2015 as a
result of its
relicensing
process.
United
States
of
Americ
a
Mississippi
River
Physical-Climate
change
Physical-Declining
water quality
Physical-Drought
PhysicalEcosystem
vulnerability
Physical-Increased
water stress
Physical-Projected
water stress
RegulatoryRegulatory
uncertainty
Plant/producti
on disruption
leading to
reduced
output
Thermal
Discharges
Risk
Reduction.
Exelon
operates
thermal power
generation
facilities that
depend on
adequate and
reliable water
resources for
condenser
cooling.
Climate
change and
drought may
challenge
reliability of
these
resources.
>6 years
Probable
Mediumhigh
Engageme
nt with
public
policy
makers
Engageme
nt with
other
stakeholde
rs in the
river basin
Countr
y
United
States
of
Americ
a
River basin
Other:
Chesapeake
Bay
Risk driver
RegulatoryRegulation of
discharge
quality/volumes
leading to higher
compliance costs
Potential
impact
Higher
operating
costs
Description
of
potential imp
act
Implementatio
n of total
maximum daily
loads (TMDL)
in certain
receiving
waters near
owned
facilities with
additional
costs for
treatment plant
improvements
to meet stricter
discharge
limits for
certain
pollutants. For
example, in
Maryland and
Timefra
me
4-6 years
Likeliho
od
Probable
Magnitu
de of
potential
financial
impact
Lowmedium
Response
strategy
Alignment
of public
policy
positions
with water
stewardshi
p goals
Engageme
nt with
public
policy
makers
Infrastructu
re
investment
Promote
best
practice
and
awareness
Costs of
response
strategy
Low-medium
Details of
strategy and
costs
demonstration
studies
detailing that a
balanced
indigenous
community of
aquatic life will
continue to
exist in the
waterbody
potential
environmental
impact.
While recent,
Maryland
NPDES
Municipal
Separate
Storm Sewer
System (MS4)
Permits still
require 20%
restoration of
the County’s
impervious
surface area;
The MD
General
Assembly
repealed the
rain tax in late
2015. As a
result, several
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Pennsylvania,
local
governments
are currently
developing
impervious
surface area
fees to help
improve
stormwater
quality and to
offset the
costs of
stormwater
treatment.
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
counties have
repealed or
reduced the
“rain tax” and
elected to fund
these projects
through other
measures;
however, BGE
continues to
work closely
with the
City/Counties
to look for
ways to
minimize storm
water impacts
through
thoughtful
project design.
In addition,
MDE is
requiring
facilities with
an individual
NPDES permit
to gain
coverage
under the
General Permit
for Discharges
For
Stormwater
Associated
Countr
y
United
States
of
Americ
a
River basin
Other: All
US
operations
Risk driver
Physical- Pollution
of water source
ReputationalNegative media
coverage
Potential
impact
Brand
damage
Description
of
potential imp
act
Spills could
contaminate
soils and
potentially
contaminate
Timefra
me
Currentup to 1
year
Likeliho
od
Unlikely
Magnitu
de of
potential
financial
impact
Lowmedium
Response
strategy
Promote
best
practice
and
awareness
Costs of
response
strategy
Low-medium
Details of
strategy and
costs
with Industrial
Activity when
the individual
NPDES permit
is renewed.
The General
Permit has
requirements
for facilities in
the
Chesapeake
Bay
Watershed to
reduce the
amount of
untreated
storm water
runoff by 20%.
This is
currently
impacting Fort
Smallwood
Road
Complex.
Gould Street
was also
affected in
2016.
Exelon has a
corporate-wide
goal of zero
NRCReportable
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
groundwater,
necessitating
cleanup to
applicable
environmental
standards.
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Tighter
supplier
performanc
e
standards
Water
manageme
nt
incentives
Other:
Comply
with local
legal
requiremen
ts or
company
own
internal
standards,
whichever
is more
stringent
Costs of
response
strategy
Details of
strategy and
costs
Preventable
spills, with
executive
oversight of
performance
quarterly.
Exelon Utilities
achieved their
substation goal
for sampling,
replacing or
retro-filling
PCB
equipment in
2016 and will
continue with
energy delivery
PCB phase
down and spill
prevention and
mitigation
programs. We
will also
continue the
buried pipe
and tank
inspection and
mitigation
program to
ensure all
underground
pipes
containing
hazardous
Countr
y
United
States
of
Americ
a
River basin
Other: All
US
operation
Risk driver
Physical- Pollution
of water source
ReputationalNegative media
coverage
Potential
impact
Brand
damage
Description
of
potential imp
act
Spills could
contaminate
soils and
potentially
contaminate
groundwater,
necessitating
cleanup to
applicable
environmental
standards.
Timefra
me
Currentup to 1
year
Likeliho
od
Unlikely
Magnitu
de of
potential
financial
impact
Lowmedium
Response
strategy
Promote
best
practice
and
awareness
Tighter
supplier
performanc
e
standards
Water
manageme
nt
incentives
Other:
Comply
with local
legal
Costs of
response
strategy
Low-medium
Details of
strategy and
costs
substances
(Exelon Power,
Nuclear,
PECO, BGE,
ComEd and
PHI) and will
continue
inspection of
and mitigation
of
radiologically
contaminated
liquids (Exelon
Nuclear), as
appropriate.
Exelon has a
corporate-wide
goal of zero
spills, with
executive
oversight of
performance
quarterly.
Continue with
the Exelon
Nuclear,
Power,
ComEd, PECO
and BGE
aboveground
storage tank
program to
reduce spills
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
requiremen
ts or
company
own
internal
standards,
whichever
is more
stringent
United
States
of
Americ
a
Other:
Susquehann
a,
Chesapeake
Bay,
Delaware
River,
Mississippi
River
Physical- Pollution
of water source
ReputationalNegative media
coverage
Brand
damage
Spills could
contaminate
soils and
potentially
contaminate
groundwater,
necessitating
cleanup to
applicable
environmental
standards.
Currentup to 1
year
Unlikely
Lowmedium
Promote
best
practice
and
awareness
Other:
Comply
with local
legal
requiremen
ts or
company
own
internal
standards,
whichever
is more
stringent
Details of
strategy and
costs
by identifying
and mitigating
potential spill
risks as part of
engineering,
maintenance
and project
planning
processes.
Low-medium
Exelon has a
corporate-wide
goal of zero
spills, with
executive
oversight of
performance
quarterly.
Exelon Utilities
achieved
substation goal
for sampling,
replacing or
retro-filling
PCB
equipment.
Continue with
energy
provider PCB
phase down
and spill
prevention and
mitigation
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
programs.
United
States
of
Americ
a
Trinity River
(Texas)
Physical-Climate
change
Physical-Drought
PhysicalEcosystem
vulnerability
Physical-Increased
water stress
RegulatoryIncreased difficulty
in obtaining
withdrawals/operati
ons permit
Higher
operating
costs
Thermal
discharge
impacts on
indigenous
aquatic
populations, to
assess the
impacts of a
plant uprate.
Should the
permit require
operation of
the
supplemental
cooling towers
to limit
discharge
water
temperature,
additional
operational
costs and
reduced
generation
output would
result, with the
possibility of a
temporary derate of plant
operations. It
could also
adversely
Currentup to 1
year
Probable
Low
Alignment
of public
policy
positions
with water
stewardshi
p goals
Low-medium
At Mountain
Creek, we will
have to
conduct
thermal studies
as the current
permit limits do
not align with
state water
quality
standards.
These studies
will assist in
determining
the impact, if
any, on the
aquatic
species
associated
with the
cooling water
discharge.
The thermal
study will be
conducted in
2017 for Mt.
Creek.
Countr
y
United
States
of
Americ
a
River basin
Brazos River
Risk driver
Physical-Climate
change
Physical-Drought
PhysicalEcosystem
vulnerability
Physical-Increased
water stress
RegulatoryIncreased difficulty
in obtaining
withdrawals/operati
ons permit
Potential
impact
Higher
operating
costs
Description
of
potential imp
act
affect the
ability of the
plant to obtain
the NPDES
permit.
Thermal
discharge
impacts on
indigenous
aquatic
populations, to
assess the
impacts of a
plant uprate.
Should the
permit require
operation of
the
supplemental
cooling towers
to limit
discharge
water
temperature,
additional
operational
costs and
reduced
generation
output would
result, with the
possibility of a
temporary de-
Timefra
me
Currentup to 1
year
Likeliho
od
Probable
Magnitu
de of
potential
financial
impact
Low
Response
strategy
Alignment
of public
policy
positions
with water
stewardshi
p goals
Costs of
response
strategy
Details of
strategy and
costs
Low-medium
At Wolf Hollow,
we will have to
conduct
thermal studies
as the current
permit limits do
not align with
state water
quality
standards.
These studies
will assist in
determining
the impact, if
any, on the
aquatic
species
associated
with the
cooling water
discharge.
Countr
y
United
States
of
Americ
a
River basin
Other:
Colorado
River
(Texas)
Risk driver
Physical-Climate
change
Physical-Drought
PhysicalEcosystem
vulnerability
Physical-Increased
water stress
RegulatoryIncreased difficulty
in obtaining
withdrawals/operati
ons permit
Potential
impact
Higher
operating
costs
Description
of
potential imp
act
rate of plant
operations. It
could also
adversely
affect the
ability of the
plant to obtain
the NPDES
permit.
Thermal
discharge
impacts on
indigenous
aquatic
populations, to
assess the
impacts of a
plant uprate.
Should the
permit require
operation of
the
supplemental
cooling towers
to limit
discharge
water
temperature,
additional
operational
costs and
reduced
generation
Timefra
me
Currentup to 1
year
Likeliho
od
Probable
Magnitu
de of
potential
financial
impact
Low
Response
strategy
Alignment
of public
policy
positions
with water
stewardshi
p goals
Costs of
response
strategy
Details of
strategy and
costs
Low-medium
At Colorado
Bend we will
have to
conduct
thermal
studies. The
current permit
limits do not
align with state
water quality
standards.
