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{{Adams
#REDIRECT [[TMI-13-041, Post-Shutdown Decommissioning Activities Report Submittal]]
| number = ML13190A366
| issue date = 06/28/2013
| title = Three Mile Island, Unit 2, Post-Shutdown Decommissioning Activities Report Submittal
| author name = Harden P A
| author affiliation = GPU Nuclear, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/FSME
| docket = 05000320
| license number = DPR-073
| contact person =
| case reference number = TMI-13-041
| document type = Letter, Report, Miscellaneous
| page count = 27
}}
 
=Text=
{{#Wiki_filter:mý GPU Nuclear, Inc.OGP(F Three Mile IslandNuclear StationNUCLEAR Route 441 SouthPost Office Box 480Middletown, PA 17057-0480 Tel 717-948-8461 June 28, 2013TM1-1 3-041 10 CFR 50.5110 CFR 50.82Attn: Document Control DeskU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
 
==Subject:==
Three Mile Island Nuclear Station, Unit 2Docket No. 50-320, Possession Only License No. DPR-73Post-Shutdown Decommissioning Activities Report Submittal By letter dated August 14, 2012 (Accession No. ML12235A227),
GPU Nuclear, Inc.(GPUN) notified the Nuclear Regulatory Commission (NRC) of the intent to submita post-shutdown decommissioning activities report (PSDAR) for Three Mile IslandNuclear Station, Unit 2 (TMI-2).
The letter also provided the date that GPUNintended to use as the date of permanent cessation of operations for TMI-2.By letter dated February 13, 2013 (Accession No. ML12349A291),
the NRCacknowledged GPUN's intended actions to be appropriate while noting that thetiming of the TMI-2 PSDAR submittal did not meet the requirement to submit aPSDAR prior to or within two years of cessation of operations.
This letter alsoestablished the date of permanent cessation of TMI-2 operations to coincide withLicense Amendment 45, dated September 14, 1993. The letter concluded thatGPUN's intent to restore compliance with a 2013 submittal of a TMI-2 PSDAR tobe of very low safety and security significance.
The attached PSDAR is provided to establish TMI-2 compliance with10 CFR 50.82(a)(4),
and recognizes September 14, 1993 as the established datefor permanent cessation of TMI-2 operations.
The current decommissioning planwill maintain TMI-2 in the post-defueling monitored storage state up to anadditional 20 years to coincide with the end of the TMI-1 Operating License inorder to synchronize decommissioning of TMI-1 and TMI-2.
Three Mile Island Nuclear Station, Unit 2TM1-1 3-041Page 2If there are any questions or if additional information is required, please contactMr. Gregory H. Halnon at (330) 436-1369.
President
 
==Attachment:==
 
Three Mile Island Nuclear Power Station, Unit 2 Post-Shutdown Decommissioning Activities Report, June 2013cc: NRC Region I Administrator NRC Senior Resident Inspector NRC Project ManagerDirector BRP/DEPSite BRP/DEP Representative Attachment TMI-13-041 Page 1 of 25Three Mile Island Nuclear Power Station, Unit 2Post-Shutdown Decommissioning Activities ReportJune 2013 Attachment TMI-13-041 Page 2 of 25Table of ContentsSECTION PAGEI. INTRODUCTION 3II. BACKGROUND 4III. DESCRIPTION OF DECOMMISSIONING ACTIVITIES 6IV. SCHEDULE OF DECOMMISSIONING ACTIVITIES 11V. ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES 12VI. ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES 15VII. REFERENCES 25 Attachment TMI-13-041 Page 3 of 25I. INTRODUCTION GPU Nuclear, Inc. (GPUN), acting for itself and for the Metropolitan EdisonCompany, Jersey Central Power and Light Company, and the Pennsylvania Electric
: Company, has developed this post-shutdown decommissioning activities report (PSDAR) for the Three Mile Island Nuclear Station, Unit 2 (TMI-2) inaccordance with the requirements of 10 CFR 50.82, "Termination of license,"
paragraph (a)(4)(i).
TMI-2 has a possession only license (POL), and is currently maintained inaccordance with the Nuclear Regulatory Commission (NRC) approved SAFSTORcondition (method in which a nuclear facility is placed and maintained in a condition that allows it to be safely stored and subsequently decontaminated) known as post-defueling monitored storage (PDMS). GPUN has maintained TMI-2 in the PDMSstate since the NRC provisions for cleanup were met and accepted in 1993.By letter dated August 14, 2012, GPUN informed the NRC of the TMI-2 statusrelative to the 1996 Decommissioning Rule changes specifically related to10 CFR 50.51, "Continuation of license,"
and 10 CFR 50.82, "Termination of license."
The letter stated the intent to submit a PSDAR that describes the planneddecommissioning activities,
: schedule, cost estimates, and the environmental impactsof TMI-2 plant specific decommissioning.
By NRC letter dated February 13, 2013, theNRC stated that September 14, 1993 is considered the date of TMI-2's cessation ofoperations.
The following PSDAR report is provided in accordance with the requirements in10 CFR 50.82. The PSDAR includes:
" A description of the planned decommissioning activities,
" A schedule for their accomplishment,
* A site-specific decommissioning cost estimate including the projected cost of managing irradiated fuel, and" A discussion that provides the reasons for concluding that theenvironmental impacts associated with site-specific decommissioning activities will be bounded by previously issued environmental impactstatements.
Due to the unique nature of TMI-2, GPUN has included a Section II,"Background,"
in the PSDAR report to provide information on the design, history,and current status of the Three Mile Island Nuclear Station Unit 2. Sections IIIthrough V address the 10 CFR 50.82 requirements to describe and provide a Attachment TM1-1 3-041Page 4 of 25schedule and cost estimate for the planned decommissioning activities.
Section VI provides the reasons for concluding that the activities planned for thedecommissioning of TMI-2 are bounded by previously issued environmental impact statements.
