TMI-23-005, Updated Spent Fuel Management Plan

Updated Spent Fuel Management Plan

ML23080A211
Person / Time
Site:	Three Mile Island
Issue date:	03/21/2023
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
TMI-23-005
Download: ML23080A211 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com 10 CFR 50.54(bb)

TMI-23-005 March 21, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Subject:

Updated Spent Fuel Management Plan for Three Mile Island Nuclear Station -

Unit 1

Reference:

Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Spent Fuel Management Plan for Three Mile Island Nuclear Station, Unit 1," dated April 5, 2019 (ML19095A009)

Pursuant to 10 CFR 50.54(bb), "Conditions of licenses," Constellation Energy Generation, LLC (CEG) is submitting this update to the Three Mile Island Nuclear Station, Unit 1 (TMI-1) Spent Fuel Management Plan (SFMP). The initial SFMP was submitted by letter dated April 5, 2019 (Reference). The SFMP is being updated to reflect a change in the length of time spent fuel is projected to remain at the TMI-1 site.

The updated SFMP is included as the Attachment to this letter. The SFMP in the Attachment to this letter, supersedes and replaces in entirety the SFMP submitted in 2019. An update to the TMI-1 Decommissioning Cost Estimate (DCE) is being provided under separate cover letter.

As discussed in 10 CFR 50.54(bb), a licensee shall "notify the NRC of any significant changes in the proposed waste management program as described in the initial notification."

CEG is submitting the attached SFMP to fulfil the 10 CFR 50.54(bb) requirement to submit significant changes in the SFMP to the U.S. Nuclear Regulatory Commission (NRC).

In accordance with 10 CFR 50.54(bb), a copy of this notification will be maintained until the expiration of the TMI-1 operating license. Additionally, TMI-1 will notify the NRC of any other significant changes in the proposed SFMP described in the Attachment pursuant to 10 CFR 50.54(bb).

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Docket No. 50-289 March 21, 2023 Page 2 There are no new regulatory commitments contained in this letter.

If you have any questions concerning this submittal, please contact Jill Fisher at Jill.Fisher@constellation.com.

Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC

Attachment:

Spent Fuel Management Plan Revision 1 for Three Mile Island Nuclear Station -

Unit 1 cc: w/ Attachment Regional Administrator - NRC Region I NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 2 Director, Bureau of Radiation Protection, PA Department of Environmental Resources B. Werner, Bureau of Radiation Protection, PA Department of Environmental Resources

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Docket No. 50-289 March 21, 2023 Attachment Page A-1 of A-3 ATTACHMENT SPENT FUEL MANAGEMENT PLAN REVISION 1 FOR THREE MILE ISLAND NUCLEAR STATION - UNIT 1

1. BACKGROUND By letter dated September 26, 2019, and as required by 10 CFR 50.82(a)(1)(ii) and 10 CFR 50.4(b)(9), Constellation Energy Generation, LLCs (CEG) predecessor Exelon Generation Company, LLC provided notice to the U.S. Nuclear Regulatory Commission (NRC) of the permanent removal of all fuel from the Three Mile Island Nuclear Station, Unit 1 (TMI-1) reactor vessel as of September 26, 2019 (Reference 1).

The decommissioning approach that has been selected by CEG for TMI-1 is the SAFSTOR method.

The Spent Fuel Management Plan (SFMP) for TMI-1 was previously provided to the NRC in 2019 (Reference 2). The SFMP in this Attachment supersedes and replaces in entirety the SFMP submitted in Reference 2.

In order to estimate the costs associated with maintenance of the TMI-1 site in SAFSTOR and the eventual decommissioning of the site, at the time of the estimate, CEG assumed 2035 as the first year that the U.S. Department of Energy (DOE) will begin removing spent nuclear fuel from nuclear power reactor sites. Pursuant to the Nuclear Waste Policy Act (Reference 3), the Federal government has the responsibility to remove all spent fuel from TMI-1 and other commercial nuclear power reactor sites. However, the DOE spent fuel and high-level waste management program is currently stalled. Given the status of the DOE program, CEG considered information made publicly available by DOE, the Government Accountability Office (GAO), the Blue Ribbon Commission on America's Nuclear Future, and the political environment surrounding this issue, and concluded that 2035 was the most likely timeframe for DOE to initiate removal of commercial nuclear fuel from reactor sites.

