ML20013E535

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Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7)
ML20013E535
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/12/2019
From: Halnon G
Firstenergy Service Company, GPU Nuclear Corp, Jersey Central Power & Light Co, Metropolitan Edison Co, Pennsylvania Electric Co, TMI-2 Solutions
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TMl-19-164
Download: ML20013E535 (40)
v • d • e


Text

f

. CONFIDENTIAL :FINANCIAL INFORMATION.TO BE WITHHELD FROM PUBLIC.

. DISC:µ)SlJ:RE ;pURSuAf.,it TO 10 CFR 2.390 & {o *cFR 9.17 NUCLEAR

_December 12, 201Q *.

TMl-.19-164 U.S. Nuclear Regulatory co*mmission :

ATTN; Document Control Desk Wast:iington, DC 20?55-0001

. TMI-19-164 GPU Nuclear*.

c/o.FirstEnergy Service Cpmpany. *.

Mall StopA-G0-18.

76 South Main :street Akron, OH,. 44308 10 CFR *50.51.

10 CFR 50.82(a)(-7)

Subject:

. Notification.of *Amended Post-Shutdown Oecommfssioning Activities Report" (PSDAR) f<;>r Three *Mile Island, Unif2 in Accordance 'A'.ith.

  • 16 CF~ 50.82(~)(.7):
  • Three Mile Island, ~nit 2.

NRG.Possession Only Liyeh~ No. DPR-73...

NRC Docket No. 50-320.

References:

1) Letter TMl-19-112 fro.m Halnon, G.H. (GPU Nuclear, Inc\\ and Sauger J.

(T~1.:2 Solutions.LLC), "Application for*Order Approving 'License Transfer and Conforming*Licerise'Amendm~ts,(ML19325C600) dated November 12,201.9.

GPU Nuclear,*Met;ropo~tan Edison Company, ~ersey Central Power & Light Company,

  • Pennsylvania Electric Compa~y, al")d.TMJ-2: Solt;Jtions, LLC, S!J.bmitted an "Application for Order Approving License Transfer. and Conforming License Amen~ments~ for Three

.. Mile Island Uriit-2 (TMl-2) to*th~ *u. S. N~clear Reguratory Commission (NRC) for_review *.

  • in a letter ~ated November 12:, 2019 (R~eren.ce 1) (the Application):
  • Jhis letter is provided to ootify the NRG of a sig~ificant sched~le change in the PSDAR
  • in accordance-with.10 CFR 50.82, -rerminatlon of iice11se," paragraph (a)(7). The intended ch~nge is to *accelerate the decommi~oning scheduie for TMl-2 following*

. *. approval of the Application a,nd transfer of the TMl-2 license pursuant *to the terms set *.

  • . forth. *in the Applica.tion. *.Decommissioning cost changes refl~ng the cu~ilt.

Qpon removal ¢En~losure 1.A this ~uinent is unco~trollecl: *.. *... AtJ./). I

  • N~*~*

coNFIDENTIAL ~AffCJAL INFoR,MAnoN TO.BE WITHHELb *FR9M PUBLIC.

. DlSCWSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17 TMI-19-164

.-Page2 of4 decommissioning strategy a:re also provided. Other changes to the PSDAR are

  • summarized fn the Revision History. Attachment 1 provides PSDAR Revision 3.

. Attachment 1, Enciosure 1A contains confldentlai°conimercial and financial information...

FirstEnergy and En~rgySolutions*_requests tha(this inform.atlon be wi~hel~ trorri public disclosure pursuant.to-1 O CFR 2.3.90, as described in the 'Affidavit provided i11 *:

Attac6ment 2. A re.dacted version qt Enclosure 1A, suitable for public.disclosure, is.

  • provided as Attachment 1,. Enclosure 18. :

. The *psOAR lri Attachment 1 p~vide~ fi11anclal and planning infQrmatio11 to support the Application. As decomm(ssicining planning progresses.further, TMl-2 Solutions will.'.

-.. s~b~ii an updated p'soAR for review; to b~ made.effective upon.implementation of the license transfer: The*updated PSDAR will refine and u~ate the TMl-2 decommissioning

_*project ~chedule, cos~ estimat.~s a!ld environmental-impacts, and provide a9ditlonal

. information about decommissioning planning..This is ref'.lectecf as a regulatory commitment in Attachment 3.

. In acco.rdance with. 10-CFR ~0.91(b)(1 j, a cop*y of.th!s ~bm~I has b~n s*ent to the*

Common:w~lth of Pennsylvania.

  • fn th*e*.everit th_at the NRG has any.questi<;ms, please cqntact G~ Halnon, GPU *: *
  • Nuclear, lnc._President and Chief Nuclear Officer, at 3.30-761-4270. Please also.include the following on_ the _distribution list for-all corresporn;lence related to the ':'SOAR:

For GPU Nuclear:

Karen A ~ealy Senior *corporate C(?*unsel. :

FirstEnergy Service Company*

76 South Main Street

  • Akron, OH,.. 4430_8 Phon*e: 330-761-7869 Fax: 330-384-3875 * - -

Email: ksealy.@tirstenergycorp.com

-'Upon removal*ofEncl~sure lA this document is un~ntrolled:'

.CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 &-10 CFR 9.17 For TM.1-2 Solutions:_

John Sauger President and c;;hief Nuclear Officer TMl-2 Solutions, LLC 121 West Trade Street, Suite 2700 Ch~rlotte, North Carolina 28202 Phone: 704-631-377 4 Fax: 801-413-5676 Email: jtsauger@energysolutions.com Russell G. Workman General Counsel and Secretary TM 1-2 Solutions, LLC 423 West 300 South, Suite 200 Salt Lake City, UT 841901 Phone: 801-303~0195 Fax: 801-413-5676 E-mail: rgworkrnan@energys<?lutions.com Upon removal of Enclosure lA this document is uncontrolled.

TMI-19-164 Page 3 of 4

_. CON8DEN!IAL FlNANCiAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO IO CFR 2.390 & 10 CFR 9.17 TMI-19-164.

. Page 4 of 4 ln_~ddlUon,_please pl~ce.Mr. ~uger,.M~. W~rkrj,an rv,r. ~alno*n, and ~s. Sealy on the*

NRC cprr-esp(?ndence dis.tributio_n f~r aH correspondence related to the F'SDA~

Sincerely; go

. Halnon.

  • President and*Chlef Nuclear Officer GP.U Nµctear, Inc.
  • Atta*chi'nents;
  • * - Three Mile Island Nuclear Power' Station, Unit 2 Post-:Shutdowri
  • oe*C9mnilssionlrig Actlvltie~ Report Revision 3

. :. (contains Enclosure~). -

,1 Attachment.2 -10 CFR 2.;390.Affld~vit Attaclune~t 3_~*ust of Regl:Jlat<?ry.Commitme~ts cc w/Proprietary Ehclosur~s; NRC ProjecfManager NRC Regl9n *I Administrator f':JR(? Resi~erit lnspect~r

.. cc :w/o Proprieta*ry Enck>sures~ _

  • Director, Bur~i;iu of Rad-latlon-Protec~lon~

Department of Environmental Protection; Comll'lonwealth of.

  • Flennsylyanla _

Chief, Div*is!on of.Nuclear Safety, Bureau of Radiation Protection,.

, -*_... Department of Erivironmen~I Protectloh1 C.om*monwealth of *.

*pe~*l}syiv~nia
  • Chairman; B~ard of Counfy Commissioners,. Dauphif1 County
  • Chairman, Board *of.Supervisors of Lon*dohd~rry Township _

Upon r~moval*ofEuclosur~ lA~hfs 9_ocumen~ is uncontrolled.

ATTACHMENT*2 TO TMl-19~164

. 10 CFR 2.390 AFFIDAVIT THREE MILE ISLANr;> NUCLEAR POWER-STATION, LI_NIT 2 NRC POSSESSION ONLY LICENSE NO. DPR-73

r.

A~chment 2 to ~1-19-164

. Page. 1 of2.

10 CFR2.390

  • AFFIDAVIT OF RUSSELL G.: WORKMAN I, Russell G. Workman, *General Counset*of Th11-2 Solution~ *. LL~: state

.that

1.