Section VII provides a list of references used in the PSDAR.II. BACKGROUND TMI-2 is located on the northern-most section of Three Mile Island near the eastshore of the Susquehanna River in Dauphin County, Pennsylvania.
The stationis comprised of two pressurized water reactors.
The TMI Nuclear Stationincludes the operating Unit 1, owned by Exelon Generation
: Company, LLC(Exelon),
and the shutdown Unit 2 owned by GPUN.TMI-2 is a non-operational pressurized water reactor that was rated at a corethermal power level of 2772 megawatt-thermal with a corresponding turbine-generator gross output of 959 megawatt-electric.
TMI-2 employed a two looppressurized water reactor nuclear steam supply system designed by Babcockand Wilcox Corporation.
The reactor coolant system is housed within a steel-lined, post-tensioned concrete structure (reactor building),
in the shape of a right,vertical cylinder with a hemispherical dome and a flat, reinforced concretebasemat.
A welded steel liner plate, anchored to the inside face of the reactorbuilding, serves as a leak-tight membrane.
GPUN was issued an operating license for TMI-2 on February 8, 1978, withcommercial operation declared on December 30, 1978. On March 28, 1979, theunit experienced an accident initiated by interruption of secondary feedwater flow.The lack of secondary feedwater resulted in the reduction of primary-to-secondary heat exchange that caused an increase in the reactor coolanttemperature, creating a surge into the pressurizer, and an increase in systempressure.
The pressure operated relief valve (PORV) opened to relieve thepressure, but failed to close when the pressure decreased.
The reactor coolantpumps were turned off and a core heat-up began as the reactor coolant systemwater inventory continued to decrease resulting in a reactor vessel water levelbelow the top of the core. This led to a core heat up that caused fuel damage.The majority of the fuel material travelled down through the region of thesoutheastern assemblies and into the core bypass region. A portion of the fuelmaterial passed around the bypass region and migrated down into the lowerinternals and lower head region, but overall reactor vessel integrity wasmaintained throughout the accident.
Attachment TMI-13-041 Page 5 of 25As a result of this accident, small quantities of core debris and fission productswere transported through the reactor coolant system and the reactor building.
Inaddition, a small quantity of core debris was transported to the auxiliary and fuelhandling buildings.
Further spread of the debris also occurred as part of thepost-accident water processing cleanup activities.
The quantity of fuel remaining at TMI-2 is a small fraction of the initial fuel load;approximately 99 percent (%) was successfully removed in the defueling.
Additionally, large quantities of radioactive fission products that were released intovarious systems and structures were removed as part of the waste processing activities during the TMI-2 Clean-up Program.
The cleanup to meet the NRC postaccident safe storage criteria was completed and accepted by the NRC with TMI-2entering into post-defueling monitored storage in 1993.NUREG-0683, "The Programmatic Environmental Impact Statement Related toDecontamination and Disposal of Radioactive Wastes Resulting from theMarch 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2," Supplement 3(PEIS) discusses the activities performed to achieve the PDMS state at TMI-2.The PEIS evaluates the activities associated with the post-accident cleanup forenvironmental impact, and addresses the significant amount of decontamination and waste removal that would normally be part of a decommissioning plan, whichwere completed to achieve PDMS.Approximately 99% of the fuel was removed and shipped to the Idaho NationalEngineering and Environmental Laboratory (INEEL) under the responsibility ofthe Department of Energy (DOE). The reactor coolant system wasdecontaminated to the extent practical to reduce radiation levels to as low as isreasonably achievable (ALARA).
As part of the decontamination effort, waterwas removed to the extent practical from the reactor coolant system and the fueltransfer canal, and the fuel transfer tubes were isolated.
Radioactive wastesfrom the major clean-up activities have been shipped off-site or has beenpackaged and staged for shipment off-site.
Following the decontamination activities, only the reactor building and a fewareas in the auxiliary and fuel handling buildings continued to have general arearadiation levels higher than those of an undamaged reactor facility nearing theend of its operating life.GPUN maintained TMI-2 in the PDMS state while successfully operating TMI-1until AmerGen (a joint venture between Philadelphia Energy Company and BritishEnergy) purchased the operating TMI-1 from GPUN in 1998. The sale of TMI-1included the Unit 1 buildings, structures, and the majority of the site property; however GPUN maintained ownership of TMI-2. A monitoring agreement betweenAmerGen and GPUN provides for AmerGen performing certain functions at TMI-2 Attachment TM1-1 3-041Page 6 of 25while TMI-2 is in PDMS on the behalf of GPUN. These functions includemaintenance and testing, radiological and environmental
: controls, security andsafety functions and licensing activities required by the PDMS Technical Specifications and PDMS Final Safety Analysis Report.FirstEnergy acquired GPUN and ownership of TMI-2 in 2001 as part of a largeracquisition of GPU, and continued the monitoring agreement with AmerGen.
InDecember 2003, Exelon acquired sole ownership of TMI-1. A 2004 site-specific cost estimate for decommissioning TMI-2 assumed a delayed DECON scenario, which deferred the decontamination and dismantling activities at TMI-2 until theyare synchronized with TMI-1 such that the licenses for both units are terminated concurrently.
This scenario assumed a 10-year dormancy period for TMI-2,following the TMI-1 original license expiration in 2014, with decommissioning preparation to begin in about 2024. The initial schedule assumeddecommissioning operations would begin in about 2026, and would be completed over a 10-year period with site restoration projected in 2036. Since that time anextension to the TMI-1 operating license has been granted warranting a revision tothe decommissioning schedule for TMI-2.The NRC approved a 20-year extension to the TMI-1 Operating License by letter toExelon dated October 22, 2009. As a result, the TMI-1 Operating License has beenextended until April 19, 2034. The TMI-2 PSDAR establishes the schedule for thedecommissioning of TMI-2 to commence following the expiration of the TMI-1Operating License on April 19, 2034.Ill. DESCRIPTION OF DECOMMISSIONING ACTIVITIES The objective of decommissioning TMI-2 is to safely perform all the activities associated with decontamination and dismantlement of the remaining plantsystems, components, structures, and facilities in a cost effective manner. Thedecommissioning plan assumes that TMI-2 is effectively maintained in thecurrent SAFSTOR mode of PDMS until the expiration of the TMI-1 operating license in 2034, which could extend through the period of spent fuel removal andstorage from TMI-1. The decontamination and dismantling activities at TMI-2 willthen be synchronized with the adjacent unit such that the licenses for both unitsare terminated concurrently.
