ML24240A222

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Response to Request for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 6
ML24240A222
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 08/27/2024
From: Jeffery Lynch
TMI-2 Solutions
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
TMI2-RA-COR-2024-0014
Download: ML24240A222 (1)
v • d • e


Text

TMI-2 SOLUTIONS ~

August 27, 2024 TMI2-RA-COR-2024-0014 10 CFR50.82 U.S. Nuclear Regulatory Commission ATTN; Document Control Desk Washington, DC 20555-0001

Three Mile Island, Unit 2 NRC Possession Only License No. DPR-73 NRC Docket No. 50-320

Subject:

Response to Request for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 6

References:

1) Letter TMI2-RA-COR-2022-0022 from Lackey, M.B. (EnergySolutions) to U.S. NRC (Document Control Desk), "Notification of' Amended Post-Shutdown Decommissioning Activities Report' (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7),' Revision 5," dated October 27, 2022 (ML22306A051)
2) Letter TMI2-RA-COR-2021-0002 from van Noordennen, G.P. (EnergySolutions) to Document Control Desk (U.S. NRC), "License Amendment Request-Three Mile Island, Unit 2, Decommissioning Technical Specifications," dated February 19, 2021 (ML21057A046)
3) E-Mail from Snyder, A. (U.S. NRC) to Devik, T. (TMI-2 Solutions), "Three Mile Island Nuclear Station, Unit No. 2 - Request for Additional Information Related to the Amended Post-Shutdown Decommissioning Activities Report (EPID No. L-2022-DPS-0002), dated June 29, 2023 (E-Mail: ML23187A020; RAI

Enclosure:

ML23187A033)

4) Letter TMI2-RA-COR-2023-0014 from Devik, T. (TMl-2 Solutions) to Document Control Desk (U.S. NRC), "Response to Requests for Additional Information for the TMI-2 Post Shutdown Decommissioning Activities Report, Rev. 5, dated August 8, 2023 (ML23221A140)
5) Letter TMI2-RA-COR-2023-0022 from Lynch, J. R. (EnergySolutions) to Document Control Desk (U.S. NRC), "Response to Request for Additional Information for the TMI-2 Post Shutdown Decommissioning Activities Report, Rev. 5," dated December 20, 2023 (ML23354A211 )

TMI2-RA-COR-2024-0014 Page 2 of 3

6) Letter TMI2-RA-COR-2024-0004 from Lynch, J. R. (EnergySolutions) to Document Control Desk (U.S. NRC), "Response to Request for Additional Information for the TMI-2 Post Shutdown Decommissioning Activities Report, Rev 5," dated March 14, 2024 (ML24074A392 )
7) Letter TM12-RA-COR-2023-0003 from Hazelhoff, A. (EnergySolutions) to Document Control Desk (U.S. NRC), "License Amendment Request-Three Mile Island, Unit 2, Historic and Cultural Resources Review," dated February 22, 2023 (ML23058A064 )
8) Letter TMI2-RA-COR-2024-0005 from Lynch, J. R. (EnergySolutions) to Document Control Desk (U.S. NRC), "Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7), Rev 6," dated March 28, 2024 (ML24088A012 )
9) Letter from Snyder, Amy M., (U.S. NRC) to Sauger, John T. (EnergySolutions), "Three Mile Island Nuclear Station, Unit 2-Issuance of Amendment No. 67 (EPID: L-2021-LLA-0038),"

dated March 31, 2023 (ML23051A045), and Amendment No. 67 to Possession Only License No. DPR-73, dated March 31, 2023 (ML23051A043)

10) Letter from Allen, W.C, (U.S. NRC) to Richardson, J (EnergySolutions), "Request for Additional Information Regarding Three Mile Island Station, Unit 2, Amended Post Shutdown Decommissioning Activities Report, Rev 6 (EPID No. L-2022-DPS-0002)" dated June 13, 2024 (ML24157A367 )

1 l)Letter from Van Noordennen, G. to Document Control Desk (U.S. NRC), "TMI-2 Solutions Plan for Management of Debris Material", dated March 15, 2021 (ML21085A692 )

In Reference 1, TMI-2 Solutions submitted Revision 5 to the TMI-2 PSDAR to incorporate information from the DECON License Amendment Request (LAR) (Reference 2) and its supplements, revised descriptions of decommissioning plans, and updates to the licensee evaluation of potential environmental impacts regarding Historic, Cultural, and Archaeological Resources (PSDAR Section 6. 1.14). In Reference 3, the NRC issued a Request for Additional Information (RAI) to support its review of the PSDAR, Revision 5. TMI-2 Solutions provided responses in References 4, 5 and 6, including information from the February 2023 License Amendment Request for Historic and Cultural Resource Reviews (Reference 7).

On March 28, 2024, TMI-2 Solutions submitted Revision 6 of the TMI-2 PSDAR (Reference 8). The amended PSDAR, Revision 6 includes TMI-2 Solutions decommissioning plans and pertinent information described in TMI-2 License Amendment No. 67 (Reference 9) which updated the Technical Specifications and allowed the site to transition to active decommissioning. It also includes pertinent information in the February 22, 2023, LAR (Reference 7), as supplemented, to address potential historic, cultural, and archaeological impacts from active decommissioning. Revision 6 of the PSDAR represents a revision that incorporates all changes since Revision 3 of the PSDAR.

On June 13, 2024, the NRC issued a request for additional information (Reference 10). Attachment 1 provides the responses to the questions.

The list of Regulatory Commitments included in Reference 8 is superseded by the revised list of Regulatory Commitments included in this response (Attachment 4). The commitment regarding the LTP groundwater monitoring plan is canceled.

