ML24074A392

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

ML24074A392
Person / Time
Site:	Three Mile Island
Issue date:	03/14/2024
From:	Jeffery Lynch TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
TMI2-RA-COR-2024-0004
Download: ML24074A392 (1)

Text

March 14, 2024 TMI2-RA-COR-2024-0004 10 CFR 50.82 U.S. Nuclear Regulatory Commission ATTN; Document Control Desk Washington, DC 20555-0001

Three Mile Island, Unit 2 NRC Possession Only License No. DPR-73 NRC Docket No. 50-320

Subject:

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

References:

1) Letter TMI2-RA-COR-2022-0022 fr om Lackey, M.B. (Energy Solutions) to U.S.

NRC (Document Control Desk), No tification of Amended Post-Shutdown Decommissioning Activities Re port (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7), Revision 5, dated October 27, 2022 (ML22306A051)

2) Letter TMI2-RA-COR-2021-0002 from van Noordennen, G.P. (Energy Solutions) to Document Control Desk (U.S. NRC) , License Amendment Request - Three Mile Island, Unit 2, Decommissioning T echnical Specifications, dated February 19, 2021 (ML21057A046)

3) E-Mail from Snyder, A. (U.S. NRC) to De vik, T. (TMI-2 Solutions), Three Mile Island Nuclear Station, Unit No. 2 - Re quest for Additional Information Related to the Amended Post-Shutdown Decomm issioning Activities Report (EPID No.

L-2022-DPS-0002), dated June 29, 2023 (E-Mail: ML23187A020; RAI

Enclosure:

ML23187A033)

4) Letter TMI2-RA-COR-2023-0014 from De vik, T. (TMI-2 Solutions) to Document Control Desk (U.S. NRC), Response to Requests for Additional Information for the TMI-2 Post-Shutdow n Decommissioning Activities Report, Rev. 5, dated August 8, 2023 ( ML23221A140)

5) Letter TMI2-RA-COR-2023-0022 from Lynch, J. R. (Energy Solutions) to Document Control Desk (U.S. NRC), Response to Request for Additional Information for the TMI-2 Post-Shutdow n Decommissioning Activities Report, Rev. 5, dated December 20, 2023 ( ML23354A211)

TMI2-RA-COR-2024-0004 Page 2 of 2

6) Letter TMI2-RA-COR-2023-0003 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 February 22, 2023 (ML23058A064)

In Reference 1, TMI-2 Solutions submitted Revision 5 to the TMI-2 PSDAR to incorporate information from the DECON License Amendment Request (Reference 2) and its supplements, revised descriptions of decommissioning plans, and updates to the licensee evaluation of potential environmental impacts regarding Historic, Cultural, and Archaeological Resources (PSDAR Section 6.1.14). In Reference 3, the NRC issued a Request for Additional Information (RAI) to support its review of the PSDAR, Revision 5. TMI-2 Solutions provided responses in References 4 and 5, including information from the February 2023 License Amendment Request for Historic and Cultural Resource Reviews (Reference 6).

In Reference 5, TMI-2 Solutions stated its plans to provide updated schedule information for the PSDAR by March 20, 2024. The updated PSDAR schedule is provided in Attachment 1 of this letter. TMI-2 Solutions plans to provide Revision 6 of the TMI-2 PSDAR incorporating changes to the descriptions of decommissioning activities based on this updated schedule as well as information submitted in the previous RAI responses to the NRC no later than March 28, 2024.

There are no Regulatory Commitments contained in this submittal.

In the event that the NRC has any questions with respect to the content of this document or wishes to obtain any additional information, please contact me at jrlynch@energysolutions.com or 508-728-1421.

Sincerely,

Joseph R. Lynch Director, D&D Licensing/Regulatory Affairs EnergySolutions

- Response to Request for Additional Information

cc: w/Attachment NRC Regional Administrator - 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 - PA Dept of Environmental Protection Chief, Division of Nuclear Safety, Bureau of Radiation Protection - PA Dept of Environmental Protection Chairman, Board of County Commissioners - Dauphin County Manager - Londonderry Township TMI2-RA-COR-2024-0004

ATTACHMENT 1

Response to Request for Additional Information

2 Pages Follow Attachment 1 TMI2-RA-COR-2024-0004

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 [to] 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-2 Solutions Response:

As stated in the December 2023 response to RAI-1 ( ML23354A211), TMI-2 Solutions does not intend to change the decommissioning method to SAFSTOR following completion of Phase 1b, and a 90-day extension was needed to fully evaluate the impact of the unique challenges presented by the radiological conditions at TM I-2 on project plans, contingencies, and timing.

Based on the dose rates measured and ALARA principles, TMI-2 Solutions has been reassessing the sequence of several major decommissioning ac tivities in the TMI-2 Reactor Building. Table 5-1 in the PSDAR Rev. 5 provides the TMI-2 Decommissioning Project Schedule, which has been updated to the following:

Table 5-1

Three Mile Island Unit 2 Decommissioning Project Schedule Description Start End Approx.

Duration (years)

Phase 1 - Planning, Engineering, Source Term Reduction

• License Transfer Approved 12/2020 12/2020 -

• Contract Closing & Asset Transfer 12/2020 12/2020 -

• DECON License Amendment Request Approval 02/2021 03/2023 2 Begin Phase 1b Infrastructure Upgrades 07/2022 12/2027 5.5 Decommissioning Electrical & Temporary 07/2022 10/2026 4.5 Power Upgrades Large Components Removal 05/2023 12/2027 5 Field Waste Preparations 02/2023 07/2025 2 Liquid Radwaste & Water Processing Rad Building Interior/Systems D&D 05/2023 01/2029 6 Fuel Debris Material Program ISFSI Design & Construction 05/2023 10/2028 5.5 Procure Debris Material Casks Debris Material Transfer Operations Reactor Vessel (RV)

RV Isolation 10/2023 01/2028 4 RV Internals Segmentation & Removal RV Segmentation & Removal

1 Attachment 1 TMI2-RA-COR-2024-0004

Phase 1b Field Work Complete -

Finish Reactor Building Source Term 03/2029

& Debris Material Removal Phase 2 - Decommissioning & License Termination Planning & Transition Activities 2029 2031 3 TMI-2 Rad Building Demo Auxiliary/Fuel Handling Building 2032 2035 3 Reactor Building Field Waste Operations 2035 2037 1.5 Class B/C Waste Loadout Site Restoration Clean Building Demo 2032 2034 2.5 Cooling Tower Demo Final Status Surveys 2036 2037 1.5 Phase 2 Field Work Complete 2037 -

• Completed

Per the guidance in Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, and in accordance with 10 CFR 50.82(a)(7), TMI-2 Solutions is notifying the NRC, with copy to the Commonwealth of Pennsylvania, of the schedule changes presented in the updated PSDAR Table 5-1 above. TMI-2 Solutions plans to provide Revision 6 of the TMI-2 PSDAR incorporating changes to the descriptions of decommissioning activities based on this updated schedule as well as the information submitted in the previous RAI responses to the NRC no later than March 28, 2024.

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