The decommissioning plan for TMI-2 involves activities to address the highersource term materials to eliminate elements that would contribute to higherworker exposure during activities that are typical of decommissioning anoperating plant at the end of plant life.
Attachment TM1-13-041 Page 7 of 25The decommissioning will focus on the use of both ultra high pressure watersprays and mechanical decontamination methods for the removal of theremaining high source term materials.
Since the majority of the spent fuel hasalready been removed from site and transferred to a DOE facility, there is noneed to construct an independent spent fuel storage installation (ISFSI) specificto TMI-2. GPUN will explore two options for storage and transfer of theremaining residual fuel and greater than class C (GTCC) waste. First, GPUN willwork with the DOE to obtain authorization to transport the remaining fuel andGTCC waste to INEEL, where the majority of TMI-2 spent fuel is currently stored,or to an alternate storage or repository location designated by DOE, if available, by that time. If DOE storage options are not deemed viable, GPUN will explorean agreement with Exelon to have the remaining TMI-2 fuel and GTCC stored inthe TMI-1 ISFSI until a DOE geological repository becomes operational.
Based on the above overall plan, the decommissioning of TMI-2 has beendivided into the following periods:" PDMS (SAFSTOR Dormancy)
* Preparations for Decommissioning
" Decommissioning Operations
* Non-radiological Restoration of the SiteThe following provides a discussion of the decommissioning plan, the significant activities, and the general sequencing of activities in each of the above periods.The planning required for each decommissioning
: activity, including the selection process to perform the work, will be completed prior to the start of work for thatactivity.
Period 1: PDMS (SAFSTOR Dormancy)
The PDMS condition was established following the accident at TMI-2 to establish an inherently stable and safe condition of the facility such that there was no riskto the public health and safety. The PDMS state has been approved by the NRCand is governed by a PDMS Safety Analysis Report, PDMS Technical Specifications, and PDMS Quality Program.The PDMS Technical Specification requirements to monitor and surveyradiological conditions have been established and maintained since 1993. Sitesecurity is maintained as a contracted service by Exelon that owns and operatesTMI-1.
Attachment TMI-13-041 Page 8 of 25As discussed in the TMI -2 PDMS Safety Analysis Report:" There is no credible possibility of nuclear criticality.
* Fuel and core debris removed from the reactor vessel and associated systems has been shipped offsite.* Any potential for significant release of radioactivity has beeneliminated.
* Water has been removed to the extent practical from the reactorcoolant system and fuel transfer canal, and fuel transfer tubes havebeen isolated.
The treatment and processing of accident generated water has been completed.
* Radioactive waste from the major cleanup activities has been shippedoff-site or has been packaged for shipment off-site.
" Radiation within the facility has been reduced, as necessary, consistent with ALARA principles to levels that will allow necessary plant monitoring activities, the performance of required maintenance, and any necessary inspections.
The PDMS dormancy period is expected to extend until the end of TMI-1operating license in 2034, and could extend until completion of the TMI-1 spentfuel removal and storage campaign.
In the event that circumstances dictate anearlier shut down of TMI-1, the expected TMI-2 PDMS dormancy period will bereduced, and the PSDAR will be revised to reflect a decommissioning schedulethat maintains concurrent decommissioning with TMI-1.Period 2: Preparations for Decommissioning A decommissioning organizational structure and selected staff will be developed to identify roles, responsibilities, and accountabilities for the decommissioning preparations and decommissioning operations.
Preparations include the planning for the removal of the remaining residual fuel,decontamination of the structures, and dismantling the remaining equipment andfacilities.
Attachment TMI1-13-041 Page 9 of 25In preparation for actual decommissioning, activities that will be performed include:" Conduct a characterization of the site and the surrounding environs.
This includes radiation surveys of the reactor building including
: basement, elevator block wall area, areas surrounding majorcomponents, internal piping, and primary shield cores.* Conduct radiation surveys of the auxiliary and fuel handling buildings with emphasis on areas with known and potential alpha contamination, and known fission products.
* Conduct radiation surveys and sample analysis on exterior buildings, land areas surrounding the facility, subsurface soil and groundwater.
* Develop specifications for transport and requirements for highlyradioactive waste and hazardous waste.* Develop procedures for occupational exposure
: control, control andhandling of liquid and gaseous effluents, processing of radioactive waste, site security, emergency
: programs, and industrial safety.Period 3: Decommissioning Operations The actual decommissioning and dismantlement of TMI-2 will occur during theperiod of decommissioning operations.
Significant decommissioning activities tobe performed during this period include, but are not limited to, those listed below.Some of the activities are unique to the decommissioning of TMI-2, but a numberof these activities may be coordinated with Exelon as they may be needed tosupport the concurrent decommissioning of TMI-1." Construction of temporary facilities or modifications to existing facilities to support dismantlement activities.
" Design and fabrication of temporary and permanent shielding tosupport removal and transportation activities, construction ofcontamination control envelopes, and the procurement of specialty tooling.* Procurement of shipping containers, cask liners, and industrial packages for packaging.
Attachment TMI-13-041 Page 10 of 250 Reconfiguration and modification of site structures and facilities asneeded to support decommissioning operations.
This may include theupgrading of roads and rail facilities to facilitate hauling and transport.
