ML24157A367

Updated Post-Shutdown Decommissioning Activities Report Request for Additional Information Transmittal Letter

ML24157A367
Person / Time
Site:	Three Mile Island
Issue date:	06/13/2024
From:	William Allen Reactor Decommissioning Branch
To:	Richardson J TMI-2 Solutions
References
EPID L-2022-DPS-0002
Download: ML24157A367 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Jeff Richardson President TMI-2Solutions, LLC 121 West Trade Street, Suite 2700 Charlotte, NC 28202

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THREE MILE ISLAND STATION, UNIT 2, AMENDED POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT, REV. 6 (EPID NO. L-2022-DPS-0002)

Dear Jeff Richardson:

By letter dated March 28, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24088A012), TMI-2 Solutions, LLC (TMI-2 Solutions) submitted Revision 61 to the Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island Station, Unit 2 (TMI-2), as Attachment 1.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific requests are found in the enclosed request for additional information (RAI). The NRC staff requests that a response to the RAI be provided within 45 days of the date of this letter.

In accordance with 10 CFR Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.

1 The amended PSDAR (Revision 6) includes TMI-2 Solutions decommissioning plans and pertinent information described in Amendment No. 67 ( ML23200A187) which updated the technical specification and allowed the site to transition to active decommissioning. It also includes pertinent information in the February 12, 2024 ( ML23058A064) license amendment request (LAR), as supplemented, to address potential historic, cultural, and archaeological impacts from active decommissioning. Revision 6 of the PSDAR represents a revision that incorporates PSDAR Revisions 4 (ML21084A229) and 5 (ML22306A051). Revision 4 of the PSDAR reflects transfer of the license from GPU Nuclear, Inc. (GPUN) to TMl-2 Solutions that occurred on December 18, 2020 ( ML20352A381), and the transition of TMl-2 from its Post-Defueling Monitored Storage (PDMS) state to active decommissioning should the LAR to update the technical specification for active decommissioning (resulting in Amendment No. 67) be approved.

Amendment No. 67 was approved on March 31, 2023, but the NRCs review of PSDAR Revision 4 was not completed. Revision 5 of the PSDAR was an intermediate product resulting from RAIs on Revision 4 of the PSDAR. Revision 6 of the PSDAR incorporates all changes since Revision 3 of the PSDAR.June 13, 2024 J. Richardson 2 If you have any questions regarding this matter, please contact me by telephone at (301) 415-6877 or via email at william.allen@nrc.gov.

Sincerely, Chris Allen, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-320 License No. DPR-73 EPID No. L-2022-DPS-0002

Enclosure:

Request for Additional Information cc: TMI-2 List-Serv Signed by Allen, William on 06/13/24

U.S. NUCLEAR REGULATORY COMMISSION

REQUEST FOR ADDITIONAL INFORMATION

REGARDING THE THREE MILE ISLAND STATION, UNIT 2

POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT, REV. 6

DOCKET NO. 50-320

By letter dated March 28, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24088A012), TMI-2 Solutions, LLC (TMI-2 Solutions) submitted an amended Post-Shutdown Decommissioning Activities Report (PSDAR) (Rev. 6) for Three Mile Island Station, Unit 2 (TMI-2) for the U.S. Nuclear Regulatory Commission (NRC) review.

Regulatory Basis:

NRC regulations at 10 CFR 50.82(a)(4)(i) state, in part, that a PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment. Based on a review of the information supplied to date, the NRC staff is unable to complete its review for acceptability required by 10 CFR 50.82(a)(4)(i).

TECHNICAL

a. PSDAR Table 5-1, Three Mile Island Unit 2 Decommissioning Project Schedule identifies Phase 2 of decommissioning as Decommissioning and License Termination. The Phase 2 schedule only provides a schedule for decommissioning activities through the completion of Phase 2 Field Work. The paragraph immediately following the table discusses Phase 3 activities; i.e., fuel bearing material management. The schedule in the PSDAR should identify all decommissioning activities through complete termination of the license which includes the independent spent fuel storage installation (ISFSI) for fuel bearing material.

Further, when describing Phase 3, TMI-2 Solutions refers to the Plan for Management of Debris Material (Ref 34). The NRC staff reviewed this reference and it appears that TMI-2 Solutions plans to complete decommissioning of the TMI-2 general licensed ISFSI after the regulatory required period (within 60 years). In addition, it is unclear from the text of the PSDAR and Table 5-1 whether TMI-2 Solutions is planning to conduct final status surveys in land areas or on any subsurface structures (underground piping, footers, etc.) it may be planning to leave in place at license termination.