I am authorized to. execute this 'affidavit on behalf of TMl-2 Solutions,

  • LLC (TMl-2 Solutions).: ** *
2.
  • GPU N*uclear, *1nc. is providing information in suppO~ of the above-described "Post-Shutdown Decommissioning *ActMtles Report" (PS DAR). A of the PS DAR contains trade secrets and flnanclal lnfor.matlon,
  • ... Including proprietary asp~ to the decdmmisslortlng
  • of Three MUe ~land
  • Nuclear Station, Wnit 2 ("TMl..:2"), which constitute prqprtetary commercial and.

. * * *financial Information, belonglr)g to TMl-2 Solutions, th~t should. b.e held in

  • .confidence by the*NRC'pursuant to the pollcy'reflected In 10 CFR 2.390(aX4) and 10.CFR9.17(aX4),*because:
a. This inform~Jion Is and* has: bee*n held In confidence by TMl-2 Solutions, Its. affiliates and contractors~ and Is the subject of confldentlallty obligations owed by GPU Nuclear, Inc., as well *as their
  • affiliates and contractors.
b. This information is of a* fype that Is held In e9nfldence by TMl-2 Solutions and GPU Nuclear, Inc.; and their* affiliates and contractors, and the~ Is a rational basis fo~ doing so because the. Information c;:ontalns

. sensitive trade* ~rat or flnanclal Information cqnceming the decornml~oning of'TMl-2. *

. c..This lnformailon* ls being transmitted to the NRC In confidence.

1

d. This information Is not avallable in public sources and could not be
gathered readily fr<?n:i <:>ther: publlcly aval~~ble.in!9rmation...
e. Public.disclosure* ofthls 1ntormat1o*n would create substant1ai harm to:

~

competitive positlon*of.TMl-2 Solutions ~nd Its affiliates by*

.disclosing unique decommissi<:>nlng analyses, Including approaches tq

  • decommissioning develo~ by.TMl-2 Solutions at conslderable*tlme.

and expense, to other parties whose commercial Interests may be

  • adve~e to those of TMI-~ Sqlutlons..-

/

to TMl-19-164 Page 2*ot2 Accordingly, TMl-2.Solutions requests that Enclosure 1 A to the "Post-Shutdown Decommissioning Activities Report" be wlthheld from public disclosure pursuant to 10 CFR 2.390(a)(4) and 9.17(a)(4).

STATE OF UTAH COUNTY.OF SALT LAKE TMl~2 Solutions, LLG Russell G. Wor:kman General Counsel

.Subscribed and.sworn to me, a-Notary Public, In a.nd for.the County and State above named, this 12th day.of December.

iliAe!t n~

My Commission Expires: - 1:\\ i.t [i.o*

ATIACHMENT 3 TO TMl-19-164 LIST OF REGULATORY COMMITMENTS THREE MILE lSLAND NUGLEAR POWER STATION, UNIT 2 NRC POSSESSION ONLY LICENSE NO. DPR-73 to TMI-19-164 Page 1 of 1 The following list identifies those actions committed-to by FirstEnergy in this letter and Attachment 1 ("Three Mile Island Nuclear Power Station, Unit 2 Post-

  • Shutdown Decommissioning Activities Report"). Any other actions discussed in the submittal represent int~nded or planned. actions by FirstEnergy. They are described only as information and are not Regulatory Commitments. Please_

notify Greg Halnon, G-PU Nuclec;1r, l_nc. President and Chief Nuclear Officer, at 330-761-4270 of any_questions regarding this document or associated Regulatory Commitments. -

TYPE SCHEDULED REGULATORY COMMITMENT ONE-TIME CONTINUING -

COMPLETION ACTION COMPLIANCE DATE TMl-2 Solutions will submit an updated *

. _X Prior to Cl9sing PSDAR for review, to be made effective upon implementation of the license transfer.

TMl-2 Solutions wiH submit a plan for X

Prior to Closing management of Debris Material for review bv the NRr.

ATTACHMENT 1 TO TMl-19-1&4 POST-SHUTDOWN DECO.MMISSIONl~G ACTIVITIES REPORT (PSDAR).

THREE MILE ISLAND NUCLEAR POWER STATION, 'UNIT 2 NRC POSSESSION ONLY LICENSE. NO, DPR-73 REVISION 3 DECEMBER 2019

Table of Contents.

I.

INTRODUCTION II.

BACKGROUND 111.

D.ESCRIJ:)TION OF DE:coMMIS$IONING*_ACTMTIES

    • iv.. : S~HEDULE OF DECOMMIS_SIO.NING ACTM"T:IES V. *. ESTIMATED COST.OF DECOMMISSIONING ACTIVITIES PAGE 1

2 5

8.

. ~.

VI.

.ENVIROt>iMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES 11 VII.

REFERENCES io ENCLOSURES

. A Detailed Cost.arid Schedule Information (Proprietary)

" B

  • Detail~ Cost and Schedule lnror:matlon (Nori-Proprietary)

REVISION HISTORY Revision Number Revision* Describtion

.. ',O

. Initial Issue (June 2013) 1.

lr:icorporated information to _update Table 1 to 2.012 qollars (November 2013)

Changes are on Pages 1, 2,

  • 14, an*d 15* *
  • 2
  • incorporated Information resulting froni 2014 Decommissioning Co.st Analysis, revised information on-tt,e post-defueling -monitored sto,:age agreem~nt,. ~nd incorporated. v;irious admini~tive c!arifi90tions.

(December 2015) Changes are oi,-PaQes *1,. 2, 5 through 15, and 25 3

Revised section I ".Introduction" with g~neral information pertaining to

. tr:an$fer of O\\Yfl_ership of TMl~2 and.accelerated decommissioning.

  • Reyised section II "Background" to inclupe information th~t ad~resses transfer of Possession Only License No. DPR~73.fro_m FirstEnergy to TMl-2 Soluti6ns;'Revised s*ectio'n Ill "Description of D~ommissioning Activities" to_ address actl~ties*following license transfer to TM_l-2. *

. Solutions, upqate the projecf organization, and replace :.. *.

decommissionjng_ "periods" with _de~mmission1ng "ph~ses/ Revised section _IV "S:chedule of.Decommis~ioning Activities," and section V.

. "Estimated Cost of Decommissioning Activitie~," with updated detailed schedule. and de(?01T1missionin~fcost'information:

Changes are on pages throughout.

')

to TMI-19-164 Pag~ 10r20 *

  • I. INTRODUCTION GPU.Nuclear, inc.. (GPU Nuclear), acting for itself arid *for the Metropolitan.Edisor:1*

Cornpany,. Jersey.Central Power & Light Company, and the Pennsylvania Electric*

Corti.PBr-JY, (coll_ectively the Fi~ne'rgy Companies),.has qeveloped this post-shutdown

. decommissioning ~ctivities report (PSDA~) for th~. Thr:ee Mile l~land_Nuclear Station,

.Unit 2 (TMl-2) in a*CC91"9ance with tt,e requir:emen~ of 1 O*CFR 50.82, "Tennination of

. license/ paragraph (a)(4)(i). _This revision _of the PSbAR has b~n prepa~d to* reflect

.* tf:le.applicatiori_req~esting that.the.U.S. Nuclear Regulatory Commission (NRC) consent

  • to the transfer of Possession On.ly Licen~ No. OPR-73 for TMl-2 (POL) from the FirstEnergy. Companies to TMl.-2 Solutions: LLC (TMl~2 s*olutions), a* wbolly--0wned subsidiary of EnergySo/utions Inc. (EnergySo/utions) (the Application) (Reference 1 )...

The transfer is to occur pursuant to the October 1 p, 2019 Asset Purchase and Sal~

Agreement amo_ng tlie applJ~nts,.:Fi~r:,ergy Companies arid TMl-2 $oh:rtions, whi(?h is enclosed with. the Application. Following.the closing of the transaction described in the Application, TMl-2 S~l.utions ~II be the TMl-_2 licensee:

TMl-2's POL is currently maintained in accordance with the NRC approved SAFSTOR con~!tio~.(a method in which a. !1Uclear:facllity is. pl~ced arid m~intained in a condition* _that allows* it to be safely stored and*subsequently decontaminated) kn'own as post-defueling monitored sto*rage (PDMS). *GPU Nuclear has 1')1aintained*TMh2 in the PDMS state since

  • the NRC_ provisions for cleanup were met and accepted in 1993.

