ML21085A692

Plan for Management of Debris Material

ML21085A692
Person / Time
Site:	Three Mile Island
Issue date:	03/15/2021
From:	Gerard van Noordennen TMI-2 Solutions
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21085A691	List: ML21085A692
References
TM I2-RA-COR-2021-0003
Download: ML21085A692 (15)

Text

CONFIDENTIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17

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TMI-2 SOLUTIONS March 15, 2021 TM I2-RA-COR-2021-0003 10 CFR 50.82(a)(7)

U.S. Nuclear Regulatory Commission A TIN; Document Control Desk Washington, DC 20555-0001

Subject:

TMl-2 Solutions Plan for Management of Debris Material Three Mile Island, Unit 2 NRG Possession Only License No. DPR-73 NRG Docket No. 50-320 References

1) Letter TMl-19-112 from Halnon, G.H. (GPU Nuclear, Inc.), and Sauger, J (EnergySolutions) "Application for Order Approving License Transfer and Confom,ing License Amendments" (ML19325C600) dated November 12, 2019.

2) Letter TMl-20-006 from Halnon, G. H. (GPU Nuclear, Inc.), and van Noordennen, G.P. (EnergySo/utions) "Notification of Revision of Commitment for "Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7)," (ML20066F494) dated March 2, 2020

3) Letter from USNRC to Sauger, J. (TMl-2 Solutions, LLC), "Three Mile Island Nuclear Station, Unit No. 2 - Issuance of Amendment No. 64 Re: Order Approving Transfer of License and Confom,ing License Amendment (EPID L-2019-LLA-0257)," (ML20352A381) dated December 18, 2020.

This letter satisfies the commitment provided in Reference 1, which was subsequently revised in Reference 2, to submit to the NRG, the TMl-2 Solutions "Plan for Management of Debris Material" within 90 days post-closing of the transaction described in the Purchase and Sale Agreement provided in Reference 1. The NRG approved the closing of the transaction as described in Reference 3 following upon which TMl-2 Solutions became the licensee for TMl-2. The TMl-2 Solutions "Plan for Management of Debris Material" is presented in Attachment 1 for infom,ation only.

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Upon removal of Attachment 3 this document is uncontrolled.

CONFIDENTIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17 TM I2-RA-COR-2021-0003 Page 2 of 2 presents an Affidavit requesting that the confidential financial information provided in Attachment 3 be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

In accordance with 10 CFR 50.91(b)(1), a copy of this submittal has been sent to the Commonwealth of Pennsylvania. This document contains no regulatory commitments.

In the event the NRC has any questions with respect to the content of this document or wishes to obtain any additional information, please feel free to contact me at 860462-9707.

Sincerely G~~

Gerry van Noordennen Senior Vice President Regulatory Affairs Attachments: - Plan for Management of Debris Material - 10 CFR 2.390 Affidavit - Sinking Fund Analysis (Proprietary) cc: with Proprietary

Attachment:

Ted Smith, NRC Project Manager NRC Region I Administrator NRC Lead Inspector Director, Bureau of Radiation Protection, PA DEP Chief, Division of Nuclear Safety, Bureau of Radiation Protection, PA DEP Upon removal of Attachment 3 this document is uncontrolled.

TMl-2 Service List

,cc w/o Proprietary Attachment Ken Robuck Chairman, Board of County President and CEO Commissioners, Dauphin County Energy Solutions 112 Market Street 299 South Main Street, Suite 1700 7th Floor Salt Lake City, UT 84111 Harrisburg, PA 17101 John Sauger Chairman, Board of Supervisors of President and Chief Nuclear Officer Londonderry Township Reactor D&D 783 S. Geyers Church Rd.

