ML23094A116

Decommissioning Fund Status Report

ML23094A116
Person / Time
Site:	Crane
Issue date:	03/30/2023
From:	Hazelhoff A TMI-2 Solutions
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TMI2-RA-COR-2023-0005
Download: ML23094A116 (1)

Text

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TMl-2 SOLUTIONS March 30, 2023 TMI2-RA-COR-2023-0005 10 CFR 50.75 10 CFR 50.82 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 Docket No. 50-320

SUBJECT:

Decommissioning Fund Status Report - Three Mile Island, Unit 2 Pursuant to 10 CFR 50.75 and 10 CFR 50.82, TMI-2 Solutions is hereby submitting the following two reports to the Nuclear Regulatory Commission (NRC) for Three Mile Island Nuclear Station, Unit 2 (TMI-2) for the year ending December 31, 2022. provides the following information for TMI-2:

Table I Table II Decommissioning Funding Status Report for TMI-2:

Summary Information as of December 31, 2022 Decommissioning Funding Status Report for TMI-2:

Annual Cash Flow Analysis Starting January 1, 2023, through End of Decommissioning The following information is provided in support of this filing:

1. The above-mentioned owner ofTMI-2, TMI-2 Solutions ("TMI-2S") became the TMI-2 licensee on December 18, 2020, following the closing specified in the October 15, 2019, Asset Purchase and Sale Agreement. The trust agreement has not been amended since the closing.

2. Remaining costs in Table I and II are presented in 2023 real dollars and are based on our current estimate.

3. The growth rate on Trust Funds assumes a 2.0% Real Rate of Return ("RRoR").

4. No rate regulatory authority citation is referenced because the 2% RRoR allowed by 10 CFR 50.75(e)(l)(i) is used in the calculations.

5. There are no longer any funds being collected from the ratepayers.

6. The estimated spend for 2022 shown in the 2021 Funding Analysis was $51.0M (TMl2-RA-COR-2022-0004, dated 31 March 2022, ML22091A273). This forecasted withdrawal amount was calculated in part based on the assumption that the project would start decommissioning in mid-2022. While the project remained in Post-Defueling Monitored Storage (PDMS) through 2022, TMI-2 Solutions was able to proceed with major procurements necessary to support DECON, which advanced the spend to $78.3M.

7. Due to market conditions as of December 31, 2022, the TMI-2 Funding Analysis (Table II) shows a forecasted delay between Source Term Reduction and Demolition from 2029 to 2045 as a financial mitigation measure for the Nuclear Decommissioning Trust Fund (NDTF).

There are no Regulatory Commitments contained in this letter.

If there are any questions or if additional information is required, please contact me at 269-3 70-7445.

Sincerely, Amye Hazelhoff

( Digitally signed by Amy C

\\Hazelhoff

/

_ Dal.~ 2023.03.3014

05:13

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-04'00' Amy Hazelhoff Vice President, Regulatory Affairs TMI-2 Solutions, LLC Enclosure cc:

Amy Snyder NRC Project Manager-Three Mile Island, Unit 2 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop O8-D15 11555 Rockville Pike Rockville, MD 20852-2738 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Rd., Suite 102 King of Prussia, PA 19406-1415

TMI-2 Service List w/Enclosure Ken Robuck President and CEO Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and Chief Nuclear Officer ReactorD&D Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 David Del Vecchio Senior Vice President D&D Operations EnergySolutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Amy Hazelhoff Vice President, Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 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 Director, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania Rachael Carson State Office BLDG.

13THFloor P.O. Box 8469 Harrisburg, PA 17105-8469 Chief, Division of Nuclear Safety, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania Rachael Carson State Office BLDG.

13TH Floor P.O. BOX 8469 Harrisburg, PA 17105-8469 Chairman, Board of County Commissioners, Dauphin County 112 Market Street 7th Floor Harrisburg, PA 17101 Chairman, Board of Supervisors of Londonderry Township 783 S. Geyers Church Rd.

Middletown PA 17057 TimDevik:

TMI-2 Licensing Manager Three Mile Island Generating Station Route 441 South Middletown, PA 17057

ENCLOSURE Decommissioning Funding Status Report for TMI-2 Solutions, LLC.

