ML23221A140

(TMI-2), Response to Requests for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 5

ML23221A140
Person / Time
Site:	Three Mile Island
Issue date:	08/08/2023
From:	Devik T TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23221A139	List: ML23221A140
References
TMI2-RA-COR-2023-0014
Download: ML23221A140 (1)

Text

Enclosure 1 contains Proprietary Information. Withhold from public disclosure in accordance with 10 CFR 2.390and 10 CFR 9.17.When Enclosure 1 is removed, this document is Decontrolled.

August8,2023 TMI2-RA-COR-2023-0014 10 CFR 50.82 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Possession OnlyLicense No. DPR-73 NRC Docket No. 50-320

Subject:

Response to Requests for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 5

References:

(1)Letter from Lackey, M. B. (Energy Solutions ) to 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 October27,2022 (ML22306A051)

(2) Letter from van Noordennen, G. (TMI-2 Solutions ) to U.S. NRC, Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10CFR50.82(a)(7), Revision 4,dated March17, 2021 (ML21084A229)

(3)LetterTMI-19-003from Halnon, G. H. (GPUNuclear, Inc.) to U.S. NRC, Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2, dated March28,2019 (ML19087A153)

(4)eMail from Snyder, A. (U.S. NRC) to Devik, T. (TMI-2 Solutions ),

Subject:

Three Mile Island Nuclear Station, Unit No. 2 -Request for Additional Information Related to the Amended Post-Shutdown Decommissioning Activities Report (EPID NO. L-2022-DPS-0002), dated June29,2023 (ML23187A020; RAI

Enclosure:

ML23187A033)

(5)Letter from Hazelhoff, A. C. (TMI-2 Solutions ) to U.S. NRC, Decommissioning Fund Status Report -Three Mile Island, Unit 2, dated March30,2023 (ML23094A116)

In Reference 1, TMI-2 Solutions submitted to the U.S. Nuclear Regulatory Commission (NRC) a revised Post-ShutdownDecommissioning Activities Report (PSDAR). The revisedPSDAR referenced the Decommissioning Cost Estimate (DCE) provided to the NRC in Reference 2, which was developed basedon financial information provided in Reference 3.

In Reference 4, the NRC issueda Request forAdditional Information(RAI)to support the review of the TMI-2 PSDARand the Decommissioning Trust Fund Report (Reference 5). Attachment 1 to this letter provides TMI-2 Solutions response.Enclosure1contains confidential commercial and financial information in the form of the DCE requested for RAI-2. TMI-2 Solutions requests that this information be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17, as described in the Affidavit provided in Attachment 2.

This letter contains no new Regulatory Commitments. TMI-2 Solutions is canceling a previous Regulatory Commitment as described in the response to RAI-3.

In the event that the NRC has any questions with respect to the content of this document, please contact me at (603) 384-0239 or trdevik@energysolutions.com.

Sincerely,

Timothy Devik TMI-2 Licensing Manager Energy Solutions

Attachments:

1. Response to Request for Additional Information Enclosure 1 - TMI-2 Decommissioning Cost Estimatewith Supporting Information

2. Proprietary Information Affidavit

cc: w/Attachments Regional Administrator - NRC Region I NRC Lead Inspector - Three Mile Island Nuclear Station - Unit 2 NRC Project Manager - Three Mile Island Nuclear Station - Unit 2 Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection Chief, Division of Nuclear Safety, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection Chairman, Board of County Commissioners - Dauphin County Manager - Londonderry Township Senior Vice President, Regulatory Affairs - Energy Solutions Chief Nuclear Officer - Energy Solutions

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ATTACHMENT 1

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

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ATTACHMENT 1 TMI2-RA-COR-2023-0014

RAI-1

Is the description of planned decommissioning activities and the associated schedule accurate given that TMI-2S plans to delay building demolition until 2045. Please provide your plans to update the PSDAR to reflect any change decommissioning method, decommissioning activities, and the schedule. This should also include when TMI-2S plans to move from DECON to SAFSTOR, as the Decommissioning Fund Status Report states there will be a gap between 2029 and 2045 before building demolition.

