ML13266A285

Request for Additional Information on Three Mile Island Nuclear Station Unit 2 - post-shutdown Decommissioning Activities Report

ML13266A285
Person / Time
Site:	Three Mile Island
Issue date:	10/21/2013
From:	Buckley J NRC/FSME/DWMEP/DURLD
To:	Hardin P AmerGen Energy Co
References
Download: ML13266A285 (6)

Text

October 21, 2013 Paul A. Hardin, President Three Mile Island Nuclear Station Route 441 South Post Office Box 480 Middletown, PA 17057-0480

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THREE MILE ISLAND NUCLEAR STATION UNIT 2 - POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT, LICENSE: DPR-73, DOCKET: 50-320

Dear Mr. Hardin:

On June 28, 2013, GPU Nuclear, Inc. (GPU) submitted to the U.S. Nuclear Regulatory Commission (NRC) the Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island Nuclear Station, Unit 2, (TMI-2) (ADAMS Accession No. ML13190A366) pursuant to 10 CFR 50.82(a)(4). The NRC has completed its review of the PSDAR in accordance with Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, and concludes the following:

1.Section III of the PSDAR, Description of Decommissioning Activities, provides the applicable information identified in Section C(1) of Regulatory Guide 1.185. In addition, the staff finds that the PSDAR adequately describes the activities that will occur from the time the facility transitions from its current NRC approved Post-Defueling Monitored Storage (PDMS) state through final decommissioning of the facility.

2.Section IV of the PSDAR, Schedule of Decommissioning Activities, provides the estimated dates for initiation and completion of major decommissioning activities, as described in Section C(2) of Regulatory Guide 1.185. The PSDAR informs NRC that TMI-2 decommissioning activities will be conducted concurrently with Three Mile Island Nuclear Station, Unit 1. The schedule for TMI-2 decommissioning activities is adequate to achieve TMI-2 license termination within 60 years of permanent cessation of operations as required by 10 CFR 50.82(a)(3).

3.Section V of the PSDAR, Estimated Costs of Decommissioning Activities, provides an estimate of the expected decommissioning costs for TMI-2. However, the cost estimate does not appear to be based on the latest annual update to the decommissioning cost estimate as indicated in Section C(3) of Regulatory Guide 1.185. The PSDAR provides an estimated total decommissioning cost of $844,885,000 (based on 2008 dollars). On March 29, 2013, GPU Nuclear submitted the Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2 (ADAMS No. ML13088A143). This report states that the decommissioning costs are estimated to be $943,927,246, in 2012 dollars.

P. Hardin 2 This cost estimate is based upon the site specific decommissioning cost study, Decommissioning Cost Analysis for Three Mile Island Unit 2, dated January 2009.

The NRC staff is currently reviewing the March 29, 2013, Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2, for adequacy. Therefore,Section V of the PSDAR should be updated to reflect this most recent decommissioning cost estimate.

4.Section VI of the PSDAR, Environmental Impacts of Decommissioning Activities, provides a discussion of the potential environmental impacts associated with TMI-2 decommissioning activities as directed by Section C(4) of Regulatory Guide 1.185. The PSDAR includes a comparison of potential environmental impacts from planned decommissioning activities with impacts from similar activities provided in NUREG-0683, Supplement 3, Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2, (PEIS) and NUREG-0586, Generic Environmental impact Statement on Decommissioning of Nuclear Power Facilities, dated August 1988 and Supplement 1, dated November 2002 (GEIS).

The PEIS evaluated the environmental impacts associated with the activities necessary for decontamination, defueling, and waste disposition at the TMI-2 facility following the 1979 accident. The available alternatives evaluated in the PEIS ranged from no activity to full cleanup of the facility. The GEIS, and supplement, evaluated the environmental impacts of decommissioning activities at nuclear power reactors necessary to reduce residual radioactivity to levels that allow for termination of NRC licenses.

Since the decommissioning activities planned for the TMI-2 facility are similar to the activities conducted to bring the TMI-2 facility to its current PDMS state following the accident, and similar to routine nuclear power facility decommissioning activities, the staff agrees with GPU Nuclears conclusion that the potential environmental impacts associated with TMI-2 decommissioning activities are bounded by the previously issued PEIS and GEIS and its supplement.