0 Decontamination of components and structures as required to reducesource term and control (minimize) worker exposure.
0 Inventory, decontamination, and removal of legacy equipment inventory left over from defueling campaign.
* Disassembly and segmentation of the remaining reactor vesselinternals.
Some internals are expected to exceed GTCC requirements.
As such, the segments will be appropriately packaged for disposal.
0 Removal of control rod drive housings and the head servicestructure from reactor vessel head.0 Segmentation of the reactor vessel head.* Segmentation of the reactor vessel.0 Removal of the steam generators and pressurizer for materialrecovery and controlled disposal.
0 Removal of the free standing concrete and other internal structures inthe reactor building including:
polar crane, biological shield, D-rings,floors, etc.A license termination plan (LTP), in accordance with 10 CFR 50.82(a)(9),
will beprepared at least two years prior to the anticipated date of license termination.
The LTP will include a site characterization, description of remaining dismantling activities, plans for site remediation, updated cost estimate to complete thedecommissioning, any associated environmental
: concerns, designation of theend use of the site, and the procedures for the final radiation survey. The LTPwill be developed following the guidance contained in Regulatory Guide 1.179,"Standard Format and Content of License Termination Plans for Nuclear PowerReactors."
As described in Regulatory Guide 1.179, the LTP will use theguidance contained in NUREG-1575, "Multi-Agency Radiation Survey and SiteInvestigation Manual (MARSSIM)"
to develop the final radiological survey planand survey methods.
The use of MARSSIM to develop the final radiological survey plan and survey methods will demonstrate compliance with therequirements 10 CFR 20, Subpart E, "Radiological Criteria for LicenseTermination."
Once the LTP is approved, the final remediation of the site Attachment TMI-13-041 Page 11 of 25facilities and services can commence.
These activities
: include, but are notlimited to:" Removal of remaining plant systems and components as they becomenonessential to the decommissioning
: program, or worker health andsafety (for example, waste collection and processing systems,electrical power and ventilation systems).
* Removal of contaminated yard piping and any contaminated soil." Remediation and removal of the contaminated equipment and materialfrom the auxiliary and fuel buildings, and any other contaminated facility.
Use of the NUREG-1 575 guidance ensures that the surveys are conducted in amanner that provides a high degree of confidence that applicable NRC criteriaare satisfied.
Once the final survey is complete, the results are provided to theNRC. The NRC will terminate the license if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable forrelease.Period 4 -Site Restoration Following completion of decommissioning operations, site restoration activities will begin. Site restoration will involve the dismantling and disposal of anyremaining non-radiological structures.
Restored areas of the site will bebackfilled, graded and landscaped to support vegetation for erosion control.IV. SCHEDULE OF DECOMMISSIONING ACTIVITIES The decommissioning plan for TMI-2 can be characterized as a delayed DECONapproach.
The schedule for decommissioning of TMI-2 is based on theassumption that TMI-2 will be decommissioned with TMI-1 to achieve economies of scale, by sharing costs between units, and coordinating the sequence of workactivities.
The high level schedule for decommissioning of TMI-2 assumes that the PDMSSAFSTOR dormancy period will extend past the TMI-1 shutdown date to allowfor TMI-1 ISFSI construction and spent fuel removal and storage.
Prior tocompletion of the TMI-1 ISFSI program, the preparation for TMI-2decommissioning will begin. As decommissioning approaches, schedulevariations to account for availability of waste disposal facilities and coordination Attachment TMI-13-041 Page 12 of 25with Exelon and vendors will be incorporated.
It is not expected that thesevariations will impact the overall completion schedule.
The schedule for decommissioning of TMI-2 has been developed in order toachieve the termination of license by September 14, 2053. This termination dateensures compliance with the NRC requirement to complete decommissioning 60years from certificate of cessation to operate as defined in 10 CFR 50.82(a)(3).
In the event of any unforeseen circumstances that should warrant a request thatTMI-2 license termination be allowed beyond September 14, 2053, GPUN willnotify the NRC to request consideration of an exemption to the 60-yearrequirement as defined in 10 CFR 50.82(a)(3).
As noted in letter from the NRCto GPUN dated February 13, 2013, the equivalent to the certificate ofcessation of operations was determined to be the NRC's issuance of TMI-2License Amendment 45, converting the TMI-2 operating license to a possession only license.
This amendment was granted on September 14, 1993 andestablishes that date as the date that TMI-2 is considered to have submitted certification of permanent cessation of operations.
Upon receipt of NRCtermination of license, site restoration activities will commence.
It is estimated that the site restoration will take approximately one year to complete therebyrendering the Three Mile Island site restored to greenfield status in 2054.Major milestones established for decommissioning of TMI-2 are listed in the tablebelow.MAJOR DECOMMISSIONING ACTIVITY DATESTMI-2 PDMS SAFSTOR Dormancy 1993- 2043TMI-1 Shutdown April 19, 2034TMI-2 Decommissioning Preparation 2043- 2044TMI-2 Decommissioning Operations 2044 -2053TMI-2 Site Restoration 2053-2054 V. ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES In February 1996, TLG Services, Inc. completed the first TMI-2 site-specific decommissioning cost estimate that was developed for GPUN. That analysiswas first updated in 2004 and has been further refined to reflect currentassumptions pertaining to disposition of the nuclear unit and relevant industryexperience in undertaking decommissioning projects.
The decommissioning activities for TMI-2 are a continuation of the decontamination efforts started in the 1980s. The cost estimate recognizes the present state of TMI-2decontamination, contingency for unknown or uncertain conditions, the availability of Attachment TMI-13-041 Page 13 of 25low and high level radioactive waste disposal sites, and site remediation requirements.
The methodology used to develop the cost estimate follows the basicapproach developed by the Atomic Industrial Forum (now the Nuclear EnergyInstitute) in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear PowerPlant Decommissioning Cost Estimates."