By letter dated August-14, 201Z, (Reference 2)(ML12235A227} GPU Nuclear informed ttie NRC of tf:le *1Ml-2 status relative ~o the 1996 Decommissioning Rule changes spe'cifically related to* 10 CFR.50.51, "Gontinuation of license,": and 1 o: GFR ~0.~2. "Te~ination of 1*0

-1*0.

1*0

license;' The. letter state9 the intent to submit a PS DAR that describes the planned

. decommissionin*g actlviti~s. schedule, cost estimates, and the environmental impacts of TM~~2 plant' spec!fic decommi~ioning. By NRC letter dated February 13, 2013, (Ref~ren<?9 1

  • IJl
3) (ML12349A29~) th_e NRC stated that se*ptember 14, 1993 is considered the date of TMI-u 2's cessatic;>n of operatio~s.

The PS DAR_ is provide<;! in ~ccordance with the requirements of 10 CFR 90.82. Tlie PSDAR includes:

  • A description of the_ planned: d.ecom~issio!'ling* ~cpvities,. *
  • ~ A sch~ule for. their:a~~1ptish~~nt, :.
  • A site.:.specific decommissioning cost*estimate including the projected cost of
  • . managing irradiated fuel, ai:,d*. :

. *. A discussion.that provides the reasons for con.cluding:that the environmental impacts associated with'site-spectfic decommissioning activities wili be.

bounded by *previo~sly issued environmental impact statements.

l~l to TMI-19-164

. rage 2 of io.

Due to the unjqµe ~ature ~f TMl-2, GPU Nuclear has i~c)uded a Section II, "Background," in the PSDAR to.provide infomiatlon on the design, history; and current.

status of TMl:-2. Sectior:,s 111 through V add~ lhe 10 CFR 50.82 require!'Tlents to describe ahq provide a schedµle and cost estimate 'for th!3 planned d~mmissioning*

activities:.Section VI provides the reasons for concluding ~at the activitl~ planned for the decommissioning of TMl-2 are bounded by previously issued environmental impact

.statements.- Section V.11 provides a list of ~e~nces used:in the* PSDAR. *

  • II. BACKGROUND. *.

TM l_.2 is located on the north~rn-most *section of Three Mile Island near the east shore of the.Susquehanna River in Dauphin County,.Pennsylvania. The* station Is comprised

  • of tw9 pr~urized water reactors.* Tile TMI Nuclear Station includes Unit 1, owned by Exelori-Gerieration Compar:,y, LLQ (Exelon), which has. pem,aneritly ceased* power.

operations and as such the fuel has been removed frorri the reactor vessel, and the

shutdown Unit 2 owned *by GPU Nucle'ar.
TMl-2 is a non-operati6n~I pressurized water reactor that wai rated at a cqre*ttiennal
  • power level of 2772 megawatt-themial with a corresponding turbine-:g.enerator gross*

output of 959 megawatt-el_ectric. l."Ml-2 employed.a two loop pressurized water reactor*

  • nuclear st~m suppfy system designed by Babcock and-Wilcox Corporation. The
  • reactor coola*nt system is housed within a* steel-lined, post-tensfoned concrete structur-e (rea.ctor building), in. the shape o_f a right, vertical cylinder with a0heinispherical dome anp a flat, reinforced concret~ basemat. A welded steel liner plate, anchored to _the inside face of the reactor building, serves as* a le~~~tlght me'!lbrane: :.

1*0*

  • . GPU_ Nuclear was issued* an operating lice~se for TMl-2 on P~bruary 8,
  • 1 ~1'?8, with.

\\ r-;1 * *:

commercial operation 'declared 011 December 30, 1978. On Maret, 28;1979, the unit

  • *
  • LJ expeiienced an accident initiated by interruption of secondary: fe~water flo~. *.

The lack of seconda.ry feedwater resulted in.th~ (eduction of primary.:.to-.se_condary heat.

  • exchange tha( caused an increase i_n_ the rea~or"90ola.nt tempe~ture, creating a s_urge into the*pressurizer, and *an in*crease in &yst~m pressure. The pressure operated. 'relief

. valve (PORV) opene.cf to reli~ve the pressure, but ~iled to clo_se when th~ pressure.

decreased. The r~ctor coolan, pumps were turned off and a. core heat-up began as.

the reactor coolant system water inventory continued.to d~qrease resulting in a rea.ctor

. vessel water level below 'the top of the core*.' ThJs led 'to' a. core heat up *that cau~ fuel

_... _ damage.. The majority_ of the.fuel material travelled down through the region of ttie southeastern *assemblies and:lnto the core bypass region.. A portion of the fuel material

'passed a*round the bypass region and migrated _down ioto* the lower interna.ls and low_er head. ~ib~, but overall ~ctor yE;lssel integrity was*maintained throughout the accident.

As a r~sult of this acciderit,-sm*a11 quantities of core debris and fission products.were tran'sported through *the reactor coplant *system and the reacto'r building: In. addition, a.

small quantity of C<?re debris was transpo~ed to the_ auxiliary and fuel handling buildings.

I

  • to TMI-19-i64 Pf$~ 3 of20 -.

. Further spread qf the debri~ ~lso occurred* as* part of the post-:acciderit water processing cleanup activities. '

The *quantity of fµel ~ainlng at TMl-2 is a: smaJI fraction. of tt:i.e initl~il fuel load;_

app_roximately'99 percent(%) was su~lly remove<;J in 'the defueling. Additlonalty, large "quar:itities of ~dio~ctive fission products that were released into various _systems and :

strµctures were* removed as part of the waste processing activitjes during. the_ TMl-2 c1ea:n-up Program. The cleanup to meet the NRC*pos_t accident safe storage criteria*was completed and accepted by-the NRG.with TMl-2 entering info post-defueling monitored storage in 1993. -

NUREG-0683, "The Programmatic Environme~tal. lmpact Statement Related to Decontan:iination and Disp_osal of.Radioactive Wastes Resulting from the

  • March 28, 1*979 Accipent Th~ Mite*.1siand.Nuclear Station, Unit 2;" Supplement 3 **

(PEIS) (Reference 4), discusses the activities perfonned to achieve the PDMS state:at TMl-2: The PEIS. evaluates the activities.associate:d with the post-accide.nf cleanup for environmental impact, and addresses the significant am<?unt <;>f decontamination.and:.

  • . waste removal that would normally be part of a decqmmissionlrig plan, Which were

. completed tq achieve PDMS.

. Approximately ~9% of the fuel wa~ ~moved *and shippeq to the Idaho National Engineering and Environmental Laboratory.(INEEL.) under the responsibility of the-U.S.

. D~p~rtn,ent ~f Energy (DOE). The reactor (?OOlant syste~ was decontaminated to the extent:practical:to reduce radiation levels to as low as*is _reasonably achievable (ALARA). As part of the *decontamination effort, water was removed to the extent

'practical fron:t the react9r-coolant system arid the fuel transfer canal, *and the fuel.

transfer tube~ were isolated. Radioactive wastes from the major clean-up activities have been shipped off-:-sit.e o'rhas.been packaged ar,d.staged for ~hipment off-sjte. :

Fo.ll9wing th~ *decontamil"!atior:i activ:itie~, only the reactor. quilding and a* few. a~s in the*.

auxiliary and fuel handling buildings continued to have general area radiation levels

  • . higher than *those bf an unp~ril~ged rE;?actor facility riearing.'the "~nd Qf its *operatin~~ life.

GPU*Nuclear'~aintained TMl-2 i~ the PDMS state whne_ successfully-operating TMl".'1 until AmerGen (a joint venture between Philadelphia Energy Company.and British.

