ML23192A827

TMI-2 Solutions, LLC - Response to SHPO Request for Additional Information for Er Project 2021PR03278.006, TMI-2 Decommissioning Project

ML23192A827
Person / Time
Site:	Three Mile Island
Issue date:	07/10/2023
From:	Devik T TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards
References
MI2-RA-COR-2023-0013
Download: ML23192A827 (7)

Text

July 10, 2023 TMI2-RA -COR-2023-0013 36 CFR 800 ATTN: Emma Diehl PA State Historic Preservation Office State Museum Building 300 North Street Harrisburg, PA 17120

Subject:

Response to SHPO Request for Additional Information for ER Project

1. 2021PR03278.006, TMI-2 Decommissioning Project

References:

1. Letter from Diehl, E. (Pennsylvania State Historic Preservation Office) to Pell, H. (TMI -

2 Solutions, LLC), ER Project # 2021PR03278.006, TMI-2 Decommissioning Project, Dauphin County, Pennsylvania, Nuclear Regulatory Commission, Conoy Township, Lancaster County, dated 17 November 2022 (ML22343A141).

2. Letter from Diehl, E. (Pennsylvania State Historic Preservation Office) to Sun, R. ( U.S.

NRC), ER Project # 2021PR03278.008, TMI -2 Decommissioning Project, Dauphin County, Pennsylvania, Nuclear Regulatory Commission, Conoy Township, Lancaster County, dated 17 May 2023 (ML23138A066).

3. Letter from Hazelhoff, A. C. (EnergySolutions) to Document Control Desk (U.S. NRC),

License Amendment Request - Three Mile Island, Unit 2, Historic and Cultural Resources Review, dated 22 February 2023 (ML23058A064).

4. Letter from Snyder, A. M. (U.S. NRC) to Sauger, J. (TMI -2 Solutions, LLC), Three Mile Island, Unit 2 - Acceptance Review and Request for Additional Information for the Historic and Cultural Resources License Amendment Request - EPID: 2023-LLA -

0026, dated 31 March 2023 (ML23062A737 ).

Per References 1 and 2, the Pennsylvania State Historic Preservation Office (SHPO) requested additional information to support identification of Above G round resources and to comment on the TMI-2 decommissioning projects potential to affect a rchaeological resources. Attachments 1 and 2 to this letter provide TMI-2 Solutions responses to the PA SHPOs requests for additional information.

TMI-2 Solutions submitted a License Amendment Request (Reference 3) requesting review of decommissioning activities that would diminish the historic integrity (e.g., physical demolition) of the TMI-2 Solutions owned buildings previously deemed eligible for the National Register of Historic Places (NRHP) by the PA SHPO. In Reference 4, the NRC stated its plans to initiate consultation for this undertaking under Section 106 of the National Historic Preservation Act (NHPA). During a clarification call on 12 June 2023 between the NRC, PA SHPO and TMI-2 Solutions, the NRC requested that TMI-2 respond directly to the PA SHPO inquiries in References 1 and 2 and copy the NRC.

If you have any questions with regards to the content of this letter, please contact me at trdevik@energysolutions.com or (603) 384-0239.

Sincerely,

Timothy Devik TMI-2 Licensing Manager EnergySolutions

cc: w/ Attachments Amy M. Snyder - NRC, Senior Project Manager, Amy.Snyder@nrc.gov Jean Trefethen - NRC, Environmental Project Manager, Jean.Trefethen@nrc.gov Stacey Imboden - NRC, Senior Project Manager, Stacey.Imboden@nrc.gov Hannah Pell - EnergySolutions, Licensing Engineer, hepell@energysolutions.com Justin Wheat - EnergySolutions, Director, Regulatory Affairs, jtwheat@energysolutions.com Amy C. Hazelhoff - EnergySolutions, Senior Vice President, Regulatory Affairs, achazelhoff@energysolutions.com

Attachments

1. PA SHPO Request for Additional Information #1 (November 2022)

2. PA SHPO Request for Additional Information #2 (May 2023)

ATTACHMENT 1 TMI2-RA-COR-2023- 0013 PA SHPO REQUEST FOR ADDITIONAL INFORMATION #1 (NOVEMBER 2022)

PA SHPO RAI-1A:

The purpose of this letter is to clarify the PA SHPO response dated 9/12/2022 with regards to the Identification of Historic Properties, specifically Three Mile Island.