These studies
will assist in
determining
the impact, if
any, on the
aquatic
species
associated
with the
cooling water
discharge.
Countr
y
River basin
Risk driver
Potential
impact
Description
of
potential imp
act
Timefra
me
Likeliho
od
Magnitu
de of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy and
costs
output would
result, with the
possibility of a
temporary derate of plant
operations. It
could also
adversely
affect the
ability of the
plant to obtain
the NPDES
permit.
W3.2d
Please list the inherent water risks that could generate a substantive change in your business operations, revenue or expenditure, the potential impact to
your supply chain and the strategies to mitigate them
Country
W3.2e
River
basin
Risk driver
Potential
impact
Description
of potential
impact
Timeframe
Likelihood
Magnitude of
potential
financial
impact
Response
strategy
Costs of
response
strategy
Details of
strategy
and costs
Please choose the option that best explains why you do not consider your organization to be exposed to water risks in your direct operations that could
generate a substantive change in your business, operations, revenue or expenditure
Primary reason
Please explain
W3.2f
Please choose the option that best explains why you do not consider your organization to be exposed to water risks in your supply chain that could
generate a substantive change in your business, operations, revenue or expenditure
Primary reason
Risks exist, but no
substantive impact
anticipated
Please explain
Over 90% of the company’s commodities spend is on non-fuel goods and services secured from U.S. domestic companies. Less than
10% of this spend is from non-domestic sources for which there are identified alternative suppliers, helping to mitigate risk from water
constrained areas. Review of the supplier’s business continuity and readiness plans are required for sole source contracts. Fuels are
procured outside of Exelon’s supply chain and are reliant upon pipeline gas and nuclear fuel.
W3.2g
Please choose the option that best explains why you do not know if your organization is exposed to water risks that could generate a substantive
change in your business operations, revenue or expenditure and discuss any future plans you have to assess this
Primary reason
Future plans
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Page: W4. Water Opportunities
W4.1
Does water present strategic, operational or market opportunities that substantively benefit/have the potential to benefit your organization?
Yes
W4.1a
Please describe the opportunities water presents to your organization and your strategies to realize them
Country
or region
Companywide
Opportunity
Carbon management
Improved community
relations
Increased shareholder
value
Improved water
efficiency
Social licence to
operate
Other: Sustained
capacity for generating
low-carbon electricity
from existing assets.
Strategy to realize opportunity
FERC issued a 40-year operating license for Muddy
Run on December 22, 2015. Conowingo
Hydroelectric facility is still undergoing relicensing
with annual renewals of its FERC license. Exelon
continues to work with stakeholders related to
relicensing Conowingo. In particular, Exelon
provided $3.5 million in 2015 for funding towards a
two-year study at the University of Maryland Center
for Environmental Science to quantify the amount of
sediment and associated nutrients entering the
Lower Susquehanna River Reservoir System and
the upper Chesapeake Bay. This study will help
policymakers determine best management options
to address sediment and nutrient loads entering and
Estimated
timeframe
1-3 years
Comment
Continue operation of the Conowingo hydroelectric
project and the Muddy Run pumped storage projects.
Due to the low fuel cost for the Conowingo project
and the ability to arbitrage the off-peak and on-peak
market price differential, continued operation of both
projects represents an opportunity for continued,
profitable operation of these low carbon generation
assets with the capacity to generate 1,642 MW of
low carbon energy.
Country
or region
Opportunity
Strategy to realize opportunity
Estimated
timeframe
Comment
exiting Conowingo Pond during high flow events.
Companywide
Companywide
Companywide
Carbon management
Climate change
adaptation
Competitive advantage
Increased brand value
Increased shareholder
value
Improved water
efficiency
Innovation
Sales of new
products/services
Staff retention
Increased brand value
Increased shareholder
value
Improved water
efficiency
Sales of new
products/services
Staff retention
Climate change
adaptation
Competitive advantage
Cost savings
Ensuring supply chain
resilience
Increased brand value
Increased shareholder
value
Improved water
efficiency
Innovation
Social licence to
Responding to customer demand for renewables
that in turn consume less water than conventional
power generation. Our strategy is to continue to
provide innovative solutions to help customers meet
their energy needs. Governments, businesses and
non-profit organizations can develop sustainable
and responsible strategies that account for this
“triple bottom line” by using green technologies such
as solar and wind power.
Federal government, state & local government,
public housing authorities, healthcare, education,
and commercial customers have turned to us for
more than 25 years to evaluate existing energy
infrastructure and usage and develop customized
energy management strategies.
The U.S. Department of Energy (DOE) is seeking
participation from the power sector in a voluntary
partnership to enhance U.S. energy security by
improving the resilience of energy infrastructure to
extreme weather and climate change impacts. The
goal is to accelerate investment in technologies,
practices, and policies that will enable a resilient
21st century energy system. Under this Partnership,
owners and operators of energy assets will develop
and pursue strategies to reduce climate and
weather-related vulnerabilities. The scope will
engage power generation as well as transmission &
distribution.
4-6 years
Continued growth of our solar and wind solutions
business segment. There is very little water use in
our solar and wind operations, which are located
mainly in the west, where water stress is a more
important issue relative to the east. Exelon
Generation is the country’s 12th largest wind
producer, with approximately 1,500 megawatts of
wind generation in 11 states.
4-6 years
We provide a wide array of energy efficiency options
which also use less water, to manage energy costs,
ranging from long-term performance contracts to
design-build services structured through flexible
contracts. There is very little water use in our solar
and wind operations, which are located mainly in the
west, where water stress is a more important issue
relative to the east.
>6 years
Exelon has undertaken a corporate-wide Climate
Change Vulnerability Assessment, and is developing
a corporate Strategic Plan for Climate Change
Resilience. The Strategic Plan is geared to support
Exelon’s participation in the U.S. Department of
Energy Voluntary Partnership for Energy Sector
Climate Resilience, fulfilling the Partnership
agreement that each participating company would
develop a climate change resiliency strategy. In
general, the initiatives that have been implemented,
that support maintaining and increasing resiliency,
fall into several key areas: Investments to harden
existing and new T&D infrastructure and generating
Country
or region
Opportunity
Strategy to realize opportunity
Estimated
timeframe
operate
Companywide
Comment
plants; Enhancing emergency response programs to
more effectively and efficiently restore operability
following severe events; and, Conducting
assessments and research to gain a better
understanding of future changes in support of
developing appropriate responses for ensuring
service and protecting investments.
Competitive advantage
Increased brand value
Improved community
relations
Increased shareholder
value
Improved water
efficiency
Innovation
R&D
Sales of new
products/services
Social licence to
operate
Staff retention
Water is a sizeable adjacent market for Exelon. The
inter-relationship of electricity and water creates
opportunities for Exelon to leverage existing assets
and competences to create value.
>6 years
Exelon's TechExchange is an internal matrixed
group of experts who work on developing energy
innovation businesses, including emergent
technologies and market evaluation of the waterenergy nexus, and, in 2015, identified recommended
investment opportunities.
W4.1b
Please choose the option that best explains why water does not present your organization with any opportunities that have the potential to provide
substantive benefit
Primary reason
Please explain
W4.1c
Please choose the option that best explains why you do not know if water presents your organization with any opportunities that have the potential to
provide substantive benefit
Primary reason
Please explain
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Module: Accounting
Page: W5. Facility Level Water Accounting (I)
W5.1
Water withdrawals: for the reporting year, please complete the table below with water accounting data for all facilities included in your answer to W3.2a
Facility reference
number
Country
River basin
Facility name
Total water
withdrawals
(megaliters/year)
at this facility
How does the
total water
withdrawals at
this facility
compare to the
last reporting
year?
Please explain
Facility reference
number
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Country
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
United States of
America
River basin
Other: Barnegat Bay
Mississippi River
Delaware River
Facility name
Oyster Creek Nuclear
Generating Station
Quad Cities Nuclear
Generating Station
Limerick Nuclear Generating
Station
Total water
withdrawals
(megaliters/year)
at this facility
How does the
total water
withdrawals at
this facility
compare to the
last reporting
year?
1835228.20
About the same
1595993.96
About the same
58239.68
About the same
Delaware River
Eddystone
486224.10
About the same
Delaware River
Fairless Hills
72369.20
About the same
Other: Chesapeake
Bay
Other: Chesapeake
Bay
Calvert Cliffs Nuclear
Generating Station
5208855.31
About the same
Gould Street
5491.91
About the same
Trinity River (Texas)
Handley
514.5
About the same
Trinity River (Texas)
Mountain Creek
254982.27
About the same
Other: Massachusetts
Bay
Mystic 7
165545.26
About the same
2987560.54
About the same
20767529.44
Lower
596963.22
About the same
675298.53
About the same
686214.53
About the same
Susquehanna River
Susquehanna River
Other: Lake Ontario
Other: Lake Ontario
Other: Kankakee
River
Peach Bottom Nuclear
Generating Station
Conowingo Hydroelectric
Generating Station
Nine Mile Point Nuclear
Generating Station
R.E. Ginna Nuclear
Generating Station
Dresden Nuclear
Generating Station
Please explain
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
generation
About the same
because generation
About the same
generation
About the same
generation
About the same
generation
Facility reference
number
Country
United States of
America
United States of
America
Facility 16
Facility 17
River basin
Facility name
Brazos River
Other: Colorado River
(Texas)
Wolf Hollow Generating
Station
Colorado Bend Generating
Station
Total water
withdrawals
(megaliters/year)
at this facility
How does the
total water
withdrawals at
this facility
compare to the
last reporting
year?