EnergySolutions Middletown PA 17057 121 W. Trade Street, Surte 2700 Charlotte, NC 28202 Mike Lackey Senior Vice President D&D Operations EnergySolutions 121 W. Trade Street, Surte 2700 Charlotte, NC 28202 Gerard van Noordennen Senior Vice President Regulatory Affairs EnergySolutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Scott Baskett Project Director TMl-2 Solutions 121 W. Trade Street, Surte 2700 Charlotte, NC 28202 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Daniel F. Stenger Hogan Lovells US LLP 555 13th St NW Washington, D.C. 20004 Upon removal of Attachment 3 this document is uncontrolled.

STATE OF CONNECTICUT

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COUNTY OF NEW LONDON )

Gerard van Noordennen, being duly sworn according to law deposes and says:

I am the Senior Vice President Regulatory Affairs of TMl-2 Solutions, LLC, and as such I am familiar with the contents of this correspondence and the attachments thereto. The matters set forth therein regarding TMl-2 Solutions, LLC, their affiliates, and Three Mile Island Nuclear Station, Unit 2 are true and correct to the best of my knowledge, information and belief.

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Gerard van Noordennen Subscribed and Sworn to before me this /'5'4iay o f ~ 2021

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Notary Public of Connecticut

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to TMl2-RA-COR-2021-0003 Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 Plan for Management of Debris Material

Attachment 1 to TMl2-RA-COR-2021-0003 Page 1 of 8 Plan for Management of Debris Material

1. Background and Introduction The "Plan for Management of Debris Materialn provides the NRC information similar to the information that a licensee would be required to provide for spent fuel in accordance with 10 CFR 50.54(bb).

10 CFR 50.54 (bb) requires licensees that have permanently ceased operations by April 4, 1994 to submit written notification that the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.

As discussed in Reference 1, General Public Utilities Nuclear (GPUN) concluded that this regulation does not apply to TMl-2, which has already transferred approximately 99% of its fuel to the Department of Energy (DOE).

The quantity of fuel (i.e., Uranium Dioxide) remaining at TMl-2 is a small fraction of the initial fuel load. The approximately 1% of fuel remaining is comprised of spent nuclear fuel, damaged core material, and high level waste (collectively referred to as "Debris Material").

On December 28, 1993 Amendment No. 48 to Possession Only License DPR-73 was issued, which initiated the start of TMl-2 Post Defueling Monitored Storage (PDMS)

(Reference 2). In approving Amendment No. 48, the NRC affirmed that TMl-2 has been defueled and decontaminated to the extent that the plant is in a safe, inherently stable condition suitable for long-term management and any threat to the public health and safety has been eliminated.

Reference 3 submitted a request for transfer of Possession Only License No. DPR-73 from GPU Nuclear, Inc. to TMl-2 Solutions. The NRC approved the license transfer in Reference 4 and following the closing of the transaction described in the Purchase and Sale Agreement (Reference 3), TMl-2 Solutions became the licensee for TMl-2.

TMl-2 Solutions is responsible for developing a storage and disposal plan for any remaining Debris Material until title to the Debris Material is transferred to the DOE for disposal. Since Debris Material recovery and site storage is an integral part of performing decontamination activities to decommission TMl-2, an exemption to withdraw funds from the decommissioning trust fund for Debris Material retrieval and storage costs is not required. The DOE has indicated that if the Debris Material is packaged and stored in NRG-approved storage and transport containers, that DOE will accept the Debris Material for disposal at a DOE facility at a future date. If the NRC disagrees with position, please let us know.

The decommissioning of TMl-2 under the TMl-2 Solutions approach will occur in three Phases. Phase 1 is comprised of Phase 1a and Phase 1b. Phase 1a pertains to the

Attachment 1 to TMl2-RA-COR-2021-0003 Page 2 of 8 preparation for decommissioning which includes activities such as engineering, procurement of long-lead time items, demolition of some SSC's located in the TMl-2 yard, and the installation and maintenance of temporary infrastructure. While in Phase 1a, TMl-2 will remain in a PDMS condition. Phase 1b pertains to Debris Material recovery and source term reduction, which includes the recovery, packaging, and storage of Debris Material and the reduction of the overall radiological source term at TMl-2 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. Phase 1b activities are consistent with the definition for active decommissioning (DEGON).