. *Energy) purchasecfthe 9perating TMl-ffrom*GPU Nuclear !n-1998. The sale of TMl-1 included the Unit 1 buildings, ~ctures; an~ th~ maj9rity. of the site. property; however; GPU-Nuclear maintained ownership of TMl':'2. -

FirstEnergy acquired GPU*Nuclear an~ qwnership of TMl-2_ ill 2001 as part of a larger * :

acquisition of GPU. In D~cember 2003; Exelon Corp. acquired sole owner:ship of TMl-f.:

A monitoring-agreement between *GPU Nuclear and* Exelon provides for Exelon

...

  • performing certain functions at TMl-2;6n behatf.of G'PU Nuclear, while:TMl-2 is in PDMS.
  • Ttiese*functions include maintenance and testlng;radiological.and environmental
  • controls, ~curity and* ~fety functions and licensing activities required by the PDMS Te:cltnical* Specifications and PDMS.Final Safety Anal~is Report.

IT~

_:IE]

-IW 10 10 to TMI-19-164

Page 4 of20 A 2004 site-specific cost analysis for decommissioning TMl-2 assumed a delayed DEGON scenario, which deferred the decontamination and dismantling activities at TMl-2 until they are synchronized with TMl-1 such that the licenses for both units are terminated concurrently. This scenario assumed a 10-year dormancy period for TMl-2, following the TMl-1 original license expiration in 2014, with decommissioning preparation to begin In about 2024. The initial schedule assumed decommissioning operations would begin in about 2026, and would be completed over a 10-year period with site restoration projected in 2036. Since that time a 20-year extension to the TMl-1 operating license was granted by the NRG. This warranted a revision to the decommissioning cost analysis for TMl-2.

A 2014 site-specific cost analysis for TMl-2 evaluated a DEGON scenario that assumes TMl-1 would commence decommissioning upon cessation of operations in 2034 and that the decommissioning programs for both units would run independently from each other.

PSDAR revision 2, section IV "Schedule of Decommissioning Activities" established the schedule for the decommissioning of TMl-2 to commence following the expiration of the TMl-1 Operating License on April 19, 2034, with TMl-2 license termination occurring in 2053. However, upon approval of the Application and transfer of the POL TMl-2 Solutions will assume all authorities provided for and responsibilities under the POL, including possession, maintenance, and eventual decommissioning of TMl-2 and associated buildings and structures. Thereafter, following completion of all necessary engineering and licensing actions, TMl-2 Solutions will move into DEGON with the goal to accelerate the decommissioning of TMl-2.

The transfer of the POL is desirable from a public health and safety perspective because TMl-2 Solutions will benefit from EnergySo/utions' and its affiliates' demonstrated capability to safely and promptly decommission TMl-2, and to help eliminate the risk associated with the cost and capacity for low level radioactive waste disposal from the TMl-2 site. EnergySo/utions and GPU Nuclear have concluded that the environmental impacts provided in revision 2 of the PSDAR remain valid based primarily on that there is no change in decommissioning technique; acceleration of the schedule and a change in ownership in themselves do not change the underlying assumptions of the environmental impacts. A more detailed review will be provided in a future revision that will be contingent on the approval of the License Transfer Application.

Upon the transfer of TMl-2 to TMl-2 Solutions, TMl-2 Solutions will initially maintain the site in a PDMS state, as it prepares for decommissioning furthering the conclusion that no additional environmental impacts need to be add~ in this revision of the

-psDAR. After taking the necessary engineering and licensing actions, TMr-2 Solutions will commence decommissioning of TMl-2 and will complete all activities necessary to terminate the license and release the TMl-2 site years ahead of the plan reflected in revision 2 of the PSDAR which presumes license termination occurring in 2053. TMl-2 Solutions anticipates completing decommissioning of TMl-2 and releasing the TMl-2 site (except for any onsite waste storage facilities) approximately 16.5 years after the license transfer-seventeen years earlier than the current schedule. Refer to Enclosure 1A Figure 1A-1 for a detailed TMl-2 decommissioning schedule.

/

Ill DESCRIPTION OF DECOMMISSIONING ACTIVITIES to TMI-19-164 Page 5 of20 The objective of decommissioning TMl-2 is to safely perform all the activities associated with decontamination and dismantlement of the remaining plant systems, components, structures, and facilities In a cost effective manner.

Following the closing of the transaction described in the purchase agreement as presented in the Application, TMl-2 Solutions will be the TMl-2 licensee. It will hold title to and ownership of any real estate encompassing the TMl-2 site; any TMl-2 improvements at the site; easements for other portions of the site; and any spent nuclear fuel, damaged core material, high level waste, and Greater-Than-Class C

("GTCC") waste within the TMl-2 facility (collectively referred to as "Debris Material").

TMl-2 Solutions will be responsible for developing NRG-compliant storage and/or disposal plans for any remaining Debris Material until title to the Debris Material is transferred to the DOE for disposal. TMl-2 Solutions will assume responsibility for all licensed activities at the TMl-2 site, including responsibility under the license to complete radiological decommissioning pursuant to NRG regulations.

TMl-2 Solutions will initially maintain the TMl-2 site under the PDMS state as it prepares for Decommissioning. The PDMS condition was established following the accident at TMl-2 to establish an inherently stable and safe condition of the facility such that there was no risk to the public health and safety. The PDMS state has been approved by the NRG and is governed by a PDMS Safety Analysis Report, PDMS Technical Specifications, and PDMS Quality Program.

v The PDMS Technical Specification requirements to monitor and survey radiological conditions have been established and maintained since 1993. Site security is maintained as a contracted service by Exelon that owns and operates TMl-1.

As discussed in the TMl-2 PDMS Safety Analysis Report:

There is no credible possibility of nuclear criticality.

Fuel and core debris removed from the reactor vessel and associated systems has been shipped offsite.

Any potential for significant release of radioactivity has been eliminated.

Water has been removed to the extent practical from the reactor coolant system and fuel transfer canal, and fuel transfer tubes have been isolated.

The treatment and processing of accident generated water has been completed.

  • ~Radioactive waste from the major cleanup activities has been shipped off-site or has been packaged for shipment off-site.

Attachment I to TMI-19-164 Page 6 of20 Radiation within the facility has been reduced, as necessary, consistent with ALARA principles to levels that will allow necessary plant monitoring activities, the perfonnance of required maintenance, and any necessary inspections.

After taking the necessary engineering and licensing actions, TMl-2 Solutions will commence decommissioning of TMl-2 and will complete all activities necessary to tenninate the license and release the TMl-2 site. TMl-2 Solutions Intends to substantially complete decommissioning of TMl-2 and release the site by 2037, except for a potential area set aside for waste storage facilities.

TMl-2 Solutions will, during a transition period, ensure continuity of the existing site procedures, currently implemented for the TMl-2 site by Exelon on behalf of GPU Nuclear, while also establishing TMl-2 specific procedures using TMl-2 Solutions project procedures, programs, personnel and contractors, although some support functions will 1

continue to be perfonned by Exelon.

The TMl-2 Solutions organization will provide an experienced nuclear management team to assure compliance with the requirements of the License and the NRC regulations. TMl-2 Solutions will implement a management approach to assure efficient and effective decommissioning and decontamination planning, preparation, and execution, which is expected to include: a safety conscious work environment; day-to-day industrial safety; radiological protection; radioactive waste handling; management rigor; an effective corrective action program; perfonnance reporting, monitoring, and metrics; personnel perfonnance; and financial controls.

The decommissioning of TMl-2 has been divided into two Phases.

A discussion of the significant activities, and the general sequencing of activities in each of the two Phases is presented below. The planning required for each decommissioning activity, Including the selection process to perfonn the work, will be completed prior to the start of work for that activity.

Phase 1 Phase 1 focuses on planning and engineering activities (including NRC licensing actions), and remediation of the areas subject to the 1979 core-damage accident, with the overall goal of Phase 1 being to reduce the radiological source tenn at TMl-2 and the TMl-2 site to levels that are generally consistent with a nuclear plant toward the end of its operational life that has not experienced a core-damage accident The first 4-5 years under Phase 1 will be preparation for decommissioning, including engineering work, procurement of long-lead time items, and infrastructure upgrades.

