ML24220A274

Request for Additional Information Clarification Call Regarding Three Mile Island Station, Unit 2, Amended Post-Shutdown Decommissioning Activities Report, Rev. 6

ML24220A274
Person / Time
Site:	Three Mile Island
Issue date:	08/15/2024
From:	William Allen Reactor Decommissioning Branch
To:	Richardson J TMI-2 Solutions
References
EPID L-2022-DPS-0002
Download: ML24220A274 (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 CLARIFICATION CALL REGARDING THREE MILE ISLAND STATION, UNIT 2, AMENDED POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT, REV. 6 (EPID NO.

L-2022-DPS-0002)

Dear Jeff Richardson:

The U.S. Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24157A367) to TMI-2 Solutions, LLC (TMI-2 Solutions or the licensee) on June 13, 2024, on its amended Post-Shutdown Decommissioning Activities Report (PSDAR), Revision 6, for Three Mile Island Station, Unit 2 ( ML24088A012). The licensee requested a clarification call on RAI items a, e, f and n. The licensee and the NRC held a clarification call on July 17, 2024, for that purpose. A summary of the topics of interest discussed, in the order of discussion, is provided below. The list of clarification call participants is provided in the Enclosure.

RAI n: Consultation Under Section 106 of the National Historic Preservation Act The licensee asked a general question about the necessity to update its PSDAR. The NRC explained that the NRC asked in the RAI that the PSDAR be updated to reflect the current status of the consultation under Section 106 of the National Historic Preservation Act. Given that a Programmatic Agreement (PA) which resulted from the consultation was recently completed and issued ( ML24117A258), the NRC clarified that it should be reflected in the PSDAR. The licensee then asked whether the NRC expects TMI-2 Solutions to update the PSDAR in other areas to reflect changes since March 2024. The NRC staff responded that TMI-2 Solutions should update any other information in the PSDAR that is no longer current as NRC reviews Rev. 6 of the PSDAR. Thereafter, TMI-2 Solutions should update the PSDAR in accordance with Section 50.82(a)(7) of Title 10 of the Code of Federal Regulations (10 CFR).

TMI-2 Solutions asked the NRC to clarify what it means by updating the cost estimate, as necessary, due to the PA. The NRC stated that, if the PA causes TMI-2 Solutions to implement any actions that will result in use of the decommissioning trust fund, it should identify those actions in the PSDAR, either by summary or reference, and appropriately update the annual cost estimates to reflect the expenditures.August 15, 2024 J. Richardson 2

RAI a: Decommissioning Completion, Final Status Survey Timing and Partial Site Release

The licensee asked how it could provide assurance that License Termination can be achieved without specific information on when the Department of Energy would take possession of the Fuel Bearing Material allowing decommissioning of its generally licensed Independent Spent Fuel Storage Installation. The NRC staff acknowledged this uncertainty, but emphasized the need to provide a schedule that meets the regulatory requirement to terminate the license within 60 years. The NRC noted that some licensees state the dates, per their contract with DOE, when DOE agreed to begin taking their spent fuel or note the current published DOE general schedule for removal of spent fuel from commercial power plants for either permanent or temporary disposal. The NRC also said that some licensees note that DOEs current strategy is to take the oldest fuel first, and then compare the current DOE schedule to their 60-year decommissioning dates. Alternatively, the licensee could state whether it would plan to request an exemption from the 60-year decommissioning requirement.

Regarding when TMI-2 Solutions plans to conduct final status survey, TMI-2 asked the NRC what level of detail it is expecting in the PSDAR. The NRC stated that the PSDAR should identify the final status survey strategy for the impacted media (buildings, piping, soil, etc.) and impacted areas as well as when the final status survey is performed relative to the overall schedule. The NRC identified a schedule Gannt Chart as one method of providing this information. TMI-2 stated that it understands that restoration cannot occur before final status survey in impacted areas. TMI-2 Solutions stated it would clearly identify in the RAI response whether an area was impacted and when it plans to conduct final status surveys. For example, TMI-2 Solutions stated that, because the cooling towers and immediate surrounding areas are not radiologically impacted, there is no need for a final status survey in that area; however, the PSDAR would show on its Gannt Chart that restoration of this area will occur before final status surveys for impacted areas. NRC clarified that any Three Mile Island, Unit 1 areas leased to TMI-2 for conducting decommissioning, if impacted, would need to have a final status survey.

NRC stated that TMI-2 should identify whether it plans on conducting such surveys on leased areas.

TMI-2 Solutions stated that a partial site release would occur at the end of decommissioning.

The NRC stated that the TMI-2 generally licensed ISFSI would also have to be decommissioned within the 60-year decommissioning requirement and should be noted in the PSDAR. The NRC clarified that any partial site release and its timing should be identified in the PSDAR. This could be done in a Schedule Gannt chart or some other means.

RAI e: Decommissioning Phases Identified in Project Schedule and Project Cost

The licensee clarified to the NRC that there was no intention to have the activities in Table 5-1, TMI-2 Decommissioning Project Schedule directly correlate to the costs in Table 5-2, Three Mile Island Unit 2, Decommissioning Cost Summary, in the TMI-2 PSDAR. The NRC staff appreciated this insight and explained that it was important to know which costs were associated with each specific phase of the project from an inspection perspective and for public transparency. TMI-2 Solutions stated that it plans on clarifying the relationship between these tables in its RAI response by explaining that the phases identified in each table are not related, why the phases in each table are not related, and how each table is intended to be used.

J. Richardson 3 RAI f: Strategy for the Decommissioning of Fuel Bearing Material The licensee inquired about the level of detail the NRC wanted on the topic of Fuel Bearing Material removal and disposition. Specifically, the licensee asked if the NRC desired a level of specificity in the PSDAR more than that outlined in RG 1.185 " Standard Format and Content for Post-Shutdown Decommissioning Activities Report," or if the NRC believed that the remaining one percent of fuel material left was confined to the basement? The NRC stated the importance of knowing the general strategy and timing for the removal of the TMI-2 Fuel Bearing Material.

The NRC explained that TMI-2 should identify where the TMI-2 Fuel Bearing Material is generally located, whether all of it will be removed robotically, and when TMI-2 Solutions considers its removal complete. If some of the TMI-2 Fuel Bearing Material will not be removed robotically, TMI-2 should briefly explain the removal and ALARA strategies for such work.

The licensee said that they would strive to provide the responses within the 45 days specified in the RAI letter. However, the licensee also indicated that more time may be necessary.

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. 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:

Clarification Call Participants cc: TMI-2 Listserv Signed by Allen, William on 08/15/24

CLARIFICATION CALL PARTICIPANTS

TMI2 SOLUTIONS Joe Lynch Lee Hudson Don Allison

NUCLEAR REGULATORY COMMISSION Chris Allen Amy Snyder Nicole Warnek

Enclosure

Ltr ML24220A274 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB R-I/EAGLT NMSS/DUWP/RDB NAME WAllen WA ASnyder AS NWarnek NW WAllen WA DATE Aug 13, 2024 Aug 14, 2024 Aug 15, 2024 Aug 15, 2024