Phase 2 refers to the decommissioning and dismantlement of the TMl-2 site to a level that permits the release of the site, except for an area potentially set aside for storage of Debris Material on the ISFSI. Decommissioning activities that will be performed in Phase 2 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.

• Backfilling the site to the existing grade elevation.

Phase 3 refers to the long-term storage and management of Debris Material at the ISFSI, as well as decommissioning the ISFSI after the DOE has removed the multi-purpose storage and transport canisters containing the Debris Material from the site.

Major decommissioning activities will occur under Phase 1b and Phase 2. As defined in 10 CFR 50.2 "Definitions," a "major decommissioning activity" means, "any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than Class C waste in accordance with 10 CFR 61.55."

Activities associated with Phase 1b will commence following NRC approval of the TMl-2 Solutions License Amendment Request (LAR) (Reference 5) to remove or revise certain license conditions and TS requirements to support the transition of TMl-2 from a PDMS condition to that of a facility undergoing radiological decommissioning (DEGON). The LAR proposes the elimination of those TS no longer applicable based on current plant radiological conditions and updated safe fuel mass limits (SFML). Changes to TS limiting conditions for PDMS, definitions, surveillance requirements, and administrative controls, as well as several license conditions are also proposed. Upon issuance, this proposed amendment will modify the 10 CFR Part 50 License and the TS to support entry into DEGON.

Attachment 1 to TMl2-RA-COR-2021-000 3 Page 3 of 8

2. Debris Material Management Strategy Following the accident at TMl-2 in 1979, DOE collected approximately 99% of the spent nuclear fuel and damaged core material from the site, pursuant to DOE Contract No.

DE-SC07-83ID12355. Title to and possession of this material remains with DOE.

Because the accident occurred within the first few months of reactor operation, no spent nuclear fuel was otherwise stored at TMl-2. As stated in Revision 2 of the Post-Shutdown Decommissioning Activities Report, dated December 4, 2015, (Reference 6) it is reasonable to presume that DOE retains ultimate authority for disposal of remaining material, pursuant to Standard Contract DE-CR01-83NE44477 .11. This Standard Contract has an additional provision unique to TMl-2 as follows:

All nuclear fuel used in future generation at TMl-2 as well as any damaged core material, if any, remaining after the completion of Contract No. 12355 [Contract No. DE-SC07-84ID12355] will be covered by the provisions of this Standard Contract. The fee for disposal of any such remaining damaged core material under the Standard Contract will be negotiated by GPU Nuclear and DOE in accordance with the requirements of the Nuclear Waste Policy Act.

The cost estimates for decommissioning TMl-2 were provided in the License Transfer Amendment (Reference 3) including the costs for recovery and packaging of the Debris Material. Beyond this, however funds must be set aside for long-tenn storage of the Debris Material. TMl-2 Solutions conservatively estimates that long-tenn storage of Debris Material after the completion of Phase 2 of decommissioning, until DOE acceptance will cost approximately $59.5 million (in 2020 dollars). This includes the cost of decommissioning the storage facility after DOE acceptance. This estimate is based on a currently assumed DOE acceptance date in 2053 and ISFSI decommissioning in 2054.

Interim storage of the Debris Material, until the DOE has completed the transfer, will be at the TMl-2 ISFSI located on the TMI site. It is estimated that approximately 12 to 14 casks will be required to contain the volume of Debris Material removed from the TMl-2 facility.

The ISFSI is scheduled to be decommissioned once the canisters containing the Debris Material have been removed, and any required decontamination perfonned on the concrete storage modules. Storage casks can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad can then be removed and the area regraded. Any contaminated material will be disposed of as low-level radioactive waste (LLRW).