While we understand that this project is limited to TMI-2, it is necessary to assess the property in its entirety due to potential effects. It should be noted that the evaluation in 2010 took place before the property was 50 years of age; consequently, only considering the exceptional significance of the property in relation to the events of March 28, 1979-April 4, 1979. Now that the property has achieved 50 years of age, it is necessary to assess and evaluate other potential areas and/or periods of significance for the historic property, covering the entire time frame in which the plant was constructed and operated.

Potential areas of significance may include (but not be limited to):

• Engineering. What aspects of the construction of the site could be significant? Were any models for use in other places? Is TMI an example of a trend in engineering design?

• Labor History. TMI construction was delayed by worker strikes and environmental concerns being raised. Were any changes physically made to the property to address environmental or labor concerns?

• Social History. What is the significance of the public outreach campaigns that occurred when the plant opened? After the near meltdown?

TMI-2 Solutions Response TMI-2 Solutions submitted a License Amendment Request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) (Reference 1) requesting historic and cultural reviews required under the National Historic Preservation Act (NHPA), given that the TMI-2 Historic District was previously deemed eligible for the National Register of Historic Places (NRHP) under Criterion A and Criteria Consideration G (PA-SHARE Key No. 156047). 1 The undertaking, as defined by 36 CFR 800.16(y), described in the LAR includes decommissioning activities which may diminish the historic integrity (e.g., demolition) of the TMI-2 owned and controlled buildings eligible for the NRHP. Therefore, the property in question means the subset of TMI-2 parcels shown in of Reference 2. The buildings and structures on Three Mile Island that are located outside this property boundary or are otherwise not intermingled with the TMI-2 facility are not within the scope of the undertaking.

Regarding engineering significance, TMI-2 was relatively comparable to any other nuclear power plants in the United States prior to the historic accident which permanently terminated operations. As stated in the TMI-2 Post-Shutdown Decommissioning Activities Report (Reference 3), TMI-2 was a typical mid-twentieth century light water reactor. The design, engineering processes, and construction of TMI-2 were unexceptional and lacking any major

1 NUREG-0586, Supplement 1 (Decommissioning GEIS) states that if a nuclear facility could be potentially eligible for inclusion in the National Register of Historic Places, appropriate mitigation would be developed in consultation with the SHPO. If a decommissioning activity could result in an impact that is outside the bounds of the Decommissioning GEIS or other environmental assessments, a licensee is required to submit a license amendment request.

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ATTACHMENT 1 TMI2-RA-COR-2023- 0013 engineering innovations. Information describing the historical construction of Three Mile Island was documented in the updated TMI-2 Historic Resource Survey Form (HRSF) which was submitted by TMI-2 Solutions to the PA SHPO in August 2022 (see Three Mile Island, Met-Ed, and the Building of TMI: 1967 to 1978). 2 Due to the accident, TMI-2 ceased power production on 28 March 1979, and never resumed operations. Therefore, the entire timeframe in which the plant was constructed and operated is limited to November 1969 through March 1979.

Documentation reviewed during preparation of the updated TMI-2 HRSF indicate that construction of numerous domestic nuclear facilities was impacted by labor strikes and public demonstrations over environmental concerns, including for example the nearby Peach Bottom Atomic Power Station. The strikes and public demonstrations which occurred at TMI-2 appear to be consistent with those occurring elsewhere, both locally and nationally, and therefore do not seem to exhibit a threshold level of significance in regard to labor history that would merit further consideration. Additionally, research has not revealed that the labor strikes and/or public demonstrations directly impacted or otherwise influenced physical changes in the design or construction of TMI-2.

Prior to the accident at TMI-2, Metropolitan Edison (Met -Ed) maintained a limited public communications staff who mainly published promotional material on behalf of the utility. It became clear as the accident unfolded that Met-Ed had inadequate resources to meet the immediate and wide-spread media attention on TMI -2 and that the reporting outlets generally lacked the scientific and engineering expertise to adequately translate nuclear terminology previously unfamiliar to the public. W hile the extent of the coverage was justified, a combination of confusion and weakness in the sources of information and lack of understanding on the part of the media resulted in the public being poorly served, notes T he Report of The Presidents Commission on the Accident at Three Mile Island (Reference 4). It is our judgment that in this case, neither the utility nor the NRC not the media were sufficiently prepared to serve the public well. Consequently, communications efforts at TMI -2 were expanded over the following years to include routine publications to the community as well as frequent outreach with local elected officials and stakeholder groups during the post-accident cleanup efforts.