The method uses a unit cost factorapproach, including application of work difficulty adjustment factors to developdecommissioning activity costs, and incorporates local information related to laborrates, as well as latest available industry experience.
The unit factor methodprovides a demonstrable basis for establishing reliable cost estimates.
The detailprovided in the unit factors, including activity
: duration, labor costs (by craft), andequipment and consumable costs, ensures that essential elements have not beenomitted.The estimate presented herein is based upon the most recent update to the sitespecific cost estimate completed by TLG Services in January 2009, and providedto the NRC as part of the 10 CFR 50.75(f)(1),
"Reporting and record keeping fordecommissioning planning,"
submittal on March 29, 2010 (Accession No. ML100960464).
Consistent with a signed memorandum of understanding between FirstEnergy Corp. (parent of GPUN) and Exelon regarding the timing of decommissioning activities at TMI-2, it is assumed that decommissioning at TMI-2 will not begin untilthe expiration of the TMI-1 operating license in 2034 and will be coordinated withpost-shutdown activities for TMI-1. For the purpose of this cost estimate theintegration of site security and the final site radiological survey between the twounits is assumed.There are a number of considerations that affect the method for decommissioning the TMI-2 site and the degree of restoration required.
The cost estimate includesthe considerations identified below.The majority of the fuel was removed during the TMI-2 Cleanup Program's reactor vessel defueling effort that concluded in January 1990. Title to this fuelwas transferred to the Department of Energy (DOE). The remainder of the fuel(about 1 %) is dispersed within the primary system and to a lesser extent in othersystems and structures.
This residual material will be removed as radioactive waste. Therefore, the cost of managing irradiated fuel is not reflected within theestimates to decommission the TMI-2 site.It is expected that there will be some wastes, (GTCC waste) generated in thedecommissioning of TMI-2 that are not suitable for shallow land burial andtherefore cannot be shipped for disposal until a high level waste repository ismade available by DOE. Although the material is not classified as high-level Attachment TMI-13-041 Page 14 of 25waste, the DOE has indicated they will accept this waste for disposal at the futurehigh-level waste repository.
: However, the DOE has not developed anacceptance criteria or disposition schedule for this material, and numerousquestions remain as to the ultimate disposal cost and waste form requirements.
For purposes of the cost estimate, it is assumed that GTCC waste will bepackaged and disposed of as high-level waste, at a cost of $25,000 per cubicfoot (in 2008 dollars).
It is also assumed that the DOE will accept the GTCCmaterial in a timely manner so as not to affect the TMI-2 decommissioning schedule.
No additional costs are included for the temporary storage of GTCCmaterial.
The decommissioning cost estimate for TMI-2 has been summarized in Table 1.This PSDAR will not be updated for minor changes in anticipated decommissioning costs. However, the status of TMI-2 decommissioning fundingwill continue to be reported to the NRC in accordance with 10 CFR 50.75(f)(1) and10 CFR 50.82(a)(8)(v).
This report will include, at a minimum, the assumptions used in the rates of escalation of decommissioning costs and rates of earningsused in funding projections.
Additionally, GPUN, in accordance with 10 CFR50.82(a)(7),
will inform the NRC in writing (with a copy sent to Pennsylvania),
before performing any decommissioning activity inconsistent with or making anysignificant schedule change from those actions and schedules described in thePSDAR, including changes that significantly increase the decommissioning cost.GPUN will also include an updated site specific estimate of remaining decommissioning costs in the license termination plan in accordance with 10 CFR50.82(a)(9)(ii)(F).
The annual 10 CFR 50.75(f)(1) reports continue to demonstrate that the current fund balances are more than adequate to cover the expectedfuture cost of decommissioning.
In the event that future estimated costs or fundinglevels change significantly, GPUN will make the necessary adjustments to ensurethat sufficient funds remain available for decommissioning.
Attachment TMI-13-041 Page 15 of 25TABLE 1TMI-2 DECOMMISSIONING COST SUMMARY(Thousands based on 2008 dollars)Decontamination RemovalPackaging Transportation, Off-site Waste Processing, and DisposalProgram Management Miscellaneous Equipment Insurance and Regulatory FeesOther Decommissioning Costs$ 31,577$149,523$ 17,232$ 204,189$371,633$ 23,169$ 17,868$ 29,694Total Decommissioning Costs(Based on 2008 Dollars)$ 844,885VI. ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES 10 CFR 50.82(a)(4)(i) requires that the PSDAR include "a discussion that providesthe reasons for concluding that the environmental impacts associated with the site-specific decommissioning activities will be bounded by appropriate previously issuedenvironmental impact statements
..." The potential environmental impactsassociated with the proposed decommissioning activities for TMI-2 were comparedwith similar impacts given in the PEIS related to post-accident cleanup activities resulting from the March 28, 1979 accident; and with NUREG-0586, "GenericEnvironmental Impact Statement on Decommissioning of Nuclear PowerFacilities,"
dated August 1988 and Supplement 1, Volumes 1 and 2, datedNovember 2002 (collectively known as GELS) on decommissioning and radiological criteria for license termination.
The following discussion provides the comparison.
PEISThe PEIS identified that the post-accident cleanup activities can be categorized into four fundamental activities:
: 1. Building and equipment decontamination,
: 2. Fuel removal and the reactor coolant system decontamination,
: 3. Treatment of radioactive
: liquids, and4. Packaging,
: handling, shipment, and disposal of radioactive wastes Attachment TMI-13-041 Page 16 of 25These activities were used in the evaluation of the alternatives to GPUN'sproposed action of delayed decommissioning.
As described in the PEIS, theNRC evaluated seven alternatives relative to delayed decommissioning.
TheNRC concluded (except for the no action alternative, which was not considered acceptable) that no alternative was found to be superior to GPUN's proposalfrom an environmental impact perspective.
Of the seven alternatives evaluated in the PEIS (except for the no actionalternative) as well as the proposed GPUN's delayed decommissioning plan, theNRC concluded that each alternative could be conducted in conformance withapplicable regulatory requirements and implemented without significant impact tothe human environment.