Summary hlormation as of December 31,2022 4 Pages Follow

TMI2-RA-COR-2023-005 Docket No. 50-320 TMI-2 Decommissioning Funding Status Report Enclosure, Page 1 of 4 Table I. Decommissioning Funding Status Report for TMl-2 Solutions, LLC.:

Summary information as of December 31,2022

[10 CFR 50.82 (a)(8)(v)-(vii)]

DECOMMISSIONING TRUST FUND BALANCES 10 CFR Reference(s): 50.82(a)(B)(v)(A); 50.82(a)(B)(vii)(A)

Fund Balance Type of Trusts Comments

$723,679,264 Qualified fund balance As of: 12/31/2022

$10,118,727 Non-qualified fund balance As of: 12/31/2022

$0 Less costs incurred but not yet billed to Trust Actual Cost in: As-Spent Dollars

$733,797,991 Adjusted decommissioning fund balance As of: 12/31/2022 OTHER FINANCIAL ASSURANCE METHODS BEING RELIED UPON 10 CFR Reference(s): 50.82(a)(8)(v)(A)

NONE PRIOR YEARS DECOMMISSIONING EXPENDITURES 10 CFR Reference(s): 50.82(a}(8)(v)(A)

Total Decommissioning Comments Soend

$56,513,766 2020 2021 Spend

$78,265,028 2022 Spend

$134,778,794 Total Prior Year in: As-Spent Dollars PRIOR YEAR EXPENDITURES - VARIANCE TO ESTIMATED ESCALATED COST 10 CFR Reference(s): 50.82(a)(8)(v)(B)

Total Decommissioning Comments Soend

$78,265,028 2022 Expenditures

$51,024,604 Amount Forecast in 2022 NRG Funding Status Report

($27,240,424)

Variance Variance: The estimated spend for 2022 shown in the 2021 Funding Analysis was $51.0M {TM12-RA-COR-2022-0004, dated 31 March 2022, ML22091A273). This forecasted withdrawal amount was calculated in part based on the assumption that the project would start decommissioning in mid-2022. While the project remained in PDMS through 2022, TMl-2 Solutions was able to proceed with major procurements necessary to support DECON, which advanced the spend to $78.3M.

REMAINING DECOMMISSIONING ESTIMATED COST 10 CFR Reference(s): 50.82(a)(8)(v)(B); 50.82(a)(8)(vi1)(B)

Remaining Decommissioning Comments Spend

$999,382,715 Estimate in: 2023 Dollars

• Total remaining decommissioning estimated amounts are costs net of assumed DOE reimbursements.

DECOMMISSIONING CRITERIA UPON WHICH THE ESTIMATE IS BASED 10 CFR Reference(s): 50.82(a)(8)(v)(B)

Estimate based on the assumption that the TMl-2 project enters DEGON in 2023 ANY MODIFICATION To METHOD OF PROVIDING FINANCIAL ASSURANCE 10 CFR Reference(s): 50.82(a)(8)(v)(C)

NONE ANY MATERIAL CHANGES To TRUST AGREEMENT SINCE PREVIOUS REPORT 10 CFR Reference(s): 50.82(a)(B)(v)(D)

NONE NEED FOR ADDITIONAL FINANCIAL ASSURANCE 10 CFR Reference(s): 50.82(a)(8J(vl); 50.82(a)(B)(vii)(C)

NONE 1

Year 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2020- 2037 2038-2055 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 Total TMI2-RA-COR-2023-005 Docket No. 50-320 TMI-2 Decommissioning Funding Status Report Enclosure, Page 2 of 4 TMI-2 Solutions, LLC Table II. Funding Analysis December 31, 2022 Three JVlile Island Nuclear Station, Unit 2 Beginning Deposits Earnings Withdrawals Ending Balance Balance