2373.83
About the same
3004.40
About the same
Please explain
About the same
generation
About the same
generation
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Page: W5. Facility Level Water Accounting (II)
W5.1a
Water withdrawals: for the reporting year, please provide withdrawal data, in megaliters per year, for the water sources used for all facilities reported in
W5.1
Facility
reference
number
Facility 1
Fresh
surface
water
0.00
Brackish
surface
Rainwater
water/seawater
Groundwater
(renewable)
Groundwater
Produced/process
(nonwater
renewable)
Municipal
water
Wastewater
from
another
organization
1835228.20
18.93
0.00
0.00
0.00
0.00
0.00
Comment
About the same
because
generation was
Facility
reference
number
Fresh
surface
water
Brackish
surface
Rainwater
water/seawater
Groundwater
(renewable)
Groundwater
Produced/process
(nonwater
renewable)
Municipal
water
Wastewater
from
another
organization
Facility 2
1595993.96
0.00
0.00
673.80
0.00
0.00
0.00
0.00
Facility 3
58239.68
0.00
0.00
37.81
0.00
0.00
0.00
0.00
Facility 4
486224.10
0.00
0.00
0.00
0.00
0.00
203.12
0.00
Facility 5
72369.20
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 6
0.00
5208855.31
0.00
567952.13
0.00
0.00
0.00
0.00
Facility 7
0.00
5491.91
0.00
0.00
0.00
0.00
0.00
0.00
Facility 8
514.54
0.00
0.00
0.00
0.00
0.00
0.85
0.00
Facility 9
254982.27
0.00
0.00
0.00
0.00
0.00
98.04
0.00
Facility 10 165545.26
0.00
0.00
0.00
0.00
0.00
569.37
0.00
Comment
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
Facility
reference
number
Fresh
surface
water
Brackish
surface
Rainwater
water/seawater
Groundwater
(renewable)
Groundwater
Produced/process
(nonwater
renewable)
Municipal
water
Wastewater
from
another
organization
Facility 11 2987560.54
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 12 20767529.44
0.00
0.00
4.46
0.00
0.00
0.00
0.00
Facility 13 596963.22
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 14 675298.53
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 15 686214.53
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 16 2373.83
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Facility 17 0.00
0.00
0.00
3004.40
0.00
0.00
0.00
0.00
Comment
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
About the same
because
generation was
about the same
W5.2
Water discharge: for the reporting year, please complete the table below with water accounting data for all facilities included in your answer to W3.2a
Facility reference number
Total water discharged
(megaliters/year) at this
facility
How does the total water discharged at
this facility compare to the last
reporting year?
Facility 1
1816857.59
About the same
Facility 2
1579421.43
About the same
Facility 3
11105.20
About the same
Facility 4
485687.92
About the same
Facility 5
71853.85
About the same
Facility 6
4640263.75
About the same
Facility 7
5491.91
About the same
Facility 8
512.54
About the same
Facility 9
254124.46
About the same
Facility 10
165199.42
About the same
Facility 11
2952876.79
About the same
Facility 12
20767527.21
About the same
Facility 13
577502.42
About the same
Facility 14
675298.53
About the same
Please explain
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
Facility reference number
Total water discharged
(megaliters/year) at this
facility
How does the total water discharged at
this facility compare to the last
reporting year?
Facility 15
666943.00
About the same
Facility 16
548.39
About the same
Facility 17
491.31
About the same
Please explain
same
About the same because generation was about the
same
About the same because generation was about the
same
About the same because generation was about the
same
W5.2a
Water discharge: for the reporting year, please provide water discharge data, in megaliters per year, by destination for all facilities reported in W5.2
Facility reference
number
Fresh surface
water
Municipal/industrial
wastewater
treatment plant
Seawater
Groundwater
Wastewater for
another
organization
Facility 1
0.00
0.00
1816857.59
0.00
0.00
Facility 2
1579421.43
0.00
0.00
0.00
0.00
Facility 3
11105.21
0.00
0.00
37.85
0.00
Facility 4
485687.92
4.09
0.00
0.00
0.00
Facility 5
71853.85
0.00
0.00
0.00
0.00
Facility 6
0.00
0.00
4640263.75
0.00
0.00
Comment
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
Facility reference
number
Fresh surface
water
Municipal/industrial
wastewater
treatment plant
Seawater
Groundwater
Wastewater for
another
organization
Facility 7
0.00
0.00
5491.91
0.00
0.00
Facility 8
512.54
0.00
0.00
0.00
0.00
Facility 9
254124.46
0.00
0.00
0.00
0.00
Facility 10
165199.42
67.38
0.00
0.00
0.00
Facility 11
2952876.79
0.00
0.00
0.00
0.00
Facility 12
20767527.21
0.00
0.00
2.23
0.00
Facility 13
577502.42
0.00
0.00
0.00
0.00
Facility 14
675298.53
0.00
0.00
0.00
0.00
Facility 15
666943.00
0.00
0.00
55.64
0.00
Facility 16
548.39
0.00
0.00
0.00
0.00
Facility 17
0.00
0.00
0.00
491.31
0.00
Comment
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
About the same because generation
was about the same
W5.3
Water consumption: for the reporting year, please provide water consumption data for all facilities reported in W3.2a
Facility reference number
Consumption (megaliters/year)
How does this compare to
the last reporting year?
Facility 1
18370.60
About the same
Facility 2
16572.53
About the same
Facility 3
47134.48
About the same
Facility 4
536.19
About the same
Facility 5
515.34
About the same
Facility 6
568591.56
About the same
Facility 7
0.00
About the same
Facility 8
1.99
About the same
Facility 9
857.81
About the same
Facility 10
345.84
About the same
Facility 11
34683.75
About the same
Facility 12
2.23
About the same
Facility 13
19460.80
About the same
Facility 14
0.00
About the same
Facility 15
19271.53
About the same
Facility 16
1825.44
About the same
Facility 17
2513.10
About the same
Please explain
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
About the same because generation was about
the same
W5.4
For all facilities reported in W3.2a what proportion of their water accounting data has been externally verified?
Water aspect
%
verification
Water withdrawals- total volumes
Not verified
Water withdrawals- volume by
sources
Not verified
Water discharges- total volumes
Not verified
Water discharges- volume by
destination
Not verified
Water discharges- volume by
treatment method
Not verified
Water discharge quality dataquality by standard effluent
parameters
Not verified
Water consumption- total volume
Not verified
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
What standard and methodology was used?
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
We report water data to regulatory agencies in compliance with environmental permits. All reports require
legally responsible company executive signatures. The method and frequency of verification are within the
discretion of the regulatory agencies.
Module: Response
Page: W6. Governance and Strategy
W6.1
Who has the highest level of direct responsibility for water within your organization and how frequently are they briefed?
Highest level of direct
responsibility for water issues
Board of individuals/Sub-set of
the Board or other committee
appointed by the Board
Frequency of
briefings on
water issues
Comment
The Executive Committee, led by the President and CEO, addresses strategic water issues. The Exelon
board delegated corporate governance committee oversees strategies and efforts to improve the
environment, including climate change and sustainability policies and programs, and strategic water issues.
Exelon’s Chief Sustainability Officer is briefed quarterly or more frequently and is responsible for
implementation of the Exelon Corporate Environment Policy, Water Resources Policy, and EMS.
W6.2
Is water management integrated into your business strategy?
Yes
W6.2a
Please choose the option(s) below that best explains how water has positively influenced your business strategy
Influence of water on business
strategy
Alignment of public policy
positions with water stewardship
goals
Accelerating vital research and
development
Exploration of water valuation
practices
Greater due diligence
Introduction of water
management KPIs
Investment in staff/training
Water resource considerations
are factored into location
planning for new operations
Water resource considerations
are factored into new market
exploration
Please explain
Exelon public policy staff participates in opportunities to align public policy with our water stewardship goals; supporting
research into public water policy issues; providing technical input to legislation and the regulatory processes, federal, state
and local. Examples: Clean Water Act cooling water intake 316(b) and thermal discharge 316(a) regulations, Waters of the
US, Steam Electric Effluent Guidelines. Our goals are based on greatest opportunities for value; while addressing
environmental impacts.
Exelon’s support of vital research and development includes: support of the Electric Power Research Institute's studies in
water resource availability, entrainment and impingement, and other wide ranging water resource management and
sustainability issues. We completed over 47 environmental studies in support of hydro relicensing including species of
concern studies for the American Shad and American Eel, fish passage projects and water quality. Our Quad Cities facility
supports fish hatchery research and operations.
Water and Land Management Best Management Practices review explores valuation of BMPs in four different ways:
intangible values, value of ecological services to the community, realized shareholder value, and risk reduction. Our
corporate Water Resources Management Policy mandates that we use BMPs to improve life-cycle water use and water
quality and reduce risk of adverse impacts on operations and the environment. Our goals are based on key issues and
greatest opportunities for value.
Water due diligence is part of company Merger and Acquisition procedures. We conduct extensive review of permits,
compliance and performance, as well as assessment of fatal flaws and environmental issues that relate to the project.
Exelon’s Environment Policy has full compliance with laws and regulations as a key principle and corporate-wide goals for
reducing spills have been established and performance is reported to management. One of our corporate KPIs is Zero
Preventable Reportable Spills. Distinguished goal of Zero Notices of Violation and Permit Non-Compliances.
We have trained staff specialized in compliance and the Exelon Environmental Management System. All company
employees receive environmental awareness training appropriate to their job functions, in keeping with our ISO 14001
certifications. Our field operations personnel receive spill and wetlands/endangered species avian protection training in
addition. We engage our employees with Eco-Team year-round volunteer events, as well as the Wildlife Habitat Council,
National Wildlife Federation and Audubon certification projects.