Attachment 1 to TMl2-RA-COR-2021-0003 Page 4 of 8

3. Cost Consideration Table 3-1 "Material Costs" presents information related to the management of Debris Material. Attachment 3, "Sinking Fund Analysis" demonstrates that the Nuclear Decommissioning Trust (NOT) contains sufficient funds to support long-term storage of Debris Material until acceptance by DOE.

Based on DOE interactions and our understanding of previous utility settlements and litigation outcomes, TMl-2 Solutions has estimated the Debris material related transfer and storage costs for TMl2 that would be eligible for cost recovery. Those estimated costs are:

Table 3-1 Material Costs ISFSI Design and Construction $ 7,675,931 DCM Canister and Equipment Procurement 26,574,496 DCM Canister Transfer to ISFSI 6,896,100 ISFSI Security, Operations Ta>ees and Fees 91,811,053 DOE Transfer and ISFSI Decommissioning 12,119,251 GRAND TOTAL $ 145,076,831

4. Use of Nuclear Decommissioning Trust Funds for Debris Material Management I. INTRODUCTION TMl-2 Solutions is responsible for developing a storage and disposal plan for any damaged core material remaining at TMl-2 ("Debris Material") until title to the Debris Material is transferred to the DOE for disposal, pursuant to Standard Contract DE-CR01-83NE44477. The following provides an outline of how TMl-2 Solutions characterizes and intends to fund Debris Material management in compliance with NRC requirements.

Due to the unique nature of TMl-2, this analysis includes a Section II, "Background," to provide context on the current status of TMl-2, and how rt may influence Debris Material management planning and funding. Sections Ill and N address NRC requirements related to management and funding of Debris Material until its transfer to DOE for ultimate dispositioning. More specifically, Section Ill addresses management and funding during Phases 1 and 2 of decommissioning, and Section IV addresses management and funding following the completion of Phase 2.

II. BACKGROUND The March 28, 1979 accident created unique challenges for decommissioning the TMl-2 reactor and site, including management of Debris Material. As described in the

Attachment 1 to TMl2-RA-COR-2021-0003 Page 5 of 8 December 12, 2019 Post Shutdown Decommissioning Activities Report provided to the NRC (at pages 2-3)(Reference 7):

"[During the accident, t]he majority of the fuel material travelled down through the region of the southeastern assemblies and into the core bypass region. A portion of the fuel material passed around the bypass region and migrated down into the lower internals and lower head region, but overall reactor vessel integrity was maintained throughout the accident.

As a result of this accident, small quantities of core debris and fission products were transported through the reactor coolant system and the reactor building. In addition, a small quantity of core debris was transported to the auxiliary and fuel handling buildings.

Further spread of the debris also occurred as part of the post-accident water processing cleanup activities."

Although approximately 99% of the resulting Debris Material from the accident was removed as part of prior US Department of Energy ("DOE")-led defueling efforts, the Debris Material that remains is spread throughout the reactor and auxiliary buildings, and is integrated into the equipment and materials that need to be removed as part of the traditional decommissioning process. This challenge-specific to TMl-2-requires a unique approach to management of the TMl-2 Debris Material during the decommissioning process.

Ill. MANAGEMENT OF DEBRIS MATERIAL DURING PHASES 1 & 2 Removal & Storage of Debris Material is an Essential Decommissioning Activity Given the challenges described above, in developing the decommissioning plan for TMl-2, TMl-2 Solutions determined that removal of the remaining Debris Material from TMl-2 is required to remove the facility safely from service and release the property for unrestricted use. Therefore, removal and storage of the Debris Material during Phases 1 and 2 of decommissioning is appropriately characterized as a legitimate -

decommissioning cost under 10 CFR 50.2.

Removal of Debris Material is akin to a "cascading cost" as described in Nuclear Energy Institute ("NEI') and NRC guidance1-the removal of material essential to the decommissioning process, even if that removal would not be considered a traditional radiological decommissioning action. For example, removal of Debris Material during Phase 1 of decommissioning is essential for reducing radioactivity within the TMl-2 facility structures so that certain areas are no longer considered locked high radiation areas in accordance with NRC regulations (e.g., 10 CFR 20.1601), which is crucial for enabling further decommissioning actions to continue. Phase 2 will remove any remaining Debris Material not removed during Phase 1.

