ML24256A042

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Updated Post-Shutdown Decommissioning Activities Report, Rev. 6
ML24256A042
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/04/2024
From: William Allen
Reactor Decommissioning Branch
To: Richardson J
TMI-2 Solutions
References
Download: ML24256A042 (1)
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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:

THREE MILE ISLAND UNIT 2, UPDATED POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT, REV. 6

Dear Jeff Richardson:

On March 28, 2024, TMI-2 Solutions provided updates to the Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 (TMI-2) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24088A012), in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(7). This update, Revision 6, was provided in response to a request for additional information (RAI), dated June 29, 2023 (ML23187A020), which the NRC staff issued as part of its review of PSDAR, Revision 5. In its letter, TMI-2 Solutions indicated that, since submitting Revision 4 of the TMI-2 PSDAR following transfer of the TMI-2 Possession-Only License from General Public Utilities Nuclear to TMI-2 Solutions, TMI-2 Solutions changed the PSDAR in order to:

  • incorporate information from the February 19, 2021, License Amendment Request (ML21057A046), supplements to the License Amendment Request, as well as TMI-2 Solutions plans for using innovative technologies and chemical decontamination methods
  • provide decommissioning plan descriptions
  • revise both Table 5-1, TMI-2 Decommissioning Project Schedule and Table 5-2, TMI-2 Decommissioning Cost Summary
  • add Section 3.1.3, Transition Activities
  • reflect TMI-2 Solutions updated plans to acquire backfill from an offsite source versus potentially sourcing from Three Mile Island outside the operational area
  • update Section 6.1.7, Threatened and Endangered Species and
  • describe TMI-2 Solutions plans to ensure that any potential impact to terrestrial or aquatic ecologies, as well as any threatened or endangered species observed on or near the TMI-2 operational area, are avoided.

In general, the NRC staff finds that the updates reflect changes in the decommissioning status, decontamination methods employed, provide greater clarity regarding both the decommissioning schedule and the transition between Phase 1b and Phase 2 operations, update decommissioning costs, and explain changes to the plans for site restoration. Revision 6 of the PSDAR identifies changes to the list of threatened and endangered species as well as plans to avoid impacting threatened species, endangered species, terrestrial ecologies or October 4, 2024 J. Richardson aquatic ecologies. Finally, the changes discuss the steps taken to mitigate the potential impacts of decommissioning activities on Historic, Cultural, and Archaeological Resources.

The NRC staff agrees that the environmental impacts associated with the site-specific decommissioning activities, as reflected in Revision 6 of the PSDAR, will be bounded by the appropriate previously issued generic and plant specific environmental reviews. Also, the NRC staff concluded that the update identified neither significant cost nor significant schedule modifications. Moreover, the NRC staff recently completed its review of the adequacy of decommissioning trust fund balances in accordance with the annual review of reactors in decommissioning. After evaluating your March 23, 2023, submittal, Decommissioning Fund Status Report - Three Mile Island, Unit 2 (ML23082A312), the NRC staff has concluded that funding for TMI-2 is adequate to meet current decommissioning cost estimates for this facility.

In addition, on August 27, 2024 (ML24240A222), TMI-2 Solutions responded to a second RAI, which was issued on June 13, 2024 (ML24157A367). In its RAI response, TMI-2 Solutions provided information about the following topics:

  • work schedules
  • maintaining or obtaining a skilled workforce when transitioning from Phase 1 activities to Phase 2 activities
  • funding for proposed work activities
  • fuel bearing material removal
  • Department of Energy (DOE) accepting TMI-2 fuel bearing material for permanent disposal
  • groundwater management
  • characterization of land areas and structures
  • wastewater management strategies
  • license termination strategy
  • low level waste interim storage plans
  • updating the PSDAR to reflect the NRCs compliance with Section 106 of the National Historic Preservation Act (NHPA)

In general, the RAI responses provide greater clarity regarding work schedules, proposed work activity funding, fuel bearing material removal and the future license termination strategy.

Additionally, the RAI responses adequately explain how a skilled workforce will be maintained or obtained when transitioning from Phase 1 activities to Phase 2 activities, the process of cooling tower decommissioning, and the interim on-site storage plans for low-level waste. The RAI responses also sufficiently identify how land areas and structures would be characterized, as well as how wastewater and groundwater will be managed, and reflect NRCs development and approval of a Programmatic Agreement that was incorporated into the TMI-2 License as part of the LAR approval received August 9, 2024, (ML24135A327) in accordance with Section 106 of the NHPA. Finally, the information provided demonstrates that the DOE has agreed to take possession of any TMI-2 fuel bearing material associated with decommissioning activities for permanent disposal under the DOEs Standard Contract for the Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (10 CFR 961).

The NRC staff has completed its review of Revision 6 of the PSDAR for TMI-2, as supplemented on August 27, 2024. The staff reviewed the TMI-2 PSDAR against the requirements in 10 CFR 50.82(a)(4). In addition, the NRC staff used the guidance in Regulatory Guide 1.185, Revision 1, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, June 2013 (ML13140A038), in conducting its review. Based on this review, the NRC staff finds that Revision 6 of the PSDAR, as supplemented, contains the information required by 10 CFR 50.82(a)(4)(i). The regulations do not require the NRC to approve a licensees PSDAR; rather, NRC approval is required for the licensees decommissioning plan and license termination plan, in accordance with 10 CFR 50.82(a)(9)-(10). The NRC will continue to conduct inspections at TMI-2 throughout decommissioning under NRC Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, to ensure that decommissioning activities are performed safely and in compliance with the Commissions rules and regulations, and the conditions of the license.

In accordance with 10 CFR 2.390, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the U.S. Nuclear Regulatory Commission (NRC) Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. If you have any questions regarding this letter, please contact me at 301-415-6877 or by e-mail 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 cc: TMI-2 List-Serv Signed by Allen, William on 10/04/24

Ltr ML24256A042

  • via email OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/REFS NMSS/REFS/FAB

/EPMB2 NAME ASnyder AS WAllen WA AMinor AM RTurtil RT DATE Sep 24, 2024 Sep 12, 2024 Sep 12, 2024 Sep 17, 2024 OFFICE OGC/GCRPS R-I/EAGLT NMSS/DUWP/RDB

/HLWFCNS/NLO*

NAME ACoggins AC NWarnek NW WAllen WA DATE Oct 1, 2024 Oct 3, 2024 Oct 4, 2024

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