Our Water Resources Management Policy mandates that we ensure adequate and economical water supplies, enhance
water quality, preserve and restore biodiversity, and maintain quality community recreational areas. Fatal flaw analyses
carried out as implementation of our Water Policy will identify the water resource and other environmental issues of the site
with regard to the requirements of the proposed technology and the lifespan of the project. As an example, we constructed
two combined-cycle gas turbine (CCGT) units in Texas utilizing a new General Electric technology that makes them among
the cleanest, most efficient CCGTs in the state and the nation. Each new unit will add approximately 1,000 MW of capacity
to their respective sites; being mindful of increased water efficiency in drought-prone Texas, the new units will be cooled with
air instead of the traditional water cooling.
Integration of low-water intensity renewables, such as Exelon wind and solar, is important to our vision of the energy power
grid of the future. Exelon is ranked 12th in the U.S. for wind energy capacity and is the fourth largest owner and operator of
commercial private solar in the U.S. Exelon Generation has several utility-scale solar projects including the 242 MW
Influence of water on business
strategy
Publicly demonstrated our
commitment to water
Water is factored into
procurement directives
Tighter operational performance
standards
Other: Watershed stewardship
Water resource considerations
are factored into site expansions
Please explain
Antelope Valley project in southern California and the 9 MW City Solar project in Chicago, and commenced commercial
operation of the 10 MW Clinton Battery Storage facility in Ohio in 2016. Our Constellation business has a distribution
agreement with Bloom to market 60 MW of fuel cells, and PHI Delmarva Power has a 30 MW agreement with Bloom in
Delaware. We are investing in technology that will enable the interconnected power grid of the future such as ComEd’s two
micropower grid projects, one with IIT in the Bronzeville neighborhood and another focused on deployment of a network of
micropower grids. PECO obtained regulatory commission approval in October 2015 to invest an additional $274 million
through 2020, to install advanced equipment, explore micropower grids and reinforce the future electric system to make it
more weather resistant and less vulnerable to storm damage.
Our Corporate Responsibility Report conveys our commitment to sustainable management of water resources. We have
also published our Water Resources Management Policy, approved by our CEO. Our qualitative watershed stewardship
goals, Key Performance Indicators (KPIs) for water compliance and our Water Resources Management Policy, and
Biodiversity and Habitat Policy (new 2015) demonstrate our public commitment.
Exelon participates in the Electric Utility Sustainable Supply Chain Alliance voluntary procurement standards and supply
chain environmental management practices, including environmental compliance, and water use. These best management
procurement practices have been implemented with the expectation that our suppliers will lessen their environmental
impacts, including water use. Exelon's procurement process weighs supplier environmental performance as 7% of the
evaluation.
Our Water Resources Management Policy mandates Best Management Practices (BMP) and standards, to improve lifecycle water use and water quality and reduce risk of adverse impacts on operations and the environment. Exelon generation
and utilities report performance against the established targets monthly to the Executive Committee and to the Generation
Oversight Committee and performance is reviewed quarterly by senior leadership and at least annually with the Board and
the Chairman/CEO.
Our commitment to watershed stewardship and education is demonstrated through 32 site certifications from the Wildlife
Habitat Council; 27 sites by the National Wildlife Federation, seven Audubon Bird-Friendly habitat certification, as well as
habitat protection and restoration projects that are part of our national participation and support of NGOs. Since the early
1970s, Exelon and our predecessor companies have contributed to efforts to facilitate migration of American Shad within the
Susquehanna River Basin via two fish lifts at our Conowingo facility. The East Fish Lift, operational in 1991, has a design
capacity to support upriver migration of approximately 2 million migratory fish per year, and through 2016, this lift has passed
a total of 1,363,881 American Shad. The smaller fish lift on the western side of the dam, which began operation in 1972,
continues to support U.S. Fish and Wildlife Service activities related to the study of American Shad. In addition, our Limerick
facility won the Schuylkill River Legacy Award for leadership in 2016 for establishing and supporting the Schuylkill River
Restoration Fund and preserving the historic Frick’s Lock Village.
Exelon Generation constructed two combined-cycle gas turbine (CCGT) units in Texas utilizing a new General Electric
technology that makes them among the cleanest, most efficient CCGTs in the state and the nation. Each new unit adds
approximately 1,000 MW of capacity to their respective sites; being mindful of increased water efficiency in drought-prone
Texas, the new units will be cooled with air instead of water.
Influence of water on business
strategy
Accelerating vital research and
development
Other: Developing resilience to
climate change
Establishment of sustainability
goals
Establishment of sustainability
goals
Please explain
Exelon supports the MIT Joint Program on the Science and Policy of Global Change (Joint Program): Climate change
impacts the water cycles in the watersheds Exelon depends on to cool our thermal electric generating fleet. The Joint
Program seeks to provide an integrated analysis of how climate and environmental change affects natural and managed
systems, the economic consequences of those effects, the role of adaptation, and the resulting feedbacks on emissions and
mitigation. Exelon also supports the MIT Energy Initiative which coordinates energy research, education, and outreach, and
assists in the development of technologies and solutions that will deliver clean, affordable, and plentiful sources of energy.
The Energy Initiative pairs MIT research teams and government and industry members to advance research, education and
outreach in areas such as carbon capture, utilization and storage; energy bioscience, energy storage and solar energy
among others. Exelon supports the Joint Program and the Energy Initiative in our efforts to make decisions for the electric
system of the 21st century from a basis of enlightened scientific analysis and informed policy making.
Exelon participates in the Department of Energy Partnership for Energy Sector Climate Resilience. DOE established this
Partnership with a focus on enhancing energy security by collaborating with the private sector to establish a 21st century
energy system resilient to extreme weather and climate change. The Partnership seeks to facilitate risk-based decisions and
greater investment in cost-effective strategies for a more climate-resilient power sector. Exelon has undertaken a Climate
Change Vulnerability Assessment intended to serve as a tool for communicating consistently and comprehensively about the
physical impacts of climate change on Exelon and the steps the company has been taking to address these risks. Corporate
Strategy, in consultation with the business units is developed a Strategic Plan for Climate Change Resilience, which was
completed in 2016, as part of participation and best practices sharing within the Partnership. In general, the initiatives that
have been implemented that support maintaining and increasing resiliency, fall into several key areas: investments to harden
existing and new T&D infrastructure and generating plants; enhancing emergency response programs to more effectively
and efficiently restore operability following severe events; and, conducting assessments and research to gain a better
understanding of future changes in support of developing appropriate responses for ensuring service and protecting
investments.
Exelon’s utilities recognize the untapped biodiversity and ecological services resource that the thousands of acres our power
line right-of-ways (ROWs) represent, and adopted their Integrated Vegetation Management Initiative Charter in 2015. For
the last six years we have been undertaking pilot studies in Integrated Vegetation Management (IVM), and are going forward
with scale efforts. We believe there is sustainable value for our shareholders in IVM for native species on our ROWs.
Watershed community benefits include preservation (and creation) of wetlands, native prairie, and forest. The wildlife
benefits of IVM on our BGE South River Greenway project were documented by the USFWS and USGS. PHI employs a
selective management strategy within its ROWs to promote natural habitat and actively manages for wildlife benefits along
two ROW segments which serve as U.S. FWS research sites.
In 2014, Exelon implemented its Biodiversity and Habitat Policy to help guide our efforts in activities ranging from avian
protection to integrated vegetation management (IVM). Exelon is committed to promoting and enhancing biodiversity
through natural resource conservation and protecting species and habitats, while maintaining safe, efficient and effective
operations. Enhancing the ability of our assets to provide habitats and contribute to biodiversity adds value: direct
shareholder value; enhanced relationships with stakeholders and agencies; and ecological services to the community.
Habitats and the biodiversity they support also add intangible values such as improved community aesthetics and
Influence of water on business
strategy
Please explain
opportunities for education and recreation. Our Biodiversity and Habitats Policy states that we will act responsibly as
stewards of the environment by enhancing biodiversity and habitats for others, ourselves, and future generations.
W6.2b
Please choose the option(s) below that best explains how water has negatively influenced your business strategy
Influence of
water on
business
strategy
Closure of
operations
Please explain
Exelon decided to retire Oyster Creek plant no later than December 31, 2019, ten years ahead of the 2029 license expiration, due to NJDEP’s
determination of the need to retrofit existing once-through cooling system to a closed-cycle cooling system and the limited remaining operating
life of Oyster Creek. NJDEP has determined that the existing measures at Oyster Creek represent the best technology available through 2019.
Cost of closed-cycle cooling towers would have exceeded $800 million.
W6.2c
Please choose the option that best explains why your organization does not integrate water management into its business strategy and discuss any
future plans to do so
Primary reason
Please explain
W6.3
Does your organization have a water policy that sets out clear goals and guidelines for action?
Yes
W6.3a
Please select the content that best describes your water policy (tick all that apply)
Content
Publicly available
Company-wide
Performance standards for direct
operations
Performance standards for
supplier, procurement and
contracting best practice
Commitment to customer
education
Incorporated within group
environmental, sustainability or
EHS policy
Acknowledges the human right to
water, sanitation and hygiene
Please explain why this content is included
Exelon's Water Resources Management Policy guides our efforts to: institutionalize the management of water as an essential
natural resource for sustained operations; continuously improve our management of water resources, prevent pollution, and
comply with all applicable water use laws and regulations, with the objective of advancing water resource management
beyond compliance to create or protect value; understand natural and man-made impacts on water resources, including
climate change, and continuously adapt strategies and plans to address these issues; engage local and other relevant
stakeholders when addressing water issues including those related to operational changes, development of strategic plans,
or public policy advocacy; and, build goodwill and enhance the Exelon brand by collaborating with communities and other
interested parties to address opportunities for protecting and enhancing watershed resources.