TMI-2Solutions Responses The description of planned decommissioning activitiesand the associated schedule is accurate through Phase 1b, which is currently scheduled to complete in 2029. TMI-2 Solutions does not intend to change the decommissioning method to SAFSTOR following the completion of Phase 1b. The Decommissioning Fund Status Report (ML23094A116) provided a funding analysis based on market conditions and performance as of December 31, 2022. The market conditions have since improved, and TMI-2 Solutions is evaluating the impact on projected spending and the schedule of decommissioning activities.

TMI-2 Solutions plans to provide the NRC a supplement to the PSDAR by December 28, 2023. TMI-2 has collected data on the existing radiological conditions at TMI-2, and time is needed to fully evaluate the impact of the unique challenges on existing project plans, contingencies, and timing.

RAI-2

Before NRC staff will evaluate the site specific TMI-2 DCE, please provide an updated site-specific DCE that reflects your change in decommissioning strategy after 2029 and any other changes. Once submitted, the NRC staff will evaluate it for acceptability.

TMI-2Solutions Response provides an updated Decommissioning Cost Estimate (DCE), which supersedes the DCE previously provided in Attachment 1, Enclosure 1A of the PSDAR, Rev. 4 (ML21084A229). TMI-2Solutions requests that Enclosure 1 be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

Environmental RAI

RAI-3

PSDAR Section 6.1.14 Cultural, Historic, and Archeological Resources does not reflect the latest information submitted in the January 20, 2023 RAI responses (ML23121A249) and the February 22, 2023 LAR (ML23058A064), that was submitted for review[of] major decommissioning activities, as defined in 10 CFR 50.2, 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.

Please confirm that this information remains accurate and your plans to update the PSDAR due to the change in major decommissioning activities.

TMI-2Solutions Response TMI2 Solutions plans to update Section 6.1.14 of the PSDAR based on the information submitted in the January 20, 2023 RAI response (ML23025A039) and the February 22, 2023 LAR (ML23058A064) as part of the PSDAR supplement to the NRC by December 28, 2023.

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ATTACHMENT 1 TMI2-RA-COR-2023-0014

In the PSDAR Rev. 5, TMI-2 Solutions made a Regulatory Commitment to submit the revised Historic Resource Survey Form for the TMI-2 Historic District and the PA Railroad spur to the NRC under separate cover upon acceptance from the SHPO. Additional considerations regarding historic and cultural resources will be evaluated as part of the Section 106 process, which has since been initiated by the NRC (ML23062A737). Therefore, TMI-2 Solutions is canceling this Regulatory Commitment.

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ATTACHMENT 2

PROPRIETARY INFORMATION AFFIDAVIT

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TMI-2Solutions Proprietary Information Affidavit

Affidavit of Amy C. Hazelhoff, Senior Vice President Regulatory Affairs, TMI-2 Solutions, LLC.

TMI-2 Solutions, LLC, is providing information in support of the TMI-2 Post-Shutdown Decommissioning Activities Report, Revision 5 (ML22306A051) and the Request for Additional Information dated June 29, 2023 (ML23187A020), as described in this letter. Enclosure 1 of this letter contains financial information, including proprietary aspects to the decommissioning of TMI-2, which constitute proprietary commercial and financial information, belonging to TMI-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 TMI-2 Solutions,

LLC. The basis for this declaration is:

I. This information is owned and maintained as proprietary by TMI-2 Solutions, LLC,

II. This information is routinely held in confidence by TMI-2 Solutions, LLC, and not disclosed to the public,

III. 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 TMI-2 Solutions, LLC, if it were released publicly, and

VI. The information to be withheld was transmitted to the NRC in confidence.

I declare under penalty of perjury that the foregoing is true and correct.

_________________________________ Executed On _August 8, 2023_____

Amy C. Hazelhoff Senior Vice President, Regulatory Affairs Energy Solutions

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