Hence, it is reasonable to conclude that the activities described for the TMI-2 decommissioning will be accomplished with no adverseenvironmental impacts based upon the following:
" The activities to be performed for decommissioning are equivalent tothe activities performed during the post-accident cleanup evaluated inthe PEIS," The radiation control techniques and decontamination methods sincethe post TMI-2 accident cleanup have improved,
* No site-specific activities pertaining to TMI-2 decommissioning wouldalter the conclusions of the PEIS," Radiation dose to the public will be minimal, and* Radiation dose to decommissioning workers will be maintained ALARAaccording to 10 CFR Part 20.As noted in the PEIS, the outcome of completing the clean-up activities at TMI-2would result in many areas decontaminated to the point where general area doserates approximate those in an undamaged reactor facility nearing the end of itsoperating life.GElSThe remaining decommissioning activities for the delayed decommissioning ofTMI-2 can be compared to the activities evaluated in the GELS.As a general matter, TMI-2 is smaller than the reference PWR used in NUREG-0586 to evaluate the environmental impacts of decommissioning, and is likewisesmaller than a number of PWRs that were evaluated in NUREG-0586, Supplement
: 1.
Attachment TMI1-13-041 Page 17 of 25Decommissioning activities are identified in Appendix E of NUREG-0586, Supplement
: 1. No activities planned for TMI-2 deviate from the activities listed interms of environmental impact. A deviation exists in terms of the variables associated with transuranic fuel and higher source terms. However, thesevariables are addressed through controlled decontamination and dismantlement, and following NRC regulations associated with dose. So long asdecontamination and dismantlement are performed within the guidelines of theregulations regarding release of effluents, occupational dose, and offsite dose;and GTCC waste is contained in approved shipping containers; thedecommissioning activities at TMI-2 are directly comparable to the activities evaluated in the GELS.NUREG-0586, Supplement 1, Section 4.3, "Environmental Impacts from NuclearPower Facility Decommissioning,"
provides a listing of 18 issues pertinent to thedecommissioning of a reactor.
A discussion of these issues follows.1. Onsite/Offsite Land UseThe GElS concluded that the impacts on land use are not detectable or small forfacilities having only onsite land-use changes as a result of large component
: removal, structure dismantlement, and low level waste packaging and storage.There are no anticipated changes in land use beyond the site boundary duringdecommissioning.
Therefore, it can be concluded that the impacts on land useare bounded by the GELS.2. Water UseSince the shutdown of TMI-2 and the entry into the PDMS state, the demand forpotable water has decreased significantly below the demand during operation.
The operational demand for cooling water, makeup water, and service water hasceased. The demand for water needed to conduct plant decommissioning activities (flushing piping, hydro-lasing, dust abatement, etc.) will be less than thedemand for water supply during operation.
Hence, the impacts on water use arebounded by the GELS.3. Water Quality -Non-Radiological Programs and processes designed to minimize, detect, and contain spills will bemaintained throughout the decommissioning process.
: Federal, state and localregulations, and permits pertaining to water quality will remain in effect, and nosignificant changes to water supply reliability are expected.
Therefore, theimpact of TMI-2 decommissioning on water quality is bounded by the GELS.
Attachment TMI-13-041 Page 18 of 254. Air QualityThere are many types of decommissioning activities that have the potential toaffect air quality.
These activities are listed in the GElS and evaluated from theperspective of the ability to mitigate consequences of activities through the use ofhigh efficiency particulate filters.
In addition, the release of any effluents must becontrolled to keep contaminated material within the NRC's regulatory limits. Forthe purposes of assessing radiological
: impacts, impacts are of small significance if doses and releases do not exceed limits established by the NRC's regulations.
GPUN does not anticipate any activities beyond those listed in the GElS thatcould potentially affect air quality.
Therefore, the impact of the TMI-2decommissioning on air quality is bounded by the GELS.5. Aquatic EcologyGPUN does not anticipate disturbance of lands beyond the current operational areas of the plant. No alteration to the shores of the Susquehanna River willoccur. All activities within the current operational areas of the plant will beconducted in accordance with required permits.
Therefore, the impacts ofdecommissioning TMI-2 on aquatic ecology are bounded by the GELS.6. Terrestrial EcologyTerrestrial ecology considers the plants and animals in the vicinity of Three MileIsland as well as the interaction of those organisms with each other and theenvironment.
Evaluations of impacts to terrestrial ecology are usually directed atimportant habitats and species, including plant and animals that are important toindustry, recreational activities, the area ecosystems, and those protected byendangered species regulations and legislation.
GPUN does not anticipate activities to be conducted that would disturb habitat beyond the operational areasof the plant. In addition, the Pennsylvania Department of Natural Resources controls impacts to the environment through regulation of construction activities.
Therefore, the impacts of decommissioning TMI-2 on terrestrial ecology arebounded by the conclusions in the GELS, which concludes the impact to be small.7. Threatened and Endangered SpeciesOf the state or federally listed endangered or threatened animal and plantspecies, only the bald eagle, the osprey, the peregrine falcon, and Americanholly were identified to have a presence on or near the island.The bald eagle has recently been removed from the endangered species list butremains protected by two other federal laws. The Bald and Golden EagleProtection Act and the Migratory Bird Treaty Act became effective in 2007. Bald Attachment TM1-13-041 Page 19 of 25eagles have become relatively common along the Susquehanna River and havebeen known to nest in Dauphin, Lancaster, and York counties.
Occasionally theyhave been observed on Three Mile Island, but there are no known nests on theisland. There is a bald eagle nest located approximately 20 miles south, nearHoltwood Dam.The Susquehannah River and the associated environment and wetland areas inthe vicinity of Three Mile Island are used by many migratory and resident birdspecies.