W6.4
How does your organization's water-related capital expenditure (CAPEX) and operating expenditure (OPEX) during the most recent reporting year
compare to the previous reporting year?
Water
CAPEX
(+/- %
change)
0
Water
OPEX (+/%
change)
-5
Motivation for these changes
Total water-related CAPEX is not accounted separately; water related aspects of large CAPEX Project costs are not tracked as “water
related.” Water-related OPEX for GenCo Nuclear is about $3.4 million; and GenCo Power is about $10.4 million, for a total for the
generation businesses of $13.8 million. OPEX includes: Water Use Rights; NPDES Annual Compliance Fees; NPDES Sampling:
Permit Renewals; Wetlands Protection; O & M Costs for Water systems; O&M costs for cooling water; wastewater treatment O&M
costs, and any penalties of fines for water related non-compliance.” The principal decrease was for water use rights for GenCo
Nuclear.
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Attachments
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/Jury, Kevin Abstract.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/Conowingo eels.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/ComEd Restore our Prairies and
Grasslands.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/BGE Patuxent National Research
Refuge ROW Partnership.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared
Documents/Attachments/Water2017/W6.GovernanceandStrategy/Summary_wildlife_surveys_BGE_ROW_final south river greenway.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/EN-AC-1 Environmental Policy Rev 5
Signed.docx
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/2016_Quad Cities Fish Hatchery.docx
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/Exelon Kennett WaW (2).pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/PRR Pepco ROW VM Plan 2015
Partial.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W6.GovernanceandStrategy/FINAL News Release MD Parks IVM
11.09.16.docx
Page: W7. Compliance
W7.1
Was your organization subject to any penalties, fines and/or enforcement orders for breaches of abstraction licenses, discharge consents or other water
and wastewater related regulations in the reporting year?
Yes, not significant
W7.1a
Please describe the penalties, fines and/or enforcement orders for breaches of abstraction licenses, discharge consents or other water and wastewater
related regulations and your plans for resolving them
Facility
name
Wolf Hollow
Generating
Station
PHI (Pepco)
Benning
Service
Center
Incident
Incident description
Frequency
of
occurrence
in
reporting
year
Financial
Currency
impact
Fine
During a wastewater inspection it was
discovered that the pH meter calibrations
were not being conducted as required by
the permit.
1
48937
USD($)
Enforcement
order
On October 30, 2015, the U.S. EPA filed a
Clean Water Act civil enforcement action
against Pepco in Federal District Court for
violations of metal limits of the National
Pollutant Discharge Elimination System
(NPDES) for stormwater discharges from
4
2100000
USD($)
Incident resolution
Corrective actions were put in place to
ensure calibrations were conducted as
required by the permit including updating of
tasks in the environmental management
information system to trigger calibration
notifications.
Pepco has paid a civil penalty in the amount
of $1.6 million. Pepco will continue
implementing its comprehensive program of
using best management practices for
reducing the concentrations of metals in
permitted storm water discharges from the
Facility
name
Incident
Incident description
Frequency
of
occurrence
in
reporting
year
Financial
Currency
impact
the Benning Service Center. Pepco
reached an agreement in principle with the
EPA on the settlement terms as of
November 4, 2016. The terms and
conditions were documented in a consent
decree which has been approved by the
Court.
W7.1b
What proportion of your total facilities/operations are associated with the incidents listed in W7.1a?
1%
W7.1c
Incident resolution
site including inspection and maintenance of
storm drain inlets, on-going metals
management and good housekeeping
practices. Pepco has installed new, metal
absorbing filters at more than 90 storm drain
inlets across the property. In 2016, Pepco
constructed a covered warehouse for the
storage of off-line transformers and other
electric equipment while being staged at the
site for processing or disposal. Pepco has
designed and will construct a new storm
water treatment system utilizing filtration
technology to be fully operational by
December 31, 2017. Pepco will also design
and construct a new “green” storm water
retention structure at the facility to completely
eliminate the storm water discharges from
one of the two, permitted discharge points
into the Anacostia River.
Please indicate the total financial impacts of all incidents reported in W7.1a as a proportion of total operating expenditure (OPEX) for the reporting year.
Please also provide a comparison of this proportion compared to the previous reporting year
Impact as % of OPEX
0.00
Comparison to last year
No change
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
Page: W8. Targets and Initiatives
W8.1
Do you have any company wide targets (quantitative) or goals (qualitative) related to water?
Yes, targets and goals
W8.1a
Please complete the following table with information on company wide quantitative targets (ongoing or reached completion during the reporting period)
and an indication of progress made
Category of
target
Motivation
Water
pollution
prevention
Water
stewardship
Water
pollution
prevention
Brand value
protection
Water
pollution
prevention
Risk
mitigation
Water
pollution
prevention
Water
stewardship
Description of target
Distinguished goal of Zero Notices of Violation; The Exelon
Environment Policy commits the company to continually
improving its environmental performance, preventing pollution
and utilizing natural resources more efficiently.
Distinguished goal of Zero Permit Non-Compliances. The
Exelon Environment Policy commits the company to continually
improving its environmental performance, preventing pollution
and utilizing natural resources more efficiently.
Goal: Zero Preventable Reportable Spills. The Exelon
Environment Policy commits the company to continually
improving its environmental performance, preventing pollution
and utilizing natural resources more efficiently.
Distinguished Goal: Zero Reportable Spills. The Exelon
Environment Policy commits the company to continually
improving its environmental performance, preventing pollution
and utilizing natural resources more efficiently.
Quantitative unit of
measurement
Baseline
year
Target
year
Proportion of
target
achieved, %
value
Other: Number of
NOVs
2015
2016
67%
Other: Number of
Permit NonCompliances
2015
2016
56%
Other: Number of
Preventable
Reportable Spills
2015
2016
75%
Other: Number of
Reportable Spills
2015
2016
22%
W8.1b
Please describe any company wide qualitative goals (ongoing or reached completion during the reporting period) and your progress in achieving these
Goal
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Motivation
Risk mitigation
Description of goal
In support of mitigation of unplanned releases of
tritium, Exelon launched an extensive monitoring and
mitigation program, performed risk assessments and
has engaged in regular public outreach with the
surrounding communities, cooperating with regulatory
Progress
Exelon Nuclear has implemented a radiological
groundwater protection program across the nuclear fleet to
identify and mitigate unplanned releases to soils,
groundwater and surface water.
Goal
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Strengthen links with
local community
Motivation
Water
stewardship
Water
stewardship
Description of goal
agencies and elected officials. We also adopted the
Nuclear Energy Institute program 07-07 for the
prevention of tritium releases and 09-14 for the
protection and monitoring of buried piping and tanks
containing hazardous substances.
Exelon participates in management of watershed
issues where it has operations (e.g., Susquehanna
River Basin Commission, Delaware River Basin
Commission, and Barnegat Bay National Estuary
Program). Exelon collaborates with environmental
NGOs and wildlife organizations to preserve, protect
and restore sensitive habitats (e.g., Wildlife Habitat
Council, Ducks Unlimited, Partnership for the Delaware
Estuary, Trout Unlimited and the Water Resources
Association for the Delaware River Basin, Center for
Inland Bays, Anacostia Watershed Society, Delaware
Nature Society, The Nature Conservancy, and many
others.
Wildlife Habitat Council (WHC) and National Wildlife
Federation (NWF) certificated wildlife habitat projects
and programs help educate employees and the
community at large, making global sustainability issues
part of our everyday lives. Nuclear power plants, in
particular, tend to include significant buffer areas within
their boundaries, making them ideal locations for
habitat conservation efforts, while utility right-of-ways
have the potential for a network of habitat through
community greenways managed for native vegetation,
we refer to as Integrated Vegetation Management
(IVM).
Progress
Ongoing representation, support and presentation at
organizational meetings and forums.
Exelon has a longstanding partnership with the Wildlife
Habitat Council (WHC) to restore and enhance wildlife
habitats at our facilities and on our ROWs. Exelon has
been a member of the WHC for more than 11 years and
has accrued a total of 32 sites with WHC certifications. The
WHC Certification Program provides us with a guidance
tool and objective oversight for creating and maintaining
high-quality wildlife habitats, as well as implementing
environmental education programs. Three of our facilities
and twenty-four of our ROWs have National Wildlife
Federation habitat certifications, and one facility has an
Audubon Bird-Friendly habitat certification. The PHI Pepco
WaterShed Sustainability Center in Rockville, MD which
has a WHC certification, is open to the public, including
students and educators, providing community education
and outreach by combining hands-on learning with
interactive displays that educate visitors and help them
apply the lessons of WaterShed in their own homes. The
Center is also a working laboratory for collaboration
between Pepco and the University of Maryland, focused on
Goal
Motivation
Description of goal
Progress
advances in energy efficiency and sustainable living.
Strengthen links with
local community
Engagement with
public policy makers
to advance
sustainable water
policies and
management
Engagement with
public policy makers
to advance
sustainable water
policies and
management
Water
stewardship
Recommended
sector best
practice
Water
stewardship
Our utilities BGE, ComEd, PECO and PHI have been
implementing a technique for managing vegetation in
their power line ROWs that restores native plant
communities; providing for wildlife habitat that is much
improved over traditional, non-selective mowing
techniques. This “Integrated Vegetation Management”
(IVM), works to develop sustainable plant communities
that are compatible with the safe and reliable operation
of the electrical facilities while controlling non-native
invasive plants, and improving wildlife and pollinator
habitat. “The new aesthetic now is to not to create
more areas of mown grass but to use areas that need
to stay open as pollinator gardens, creating beautiful
landscapes at the same time,” says Sam Droege,
Wildlife Biologist with the U.S. Geological Survey.
