ML23187A033

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TMI Unit 2, PSDAR Rev. 5 RAIs
ML23187A033
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 06/29/2023
From: Amy Snyder
Reactor Decommissioning Branch
To:
References
EPID L-2022-DPR-0002
Download: ML23187A033 (2)


Text

Request for Additional Information Related to Three Mile Island Station, Unit 2, Post-Shutdown Decommissioning Activities Report to Possession-Only License No. DPR-73 TMI-2 Solutions, LLC Three Mile Island Nuclear Station, Unit 2 Docket No. 50-320 TMI-2Solutions, LLC (TMI-2S) submitted the Post-Shutdown Decommissioning Activities Report (PSDAR), Revision 5 (ML22306A051) for Three Mile Island Nuclear Power Station, Unit 2 (TMI-2), to the U.S. Nuclear Regulatory Commission (NRC) on October 27, 2022. In this document, TMI-2 Solutions describes major decommissioning activities as occurring in Phase 1b and Phase 2, including demolishing plant structures to nominally three feet below grade (PSDAR Section 3.2). The PSDAR indicates that Phase 2 is expected to be completed in 2037, the year in which license termination is scheduled to occur.

Requirement:

Paragraph 50.82(a)(4)(i) of Title 10 of the Code of Federal Regulations (10 CFR) states that a PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment, a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements, and a site specific DCE, including the projected cost of managing irradiated fuel.

In the TMI-2, Decommissioning Fund Status Report (ML23094A116) submitted on March 30, 2023, TMI-2S states:

Due to market conditions as of December 31, 2022, the TMI-2 Funding Analysis (Table II) shows a forecasted delay between Source Term Reduction and Demolition from 2029 to 2045 as a financial mitigation measure for the Nuclear Decommissioning Trust Fund (NDTF).

Thus, based on the March 30, 2023, report, significant portions of TMI-2Ss decommissioning plans, as presented in the PSDAR, appear to be out of date and are in need of revision.

In order to determine if the decommissioning schedule, environmental impacts associated with the site-specific decommissioning activities are bounded, and the site specific DCE is reflective of the change of schedule, the NRC staff is requesting additional information:

RAI-1

Is the description of planned decommissioning activities and the associated schedule accurate given that TMI-2S plans to delay building demolition until 2045. Please provide your plans to update the PSDAR to reflect any change decommissioning method, decommissioning activities, and the schedule. This should also include when TMI-2S plans to move from DECON to SAFSTOR, as the Decommissioning Fund Status Report states there will be a gap between 2029 1

and 2045 before building demolition.

RAI-2

Before NRC staff will evaluate the site specific TMI-2 DCE, please provide an updated site-specific DCE that reflects your change in decommissioning strategy after 2029 and any other changes. Once submitted, the NRC staff will evaluate it for acceptability.

Environmental RAI

RAI-3

PSDAR Section 6.1.14 Cultural, Historic, and Archeological Resources does not reflect the latest information submitted in the January 20, 2023 RAI responses (ML23121A249) and the February 22, 2023 LAR (ML23058A064), that was submitted for review major decommissioning activities, as defined in 10 CFR 50.2, that would diminish the historic integrity (e.g., physical demolition) of the TMI-2 Solutions owned buildings previously deemed eligible for the National Register of Historic Places. Please confirm that this information remains accurate and your plans to update the PSDAR due to the change in major decommissioning activities.

2