During this time TMl-2 will remain In PDMS.

to TMI-19-164 Page 7 of20 As indicated in Enclosure 1A Figure 1A-1 physical dismantlement and decontamination activities will start in 2024, with containment opening. Phase 1 is thereafter expected to last 5 years, until remediation of the reactor building is complete and Debris Material Is packaged In 2029. Specific Phase 1 decommissioning objectives include:

Reducing the reactor building source term.

Reducing the source term and cleaning out the Debris Material from the reactor vessel.

Reducing the source term of large components by removing Debris Material.

Packaging, transporting, and storing Debris Material.

Removing and packaging Class B and C radioactive waste.

Phase 2 The overall goal of Phase 2 Is decommissioning of the TMl-2 site to a level that permits the release of the site, except for an area potentially to be set aside for waste storage facilities. Specific Phase 2 decommissioning objectives include:

Removing, packaging, and disposing of all remaining systems and equipment in preparation for structural demolition.

Demolishing and dispositioning all plant structures to nominally three feet below grade.

Demolishing the cooling towers.

Backfilling the site to the existing grade elevation.

Phase 2 is expected to complete in 2037.

Also included in Phase 2 is the preparation and execution of the license termination plan (L TP) and site restoration activities. The L TP will be prepared in accordance with the requirements of 10 CFR 50.82(a)(9), and will be prepared at least two years prior to the anticipated date of license termination. The LTP will include a site characterization, description of remaining dismantling activities, plans for site remediation, updated cost estimate to complete the decommissioning, any associated environmental concerns, designation of the end use of the site, and the procedures for the final radiation survey.

The L TP will be developed following the guidance contained in Regulatory Guide 1.179, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors." As described in Regulatory Guide 1.179, the LTP will use the guidance contained in NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" to develop the final radiological survey plan and survey methods.

The use of MARSSIM to develop the final radiological survey plan and survey methods will demonstrate compliance with the requirements 10 CFR 20, Subpart E, "Radiological Criteria for License Termination." Once the L TP is approved, the final remediation of the site facilities and services can commence. These activities Include, but are not limited to:

to TMI-19-164 Page 8 of20 Removal of remaining plant systems and components as they become nonessential to the decommissioning program, or worker health and safety (for example, waste collection and processing systems, electrical power and ventilation systems).

Removal of contaminated yard piping and any contaminated soil.

Remediation and removal of the contaminated equipment and material from the auxiliary and fuel buildings,. and any other contaminated facility.

Use of the NUREG-1575 guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied.

Once the final survey is complete, the results are proviQed to the NRC. The NRC will terminate the license if it determines that site remediation has been performed in accordance with the L TP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.

Following completion of decommissioning operations, site restoration activities will begin. Site restoration will involve the dismantling and disposal of any remaining non-radiological structures. Restored areas of the site will be backfilled, graded and landscaped to support vegetation for erosion control. B, Figure 1 B-2 provides a high level schedule of activities per phase.

IV. SCHEDULE OF DECOMMISSIONING ACTIVITIES As noted in letter from the NRC to GPU Nuclear dated February 13, 2013, (Reference

3) (ML12349A291) the equivalent to the certificate of cessation of operations was determined to be the NRC's issuance of TMl-2 License Amendment 45, converting the TMl-2 operating license to a possession only license. This amendment was granted on September 14, 1993 (Reference 5) and establishes that date as the date that TMl-2 is considered to have submitted certification of permanent cessation of operations.

TMl-2 has been In a PDMS state since its permanent shutdown and defueling. with preparations for decontamination and dismantlement deferred until the license expiration date for the TMl-1 facility. Upon the transfer of the POL to TMl-2 Solutions, and completion of further engineering and licensing actions, TMl-2 Solutions plans to accelerate the decommissioning schedule and begin decommissioning. TMl-2 Solutions' goal is to complete the decommissioning, restoration, and release of the TMl-2 site approximately 16.5 years after the license transfer. This is seventeen years earlier than the schedule provided in the current PSDAR.

The PSDAR does not provide information about the long-term management of certain wastes referred to in the Application as Debris Material. At an appropriate time, TMl-2 Solutions will submit to the NRC a plan for management of Debris Material, which will provide more information about the long-term plan for management of Debris Material at

\\0 10 to TMI-19-164 Page 9 of20 TMl-2 until DOE acceptance. This is reflected as a regulatory commitment in the Application, which is repeated in Attachment 3. A, Figure 1A-1 provides a detailed schedule of decommissioning activities. B, Figure 1 B-2 provides a high level schedule of activities per phase. The schedule begins with the date that the various contractual agreements are signed between the parties, and ends with the NRG approval of the license amendment that permits complete or partial site release. Following the transfer, expected to occur in the second half of 2020, the decommissioning of TMl-2 will largely be independent of the decommissioning activities at TMl-1.

V. ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES In February 1996, the first TMl-2 site-specific decommissioning cost analysis was developed for GPU Nuclear. That analysis was updated in 2004, 2009, 2014 and 2018 (References 6, 7, 8 and 9 respectively) to reflect current assumptions pertaining to disposition of the nuclear unit and relevant industry experience in undertaking decommissioning. The updated 2018 cost analysis (provided in the 2019 Status Report) provides a total decommissioning cost estimate of approximately $1.32 billion dollars, based on the decommissioning approach in consideration at that time.

For estimating costs under an accelerated decommissioning approach, the updated estimate completed in December 2018 was utilized to obtain site-specific commodity quantities, and then EnergySo/utions applied its weights and currently estimated unit cost factors, which take into consideration the EnergySolutions execution strategy and the methods and schedule discussed in section IV above, to arrive at an updated estimated cost to decommission TMl-2. EnergySolutions also utilized the latest available industry experience (e.g., Information from the Zion and La Crosse projects, and 25 years of experience in planning and engineering for other facilities, including complex decommissioning).

The cost estimate recognizes the present state of TMl-2 decontamination, contingency for unknown or uncertain conditions, the availability of low and high level radioactive waste disposal sites, and site remediation requirements. The methodology used to develop the cost estimate follows the basic approach developed by the Atomic Industrial Forum (now the Nuclear Energy Institute) in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates."

The decommissioning cost analysis for TMl-2 has been summarized in Table 1. A detailed cost estimate associated with the decommissioning of TMl-2 is presented in A, Table 1A-1 "Decommissioning Cost E;stimate": In addition Enclosure 1 B presents Table 1 B-2 and Table 1 B-3 "TMl-2 Estimated Annual Spending" and "TMl-2 Sinking Fund Analysis" respectfully.

This PSDAR will not be updated for minor changes in anticipated decommissioning costs. However, the status of TMl-2 decommissioning funding will continue to be

.to TMI-19-164 Page 10 of20 reported to the NRG in accordance with 10 CFR 50.75(f)(1 ).and 10-GFR 50.82(a)(8)(v).

This report will include, at a minimum, the assumptions used in the rates of escalation of decommissioning costs and rates of earnings used in funding projections.. Additionally; GPU Nuclear, in acco*rdance with* 10 GFR 50.82(aX7), will. infonn the NRG in writing (with_ a.copy sent to Pennsylvania), before perfonning any decommissioning activity inconsistent with or making any signi~ca-nt schedule change trorri those ~ctlons and schedules described ii"! th~ PSDAR, including.changes that signifi~ntly increase the decommissioning cost. TMl-2 Solutions will also* include an updated site specific *.*

  • estimate of *remaining decommissioning costs in the license tennination* plan in accordance with 10 GFR 50.82(a)(9)(ii)(F). The annual 10 GFR 50.75(f)(1) reports continue to* demonstrate that the current fund balances are more than adequate to cover the expected future cost of decommissioning. In the event that future estim*ated

. costs or funding levels change significan~y. TMl-2 Solutions will make the necessary

. adjustments to ensure that syfficient funds remain available for decommissioning._

  • TABLE 1 niree Mlle Island Unit 2.