For years, Exelon has funded research by the Electric
Power Research Institute (EPRI) on technologies for
fish protection associated with cooling water intake
structures. The results of this research have been
used by Exelon to inform rulemaking process for the
Clean Water Act Section 316 (b) water intake
regulations to ensure that the final regulations consider
all aspects of the issue and technology options.
Identify potential impacts to the American eel and
potential management measures that could be
implemented in the Conowingo relicensing process
and the final Muddy Run FERC license to benefit the
species.
As of 2016, twenty-four ROW segments managed as
Integrated Vegetation Management (IVM) held National
Wildlife Federation (NWF) certifications as wildlife habitat;
sixteen IVM ROWs hold Wildlife Habitat Council (WHC)
certifications, with ten of those IVM ROW segments
holding both certifications. In addition, 6 IVM ROW
segments hold both Audubon Bird-Friendly habitat
certifications and NWF Advanced Bird certifications.
EPRI research as well as technical comments from the
trade association we support (Edison Electric Institute) and
our consulting experts have informed the complex
regulation development process. The US EPA finalized
the Clean Water Act 316(b) Phase II regulations in May,
2014, and the rule became effective October 14, 2014.
In 2013, Exelon received an EPRI Technology Transfer
Award in recognition of our work on the American eel in the
Susquehanna. With EPRI, members of Exelon developed
a first-of-its-kind report that compiles the life history
information of the American eel and implications of
upstream passage at hydroelectric facilities on the
Susquehanna. The report presented data in a manner that
can be applied elsewhere in the United States and
Canada. In 2015, Exelon began operating of a temporary
eel trapping facility on Octoraro Creek in Lancaster County
as part of its commitments of the final Muddy Run FERC
license which continued in 2016. During the 2016 season,
May 1-September 15, the facility collected 21,094 juvenile
eels and transported them to designated stocking sites
Goal
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Motivation
Description of goal
Other: Ecological
Sustainability
Support Threatened and Endangered Species in the
Des Plaines River Valley, Illinois.
Other: Ecological
Sustainability
Support Threatened and Endangered Species: Since
the early 1970s, Exelon and its predecessor
companies have contributed to efforts to facilitate
migration of American shad and other species within
the Susquehanna River Basin via the Conowingo
Hydroelectric Generation Station fishways.
Strengthen links with
local community
Brand value
protection
The smaller fish lift on the west side of the Conowingo
dam continues to support U.S. Fish and Wildlife
Services (USFWS) spawning and stocking activities
related to protecting American shad, as well as
providing support to the USFWS for studies of the
American eel. In an effort of engage stakeholders in
the value of natural resources, Exelon Generation
opens lands for public use.
Watershed
Brand value
Exelon funds a major aquaculture facility at the Quad
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Progress
within the Susquehanna watershed. Exelon is also
working on the design and installation of a permanent eel
passage facility at Conowingo.
In 2013, ComEd submitted a Low-Effect Habitat
Conservation Plan to the USFWS for the Hine’s Emerald
Dragonfly, Blanding’s Turtle, Spotted Turtle, Black-billed
Cuckoo, Lakeside Daisy and Leafy Prairie Clover in the
Des Plaines River Valley. The purpose of this Habitat
Conservation Plan is to evaluate ComEd’s impacts from
routine activities on these species and their habitats, and
to propose conservation measures for avoiding, minimizing
or mitigating impacts. This is an ongoing activity. In 2016,
ComEd underwent two very large projects, including both
distribution and transmission, to relocate and remove
electric lines in the most sensitive areas of the Hine’s
emerald dragonfly area. This will improve reliability while
bettering the species and its habitat. activity.
During the 2016migratory season, Conowingo passed
more than 14,276 American shad via its east fish lift.
Through 2016, this lift has passed a total of 1,363,881
American shad. The east lift also passes many other
species of fish, such as gizzard shad, river herring, striped
bass, small- and large-mouth bass, walleye and others;
over the past five years, an annual average of more than
980,000 of these other species have been passed through
the lift.
Exelon Nuclear is contributing $50,000 per year over five
years (2011 to 2015) to a Pennsylvania Fish and Boat
Commission project to increase egg viability of American
shad in the river. Exelon is maintaining access to these
areas at Exelon’s expense. Exelon Generation provides
public access to its property for a number of recreational
opportunities, including fishing, boating, camping,
hiking/backpacking, bird watching, swimming and nature
photography. The Muddy Run pumped storage facility also
maintains a visitors center and community park land on the
over 700 acres of woods and fields.
The Quad Cities hatchery celebrated its 33rd year of
Goal
remediation and
habitat restoration,
ecosystem
preservation
Strengthen links with
local community
Engagement with
public policy makers
to advance
sustainable water
policies and
management
Motivation
protection
Brand value
protection
Other: Ecological
Sustainability
Engagement with
public policy makers
to advance
sustainable water
policies and
management
Water
stewardship
Engagement with
Water
Description of goal
Cities Nuclear Station in Illinois, in cooperation with
Illinois DNR, Iowa DNR and U.S. Fish and Wildlife
Service, to enhance stocks of several aquatic species
in the area.
The Quad Cities aquaculture program is a valuable
community and regional resource, offering many tours
each year for school groups, local neighbors, fishing
clubs and other resource-oriented groups with an
interest in Mississippi River fisheries.
During 2014, Exelon continued engagement with
interested stakeholders regarding a number of areas,
including fish and eel passage, management of
species of concern, and recreation and shoreline
management. In July 2014, the FERC issued the Draft
Environmental Impact Statement for the Susquehanna
River projects Conowingo and Muddy Run. Exelon
filed comments in response in September and
clarifying information in October 2014 in response to
comments submitted by interested stakeholders.
Exelon served as a participant in the Lower
Susquehanna River Watershed Assessment (LSRWA),
led jointly by the Maryland Department of the
Environment and the U.S. Army Corps of Engineers.
The objective of the three-year LSRWA was to
evaluate sediment and associated nutrient loading and
transport in the Lower Susquehanna River to the
Chesapeake Bay, as well as evaluate sediment and
nutrient load reduction strategies.
Support habitat improvement and stream restoration
Progress
operation. The hatchery produced more than 75,000
healthy walleye advanced fingerlings and more than
35,000 fingerling hybrid striped bass for the Mississippi
River, Clinton Lake and Braidwood Lake. The hatchery
also produced nearly 2,000 harvestable-sized blue catfish
for Clinton Lake in 2016. The hatchery produced 1,597
alligator gar which were stocked throughout the state of
Illinois as part of a species reintroduction program. The
site, in partnership with the agencies, also raised
freshwater mussels such as the federally endangered
Higgin’s Eye Mussel, the state threatened Black Sandshell
and an Iowa species of interest, the Fat Mucket, for
release in local waters.
Ongoing implementation of Exelon’s Water Policy mandate
for community engagement and STEM education.
Exelon continues to work with stakeholders on the
implementation of the Bald Eagle Management Plan and
Bog Turtle Management Plan, which are both a part of the
40-year operating license for Muddy Run, issued by FERC
on December 22, 2015. Conowingo Hydroelectric facility is
still undergoing relicensing with annual renewals of its
FERC license. Exelon continues to work with
stakeholders in support of Conowingo relicensing.
The study found that nutrients have a larger impact on
Chesapeake Bay water quality than sediment; additionally,
the study determined that upstream sources of nutrients
and sediments have a larger impact on Chesapeake Bay
water quality than those contributed by Conowingo Pond
during scour events. A final report was issued in March
2016 with no substantive changes from the draft version.
To better understand the effects of nutrient and sediment
Goal
suppliers to help them
improve water
stewardship
Engagement with
public policy makers
to advance
sustainable water
policies and
management
Other: Transparency
Motivation
stewardship
Water
stewardship
Brand value
protection
Other: Sustainable
Water Supplies
Other:
Sustainable
Revenue
Watershed
remediation and
habitat restoration,
ecosystem
Other:
Community
Engagement
Description of goal
Progress
projects within the watershed that promote the
reduction of sediment and nutrient loads associated
with sediment transport.
transport of Conowingo Pond, Exelon has funded a $3.5
million study involving nutrient and sediment transport in
the Lower Susquehanna River to support the Maryland 401
Water Quality Certification application process. To aid in
efforts to reduce sediment deposition into the Lower
Susquehanna River, Exelon has also funded the Trout
Unlimited stream restoration project on Climbers Run for
six years.
Exelon Supply Management incorporates
environmental performance requirements and
participation in voluntary pollution reduction programs
into the supply procurement process, including
measures to address supplier water use.
In 2016, Exelon Supply Chain continued the use of the
Electric Utility Sustainable Supply Chain Alliance voluntary
procurement standards in alignment with Exelon Water
Resources Management Policy which were implemented in
2015.
Exelon is committed to the Ceres Principles and
annually Ceres facilitates a corporate level review of
Exelon’s material sustainability issues and
performance with a group of interested stakeholders.
Water resource issues and the company’s response
are addressed as part of the review. Exelon also
publishes an annual report on its environmental
performance which includes a discussion of water use
and issues, our 2016 Corporate Social Responsibility
Report (CSR) to be published in June 2017.
Sustainable water supplies which are reliable,
affordable and adequate. Water impacts are diverse,
lending themselves to measurement techniques more
complex than consumptive or non-consumptive use
(gallons/MWh). The disparity in the volume of cooling
water compared to other uses presents a challenge to
combining water use metrics across the energy value
chain. Our goals are based on key issues and
greatest opportunities for value; while addressing
environmental impacts.
In 2016, Exelon contributed over $3.2 million in support
of community environmental activities in the Lake
Ontario; Chesapeake Bay; Delaware Bay; Midwest
(upper Mississippi watersheds); Gulf states and non-
Exelon published an integrated 2016 sustainability
performance report, and conducted a stakeholder review of
Exelon's material sustainability issues, facilitated by the
international NGO Ceres.