With the exception of the outdated decommissioning cost estimate discussed in Conclusion 3 above, the staff finds that the PSDAR is acceptable. Within 30 days of the date of this letter, GPU Nuclear should provide an updated decommissioning cost estimate which reflects the most recent annual update.

In accordance with 10 CFR 50.82(a)(7), GPU Nuclear must notify the NRC in writing before performing any significant decommissioning activity inconsistent with, or making a significant schedule change from, the planned decommissioning activities or schedules described in the PSDAR, including changes that significantly increase the decommissioning costs.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders, 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 NRCs Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

P. Hardin 3 If you have any questions regarding this letter, please contact John Buckley, at (301) 415-6607, or by e-mail at John.Buckley@nrc.gov Sincerely,

/RA/

John T. Buckley, Senior Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket No.: 50-320 License No.: DPR-73 cc: TMI-2 Distribution List

P. Hardin 3 If you have any questions regarding this letter, please contact John Buckley, at (301) 415-6607, or by e-mail at John.Buckley@nrc.gov.

Sincerely,

/RA/

John T. Buckley, Senior Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket No.: 50-320 License No.: DPR-73 cc: TMI-2 Distribution List DISTRIBUTION: DWMEP r/f CRegan SHarwell LKauffman ML13266A285 OFFICE: DWMEP DWMEP DWMEP OGC DWMEP NAME: JBuckley CHolston BWatson HBenowitz JBuckley DATE: 9/30/2013 10/01/2013 10/02/2013 10/21/2013 10/21/2013 OFFICIAL RECORD COPY

Three Mile Island - Unit 2 Service List cc:

Mr. James H. Lash Chairperson Chief Nuclear Officer, GPU Nuclear Inc. Dauphin County Board of Commissioners FirstEnergy Corporation Dauphin County Courthouse 76 South Main Street Front and Market Streets Akron, OH 44308 Harrisburg, PA 17120 Mr. Danny L. Pace Director President, GPU Nuclear Inc. Bureau of Radiation Protection FirstEnergy Corporation Department of Environmental Protection Mail Stop: A-WAC-A3 13th Floor, Rachel Carson State Office Bldg. P.

341 White Pond Drive O. Box 8469 Akron, OH 44320 Harrisburg, PA 17105-8469 Mr. Greg Halnon Mr. Rick W. Libra Director, Regulatory Affairs Site Vice President, TMI-1 FirstEnergy Corporation Exelon Generation Company LLC Mail Stop: A-WAC-A3 P.O. Box 480 341 White Pond Drive Middletown, PA 17057 Akron, OH 44320 Mr. Eric Epstein Mr. Ad Crable EFMR Monitoring Group Lancaster New Era 4100 Hillsdale Road 8 West King Street Harrisburg, PA 17112 Lancaster, PA 17601 Mr. Kevin L. Ostrowski Mr. Jerome Boyd Vice President GPU Nuclear Fleet Oversight PDMS Supervisor Mail Stop: A-WAC-A3 Exelon Generation Company LLC 341 White Pond Drive P.O. Box 480 Akron, OH Middletown, PA 17057 U.S. Environmental Protection Agency Mr. Michael J. Casey Region III Office GPU Nuclear Responsible Engineer TMI-2 ATTN: Mr. B. Hoffman FirstEnergy Nuclear Operating Company EIS Coordinator Mail Stop: A-WAC-A3 3ES30 341 White Pond Drive 1650 Arch Street Akron, OH 44320 Philadelphia, PA 17103 Mr. Walter W. Cohen, Consumer Advocate Dr. Judith H. Johnsrud Department of Justice Environmental Coalition on Nuclear Power Strawberry Square, 14th Floor 433 Orlando Avenue Harrisburg, PA 17127 State College, PA 16803-3477

Mr. Scott Fuhrman Mr. Dave Atherholt Manager PDMS Site Regulatory Assurance Manager, TMI-1 Exelon Generation Company LLC Exelon Generation Company LLC P.O. Box 480 P. O. Box 480 Middletown, PA 17057 Middletown, PA 17057 Senior Resident Inspector (TMI-1) 44320 The Patriot U.S. Nuclear Regulatory Commission 812 Market Street P.O. Box 311 Harrisburg, PA 17105 Middletown, PA 17057 Mr. David W. Jenkins, Esq.

First Energy Legal Department 76 South Main St.

Akron, OH 44308