Decommissioning ~st Summary**

(thousands of 2019 dollars)*

DescrlptloF11 Total Cost Planning & Transition*

2,854 Enginee*rlng *& Procedures 12,~51

. Site Upgrades & Prepa'ratlons 33,257 Large 'component & Bulldir:ig Sou me Term Reduction 51,340 Waste Packaging Transportation & Disposal 28,345 Other Direct Costs 56,005 Undistributed Costs*

264,846 Performance Baseline 449,099 Contingency 113,869 PHASE 1 TOTAL - SOURCE TERM REDUCllQ~

562,968

.Planning&_ Tra*nsition 3,773.

Engineering*& Procedures.

6,285 Large Component Removal & Building Demolition

  • 36,5~3 Waste Packaging T~nsportation & Disposal 182,968.

Fina I Surveys & License Termination 5,685 Site-Restoration 27,999

  • Oth!:!r Direct <;osts 21,213 Undistributed Costs*

134,728*

Performance Baseline

  • 419,214 Contingency.

74,692 PHASE 2 TOTAL-DECOMMISSIONING & UCENSE.liERMINATIQN 493,906 TOTAL PROJECT 1,056,874

  • Undlstnbuted Costs may also be referred to as "Allocated Support Costs"

-*Does not Include anticipated costs for long-term storage.of Debris Materla~after Phase 2 until acceptance by the DOE (estimated to be $56 million dollars).

to TMI-19-164 Page 11 of20 VI ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES There are no changes to the lnfonnation previously provided in this section. As stated above, EnergySolutions and GPU Nuclear have concluded that the environmental impacts provided in revision 2 of the PSDAR remain valid based primarily on that there is no change In decommissioning technique; acceleration of the schedule and a change in ownership does not change the underlying assumptions of the environmental impacts. A more detailed review wilt be provided in a future revision of the PSDAR that will be contingent on the approval of the License Transfer Application.

10 CFR 50.82(a)(4)(i) requires that the PSDAR Include "a discussion that provides the reasons for concluding that the environmental impacts associated with the site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements... " The potential environmental impacts associated with the proposed decommissioning activities for TMl-2 were compared with similar impacts given in the PEIS related to post-accident cleanup activities resulting from the March 28, 1979 accident; and with NUREG-0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Power Facilities," dated August 1988 and Supplement 1, Volumes 1 and 2, dated November 2002 (Reference 10) (collectively known as GEIS) on decommissioning and radiological criteria for license tennination. The following discussion provides the comparison.

The PEIS identified that the post-accident cleanup activities can be categorized into four fundamental activities:

1. Building and equipment decontamination,
2. Fuel removal and the reactor coolant system decontamination,
3. Treatment of radioactive liquids, and
4. Packaging, handling, shipment, and disposal of radioactive wastes These activities were used in the evaluation of the alternatives to GPU Nuclear's proposed action of delayed decommissioning. As described in the PEIS, the NRG evaluated seven altemative_s relative to delayed decommissioning. The NRG concluded (except for the no action alternative, which was not considered acceptable) that no alternative was found to be superior to GPU Nuclear's proposal from an environmental impact perspective.

Of the seven alternatives evaluated in the PEIS (except for the no action alternative) as well as the proposed. GPU Nuclear's delayed decommissioning plan, the NRG concluded that each alternative could be conducted in confonnance with applicable regulatory requirements and implemented without significant impact to the human I 0 I [TI to TMI-19-164 Page 12 of20 environment. Hence, it is reasonable to conclude that the activities described for the TMl-2 decommissioning will be accomplished with no adverse environmental impacts based upon the following:

The activities to be perfonned for decommissioning are equivalent to the activities perfonned during the post-accident cleanup evaluated in the PEIS, The radiation control techniques and decontamination methods since the post TMl-2 accident cleanup have improved, No site-specific activities pertaining to TMl-2 decommissioning would alter the conclusions of the PEIS, Radiation dose to the public will be minimal, and Radiation dose to decommissioning workers will be maintained ALARA according to 10 CFR Part 20.

As noted in the PEIS, the outcome of completing the clean-up activities at TMl-2 would result in many areas decontaminated to the point where general area dose rates approximate those in an undamaged reactor facility nearing the end of its operating life.

The remaining decommissioning activities for the delayed decommissioning of TMl-2 can be compared to the activities evaluated in the GEIS.

As a general matter, TMl-2 is smaller than the reference PWR used in NUREG-0586 to evaluate the environmental impacts of decommissioning, and is likewise smaller than a number of PWRs that were evaluated in NUREG-0586, Supplement 1.

Decommissioning* activities are identified in Appendix E of NUREG-0586, Supplement

1. No activities planned for TMl-2 deviate from the activities listed in tenns of environmental impact. A deviation exists in tenns of the variables associated with transuranic fuel and higher source tenns. However, these variables are addressed through controlled decontamination and dismantlement, and following NRC regulations associated with dose. So long as decontamination and dismantlement are perfonned within the guidelines of the regulations regarding release of effluents, occupational dose, and offslte dose; and GTCC waste is contained in approved shipping containers; the decommissioning activities at TMl-2 are directly comparable to the activities evaluated in the GEIS.

NUREG-0586, Supplement 1, Section 4.3, "Environmental Impacts from Nuclear Power Facility Decommissioning," provides a listing of 18 issues pertinent to the decommissioning of a reactor. A discussion of these issues follows.

1. Onsite/Offsite Land Use to TMI-19-164 Page 13 of20 The GEIS concluded that the impacts on land use are not detectable or small for facilities having only onsite land-use changes as a result of large component removal, structure dismantlement, and low level waste packaging and storage. There are no anticipated changes in land use beyond the site boundary during decommissioning.

Therefore, it can be concluded that the Impacts on land use are bounded by the GEIS.

2. Water Use Since the shutdown of TMl-2 and the entry Into the PDMS state, the demand for potable water has decreased signrflcantly below the demand during operation. The operational demand for cooling water, makeup water, and service water has ceased. The demand for water needed to conduct plant decommissioning activities (flushing piping, hydro-lasing, dust abatement, etc.) will be less than the demand for water supply during operation. Hence, the impacts on water use are bounded by the GEIS.
3. Water Quality - Non-Radiological Programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process. Federal, state and local regulations, and permits pertaining to water quality will remain In effect, and no significant changes to water supply reliability are expected. Therefore, the impact of TMl-2 decommissioning on water quality is bounded by the GEIS.
4. Air Quality There are many types of decommissioning activities that have the potential to affect air quality. These activities are listed in the GEIS and evaluated from the perspective of the ability to mitigate consequences of activities through the use of high efficiency particulate filters. In addition, the release of any effluents must be controlled to keep contaminated material within the NRC's regulatory limits. For the purposes of assessing radiological impacts, impacts are of small significance if doses and releases do not exceed limits established by the NRC's regulations. GPU Nuclear does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality. Therefore, the impact of the TMl-2 decommissioning on air quality is bounded by the GEIS.
5. Aquatjc Ecology GPU Nuclear does not anticipate disturbance of lands beyond the current operational areas of the plant. No alteration to the shores of the Susquehanna River will occur. All activities within the current operational areas of the plant will be conducted in accordance with required permits. Therefore, the impacts of decommissioning TMl-2 on aquatic ecology are bounded by the GEIS.
6. Terresbial Ecology I 0 10

~ttachment 1 to TMI-19-164 Page 14 of20 Terrestrial ecology considers the plants and animals in the vicinity of Three Mile Island as well as the interaction of those organisms with each other and the environment.

Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plant and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation. GPU Nuclear does not anticipate activities to be conducted that would disturb habitat beyond the operational areas of the plant. In addition, the Pennsylvania Department of Natural Resources controls impacts to the environment through regulation of construction activities. Therefore, the impacts of decommissioning TMl-2 on terrestrial ecology are bounded by the conclusions in the GEIS, which concludes the impact to be small.

7. Threatened and Endangered Species Of the state or federally listed endangered or threatened animal and plant species, only the bald eagle, the osprey, the peregrine falcon, and American holly were identified to have a presence on or near the island.

The bald eagle has recently been removed from the endangered species list but remains protected by two other federal laws. The Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act became effective in 2007. Bald eagles have become relatively common along the Susquehanna River and have been known to nest in Dauphin, Lancaster, and York counties. Occasionally they have been observed on Three Mile Island, but there are no known nests on the island. There is a bald eagle nest located approximately 20 miles south, near Holtwood Dam.