Osprey and peregrine falcon nests are known to occur on Three MileIsland. Ospreys have nested on the meteorological tower every year since 2004.A 55-foot nesting platform was erected near the tower, but the ospreys have notused it. Peregrine falcons have nested on the TMI-1 Reactor Building since2002. A nest box designed for peregrine falcons was placed on the TMI-2reactor building in 2002, but the birds have not used it. Exelon regularly monitorsthe osprey and the peregrine falcon nests on Three Mile Island. The Americanholly, state-listed as threatened, has been recorded on the TMI-1 property.
Should the situation change and the identified species routinely be found in oraround any of the TMI-2 buildings or property, it is GPUN's intent to notify theNRC and the Pennsylvania Department of Environmental Protection to evaluatethe impact of decommissioning activities.
: 8. Radiological Occupational DoseIt is anticipated that low-level radioactive waste removed from TMI-2 will bedisposed of at approved waste disposal sites, and that the disposal at localcommercial landfills will be minimized in favor of low-level radioactive wastedisposal to reduce the risk of inadvertent release of radiological material.
Radiation dose to the public is expected to remain below levels comparable towhen TMI-2 was operating, through the continued application of radiation protection and contamination controls combined with the reduced source termavailable in the facility.
It is anticipated that an occupational dose estimate for the decommissioning ofTMI-2 will be performed prior to the start of decommissioning activities based onconfirmed characterization results of area contamination and activity levels.Occupational dose will be limited to 5 rem/year total effective dose equivalent (TEDE) as required by 10 CFR 20.1201(a)(1)(i),
and is expected to beadministratively controlled to a lower TEDE limit to ensure that personnel dosesdo not exceed regulatory limits. It is also anticipated that administrative practices will result in equitable distribution of dose among available qualified workers toensure collective dose to the work force is kept ALARA.
Attachment TMI-13-041 Page 20 of 25The decommissioning activities dose will be maintained within the regulatory limits, and as such, is consistent and within the conclusions of the GElS9. Radiological Accidents The likelihood of a large offsite radiological release that impacts public health andsafety with TMI-2 in the PDMS state is considerably lower than the likelihood of arelease from the plant during power operation.
This is because the majority ofthe potential releases associated with power operation are not relevant after thefuel has been removed from the reactor.GELS, Supplement 1 also considers the possibility of a zircalloy fire. Thisaccident is not relevant to TMI-2 in the current PDMS condition withapproximately 99% of the fuel material having been removed from the site andsent to INEEL.The potential for decommissioning activities to result in radiological releases notinvolving spent fuel (that is, releases related to decontamination anddismantlement activities) will be minimized by use of procedures designed tominimize the likelihood and consequences of such releases.
Therefore, GPUN concludes that the impacts of decommissioning on radiological accidents are small and bounded by the GELS.10. Occupational IssuesGPUN will continue to maintain appropriate administrative controls andrequirements to ensure occupational hazards are minimized and that applicable
: federal, state and local occupational safety standards and requirements continueto be met. GPUN has reviewed the occupational hazards and injuries in theGElS and concluded that they are not unique or different than activities performed during construction and cleanup of TMI-2. Therefore, the impact ofdecommissioning TMI-2 on occupational issues is bounded by the GELS.11. CostDecommissioning costs for TMI-2 are discussed in Section IV of the PSDARreport. The GElS recognizes that an evaluation of decommissioning cost is not aNational Environmental Policy Act requirement.
Therefore, a bounding analysisis not applicable.
Attachment TMI-13-041 Page 21 of 2512. Socioeconomics Decommissioning of TMI-2 is expected to result in positive socioeconomic impacts.
As TMI-2 transitions from the PDMS state to a unit undergoing decommissioning, the potential for local employment to support decommissioning operations becomes available.
GPUN has reviewed the GElS and has determined that the decommissioning ofTMI-2 is bounded by the GElS analysis of socioeconomic effects on theshutdown and decommissioning of an operating unit.13. Environmental JusticeExecutive Order 12898, dated February 16, 1994, directs Federal executive agencies to consider environmental justice under the National Environmental Policy Act. It is designed to ensure that low-income and minority populations do not experience disproportionately high and adverse human health orenvironmental effects because of federal actions.Because the activities of the decommissioning plan create the potential foradditional work opportunities, the decommissioning of TMI-2 could have apositive impact on environmental justice by providing job opportunities for lowerincome or minority populations around the area.The decommissioning activities are bounded by the evaluation of the postaccident clean up activities relative to socioeconomic and environmental justice.GPUN concludes that the employment opportunities created bydecommissioning will have a positive impact on environmental justice and thatno further evaluation of detrimental impacts is required.
: 14. Cultural,
: Historic, and Archeological Resources The PEIS makes no mention of cultural, historic or archeological resources onThree Mile Island. In addition, GPUN expects that most decommissioning activities will be conducted within the protected areas of the site. As stated in theGELS, where disturbance of lands beyond the operational areas is notanticipated, the impacts on cultural, historic and archeological resources are notconsidered to be detectable or destabilizing.
GPUN has concluded that theimpact of decommissioning TMI-2 on cultural,
: historic, and archeological resources to be bounded by the GELS.
Attachment TMI-13-041 Page 22 of 2515. Aesthetic IssuesThe impact of decommissioning activities on aesthetic resources will betemporary and remain consistent with the aesthetics of an industrial plant. Afterthe decommissioning process is complete, site restoration activities will result instructures being removed from the site and the site being backfilled, graded andlandscaped as needed. The removal of structures is generally considered beneficial to the aesthetic impact of the site. Therefore, GPUN has concluded that the impact of decommissioning TMI-2 on aesthetic issues is bounded by theGELS.16. NoiseGeneral noise levels during the decommissioning process are not expected to beany more severe than during refueling outages and are not expected to present anaudible intrusion on the surrounding community.
Some decommissioning activities may result in higher than normal noise levels (that is, some types of demolition activities).
