ML24092A001

(TMI-2), Decommissioning Trust Fund Annual Report

ML24092A001
Person / Time
Site:	Crane  (DPR-073)
Issue date:	03/28/2024
From:	Jeffery Lynch TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
TMI2-RA-COR-2024-0006
Download: ML24092A001 (6)

Text

March 28, 2024 10 CFR 50.75(f)(1)

TMI2-RA-COR-2024-0006 10 CFR 50.82(a)(7) 10 CFR 50.82(a)(8)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 2 (TMI-2)

NRC Possession Only License No. DPR 73 NRC Docket No. 50-320

Subject:

Decommissioning Trust Fund Annual Report In accordance with 10 CFR 50.75(f)(1), 10 CFR 50.82(a)(7), and 10 CFR 50.82(a)(8)(v) - (vii), TMI-2 Solutions, LLC, (TMI-2S) is submitting the annual status of decommissioning funding, status of funding for managing irradiated fuel, and financial assurance report for Three Mile Island, Unit 2 (TMI-2), as of December 31, 2023. The report is provided in Enclosure 1 to this letter.

The estimates provided in Enclosure 1 using December 31, 2023, trust fund balances, indicate that TMI-2 has met the NRCs funding requirements. Accordingly, TMI-2S concludes that no further action is currently required to demonstrate adequate funding assurance for decommissioning.

This letter contains no new regulatory commitments. If you have any questions with respect to the contents of this letter, please contact me at 508-728-1421 or jrlynch@energysolutions.com.

Respectfully, Joseph R. Lynch Regulatory Affairs/Licensing Director (D&D)

EnergySolutions JRL/bed cc:

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

Decommissioning Fund Status and Financial Assurance Report - Three Mile Island, Unit 2 Joseph R. Lynch Digitally signed by Joseph R.

Lynch Date: 2024.03.28 07:27:47 -04'00' Three Mile Island, Unit 2 Annual Decommissioning Fund Status and Financial Assurance Report as of December 31, 2023 Page 1 of 3 As required by 10 CFR 50.75(f)(1), 10 CFR 50.82(a)(7), and 10 CFR 50.82(a)(8), TMI-2 Solutions, LLC, (TMI-2S) reports the following information for Three Mile Island, Unit 2 (TMI-2):

A. Formula Cost Amount per 10 CFR 50.75(c)

TMI-2S does not use this calculation for any decommissioning cost estimates or evaluations.

B. Current Decommissioning Cost Estimate The required minimum funding assurance amount for TMI-2, as of December 31, 2023, is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the TMI-2 Post-Shutdown Decommissioning Activities Report (PSDAR), Revision 6 (Reference 4).

Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides TMI-2S revised total estimate information as required by 10 CFR 50.82. The revised total estimate to complete decommissioning for the TMI-2 site is $1,158.4M (in 2024 dollars, net of DOE reimbursements) as shown in cash flow analysis in Table 1 and as described below. Of that total cost estimate, the revised estimate includes the following expenses:

$1,101.9M for license termination (the cumulative decommissioning expenditures in the amount of $188.4 and the remaining decommissioning estimated cost of $913.5)

$16.9M for spent fuel management, (the cumulative decommissioning expenditures in the amount of 16.3M and the remaining decommissioning estimated cost of 0.6M net of DOE reimbursements)

$39.7M for the decommissioning cost estimate for site restoration. There have been no cumulative site restoration expenditures.

C. Current Decommissioning Fund Balance The TMI-2 Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2023, was

$784.7M. This amount represents the market value of the NDT fund as of December 31, 2023, net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. The trust fund amount is the total available for decommissioning including costs of license termination, spent fuel [debris] management, and site restoration activities. TMI-2S intends to seek an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the TMI-2 Trust Fund to be used for site restoration costs. In Reference 5, the NRC staff concluded that an exemption for the decommissioning activities of the TMI-2 debris material and associated costs, up to and including Phase 2 of decommissioning, is not required.

D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earnings on Funds, and Other Factors Used in Funding Projections TMI-2S has assumed a 2% real rate of return as allowed by 10 CFR 50.75(e)(1)(i).

Three Mile Island, Unit 2 Annual Decommissioning Fund Status and Financial Assurance Report as of December 31, 2023 Page 2 of 3 E. Rates used to Inflate Decommissioning Costs The estimates in Reference 2 were provided in 2023 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2024 dollars. The Bureau of Labor Statistics (BLS) data provided the basis for the DCE inflation rate forecast. Decommissioning costs are inflated using a weighted average of BLS indices for Labor, Energy, Consumer Price Index, Materials, and Equipment. TMI-2S has used a factor of 1.02125 to calculate the inflation to 2024 dollars.

F. Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel [Debris] Storage Installation (ISFSI) decommissioning cost estimate is $16.9M (2024 dollars, net of DOE reimbursements).

G. Decommissioning Financial Assurance Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1) as approved by the NRC in their approval of the license transfer to TMI-2S (Reference 6).

H. Changes in the Decommissioning Funding Plan Trust Agreement There are no changes to the Decommissioning Funding Plan Trust Agreement.

Refer to Tables 1 and 2 of this Enclosure for additional required reporting data. Table 2 provides a cash flow analysis using the updated Decommissioning Cost Estimates developed by TMI-2S.

This cash flow analysis demonstrates that the TMI-2 decommissioning trust fund is sufficiently funded to cover costs as estimated for the license termination, debris management and site restoration activities necessary to complete safe and compliant decommissioning of the site.

In accordance with 10 CFR 50.82(a)(7), in Reference 3, TMI-2S notified the NRC of a schedule change from that described in Reference 1. TMI-2S has updated to PSDAR, Revision 6, to incorporate the updated schedule and to reflect the current decommissioning plan (Reference 4).

PSDAR, Revision 6, Table 5-1, provides the major decommissioning project milestones and their updated scheduled completion dates.

The estimate to complete and cash flow analyses provided in Tables 1 and 2 confirm that the schedule changes in PSDAR, Revision 6, did not increase the decommissioning cost per 10 CFR 50.82(a)(7). TMI-2S also has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the TMI-2 PSDAR.

Three Mile Island, Unit 2 Annual Decommissioning Fund Status and Financial Assurance Report as of December 31, 2023 Page 3 of 3

References:

1. Letter TMI2-RA-COR-2022-0022 from Lackey, M.B. (EnergySolutions) to U.S. NRC (Document Control Desk), 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 October 27, 2022 (ML22306A051)

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

3. Letter TMI2-RA-COR-2024-0004 from Joseph R. Lynch (EnergySolutions) to U.S. NRC (Document Control Desk), Response to Request for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev 5, dated March 14, 2024 (ML24074A392)

4. Letter TMI2-RA-COR-2024-0005 from Joseph R. Lynch (EnergySolutions) to U.S. NRC (Document Control Desk), 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 6, dated March 28, 2024

5. Letter from Amy Snyder, U.S. NRC, to John T. Sauger, TMI2 Solutions, LLC, Three-Mile Island Station, Unit 2 - Review of the Management Plan for Three-Mile Island Station, Unit No. 2, Debris Material (EPID: L-2023-LLL-0015), dated January 5, 2024 (ML23325A109)

6. Letter from Theodore B. Smith, U.S. NRC, to John Sauger, TMI-2 Solutions, LLC, Three Mile Island Nuclear Station, Unit No. 2 - Issuance of Amendment No. 64 Re: Order Approving Transfer of License and Conforming License Amendment (EPID L-2019-LLA-0257), dated December 18, 2020 (ML20352A381)

Page 1 of 1 Year Type of Trust Comments 2023 Decommissioning Trust

$ 784.7 As of 12/31/2023; net of tax liabilities on realized gains Year License Termination Spent Fuel [Debris]

Mgmt Site Restoration Total Comments 2020-2022

$ 120.8 $ 14.0 0.00 $ 134.8 2020-2022 costs in as-spent dollars 2023

$ 67.6 $ 2.3 0.00 $ 69.9 2023 costs in as-spent dollars Total to Date

$ 188.4 $ 16.3 0.00 $ 204.7 As-Spent Dollars Year License Termination Spent Fuel [Debris]

Mgmt Site Restoration Total Comments 2023 Est.

$ 76.0 $ 5.5 0.00 $ 81.5 Estimate in 2023 Dollars 2023 Actuals

$ 67.6 $ 2.3 0.00 $ 69.9 Delayed start to decommissioning due to delay of LAR approval Year License Termination Spent Fuel [Debris]

Mgmt Site Restoration Total Comments 2023

$ 913.5 $ 0.6 $ 39.7 $ 953.7 Estimate in 2024 Dollars. Columns may not add due to rounding.

No material changes to trust agreement since previous report.

Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C) / (vii)(C)

No need for additional financial assurance.

DECON Any Modification to Method of Providing Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C)

No modification to method of providing financial assurance.

Any Material Changes to Trust Agreement Since Previous Report 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(D)

Decommissioning Criteria Upon Which the Estimate is Based 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(B)

Other Contracts or Financial Assurance Methods Being Relied Upon 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(A)

None are being relied upon.