The Susquehanna River and the associated environment and wetland areas in the vicinity of Three Mile Island are used by many migratory and resident bird species.

Osprey and peregrine falcon nests are known to occur on Three Mile Island. Ospreys have nested on the meteorological tower every year since 2004. A 55-foot nesting platform was erected near the tower, but the ospreys have not used it. Peregrine falcons have nested on the TMl-1 Reactor Building since 2002. A nest box designed for peregrine falcons was placed on the TMl-2 reactor ~uilding in 2002, but the birds have not used it. Exelon regularly monitors the osprey and the peregrine falcon nests on Three Mile Island. The American holly, state-listed as threatened, has been recorded on the TMl-1 property.

Should the situation change and the identified species routinely be found in or around any of the TMl-2 buildings or property, it is GPU Nuclear's intent to notify the NRC and the Pennsylvania Department of Environmental Protection to evaluate the impact of decommissioning activities.

8. Radiological Occupational Dose It is anticipated that low-level radioactive waste removed from TMl-2 will be disposed of at approved waste disposal sites, and that the disposal at local commercial landfills will 10 10 to TMI-19-164 Page 15 of20 be minimized in favor of low-level radioactive waste disposal to reduce the risk of Inadvertent release of radiological material.

Radiation dose to the public is expected to remain below levels comparable to when TMl-2 was operating, through the continued application of radiation protection and contamination controls combined with the reduced source term available in the facility.

It is anticipated that an occupational dose estimate for the decommissioning of TMl-2 will be performed prior to the start of decommissioning activities based on confirmed characterization results of area contamination and actMty levels.

Occupational dose will be limited to 5 rem/year total effective dose equivalent (TEDE) as required by 10 CFR 20.1201(a)(1)(i), and is expected to be administratively controlled to a lower TEDE limit to ensure that personnel doses do not exceed regulatory limits. It is also anticipated that administrative practices will result in equitable distribution of dose among available qualified workers to ensure collective dose to the work force is kept ALARA.

The decommissioning activities dose will be maintained within the regulatory limits, and as such, is consistent and within the conclusions of the GEIS

9. Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety with TMl-2 in the PDMS state is considerably lower than the likelihood of a release from the plant during power operation. This is because the majority of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor.

GEIS, Supplement 1 also considers the possibility of a zircalloy fire. This accident is not relevant to TMl-2 in the current PDMS condition with approximately 99% of the fuel material having been removed from the site and sent to INEEL.

The potential for decommissioning activities to result in radiological releases not involving spent fuel (that is, releases related to decontamination and dismantlement activities) will be minimized by use of procedures designed to minimize the likelihood and consequences of such releases.

Therefore, GPU Nuclear concludes that the impacts of decommissioning on radiological accidents are small and bounded by the GEIS.

10. Occupational Issues GPU Nuclear will continue to maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state and local occupational safety standards and requirements continue to be met.

10 10 10 to TMI-19-164 Page 16 of20 GPU Nuclear has reviewed the occupational hazards and injuries in the GEIS and concluded that they are not unique or different than activities performed during construction and cleanup of TMl-2. Therefore, the impact of decommissioning TMl-2 on occupational issues is bounded by the GEIS.

11. Cost Decommissioning costs for TMl-2 are discussed in Section IV of the PS DAR report.

The GEIS recognizes that an evaluation of deconimissioning cost is not a National Environmental Policy Act requirement. Therefore, a bounding analysis is not applicable.

12. Socioeconomics Decommissioning of TMl-2 is expected to result in positive socioeconomic impacts. As TMl-2 transitions from the PDMS state to a unit undergoing decommissioning, the potential for local employment to support decommissioning operations becomes available.

GPU Nuclear has reviewed the GEIS and has determined that the decommissioning of TMl-2 is bounded by the GEIS analysis of socioeconomic effects on the shutdown and decommissioning of an operating unit.

13. Environmental Justice Executive Order 12898, dated February 16, 1994, directs Federal executive agencies to consider environmental justice under the National Environmental Policy Act. It is designed to ensure that low-income and minority populations do not experience djsproportionately high and adverse human health or environmental effects because of federal actions.

Because the activities of the decommissioning plan create the potential for additional work opportunities, the decommissioning of TMl-2 could have a positive impact on environmental justice by providing job opportunities for lower income or minority populations ~round the area.

The decommissioning activities are bounded by the evaluation of the post accident clean up activities relative to socioeconomic and environmental justice. GPU Nuclear concludes that the employment opportunities created by decommissioning will have_a positive impact on environmental justice and that no further evaluation of detrimental impacts is required.

1,4_ Cultural, Historic, and Archeological Resources The PEIS makes no mention of cultural, historic or archeological resources on Three Mile Island. In addition, GPU Nuclear expects that most decommissioning activities will be conducted within the protected areas of the site. As stated in the GEIS, where 10

\\0 10 to TMI-19-164 Page 17 of20 disturbance of lands beyond the operational areas is not anticipated, the impacts on cultural, historic and archeological resources are not considered to be detectable or destabilizing. GPU Nuclear has concluded that the Impact of decommissioning TMl-2 on cultural, historic, and archeologlcal resources to be bounded by the GEIS.

15. Aesthetic Issues The impact of decommissioning activities on aesthetic resources will be temporary and remain consistent with the aesthetics of an industrial plant. After the decommissioning process is complete, site restoration activities will result in structures being removed from the site and the site being backfilled, graded and landscaped as needed. The removal of structures is generally considered beneficial to the aesthetic impact of the site. Therefore, GPU Nuclear has concluded that the impact of decommissioning TMl-2 on aesthetic issues is bounded by the GEIS.
16. Noise General noise levels during the decommissioning process are not expected to be any more severe than during refueling outages and are not expected to present an audible Intrusion on the surrounding community. Some decommissioning activities may result in higher than normal noise levels (that is, some types of demolition activities). However, these noise levels would be temporary and are not expected to present an audible intrusion on the surrounding community. Therefore, GPU Nuclear has concluded that the impact of decommissioning TMl-2 on noise is bounded by the GEIS.
17. Transportation The GEIS states'that NRC regulations are adequate to protect the public against unreasonable risk from the transportation of radioactive material and that the effects of transportation of radioactive waste on public health and safety are considered to be neither detectable nor destabilizing. The NRC analysis further determined that their consideration of the existing data for decommissioning methods and transportation modes should bound the transportation impacts for all decommissioning options for pressurized water reactors and boiling water reactors.

For the decommissioning of TMl-2, the transportation modes assumed are shielded container removal by rail or truck. The reactor vessel internal components are expected to be transported in spent fuel casks by rail. Other highly radioactive wastes will be transported in shielded containers via truck. The major transport mode for waste generated from filtering and demineralization of the reactor coolant system and the fuel transfer pool water is assumed to require shipment in shielded truck casks. The low level radioactive wastes requiring controlled disposal are expected to be sent to a waste processor or a low-level radioactive waste disposal facility via railroad.

The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is 10 10

., to TMI-19-164 Page 18 of20 shipped, and the radiological waste/fixed waste quantities and disposal plans. The estimated number and volume of shipments from the plant will be much smaller than shipments to the plant during decommissioning. The shipments from the plant would be primarily radioactive wastes and non-radioactive wastes associated with dismantlement and disposal of structures, systems and components.

GPU Nuclear must comply with applicable regulations when shipping radioactive waste, and the NRC has concluded in the GEIS that these regulations are adequate to protect the public against unreasonable risk from transportation of radioactive materials. In addition, shipments of waste from the site are not expected to result in measurable deterioration of affected roads or a destabilizing increase in traffic density.

1 Therefore, GPU Nudear has concluded that the.impact of decommissioning TMl-2 on transportation is bounded by the GE:IS.

18. Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Uranium is a natural resource that is irretrievably consumed during power operation.

After the plant is shutdown uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment but rather a relatively short-term investment. Since the decommissioning plan is to release the site for unrestricted use after license termination, land is not considered an irreversible resource. The only Irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (for example, rags, solvents, gases, and tools) and the fuel used for decommissioning activities and.transportation of materials to and from the site.