: However, these noise levels would be temporary and are not expectedto present an audible intrusion on the surrounding community.
Therefore, GPUNhas concluded that the impact of decommissioning TMI-2 on noise is bounded bythe GELS.17. Transportation The GElS states that NRC regulations are adequate to protect the public againstunreasonable risk from the transportation of radioactive material and that theeffects of transportation of radioactive waste on public health and safety areconsidered to be neither detectable nor destabilizing.
The NRC analysis furtherdetermined that their consideration of the existing data for decommissioning methods and transportation modes should bound the transportation impacts forall decommissioning options for pressurized water reactors and boiling waterreactors.
For the decommissioning of TMI-2, the transportation modes assumed areshielded container removal by rail or truck. The reactor vessel internalcomponents are expected to be transported in spent fuel casks by rail. Otherhighly radioactive wastes will be transported in shielded containers via truck.The major transport mode for waste generated from filtering and demineralization of the reactor coolant system and the fuel transfer pool water is assumed torequire shipment in shielded truck casks. The low level radioactive wastesrequiring controlled disposal are expected to be sent to a waste processor or alow-level radioactive waste disposal facility via railroad.
Attachment TMI-13-041 Page 23 of 25The transportation impacts of decommissioning are dependent on the number ofshipments to and from the plant, the types of shipments, the distance thematerial is shipped, and the radiological waste/fixed waste quantities anddisposal plans. The estimated number and volume of shipments from the plantwill be much smaller than shipments to the plant during decommissioning.
Theshipments from the plant would be primarily radioactive wastes and non-radioactive wastes associated with dismantlement and disposal of structures, systems and components.
GPUN must comply with applicable regulations when shipping radioactive waste,and the NRC has concluded in the GElS that these regulations are adequate toprotect the public against unreasonable risk from transportation of radioactive materials.
In addition, shipments of waste from the site are not expected to resultin measurable deterioration of affected roads or a destabilizing increase in trafficdensity.Therefore, GPUN has concluded that the impact of decommissioning TMI-2 ontransportation is bounded by the GELS.18. Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot berecovered, and irretrievable commitments of resources are those that are lostfor only a period of time.Uranium is a natural resource that is irretrievably consumed during poweroperation.
After the plant is shutdown uranium is no longer consumed.
The useof the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment but rather a relatively short-term investment.
Since the decommissioning plan is to release the site forunrestricted use after license termination, land is not considered an irreversible resource.
The only irretrievable resources that would occur duringdecommissioning would be materials used to decontaminate the facility (forexample, rags, solvents, gases, and tools) and the fuel used fordecommissioning activities and transportation of materials to and from the site.However, the use of these resources is minor.Therefore, GPUN has concluded that the impact of decommissioning TMI-2 onirreversible and irretrievable commitment of resources is bounded by the GELS.
Attachment TMI-13-041 Page 24 of 25Additional Considerations While not quantitative, the following considerations are also relevant toconcluding that decommissioning activities will not result in significant environmental impacts not previously reviewed.
Significant cleanup of the TMI-2 facility has already been completed withapproximately 99% of the fuel removed and shipped to INEEL.Decontamination has been completed to the extent that further majordecontamination programs are not justified on the basis of worker dose.Prior to decommissioning, TMI-2 will be maintained in accordance with the NRCapproved PDMS mode governed by the associated PDMS Technical Specifications, PDMS Quality Assurance
: Program, and PDMS Final SafetyAnalysis Report. As such, TMI-2 will be maintained in a condition of stability andsafety such that there is minimal risk to public health and safety.Radiation protection techniques used at the time of decommissioning areexpected to improve over current practices and should ensure reduction inoccupational exposure.
Site access control processes during decommissioning are expected to reducethe risk of public contamination due to trespassing.
Conclusion Based on the above discussion, the potential environmental impacts associated with decommissioning TMI-2 have already been postulated in and will bebounded by the previously issued environmental impact statements, specifically the PEIS, and the GElS and its supplement.
This is principally due to thefollowing reasons:* The postulated impacts associated with the decommissioning methodchosen have already been considered in the PEIS and the GELS,including its supplement.
* There are no unique aspects of TMI-2 or of the decommissioning techniques to be utilized that would invalidate the conclusions reachedin the PEIS, and the GElS and its supplement.
Attachment TM1-1 3-041Page 25 of 25VII. REFERENCES
: 1. Pace, D. L. (GPU Nuclear) to NRC letter, "Notification of Intent to Submit aPost-Shutdown Decommissioning Activities Report,"
dated August 14, 20122. Camper, L. W. (NRC) to Pace, D. L. (GPU Nuclear) letter, "Three Mile IslandNuclear Station, Unit 2 (TMI-2) -Failure to Submit Post-Shutdown Decommissioning Activities Report -Non-cited Violation (Docket:
05000320),"
dated February 13, 20133. Masnik, M. T. (NRC) to Long, R. L. (GPU Nuclear) letter, "Issuance ofAmendment No. 45 for Facility Operating License No. DPR-73 to Possession Only License for Three Mile Island Nuclear Station Unit 2 (TAC No.ML69115),"
dated September 14, 19934. NUREG-0683, Supplement 3, "Programmatic Environmental ImpactStatement Related to Decontamination and Disposal of Radioactive WastesResulting from March 28, 1979 Accident Three Mile Island Nuclear Station,Unit 2," Supplement 3, dated August 19895. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile IslandUnit 2," dated September 20046. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile IslandUnit 2," dated January 20097. Robinson, J. E. (NRC) to Gallagher, M. P. (Exelon Generation Company,LLC) letter, "Issuance of Renewed Facility Operating License No. DPR-50 forthe Three Mile Island Nuclear Station, Unit 1," dated October 22, 20098. NUREG-0586, "Generic Environmental Impact Statements onDecommissioning and Radiological Criteria for License Termination,"
datedAugust 1988, and Supplement 1, Volumes 1 and 2, November 2002}}

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