Request: Please identify the activities or areas (impacted vs. non-impacted) and type of media (soil, buildings, sediment, metal, etc.) where TMI-2 Solutions is planning to conduct site restoration before final status survey and why it is technically feasible.

The NRC staff also requests that TMI-2 Solutions directly state the schedule in this section (Table or paragraph) for activities associated with storing fuel bearing material, decommissioning the ISFSI, and termination of the license consistent with the within 60-year decommissioning requirement.

Enclosure In addition, NRC staff requests that TMI-2 Solutions clarify the general scope of the final status surveys (buildings, subsurface structures, land areas, etc.), as applicable.

b. Table 5-1 shows that TMI-2 Solutions is planning on performing site restoration before final status survey. For impacted areas, final status survey compliance demonstration must occur before site restoration of the area.

Request: Please identify the activities or areas (impacted vs. non-impacted) and type of media (soil, buildings, sediment, metal, etc.) where TMI-2 Solutions is planning to conduct site restoration before final status survey and explain why it is technically feasible.

c. Table 5-1 shows that final status survey will begin in 2036 and be completed in 2037.

Request: Please identify whether this work will be completed before (and therefore at risk),

or after the License Termination Plan (LTP) application request is submitted for approval. If after, please be mindful that a LTP license application request (LAR) review can take a year or more to complete and the schedule presented, as well as the cost estimate, may have to be modified.

d. PSDAR section 3.5 states that [t]hroughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. In addition, Table 5-1 identifies a three-year planning and transition period between completion of Phase 1b field work and building demolition that appears to start in Phase 2.

Request: The NRC staff requests that TMI-2 Solutions explain its strategy to effectively reconstitute and train personnel needed to perform during active decommissioning after a three-year hiatus of active decommissioning. Explain the general change in the amount and intensity of active decommissioning during the three-year planning period from Phase 1b and TMI-2 Solutions strategy to ensure that it will be ready to effectively implement essential programs (e.g., Radiation Protection) after the Phase 2 Planning and Transition stage is completed and during the building demolition.

e. Table 5-2, Three Mile Island Unit 2, Decommissioning Cost Summary, identifies costs for decommissioning activities and identifies phases. The phases in Table 5-2, Three Mile Island Unit 2 Decomissioning Cost Estimate, do not seem to relate to the phases in Table 5-1, thus making it difficult for staff, stakeholders, and the public to understand what is being done, when it is being done, and the associated cost.

Request: Please explain why the phases are different between Table 5-1 and Table 5-2.

Reconcile the tables or provide a cross reference supplement table for ease of relationship of activities and cost.

f. PSDAR Section, 3.1.2 Phase 1b: Fuel Bearing Material Recovery and Source Term Reduction does not list fuel bearing material recovery and source term reduction activities that will be performed in Phase 1b in a particular order.

Request: Given that the reactor building basement is currently only entered remotely through robotics, briefly explain the work sequence and strategy to accomplish fuel bearing material removal to ensure As Low As Reasonably Achievable (ALARA) and inform the NRC and the public the duration (start and end) of the removal of the 1% remaining fuel bearing material.

g. PSDAR section 3.5 states that the Department of Energy has the ultimate authority and responsibility for disposal of fuel bearing material pursuant to Standard Contract DECR01-83NE44477 and that debris material will remain on the ISFSI until it is transferred to the Department of Energy.

Request: The NRC staff requests that TMI-2 Solutions provide a copy of Standard Contract DECR01-83NE44477 or other documentation to confirm that the Department of Energy is ultimately responsible for disposal of the fuel bearing material.

h. The first paragraph of PSDAR section 3.3.7 states

Constellation manages the groundwater (GW) protection program for the TMI site in consideration of the site monitoring agreement between Constellation and TMI-2 Solutions in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document" (Reference 37). This program is controlled by procedures and will continue during decommissioning, and TMI-2 Solutions will ensure the GW protection program is properly managed for the site.

However, the PSDAR does not identify how the groundwater protection program responsibilities are separated between Constellation Energy Generation, the Three Mile Island Station, Unit 1 (TMI-1) licensee, and TMI-2 Solutions.

TMI-2 states in Attachment 2, List of Regulatory Commitments, of the March 24, 2024, submittal:

The Groundwater Protection Program will continue for TMI-2 in accordance with NEI (Nuclear Energy Institute) Technical Report 07-07 during decommissioning.

and

Scheduled completion date: Until replaced by the LTP groundwater monitoring program.

Request: Explain how TMI-2 Solutions will ensure that the groundwater protection program is properly managed for the site if Constellation Energy Generation manages the groundwater protection program. Provide a summary of the responsibilities that TMI-2 Solutions agreed to meet under the Constellation Energy Generation groundwater program.