Exelon completed a hydrology/climate modelling study for
our Braidwood facility in 2014. Since then Exelon is
continuing to pursue cutting-edge research and preeminent researchers (such as the MIT Global Change
Forum) in an effort to better understand potential climate
and water impacts and to help push the current limits of the
state of art modelling in the most efficient and effective
manner by accessing both public and private institutions.
These contributions continue to support a broad range of
environmental education, sustainability initiatives, and
watershed improvement projects by local governments and
non-governmental non-profit groups.
Goal
Motivation
preservation
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Risk mitigation
Description of goal
Gulf watersheds west of the Mississippi.
Seasonal variations of temperature and river flow rate
could potentially limit water intake needed by the
Limerick plant. To address these limitations, Exelon
collaborated with numerous regulatory agencies and
environmental stakeholders to develop a flow
augmentation alternative.
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Shared value
In upholding our Biodiversity Policy, we maintain
special management plans to protect biodiversity on
our sites and rights of ways. For example, our utilities
each have a detailed Avian Protection Plan to manage
interactions of birds and power lines. Where
threatened or endangered species are located on or
near our sites, we work with regulatory agencies to
develop and implement agreed-upon management
plans or special mitigations to reduce impacts on
wildlife as part of the permitting process.
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Other: Employee
Engagement
In 2013, we initiated an annual Exelon Environmental
Achievement Awards program, providing a way to
honor employees who are working on innovative
projects to benefit the environment.
Watershed
remediation and
Shared value
In 2014, we implemented our Biodiversity and Habitat
Policy, to help guide our efforts in activities ranging
Progress
The flow augmentation alternative continues to allow mine
water to be used to supplement flow in the Schuylkill River,
allowing the plant to continue to use the Schuylkill rather
than the Delaware River as its primary source. This
project has demonstrated that mine water can be a viable
option. It has been made part of the docket.
Recent actions have included ComEd’s development of a
Low-Effect Habitat Conservation Plan for the Des Plaines
River Valley in Illinois to protect several threatened and
endangered species. Exelon Generation’s protection of a
cave hibernaculum for the Indiana Bat as part of our
incidental take permit for the Criterion Wind Farm in
Maryland continues to provide habitat for endangered bats.
Also, Exelon Generation has enrolled in the Western
Association of Fish and Wildlife Agencies’ Range-wide
Conservation Plan for the Lesser Prairie Chicken and is
implementing the agreement at the Bluestem Wind Farm to
minimize and mitigate potential impacts to that species. In
addition, we installed bird-flight diverters on approximately
3 miles of transmission line that runs near high priority
wetland playas located in the vicinity of Bluestem to
minimize potential impacts to avian species such as
waterfowl and cranes like sandhills and endangered
whooping cranes which use these desert wetland areas for
refuge.
This year’s winners were announced in June 2016. There
were 73 nominations for the Exelon Environmental
Achievement Awards and 56 nominations for the Exelon
Safety Achievement Awards. Nominations were submitted
from all operating groups – utilities, power generation and
from Constellation. This is an impressive testimony to the
excellence and professionalism of our employees in
exceeding the requirements of their jobs and truly adding
value to our communities and the company in meaningful
ways related to safety and environmental stewardship.
In November 2015, Exelon Utilities formally adopted the
Integrated Vegetation Management Initiative, which sets
Goal
Motivation
habitat restoration,
ecosystem
preservation
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Description of goal
from avian protection to integrated vegetation
management.
Recommended
sector best
practice
PECO is an industry leader in the implementation of
Integrated Vegetation Management (IVM). IVM aligns
very strongly with the policy intent and implementation
statements contained in the Exelon Corporate Policy
for Biodiversity and Habitat (EN-AC-4). PECO utilizes
IVM throughout its 11,000 acres of ROW with 3,626
acres being certified and managed for habitat
conservation.
Recommended
sector best
practice
BGE actively manages approximately 7,000 acres of
its total 10,500 acres of ROW to control tall-growing
vegetation. Of the 7,000 acres, approximately 1,200
acres are sustainably managed using Integrated
Vegetation Management (IVM) techniques to
encourage low-growing indigenous plants that create
favorable conditions for native pollinators and other
fauna. Research is being conducted at three sites to
evaluate the impacts to pollinators and document the
transition of the plant communities that are resulting
from the IVM practices.
Progress
out milestones to be achieved with the following objectives:
Develop aligned Integrated Vegetation Management tools
for transmission vegetation management; Implement a
standard EU approach for how to classify IVM site
categories; Define IVM strategies based on goals and
objectives of each IVM site category. The expected results
will be to: Optimize transmission vegetation management
programs, and; Align with Exelon Corporate Habitat and
Biodiversity Policy (EN-AC-4). Other implementation in
2016 has included projects in pollinator support plantings
and avian protection plans and procedures.
PECO has co-sponsored scientific research into IVM on
electric transmission right-of-ways in a continuous study
since 1987. PECO owns the study site (a 500kV right-ofway). PECO has taken the lessons from this research and
applied them to over 2,000 acres of electric transmission
right-of-ways. PECO has worked cooperatively with
environmental organizations and local communities on
projects that align with Exelon Corporate Policy for
Biodiversity and Habitat (EN-AC-4). PECO is now
working with Wildlife Habitat Council on a GIS Tool for the
systematic assessment of electric transmission right-ofways that will identify sites for a variety of purposes, for
example: community involvement, avian protection,
conversion to IVM, partnership with neighboring
conversation projects, pollinator projects, and monarch
butterfly waystations.
The USFWS recognized BGE’s efforts on the IVM pilot
project in the South River Greenway in Maryland. Since
2010, BGE has collaborated with the USFWS, USGS and
other groups to conduct long-term monitoring of a variety
of bird, bee and butterfly species in the ROW. BGE will
continue to work with the USFWS to implement IVM
techniques in other ROW areas throughout its territory.
Goal
Other: Pollution
Prevention
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Motivation
Risk mitigation
Recommended
sector best
practice
Recommended
sector best
practice
Shared value
Description of goal
Progress
Removal of water from subsurface manholes for
completing electrical work is an ongoing issue for
Exelon’s utilities. Typically, manhole water is
discharged to storm sewers after being field-filtered for
contaminants. At PECO, small volumes of water are
transported via tanker truck to a central wastewater
treatment plant where the multi-stage filtration is
completed prior to discharge to the Philadelphia Water
Department system.
This treatment plant recently received a Silver Award from
the Philadelphia Water Department for three consecutive
years of 100 percent compliance. Currently, PECO is
constructing a mobile wastewater treatment plant that will
be used to field-filter manhole water to reduce the amount
of truck traffic transporting water to the centralized water
treatment plant.
Vegetation on transmission line ROW must be
managed on a regular basis to ensure system
reliability. This ongoing upkeep presents an
opportunity for instituting management practices that
benefit plants and wildlife that require open, lowgrowing habitats. We undertake a number of initiatives
to promote diverse habitats in our ROWs.
In ComEd’s territory, most of the 30,000 acres of
transmission ROW are natural green space, including
almost 300 acres of native prairie grass. This effort helps
to sequester CO2, prevent runoff and improve water
quality, while restoring wildlife habitat. We have partnered
with local agencies such as multiple forest preserve
districts and conservation agencies to manage
transmission rights of way in conjunction with larger
restoration projects. All of ComEd right-of-ways will be
assessed for viable IVM in the upcoming years.
PHI employs a selective management strategy for its
approximately 31,000 acres of ROWs to control tallgrowing vegetation. Of the 31,000 acres,
approximately 8,000 acres are sustainably managed
using Integrated Vegetation Management (IVM)
techniques to encourage low-growing indigenous
plants that create favorable conditions for native
pollinators and other fauna. This includes two right-ofway segments located at Sligo Creek and Patuxent
Wildlife Research Refuge where 15 and 65 acres,
respectively, are actively managed for wildlife benefits.
PHI (Pepco’s) efforts involving IVM on portions of its
transmission ROWs in Maryland have been recognized
by the WHC.
Exelon Generation headquarters in Kennett Square,
Pennsylvania, won North American Pollinator
Protection Campaign (NAPPC) and Wildlife Habitat
Council awards for its pollinator garden and ongoing
environmental education efforts at the site. We also
The USFWS recently recognized PHI’s efforts on the IVM
project in the Patuxent Wildlife Research Refuge in
Maryland. PHI actively collaborates with the USFWS to
conduct long-term monitoring of a variety of bird, bee and
butterfly species in the ROW. PHI will continue to work with
the USFWS to implement IVM techniques in other ROW
areas throughout its territory.
The seed planting was completed in conjunction with our
Take Your Child to Work Day. Nearly 100 participants of all
ages planted more than 800 plants and two pounds of
seed across the two meadows. Additionally, the children
participating attended workshops on energy conservation,
Goal
Motivation
Description of goal
won the Pennsylvania Governor’s Environmental
Excellence Award for our work. The Kennett Square
campus has two large open meadows. In 2014, we
worked to enhance these meadow areas with newly
planted and horticulturist-approved plant species to
support the Monarch butterfly population.
Water
stewardship
Exelon Generation is building two combined-cycle gas
turbine (CCGT) units in Texas utilizing a new General
Electric technology that will make them among the
cleanest, most efficient CCGTs in the state and the
nation.
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Shared value
Here at Exelon’s utilities we are recognizing the
untapped biodiversity and ecological services resource
that the thousands of acres our power line right-ofways represent.
Watershed
remediation and
habitat restoration,
ecosystem
preservation
Shared value
Exelon’s operation of the fish ladder at Blackrock Dam
on the Schuylkill river.