$733,797,991 $

$ 13,861,319 81,464,061

$666,195,249

$666,195,249

$ 12,575,025 74,888,019

$ 603,882,255

$603,882,255

$25,000,000 $ 11,613,979 71,366,643

$569,129,590

$569,129,590 $

$ 10,816,724 $

56,586,792

$ 523,359,522

$ 523,359,522 9,681,000 78,619,017

$ 454,421,506

$454,421,506 $

8,061,413

$ 102, 701, 736

$ 359,781,183

$359,781,183 7,237,564 (4,194,069) $371,212,816

$371,212,816 $

7,417,336 692,007

$377,938,145

$377,938,145 7,547,316 1,144,644 $ 384,340,817

$384,340,817 7,675,370 1,144,644 $390,871,543

$390,871,543 7,805,984 1,144,644 $397,532,883

$ 397,532,883 7,939,211 1,144,644 $ 404,327,450

$ 404,327,450 8,075,103 1,144,644 $411,257,909

$411,257,909 $

8,213,712 1,144,644

$418,326,976

$418,326,976 $

8,355,093 1,144,644 $425,537,425

$733,797,991 $25,000,000

$136,876,150 $ 470,136,716 $ 425,537,425

$ 425,537,425 $

$ 116,873,004 $ 529,246,000 $ 13,164,429

$425,537,425 8,499,302 1,144,644 $432,892,083

$432,892,083 8,646,395 1,144,644 $440,393,834

$ 440,393,834 8,796,430 $

1,144,644 $448,045,620

$448,045,620 $

8,949,466 1,144,644

$455,850,441

$455,850,441 $

9,105,562 1,144,644 $463,811,360

$463,811,360 $

9,264,781 1,144,644 $471,931,496

$471,931,496 9,427,183 1,144,644

$480,214,035

$480,214,035 9,592,834 1,144,644 $488,662,225

$488,662,225 9,249,760 52,348,403

$445,563,583

$445,563,583 8,274,037 63,723,440

$ 390,114,180

$390,114,180 $

7,165,049 63,723,441

$333,555,787

$333,555,787 6,033,881 63,723,440

$ 275,866,229

$275,866,229 $

4,876,580 64,074,459

$ 216,668,349

$ 216,668,349 $

3,795,842 $

53,752,479 $ 166, 711, 712

$ 166,711,712 $

3,134,049 20,018,547

$ 149,827,214

$ 149,827,214 1,554,310 $ 144,223,451 7,158,073 7,158,073 131,307 1,185,477 6,103,903 6,103,903 153,164 (3,108,605) $

9,365,672 9,365,672 223,070 $

(3,575,687) $ 13,164,429

$ 25,000,000

$253,749,154 $ 999,382,715 2

TMI2-RA-COR-2023-005 Docket No. 50-320 TMI-2 Decommissioning Funding Status Report Enclosure, Page 3 of 4 TableIIDefinitions:

Column 1 Year Column 2 Beginning of Year Balance:

Column 3 Column4 Column 5 Column 6 Reflects the beginning-of-year after-tax Trust Fund balance.

Deposits:

Reflects deposits made to the trust fund, including deposits into the provisional trust, as discussed in Reference 1, currently expected to take place in 2025.

Earnings on Trust Funds:

Reflects earnings on funds remaining in the Trust. A 2.0% RRoR Fund growth rate is used for 2023 through 2056, which reflects the allowed 2.0% RRoR over a 0.0% cost escalation rate. Earnings are based on a 2.0% rate of return on the average of Beginning Balance and Beginning Balance plus Deposits less Withdrawals.

Withdrawals reflect the following assumptions:

1) The project remaining in the PDMS condition until mid-2023

2) Source Term Reduction starting mid-2023 to mid-2028

3) Withdrawals from 2029 to 2045 are projected SAFSTOR expenditures (e.g.

security, monitoring, and project oversight)

4) Active demolition starting 2046 to 2052

5) Fuel Debris Storage Management starting mid-2029 through 2053

6) License Termination by the end of 2052

7) Withdrawal amounts are net cost including allowed DOE reimbursements for Fuel Debris Management Note: Credit balances in years 2029, 2055 and 2056 represent DOE reimbursements in excess of cost for that year.

End of Year Balance:

Reflects the end of year Trust Fund balance after projected earnings are added and projected withdrawals are deducted for the year.

3

TMI2-RA-COR-2023-005 Docket No. 50-320 TMI-2 Decommissioning Funding Status Report Enclosure, Page 4 of 4 Tables I and II General Notes: (Any minor differences in totals are due to rounding.)

1.

Table I Prior Year Expenditures - Variance to Estimated Escalated Cost compares actual expenditures in 2022 compared to estimates based on the 2021 Funding Analysis (Reference 2).

2.

The Trust Fund Balance reflects market value on December 31, 2022, net of estimated taxes on realized gains and losses.

3.

The 2.0% RRoR is based on the rate allowed by 10 CFR 50.75(e)(l)(i) and 10 CFR 50.82(a)(8)(vi) and not on any order by a rate setting authority.

4.

The funding method for providing financial assurance for decommissioning TMI-2 remains Prepayment. The cash flow analysis in Table II demonstrates that the amounts accumulated in the Trust are sufficient, with credited earnings at a 2.0% RRoR, to cover the estimated cost of license termination. Due to market conditions as of December 31, 2022, Table II presents a forecasted delay between Source Term Reduction and Demolition as a financial mitigation measure for the NDTF.

5.

The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:

References Consolidated Ownership Interest in Unit Estimated Rate of Escalation in Decommissioning Costs Estimated After-Tax Rate of Return Year of Site Restoration Completion 100%

0.00%

2.00%

2054

1) Letter TMI-19-112 from Sauger, J.S. (TMI-2 Solutions, LLC) and Halnon, G.H. (GPU Nuclear, Inc) to Document Control Desk (U.S. NRC), "Application for Order Approving License Transfer and Conforming License Amendments," dated 12 November 2019 (ML19325C600).

2) Letter TMI2-RA-COR-2022-0004 from van Noordennen, G.P. (TMI-2 Solutions, LLC) to Document Control Desk (U.S. NRC), "Decommissioning Fund Status Report Three Mile Island, Unit 2," dated 31 March 2022 (ML22091A273).

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