Also, clarify if the site refers to the TMI-2 Solutions owned property, the site boundary as defined in the TMI-2 license, or the Three Mile Island Station Island.

If water spray is used as a decommissioning radiation control measure before the LTP LAR is submitted and approved, explain how TMI-2 Solutions intends to manage the runoff so as not to adversely affect the groundwater.

Explain whether the Constellation Energy Generation groundwater or the TMI-2 LTP groundwater monitoring program identified in Attachment 2 of the submittal will provide the groundwater data required for dose calculations for license termination.

i. The first bullet of PSDAR section 3.3.6, Site Characterization identifies that site characterization activities will be performed prior to and during the decommissioning process. However, it is not clear to the NRC staff, based on the rest of the information provided in this section, if this statement includes the open land areas and any remaining structures (such as piping, footers, or utilities) regarding characterization for license termination demonstration purposes. Licensees usually perform historical site assessments and scoping surveys in preparation for LTP planning. Although TMI-2 underwent initial decommissioning after the accident and the clean-up was documented, it is unclear whether the information and data covers areas besides the impacted buildings and whether the data are sufficient to use for LTP and unrestricted release compliance purposes given its age and pedigree (data quality).

Request: The NRC staff requests that TMI-2 Solutions identify its general characterization strategy to determine the radiological status of the site (any remaining subsurface structures and land areas) in preparation for the LTP LAR and throughout the NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (ML003761445) data life cycle.

j. PSDAR sections 6.1.3, Water Quality and 6.1.5, Aquatic Ecology discuss stormwater runoff and its impact on the environment. In PSDAR section 6.1.9, Radiological Accidents TMI-2 Solutions notes that TMI-2 Solutions will use inorganic, thus non-combustible, media for processing water at TMI-2. Also, in Table 5-1, TMI-Solutions identifies Field Waste Preparations with a sub-bullet titled, Liquid Radwaste & Water Processing.

Request: The NRC staff requests TMI-2 Solutions describe its wastewater processing strategy throughout decommissioning to include whether TMI-2 Solutions plans to collect and process stormwater and runoff from decommissioning activities. Clarify whether TMI-2 Solutions has or will have a wastewater processing system on site for decommissioning and if so, what water and waste it plans to send through it.

k. Previous decommissioning scenarios assumed that the license termination for TMI-1 and TMI-2 occurred concurrently (PSDAR Section 2, Background). These scenarios became invalid once TMI-2 Solutions took possession of the TMI-2 license in December 2020 and transitioned into DECON after NRC approval of license Amendment No. 67 in March 2023.

Request: Please explain TMI-2 Solutions strategy for termination of the TMI-2 license given that the licensed boundaries currently include the TMI-1 site which recently permanently shut down and entered SAFSTOR.

Please identify if TMI-2 Solutions intends to request a partial site release after Phase 2 is complete and what the remaining site will include (ISFSI only vs other). If the site configuration will be ISFSI only, please identify when the ISFSI will be decommissioned.

Update Table 5-1, as appropriate.

l. TMI-2 Solutions states on page 25 that the cooling towers may be demolished using explosives.

Request: Please identify the radiological status of the cooling towers. If the cooling towers are non-impacted, then identify what funds will be used for planning, removal and waste management of these structures.

m. PSDAR Section 3.3.4, Radioactive Waste Management states that Class B and Class C LLRW will be stored in an onsite storage area until it can be transported and disposed of at the Waste Control Specialists (WCS) facility in Andrews, Texas, or other options available at that time.

Request: Please identify where this waste will be temporarily stored on site and any associated decommissioning planning related to building the storage area and its cost.

Clarify whether the storage area discussed in PSDAR Section 3.3.4 for this type of waste is the proposed Interim Waste Storage Facility identified in PSDAR Section 3.3.1, Decommissioning Preparation Activities.

Does TMI-2 Solutions anticipate any Greater than Class C waste resulting from decommissioning and if so, what is TMI-2 Solutions strategy to address it? If Greater than Class C waste is anticipated, please update the decommissioning cost estimate, if necessary.

OTHER

n. The PSDAR states, on page 42 of 52, that the NRC planned to initiate a consultation under Section 106 of the National Historical Preservation Act.

Request: The NRC staff requests that the PSDAR be updated to identify that this consultation has occurred and update the cost estimate to account for any commitments that TMI-2 Solutions made that will require TMI-2 Solutions resources specific to radiological decommissioning.

Ltr ML24157A367

• via email OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB R-I/EAGLT* NMSS/DUWP/RDB NAME WAllen WA ASnyder AS NWarnek NW WAllen WA DATE Jun 11, 2024 Jun 11, 2024 Jun 13, 2024 Jun 13, 2024