As with other United States nuclear facilities, public outreach at TMI -2 was an integral aspect of the facilitys construction and operation, and an examination of other contemporaneous nuclear facilities suggests similar use of public outreach and education initiatives, including the construction of visitor centers. Concerning public outreach initiatives after the TMI-2 accident, documentation reviewed did not suggest that industry-wide policy changes could be attributed solely to the coordinated, post-accident public outreach campaign at TMI-2. As evidenced by the numerous missteps in conveying accident-related information to the public, industry-wide changes to public emergency response policy were more heavily influenced by shortcomings at TMI-2 than an actual coordinated public outreach campaign. Therefore, the specific attributes of TMI-2 s public outreach campaign do not appear to be sufficiently unique to qualify it for further consideration of historical significance.

2 TMI-2 S olutions made a Regulatory Commitment to submit the revised H istoric Resource Survey Form for TMI -2 to the NRC upon acceptance from the PA SHPO (Reference 3, Attachment 2).

2 ATTACHMENT 1 TMI2-RA-COR-2023- 0013 PA SHPO RAI-1B :

The TMI-2 Control Room was also identified as a contributing factor to the accident, stating the control room is huge, with hundreds of alarms, and there are some key indicators placed in locations where the operators cannot see them; and that lessons from previous accidents did not result in new, clear instructions being passed on to the operators. Were corrections to this made at TMI-1?

What physically changed in nuclear stations as a result of this incident? Is there any evidence of this at TMI-1?

TMI-2 Solutions Response Following the events at TMI-2, the NRC issued an Order in July 1979 directing that the Three Mile Island facility remain in a cold shutdown until further order of the Commission (Reference 5). On 9 August 1979, the NRC issued a second O rder specifying the basis for its concerns and necessary resolution of short-and long-term actions required for the restart of TMI -1 to provide reasonable assurance that the facility can be operated safely over the long term (Reference 6).

Following a series of hearings that documented completion of required NRC actions, TMI-1 restarted on 9 October 1985. With respect to the n uclear industry at-large, the NRCs Backgrounder on the Three Mile Island Unit 2 Accident provides a synopsis of changes that were made as a result of the accident (Reference 7). TMI-2 Solutions cannot provide information regarding specific corrections or physical changes made to TMI-1 as a result of these industry -

wide corrective actions.

References

1) Letter TMI2-RA -COR-2023-0003 from Hazelhoff, A. C. (Energy Solutions) to Document Control Desk (U.S. NRC), License Amendment Request - Three Mile Island, Unit 2, Historic and Cultural Resources Review, dated 22 February 2023 (ML23058A064).

2) Letter TMI2-RA -COR-2023-0001 from Hazelhoff, A. C. (EnergySolutions) to Document Control Desk (U.S. NRC), License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Request for Additional Information Regarding Historical and Cultural Resources, dated 20 January 2023 (ML23025A039 ).

3) Letter TMI2-RA -COR-2022-0022 from Lackey, M. B. (Energy Solutions) to Document Control Desk (U.S. NRC), 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 5, dated 27 October 2022 (ML22306A051)

4) The Need for Change: The Legacy of TMI, Report of The Presidents Commission on the Accident at Three Mile Island, dated October 1979, Washington, D.C.

5) NRC Order, in the matter of Metropolitan Edison Company and Three Mile Island Nuclear Station Unit No. 1, dated 2 July 1979 (ML19242A719)

6) NRC Order and Notice of Hearing, in the matter of Metropolitan Edison Company and Three Mile Island Nuclear Station Unit No. 1, dated 9 August 1979 (ML19209B212)

7) Backgrounder on the Three Mile Island Accident, U.S. Nuclear Regulatory Commission, April 2022.

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ATTACHMENT 2 TMI2-RA-COR-2023- 0013 PA SHPO REQUEST FOR ADDITIONAL INFORMATION #2 (MAY 2023)

PA SHPO RAI-2A :

ABOVE GROUND RESOURCES With regards to the Area of Potential Effects (APE), based on information obtained during the site visit as well as the planned activities to occur, it is our opinion that the APE should only extend to include Three Mile Island in its entirety as well as the historically associated observation building located across the Susquehanna River, on the east shore. We look forward to continued consultation with you, the licensee, and other consulting parties, as participating, regarding the identification of historic properties and assessment of effects.