ES Decommissioning Expenditures 10 CFR 50.82(a)(8)(v)(A) Since License Transfer Prior Year Expenditures Variance to Total ES Estimated Cost 10 CFR 50.82(a)(8)(v)(B)

Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B)-(vii)(B)

Spent Fuel [Debris] Mgmt net of DOE reimbursements.

Fund Balance (2023 $)

ENCLOSURE 1 Table 1 TMI2 Solutions, LLC - Three Mile Island, Unit 2 Summary Information as of December 31, 2023 All values in Millions of Dollars Decommissioning Trust Fund Balance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(A) / (vii)(A)

Page 1 of 1 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) Net of Taxes on realized gains 4 Withdrawals includes estimated payments for taxes on unrealized gains and any estimated deposits into the NDT fund 2 2024 Beginning of Year NDT Balance is net of realized tax liabilities 5 Spent Fuel [Debris] Mgt. Cost negative years include DOE reimbursements in excess of spend due to timing of 3 Columns may not add due to rounding reimbursements.

Year License Termination Cost Spent Fuel

[Debris]

Management Cost(5)

Site Restoration Cost Total Costs Beginning of Year NDT Balance Withdrawals(4)

NDT Earnings(1)

Year Ending NDT Balance(2)(3) 2024 79.0 6.2 0.0 85.2 784.7 (85.2) 14.8 714.3 2025 77.1 8.4 0.0 85.5 714.3 (60.5) 13.7 667.5 2026 79.4 (12.8) 0.0 66.7 667.5 (66.7) 12.7 613.5 2027 79.7 (3.0) 0.0 76.7 613.5 (76.7) 11.5 548.3 2028 93.6 (7.3) 0.0 86.3 548.3 (86.3) 10.1 472.1 2029 64.7 (4.8) 0.0 59.9 472.1 (59.9) 8.8 421.0 2030 2.1 0.2 0.0 2.3 421.0 (2.3) 8.4 427.1 2031 2.1 0.7 0.0 2.8 427.1 (2.8) 8.5 432.8 2032 7.7 0.7 6.5 14.8 432.8 (14.8) 8.5 426.5 2033 14.4 0.7 15.2 30.2 426.5 (30.2) 8.2 404.5 2034 55.8 0.7 18.0 74.4 404.5 (74.4) 7.3 337.4 2035 86.0 0.7 0.0 86.7 337.4 (86.7) 5.9 256.6 2036 79.6 0.7 0.0 80.3 256.6 (81.0) 4.3 180.0 2037 37.1 0.7 0.0 37.7 180.0 (43.3) 3.2 139.8 2038 0.0 0.7 0.0 0.7 139.8 (1.2) 2.8 141.5 2039 0.0 0.7 0.0 0.7 141.5 (0.7) 2.8 143.6 2040 0.0 0.7 0.0 0.7 143.6 (0.7) 2.9 145.8 2041 0.0 0.7 0.0 0.7 145.8 (0.7) 2.9 148.1 2042 0.0 0.7 0.0 0.7 148.1 (0.7) 3.0 150.4 2043 0.0 0.7 0.0 0.7 150.4 (0.7) 3.0 152.7 2044 0.0 0.7 0.0 0.7 152.7 (0.7) 3.0 155.1 2045 0.0 0.7 0.0 0.7 155.1 (0.7) 3.1 157.5 2046 0.0 0.7 0.0 0.7 157.5 (0.7) 3.1 160.0 2047 0.0 0.7 0.0 0.7 160.0 (0.7) 3.2 162.6 2048 0.0 0.7 0.0 0.7 162.6 (0.7) 3.2 165.2 2049 0.0 0.7 0.0 0.7 165.2 (0.7) 3.3 167.8 2050 0.0 1.0 0.0 1.0 167.8 (1.0) 3.3 170.1 2051 0.0 2.1 0.0 2.1 170.1 (2.1) 3.4 171.4 2052 0.0 1.9 0.0 1.9 171.4 (1.9) 3.4 172.9 2053 155.0 1.8 0.0 156.8 172.9 (175.4) 1.7 (0.8) 2054 0.0 1.2 0.0 1.2 (0.8) (4.3) 0.0 (5.2) 2055 0.0 (3.2) 0.0 (3.2) (5.2) 3.2 0.0 (2.0) 2056 0.0 (3.7) 0.0 (3.7) (2.0) 3.7 0.0 1.7 Total 913.5 0.6 39.7 953.7 (957.2) 174.2 ENCLOSURE 1 Table 2 TMI DECON Method Annual Cash Flow in Millions (2024 Dollars )