Other: Sustainable
Development
Strengthen links with
local community
Brand value
protection
Watershed
Water
Delaware Valley Science Fair. Local outreach to
strengthen community with our efforts to improve
STEM education in the community. By doing a
research project, students develop critical problem
solving skills that they will need for careers, college,
and citizenship. Schools located in NJ, DE and PA.
Conowingo Dam has an ongoing debris management
Progress
climate change, and nuclear, wind and solar energy. We
will continue to monitor species growth over time to find
ways to enhance this program in the future.
Each new unit will add approximately 1,000 MW of
capacity to their respective sites; being mindful of
increased water efficiency in drought-prone Texas, the new
units will be cooled with air instead of water. These units
are under construction and are scheduled to be online in
2017.
For the last five years, we have been undertaking pilot
studies in Integrated Vegetation Management (IVM), and
are ready to go forward with scale efforts. We believe
there is sustainable value for our shareholders in
Integrated Vegetation Management (IVM) for native
species, as well as our preservation (and creation) of
wetlands, native prairie, and forest (see attached summary
by the USFWS of BGE South River Greenway project).
IVM Objectives at Exelon: manage electric transmission
right-of-ways in a cost-effective and reliable manner;
comply with all applicable laws and regulations; maintain
ISO 14001 Certification through an Environmental
Management System; and, establish and maintain power
line compatible native plant communities in right-of-ways.
Exelon’s continued operation of the fish ladder at
Blackrock Dam on the Schuylkill river to works to improve
upstream migration of American shad and other resident
fish species. This fishway has been in operation since
2010.
Exelon Generation donated over $11,000 and had over 13
employees volunteer as judges at the regional competition
in April. There were 891 projects with 933 students
involving 437 teachers in 315 schools. Out of these, 14
students went on to compete at the Intel International
Science and Engineering Fair (ISEF).
Cranes on top of the dam scoop up debris floating on the
Goal
remediation and
habitat restoration,
ecosystem
preservation
Strengthen links with
local community
Motivation
stewardship
Shared value
Description of goal
plan to remove material. On average, Conowingo
removes 600 tons of debris per year from Conowingo
Pond, and all of the material is recycled.
Our Green Region partnership with Openlands awards
grants for municipal efforts to plan for, protect and
improve open land in ComEd’s service area.
Progress
surface of the pond, all of which has been segregated and
recycled. Conowingo Dam recently purchased a skimmer
boat especially designed that will help with on-going debris
management. All 600 tons of material collected was
recycled.
Since the program’s inception, over $700,000 has been
awarded in grants for approximately 85 different projects to
municipalities, park districts, and forest preserve districts
throughout northern Illinois. The funds are provided in
support of the grantees’ continuing efforts to conserve and
improve public open spaces. The Green Region program
in Illinois—a joint effort by ComEd and Openlands to fund
municipal conservation and environmental projects—
relieves some of the financial strain faced by municipalities
forced to make significant cuts to environmental programs
due to budget constraints. The grants fund open space
projects at the municipal level focusing on conservation,
preservation, protecting endangered species, and
improvements to local parks and recreation resources.
Each grant applicant was eligible for a maximum of
$10,000 per project.
W8.1c
Please explain why you do not have any water-related targets or goals and discuss any plans to develop these in the future
Further Information
Distinguished goal of Zero Notices of Violation; The Exelon Environment Policy commits the company to continually improving its environmental performance,
preventing pollution and utilizing natural resources more efficiently.
Number of NOVs: 67% - 6 of 9 Business units Distinguished goal of Zero Permit NonCompliances. The Exelon Environment Policy commits the company to continually improving its environmental performance, preventing pollution and utilizing
natural resources more efficiently. Number of Permit Non-Compliances: 56% - 5 of 9 Business units. Goal: Zero Preventable Reportable Spills. The Exelon
Environment Policy commits the company to continually improving its environmental performance, preventing pollution and utilizing natural resources more
efficiently. Number of Preventable Reportable Spills: 75% - 3 of 4. Utilities. Distinguished Goal: Zero Reportable Spills. The Exelon Environment Policy commits the
company to continually improving its environmental performance, preventing pollution and utilizing natural resources more efficiently. Number of Reportable Spills:
22% - 2 of 9 Business units had 0 reportable spills.
Attachments
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/ROWHabitatGroupPresentation1-1916.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/Conowingo eels.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/Exelon Kennett WaW (2).pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/EN-AC-1 Environmental Policy Rev 5
Signed.docx
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/BGE Patuxent National Research Refuge
ROW Partnership.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/PRR Pepco ROW VM Plan 2015
Partial.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/2016_Quad Cities Fish Hatchery.docx
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/ComEd Restore our Prairies and
Grasslands.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared
Documents/Attachments/Water2017/W8.TargetsandInitiatives/Summary_wildlife_surveys_BGE_ROW_final south river greenway.pdf
https://www.cdp.net/sites/2017/13/6113/Water 2017/Shared Documents/Attachments/Water2017/W8.TargetsandInitiatives/FINAL News Release MD Parks IVM
11.09.16.docx
Module: Linkages/Tradeoff
Page: W9. Managing trade-offs between water and other environmental issues
W9.1
Has your organization identified any linkages or trade-offs between water and other environmental issues in its value chain?
Yes
W9.1a
Please describe the linkages or trade-offs and the related management policy or action
Environmental issues
Linkage
or
tradeoff
Proposed regulations under the Clean Water Act Section 316(b) establish
national requirements for reducing the adverse impacts to aquatic
organisms at existing generating stations and could require operational
and design changes at affected Exelon power plants. Exelon operates the
Oyster Creek nuclear power plant which is licensed by the Nuclear
Regulatory Commission to operate until 2029. The plant has the capacity
to produce 625 MW of low carbon electric generation.
Tradeoff
Proposed regulations under the Clean Water Act Section 316(b) establish
national requirements for reducing the adverse impacts to aquatic
organisms at existing generating stations and could require operational
and design changes at affected Exelon power plants.
Tradeoff
Air pollution (NOx) emissions controls: wet scrubbing of power plant
emissions to remove acid gasses.
Tradeoff
Water spray used in combustion turbines to increase efficiency (decrease
CO2 intensity) and lower NOx emissions.
Tradeoff
When compared with dry cooled systems, conventional water-cooled
steam turbines deliver an additional 10% of useable electric energy from
Tradeoff
Policy or action
On December 8, 2010, Exelon announced that it had decided to retire the
Oyster Creek nuclear plant ten years earlier than originally planned due
the increased expense of potentially having to meet more stringent water
permit conditions associated with the cooling water intake systems. The
total cost impact to the plant for the installation of closed-cycle cooling
towers would have exceeded $800 million over the remaining life of the
plant through 2029. As a result of this premature shutdown, Exelon’s
goal for reducing offsetting and displacing 17.5 million tonnes of GHG
emissions will be adversely impacted as the low carbon nuclear
generation from the plant will need to be replaced with a mix of
generation, including some GHG emitting fossil generation.
Should regulations require retrofitting cooling towers, increased energy
consumption required to operate closed loop cooling systems at other
Nuclear facilities where equipment may already be present but will have
to be operated more often would result in increased GHG emissions and
reduced operational efficiency. Decreased efficiency of electric power
production requiring more fuels with greater emissions and/or greater
energy consumption at the plant site for mechanical cooling equipment.
Increased cost of implementation of low/no water use technologies for
cooling in the thermoelectric cycle.
Increased water consumption resulting from operation of pollution
controls at fossil-fuel (gas) power production facilities. Not an issue with
nuclear power generation.
Increased water consumption resulting from efficiency and pollution
control practices at combustion turbine (gas and oil) power production
facilities. Not an issue with nuclear power generation.
A water-CO2 emissions trade-off is created as increased withdrawal of
water lowers fuel consumption, waste generation, and associated air
Environmental issues
Linkage
or
tradeoff
the same fuel input.
Thermal discharges from steam electric generating facilities US Clean
Water Act Section 316(a).
Tradeoff
Policy or action
emissions.
Thermal steam electric generating facilities rely on water for various uses
including cooling in the thermal cycle, mechanical cooling, steam
generation, pollution controls, fuels and waste management. The
preponderance of water withdrawn for use in thermoelectric power plants
is used for thermal cooling. A constant flow of low-temperature cooling
water allows more energy to be extracted from the system by providing a
low-pressure sink for the exhausted steam as it leaves the steam turbine
where the energy is generated. When compared with dry cooled systems,
conventional water-cooled steam turbines deliver an additional 10% of
useable electric energy from the same fuel input. Thus a water-CO2
emissions trade-off is created as increased withdrawal of water lowers
fuel consumption, waste generation, and associated air emissions (also
including SOx, NOx, PM and Hg).
Further Information
Module: Sign Off
Page: Sign Off
W10.1
Please provide the following information for the person that has signed off (approved) your CDP water response
Name
Christopher D.
Job title
Senior Vice President Corporate Strategy and
Corresponding job category
Other: Senior Vice President Corporate Strategy and
Name
Gould
Job title
Chief Sustainability Officer
Corresponding job category
Chief Sustainability Officer
W10.2
Please indicate that your organization agrees for CDP to transfer your publicly disclosed data regarding your response strategies to the CEO Water
Mandate Water Action Hub.
Note: Only your responses to W1.4a (response to impacts) and W3.2c&d (response to risks) will be shared and then reviewed as a potential collective
action project for inclusion on the WAH website.
By selecting Yes, you agree that CDP may also share the email address of your registered CDP user with the CEO Water Mandate. This will allow the Hub
administrator to alert your company if its response data includes a project of potential interest to other parties using water resources in the geographies
in which you operate. The Hub will publish the project with the associated contact details. Your company will be provided with a secure log-in allowing it
to amend the project profile and contact details.
Yes
Further Information
http://www.exeloncorp.com/sustainability/interactive-csr
CDP