2. SPENT FUEL MANAGEMENT STRATEGY The NRC requires (as discussed in 10 CFR 50.54(bb)) that licensees establish a program "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."

Pending transfer of the fuel to the DOE [Secretary of Energy], CEG will store fuel on an interim basis in the Independent Spent Fuel Storage Installation (ISFSI) located at the TMI-1 site.

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Docket No. 50-289 March 21, 2023 Attachment Page A-2 of A-3 A licensed ISFSI has been built to support decommissioning operations at TMI-1. The inventory of spent fuel that remained in the spent fuel pool at the time of permanent shutdown has been loaded in fuel storage canisters and moved to the ISFSI. The facility is being placed in a SAFSTOR condition. The ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete.

Assuming the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2035 with an annual capacity of 3,000 metric tons of uranium, spent fuel is projected to remain at the TMI-1 site for approximately 22 years after the termination of operation (spent fuel is projected to be removed from the TMI-1 site by the end of 2041). Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in spent fuel remaining at the site longer than anticipated.

Operation and maintenance costs for the ISFSI are inputs to the TMI-1 Decommissioning Cost Estimate (DCE) which will be submitted to the NRC separately and include the costs for staffing the ISFSI, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to decommission the ISFSI. A discussion of site-specific considerations for the management of spent fuel at TMI-1 will be addressed in the updated DCE report. The updated DCE will supersede in its entirety the 2019 DCE (Reference 5).

TMI-1 will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the TMI-1 ISFSI, as necessary. In addition, TMI-1 will also comply with applicable license termination requirements in accordance with 10 CFR 50.82, "Termination of license," with respect to plant shutdown and post-shutdown activities, including seeking NRC approvals as appropriate for the continued storage of irradiated fuel until transfer of the fuel to the DOE is complete.

3. COST ESTIMATE AND FUNDING FOR SPENT FUEL MANAGEMENT Total costs for spent fuel management from January 1, 2023, through transfer of the fuel to the DOE is complete under the SAFSTOR scenario will be approximately $94.0 million (2022 dollars). Further breakdown and analysis will be discussed in the DCE to be submitted under separate cover letter.

As of December 31, 2022, the TMI-1 decommissioning trust fund balance was $617.1 million. At this time, there are no annual contributions to the fund, and none are anticipated through the decommissioning period. To the extent that the trust fund balance exceeds costs required for radiological decommissioning, trust fund monies (spent fuel management exemption has been received as discussed in Section 4), in conjunction with CEG operating revenues, will be used to pay for spent fuel management costs.

U.S. Nuclear Regulatory Commission Spent Fuel Management Plan Docket No. 50-289 March 21, 2023 Attachment Page A-3 of A-3 An additional potential source of funding for TMI-1 spent fuel management costs is the Settlement Agreement between CEG and the DOE, under which the United States Government has agreed to reimburse CEG for costs incurred attributable to DOEs failure to meet its contractual obligations for the transfer of spent fuel from TMI-1 and other CEG nuclear plants (Reference 4).

4. NRC APPROVALS This SFMP contemplates potential withdrawals from the decommissioning trust for spent fuel management purposes. Constellation has been issued an exemption from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for spent fuel management expenses (Reference 6). Constellation will monitor the funding level of the decommissioning fund to ensure that spent fuel management withdrawals will not inhibit the ability of Constellation to complete radiological decommissioning.

5. REFERENCES

1. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1," dated September 26, 2019 (ML19269E480)

2. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Spent Fuel Management Plan for Three Mile Island Nuclear Station, Unit 1," dated April 5, 2019 (ML19095A009)

3. United States of America Public Law 97-425, "Nuclear Waste Policy Act of 1982," dated January 7, 1983

4. Settlement Agreement between the U.S. Department of Energy and Exelon Generation Company, LLC (including Commonwealth Edison Company and AmerGen Energy Company), signed and executed August 5, 2004, as amended by the Addendum to the Settlement Agreement signed May 4, 2009

5. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1," dated April 5, 2019 (ML19095A010)

6. Letter from Justin C. Poole (U.S. Nuclear Regulatory Commission to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1, -

Exemptions from the Requirements of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (EPID L-2019-LLE-0009)," dated October 16, 2019 (ML192549A179)