1 See NEI 15-06, Use of the Nuclear Decommissioning Trust Fund (Oct 2016), at 20-21; see also generally NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized Water Reactor Power Station (Nov. 1995) (discussing the principle of "cascading costs").

Attachment 1 to TMl2-RA-COR-2021-0003 Page 6 of 8 Removal of Debris Material during Phases 1 and 2 inherently includes storage of the removed Debris Material. Given the radioactive characteristics of the Debris Material, arrangements need to be made to package and store the Debris Material distinct from other decommissioning wastes. To this end, TMl-2 Solutions has determined that packaging the Debris Material into traditional spent nuclear fuel canisters and casks, and storing these wastes on a pad similar to an Independent Spent Fuel Storage Installation, represents the most efficient and safest approach to storing the Debris Material. Nonetheless, because the Debris Material cannot be removed during active decommissioning without a storage option available, storage of the Debris Material during Phases 1 and 2 is essential to the decommissioning process and likewise a cascading cost in line with NEI and NRC guidance. The U.S. Department of Energy (DOE) has provided feedback that Debris Material stored in NRC approved multi-purpose waste packages will be accepted by the DOE for transport and disposal at a future date at a DOE disposal facility.

Removal & Storage of Debris Material Is Distinct from Irradiated Fuel Management This approach is consistent with the regulatory history of 10 CFR 50.54(bb), which indicates that Section 50.54(bb) was intended to address costs for spent fuel management that are separable from decommissioning the plant itself. In the rulemaking for 10 CFR 50.54(bb), the NRC stated that considering spent fuel management funding as a separate matter from decommissioning funding was appropriate because the activities are readily separable. 2 Because the remaining Debris Material is intertwined with certain equipment and material to be decommissioned, removal of Debris Material is expected to be integrated with decontamination and dismantlement activities. Thus the costs for Debris Material removal are not separable from traditional decommissioning activities.

Removal & Storage of Debris Material is Appropriately Described in the PSDAR Because management of Debris Material During Phases 1 and 2 is essential to and fundamentally intertwined with the decommissioning process, and is not well-characterized as an irradiated fuel management activity, the costs related to management of Debris Material during these two phases are appropriately included in the TMl-2 PSDAR. Specifically, these costs were included within Revision 3 of the TMl-2 PSDAR in Table 1 in the body of the report and in Enclosure 1A in Table 1A-1 and in B in Table 1 B-2, which was reviewed by the NRC staff as part of the license transfer approval. The TMl-2 PSDAR demonstrates that adequate funds exist in the TMl-2 NOT to manage removal and storage of Debris Material during Phases 1 and 2 as part of site decommissioning.

2 See Final Rule, "Requirements for Licensee Actions Regarding the Disposition of Spent Fuel Upon Expiration of Reactor Operating Licensees," 49 Fed. Reg. 34,689, 34,691 (Aug. 31, 1984).

Attachment 1 to TMl2-RA-COR-2021-0003 Page 7 of 8 IV. MANAGEMENT OF DEBRIS MATERIAL POST-PHASE 2 As opposed to removal and management of the Debris Material during active decommissioning, the long-term management of the Debris Material following the end of Phase 2 is not closely related to~decommissioning. Following the conclusion of Phase 2, which includes anticipated partial release of the TMl-2 site except for those areas dedicated to storing the Debris Material, decommissioning will have ceased and the only significant activity on the site will be long-term storage of the Debris Material until acceptance by DOE.

As a result, the costs related to long-term management of Debris Material following Phase 2 are not well characterized as decommissioning costs, and may instead be more akin to traditional irradiated fuel management expenses. Consistent with this conclusion, TMl-2 PSDAR Rev. 3 does not consider the use of NOT funds for these post-Phase 2 expenses (anticipated to be approximately $59.5 million). These costs instead will t>e addressed in the TMl-2 Debris Material Management Plan.