However, the use of these resources is minor.

Therefore, GPU Nuclear has concluded that the impact of decommissioning TMl-2 on irreversible and irretrievable commitment of resources is bounded by the GEIS.

Additional Considerations While not quantitative, the following considerations are also relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed.

Significant cleanup of the TMl-2 faclllty has already been completed with approximately 99% of the fuel removed and shipped to INEEL.

Decontamination has been completed to the extent that further major decontamination programs are not justtfied on the basis of worker dose.

10 10 to TMI-19-164 Page 19 of20 Prior to decommissioning, TMl-2 will be maintained in accordance with the NRG approved PDMS mode governed by the associated PDMS iechnical Specifications, PDMS Quality Assurance Program, and PDMS Final Safety Analysis Report. As such, TMl-2 will be maintained in a condition of stability and safety such that there is minimal risk to public health and safety.

Radiation protection techniques used at the time of decommissioning are expected to improve over current practices and should ensure reduction in occupational exposure.

Site access control processes during decommissioning are expected to redu~ the risk of public contamination due to trespassing.

Conclusion Based on the above discussion, the potential environmental impacts associated with decommissioning TMl-2 have already been postulated in and will be bounded by the previously issued environmental impact statements, specifically the PEIS, and the GEIS and its supplement. This is principally due to the following reasons:

The postulated Impacts associated with the decommissioning method chosen have already been considered in the PEIS and the GEIS, including its supplement.

There are no unique aspects of TMl-2 or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the PEIS, and the GEIS and its supplement.

The environmental impacts associated with the site-specific decommissioning activities for TMl-2 will be bounded by appropriate previously issued environmental impact statements 10 to TMI-19-164 Page20 of20 VII.

REFERENCES

1. Halnon, G.H. (GPU Nuclear, Inc.), Sauger J. (TMl-2 Solutions LLC) letter

, TMl-19-112 "Application for Order Approving License Transfer and Conforming License Amendments," (ML19325C600) dated November 12, 2019

2. Pace, D. L. (GPU Nuclear) to NRC letter, "Notification of Intent to Submit a Post-Shutdown Decommissioning Activities Report," (ML12235A227) dated August 14, 2012
3. Camper, L. W. (NRC) to Pace, D. L. (GPU Nuclear) letter, "Three Mile Island Nuclear Station, Unit 2 (TMl-2) - Failure to Submit Post-Shutdown Decommissioning Activities Report-Non-cited Violation (Docket: 05000320),"

(ML12349A291) dated February 13, 2013

4. NUREG-0683, Supplement 3, "Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2,"

Supplement 3, dated August 1989

5. Masnik, M. T. (NRC) to Long, R. L. (GPU Nuclear) letter, "Issuance of Amendment No. 45 for Facility Operating License No. DPR-73 to Possession Only License for Three Mile Island Nuclear Station Unit 2 (TAC No.

ML69115)," dated September 14, 1993

6. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile Island Unit 2," dated September 2004
7. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile Island Unit 2," dated January 2009
8. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile Island Unit 2," dated December 2014
9. Halnon, G.H. (GPU Nuclear, Inc.), to USNRC letter TMl-19-003 "Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2, dated March 28, 2019
10. NUREG-0586, "Generic Environmental Impact Statements on Decommissioning and Radiological Criteria for License Termination," dated August 1988, and Supplement 1, Volumes 1 and 2, November 2002

ENCL0SURE1A DETAILED COST INFORMATION (PROPRIETARY)

ENCLOSURE1B DETAILED COST INFORMATION (NON-PROPRIETARY)

((

TABLE 18-1 to TMl-19-164 B Table 1 B-1 THREE MILE ISLAND UNIT 2 DECOMMISSIONING COST ESTIMATE ttt>-,ds of 201& clolloa)

REDACTED n

Page 1 of 2

((

TABLE 1B-1 to TMl-19-164 B Table 1 B-1 THREE MILE ISLAND UNIT 2 DECOMMISSIONING COST ESTIMATE (Q,omands of 201t -..i REDACTED n

Page 2 of 2

((

FIGURE 18-1 to TMl-19-164 8 Figure 18-1 THREE MILE ISLAND UNIT 2 2019 DECOMMISSIONING SCHEDULE REDACTED D

Page 1 of 2

((

FIGURE 18-1 to TMl-19-164 8 Figure 18-1 THREE MILE ISLAND UNIT 2 2019 DECOMMISSIONING SCHEDULE REDACTED n

Page 2 of 2

Year 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 Total TABLE 1B-2 THREE MILE ISLAND UNIT 2 to TMl-19-164 B Table lB-2 TMl2 ESTIMATED ANNUAL SPENDING (thousands of 2019 Dollars)

License Debris Site Total Termination Material Restoration 3,315 641 3,955 16,846 894 17,740 27,085 1,334 28,420 37,761 4,209 41,970 60,367 16,273 76,640 72,620 16,076 88,696 81,868 15,444 97,312 79,102 13,129 92,230 67,152 8,944 76,096 29,203 4,730 33,933 13,363 13,363 20,463 20,463 52,561 3,778 56,339 86,727 15,428 102,155 103,385 11,891 115,275 78,802 11,713 90,514 72,741 2,855 75,596 24,553 243 24,796 1,380 1,380 929,291 81,674 45,908 1,056,874 Page 1 of 1

Year 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Total TABLE 18-3 THREE MILE ISLAND UNIT 2 SINKING FUND ANALYSIS (thousands of 2019 Dollars)

Beginning Balance NOT Annual Spending NOT Earnings 900,000 A

3,955 897,545 17,740 897,578 28,420 886,825 41,970 862,172 76,640 802,010 88,696 728,467 97,312 644,751 92,230 564,493 76,096 498,926 33,933 474,632 13,363 470,628 20,463 459,373 56,339 411,658 102,155 316,715 115,275 206,621 90,514 119,334 75,596 45,369 24,796 21,232 1,380 1,056,874 A - NDT Beginning balance is assumed as of 11/30/19 B - Represents 1-months earnings Rate of Real Return is 2%

Page 1 of 1 1,500 17,773 17,667 17,317 16,477 15,153 13,596 11,973 10,529 9,639 9,359 9,208 8,624 7,212 5,182 3,227 1,631 659 411 177,137 to TMl-19-164 8 Table 1B-3 Ending Balance NOT B

897,545 897,578 886,825 862,172 802,010 728,467 644,751 564,493 498,926 474,632 470,628 459,373 411,658 316,715 206,621 119,334 45,369 21,232 20,263

Three Mlle Island - Unit 2 Project Schedule Detcr1pUon PHASE 1 - Source Term Reduction Pre-Cloq Plannln1, En11nNr1n1 & Re1ulatory Contract Clo1ln1 & Anet Tran1fer Plannln1, En11nNr1n1 & Re1ulatory PhHe 1 Lons Laad Procurement Infrastructure Up1rades & Modifications Containment Openln1 RHdy Rad Bulldln1 Source Term Reduction Walta Packa11n1, Transport & Disposal RHctor Vassal Source Term Reduction Larae Component Source Term Reduction PhHa 1 Complete FIGURE 1B-2 THREE MILE ISLAND UNIT 2 DECOMMISSIONING PHASE ACTIVITIES* to TMl-19-164 B FIGURE 1 B-2 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 ZOS1 2032 ZOSS 2034 2035 2036 2037

- -~- --

~

- ~~-

PHASE 2

  • Decommissioning & Ucense Termination PhHe z Plannln1 Pha11 2 Loni Laad Procurement Infrastructure Up1rade1 & Modlflcatlon, RHctor Vassel Removal Waite Packa11n1, Transport & Dlsposal Lars* Component Removal CIHn Bulldln1 0.moHtlon Rad Buildln1 Interior/ Systems D&D Rad Buildln1 Open Air Demolition Final Sita Surveys Site Reltoratlon PhHe 2 Complete
  • Does not include an assumed schedule for long-term storage of Debris Material after Phase 2 until acceptance by DOE in the early 2050 period.

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