Motion to Delay the License Transfer of Three Mile Island, Unit2, (Re: NRC Proceeding "Three Mile Island 50-320 LT)

Re: Three Mile Island Nuclear Station, Unit 2     
Motion To Hold in Abeyance the Proposed License    
   Transfer to TMI-2 Solutions, LLC       
   The United States Nuclear Regulatory Commission (“NRC”)  
received an application filed by GPU Nuclear, Inc., Metropolitan 
Edison Company, Jersey Central Power and Light Company, 
Pennsylvania Electric Company (collectively, the First Energy 
Companies), and TMI-2 Solutions, LLC (together with the First 
Energy Companies, the Applicants) on November 12, 2019. 
  The application requested the NRC’s approval of the direct
transfer of NRC Possession-Only License No. DPR-73 for Three 
Mile Island Nuclear Station, Unit No. 2 (“TMI-2”) from the current
holders, the First Energy Companies, to TMI-2 Solutions, LLC, 
which is an indirect wholly owned subsidiary of Energy Solutions.
On March 26, 2020, the NRC published a Notice in the Federal 
Register, Re: Three Mile Island Nuclear Station, Unit No. 2; 
Consideration of Approval of Transfer of License and Conforming 
The NRC notified the service list on January 14, 2021, of a Short 
Notice Commission Affirmation Session - Three Mile Island Nuclear 
Station, Unit 2. “The Commission Affirmation Session is scheduled
for 10:00 A.M., January 15, 2020.”  
This Motion is to inform the Nuclear Regulatory Commission that
 the decisions to approve the above stated license transfer on December 18, 
2020, and the Order to “terminate the proceeding” on January 15, 2021, 
are in error. The NRC failed to account, acknowledge or address the failure
of Applicants, the Pennsylvania Department of Environmental Protection,
and the Susquehanna River Basin Commission to comply with the Clean 
Water Act, Section 401.
The Nuclear Regulatory Commission has identified the need for
state related agencies - including the DEP or SRBC - to review the 
criteria from  the updated Clean Water Act,  Section 401, Water 
Quality Certification at nuclear plants amending and/or extending 
their licenses.
Respectfully Submitted by,
Eric J. Epstein, Chairman
Three Mile Island Alert
4100 Hillsdale Road
Harrisburg, PA 17112
Dated: March 15, 2021