As described by the NRC in its Safety Evaluation Report approving the transfer of the TMl-2 license to TMl-2 Solutions (footnote 1), it is currently anticipated that the bulk of the funds required for long-term Debris Material management following Phase 2 will be the responsibility of DOE. To the extent an exemption may be required in the future to use NOT funds for post-Phase 2 Debris Material Management activities, an exemption will be sought at the appropriate time.

Attachment 1 to TMl2-RA-COR-2021-0003 Page 8 of 8

5. References

1. Letter C311-94-2077 from Broughton, J.B. (GPU Nuclear, Inc.), "10 CFR 50.54 (bb)

Notification" dated May 31, 1994.

2. Letter from USNRC to Long, R.L., (GPU Nuclear, Inc), "Issuance of Amendment No.

48 for Possession Only License No. DPR-73 for the Three Mile Island Nuclear Station Unit2 (TAC No. M69115) dated December 28, 1993.

3. Letter TMl-19-112 from Halnon, G.H. (GPU Nuclear, Inc.), and Sauger, J.

(EnergySolutions) "Application for Order Approving License Transfer and Conforming License Amendments" (ML19325C600) dated November 12, 2019.

4. Letter from USN RC to Sauger, J. (TMl-2 Solutions, LLC), Three Mile Island Nuclear Station, Unit No. 2 - Issuance of Amendment No. 64 Re: Order Approving Transfer of License and Conforming License Amendment (EPID L-2019-LLA-0257),"

(ML20352A381) dated December 18, 2020.

5. Letter TMl2-RA-COR-2021-0002 from van Noordennen, Gerard (TMl-2 Solutions)

"License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications," dated February 19, 2021.

6. Letter TMl-15-093 from Halnon, G.H. (GPU Nuclear, Inc.), "Revision to Post-Shutdown Decommissioning Activities Report (ML15338A222) dated December 4, 2015.

7. Halnon, G.H. (GPU Nuclear, Inc.), "Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7)," Revision 3 (ML20013E535) dated December 12, 2019.

to TMl2-RA-COR-2021-0003 Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 10 CFR 2.390 Affidavit

TMl-2 Solutions Proprietary Information Affidavit Affidavit of Gerard van Noordennen, Senior Vice President Regulatory Affairs, TMl-2 Solutions, LLL.

TMl-2 Solutions, LLC, is providing information in support of the TMl-2 "Debris Material Plan" described in this letter. Attachment 3 contains financial infonnation, including proprietary aspects to the decommissioning of TMl-2, which constitute proprietary commercial and financial information, belonging to TMl-2 Solutions, that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390 and 10 CFR 9.17. Release of this information would cause irreparable harm to the competitive position of TMl-2 Solutions, LLC. This basis for this declaration is:

I. This information is owned and maintained as proprietary by TMl-2 Solutions, LLC, II. This information is routinely held in confidence by TMl-2 Solutions, LLC, and not disclosed to the public, Ill. This information is being requested to be held in confidence by the NRC by this petition, IV. This information is not available in public sources, V. This information would cause substantial harm to TMl-2 Solutions, LLC, if it were released publicly, and VI. The information to be withheld was transmitted to the NRC in confidence.

I, Gerard van Noordennen, being duly sworn, state that I am the person who subscribes my name to the foregoing statement, I am authorized to execute the Affidavit on behalf of TMl-2 Solutions, LLC, and that the matters and facts set forth in the statement are true to the best of my knowledge, information, and belief.

Gerard van Noordennen Senior Vice President Regulatory Affairs TMl-2 Solutions, LLC Sworn To And Subscribed Before Me This \~ Day of ~-A._, , f..01 /

My Comm,ission Expires ~~ Chp., I

/ DANAS CHAPEL Notary Public My Commission Expires 01/31/2024