TMI-2 Solutions Response Per 36 CFR 800.16(d), the Area of Potential Effect s (APE) is defined as the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. The scope of this undertaking includes decommissioning activities which may diminish the historic integrity (e.g., demolition) of the TMI-2 owned and controlled buildings eligible for the NRHP as described in the LAR (Reference 1).

Though the Observation Center has been considered historically associated with TMI-2 as part of the previously defined TMI-2 Historic Distr ict, the building is physically located outside the Three Mile Island operational area3 as well as TMI-2 Solutions license footprint and is not owned or controlled by TMI-2 Solutions. Therefore, TMI-2 Solutions requests clarification from the PA SHPO regarding the potential direct or indirect alterations in the character or use of the Observation Center that may be caused by this undertaking which would warrant its inclusion in the APE.

PA SHPO RAI-2B :

ARCHAEOLOGICAL RESOURCES We require additional information to be able to comment on this projects potential to affect archaeological resources. As we understand from the submissions received to date and from our site visit on April 5, 2023, the majority of decommissioning activities proposed for the undertaking will occur within areas that are previously disturbed from construction and operation of the TMI-1 and TMI-2 facilities. However, areas of the island retain intact soils and a number of archaeological sites have been identified on the island. Please define a limits of disturbance for this the undertaking so that we may provide our comments on the potential for archaeological resources to be directly affected. If this decommissioning project will lead to additional public access or new development on Three Mile Island, it may also be appropriate to consider indirect effects to archaeological resources on the island as a result of this project. We look forward to continued consultation.

3 The operational area is defined in NUREG-0586, Supplement 1 (Decommissioning GEIS ) as the portion of the plant site where most or all of the site activities occur, such as reactor operation, materials and equipment storage, parking, substation operation, facility service, and maintenance. This includes areas within the protected area fences, the intake, discharge, cooling, and associated structures as well as surrounding paved, graveled, maintained landscape, or other maintained areas. The Decommissioning GEIS concludes that impacts due to onsite land disturbance are likely to be not detectable because the amounts of land disturbance are generally very small and usually occur in areas of the site previously disturbed by construction or operation of the facility.

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ATTACHMENT 2 TMI2-RA-COR-2023- 0013 TMI-2 Solutions Response The undertaking includes only decommissioning activities with the potential to diminish the historic integrity (e.g., physical demolition) of the TMI-2 buildings, which will occur entirely within the operational area. Therefore, the operational area constitutes the limits of disturbance for this undertaking.

As stated in the TMI-2 Post -Shutdown Decommissioning Activities Report (Reference 2), it is anticipated that backfill for the demolished building and structure foundations will be sourced from onsite demolition activities within the operational area. If it is determined in the future that additional fill is needed and TMI-2 Solutions opts to source from Three Mile Island outside the operational area, TMI -2 Solutions will coordinate with the PA S HPO at that time to identify areas where backfill may be obtained. TMI-2 Solutions has proactively established a Cultural Resources Protection Plan and environmental implementing procedure which requires notification to the PA SHPO prior to executing any decommissioning activities that may occur near or within a culturally protected area to determine if any special protection measures are needed. Additionally, as previously stated, TMI-2 Solutions does not own the land on Three Mile Island and is therefore subject to restrictions regarding land-disturbing activities by the landowner.

In order to resolve adverse effects and complete the Section 106 compliance process, it may be necessary to execute a Programmatic Agreement as provided for in 36 CFR 800.14(b) to govern the implementation of ground-disturbing activities that may not occur for several years.

References

1) Letter TMI2-RA -COR-2023-0003 from Hazelhoff, A. C. (Energy Solutions) to Document Control Desk (U.S. NRC), License Amendment Request - Three Mile Island, Unit 2, Historic and Cultural Resources Review, dated 22 February 2023 (ML23058A064)

2) Letter TMI2-RA -COR-2022-0022 from Lackey, M. B. (Energy Solutions) to Document Control Desk (U.S. NRC), 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 5, dated 27 October 2022 (ML22306A051)

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