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ATTACHMENT 1

Response to Request for Additional Information

14 Pages Follow Attachment 1 TMI2-RA-COR-2024-0014

RAI-a:

PSDAR Table 5-1, "Three Mile Island Unit 2 Decommissioning Project Schedule" identifies Phase 2 of decommissioning as "Decommissioning and License Termination." The Phase 2 schedule only provides a schedule for decommissioning activities through the completion of Phase 2 Field Work. The paragraph immediately following the table discusses Phase 3 activities; i.e., fuel bearing material management. The schedule in the PSDAR should identify all decommissioning activities through complete termination of the license which includes the independent spent fuel storage installation (ISFSI) for fuel bearing material. Further, when describing Phase 3, TMI-2 Solutions refers to the "Plan for Management of Debris Material (Ref 34)". The NRC staff reviewed this reference and it appears that TMI-2 Solutions plans to complete decommissioning of the TMI-2 general licensed ISFSI after the regulatory required period (within 60 years). In addition, it is unclear from the text of the PSDAR and Table 5-1 whether TMI-2 Solutions is planning to conduct final status surveys in land areas or on any subsurface structures (underground piping, footers, etc.) it may be planning to leave in place at license termination.

Request: Please identify the activities or areas (impacted vs. non-impacted) and type of media (soil, buildings, sediment, metal, etc.) where TMI-2 Solutions is planning to conduct site restoration before final status survey and why it is technically feasible.

The NRC staff also requests that TMI-2 Solutions directly state the schedule in this section (Table or paragraph) for activities associated with storing.fuel bearing material, decommissioning the ISFSI, and termination of the license consistent with the within 60-year decommissioning requirement.

In addition, NRC staff requests that TMI-2 Solutions clarify the general scope of the.final status surveys (buildings, subsurface structures, land areas, etc.), as applicable.

TMI-2 Solutions' Response:

The term "Site Restoration" is sometimes associated with.final site restoration or evenfinal grading. However, within the TMI-2 PSDAR, the term was also used to describe clean building demolition as it relates to the work breakdown structure of planned decommissioning activities.

TMI-2 Solutions acknowledges that this was confusing in the context of accepted decommissioning terminology.

Table 5-1, "Three Mile Island Unit 2 Decommissioning Project Schedule," has been revised to include specific details associated with Phase 3, including activities associated with storing fuel bearing material (FBM), decommissioning the ISFSI, and termination of the license. The table is re-labeled as "Table 4-1" (see below) to match the section it is included in PSDAR R6. It is TMI-2 Solutions' intention to reduce the footprint of the Part 50 license to the areas limited to the interim waste storage facility (if used, see answer to RAI-m) and the TMI-2 ISFSI following the completion of Phase 2.

As described in Section 3.2.1 of the PSDAR, a License Termination Plan (LTP) will be developed near the start of Phase 2 activities. The L TP will provide the final radiological survey plan and methods that will be used to demonstrate compliance with the requirements of 10 CFR 20, Subpart E. Although the end state (final physical configuration) ofTMI-2 has yet to be finalized, all soil, subgrade basements (including all penetrations and embedded piping), above ground buildings, and buried piping, will be listed in the L TP and undergo a final status survey

Page 1 of 14 Attachment 1 TMI2-RA-COR-2024-0014

(FSS) prior to license termination (reducing the license to the ISFSI boundary). In general, buildings will be subjected to the removal of all interior structures, systems, and components (SSCs) and then demolished to three feet below ground elevation. An FSS will be performed on the basement structures and/or subsurface soils, typically followed by verification surveys conducted by an independent third-party at the behest of the NRC. The FSS will typically consist of scan surveys and static measurements using hand-held instrumentation or an in-situ object counting system (ISOCS). Once the FSS is successfully completed, the basements or excavations will be backfilled using appropriate fill material. After hydrolasing, specialized NaI or CsI detectors will be used to survey the interior of embedded piping. Above-ground structures and buried piping will undergo scan and static measurements using hand-held instrumentation or pipe crawlers, as appropriate. Land areas will undergo gamma scanning followed by soil samples that will be used as the compliance measurements.

Table 4-1 Three Mile Island Unit 2 Decommissioning Pro.iect Schedule Description Start End Approx.

Duration (years)

Phase 1 - Planning, Engineering, Source Term Reduction

  • License Transfer Approved 12/2020 12/2020 -
  • Contract Closing & Asset Transfer 12/2020 12/2020 -
  • DECON License Amendment Request 02/2021 03/2023 2 Approval
  • Begin Phase 1 b Infrastructure Upgrades 07/2022 12/2027 5.5 Decommissioning Electrical & Temporary 07/2022 10/2026 4.5 Power Um!:rades Large Components Removal 05/2023 12/2027 5 Field Waste Preparations 02/2023 07/2025 2
  • Liquid Radwaste & Water Processing Rad Building Interior/Systems D&D 05/2023 01/2029 6 Fuel Debris Material Program 05/2023 10/2028 5.5
  • ISFSI Design & Construction
  • Procure Debris Material Casks
  • Debris Material Transfer Operations Reactor Vessel (RV) 10/2023 01/2028 4
  • Reactor Isolation
  • RV Segmentation & Removal
  • RV Internals Segmentation & Removal

Phase lb Field Work Complete -

  • Finish Reactor Building Source Term & 03/2029 Debris Material Removal

Page 2 of 14 Attachment 1 TMI2-RA-COR-2024-0014

Phase 2 - DecommissioninJ & License Termination Phase 2 Planning & Transition Activities 2029 2031 3 License Termination Plan (L TP) 2030 2033 3

  • Prepare Application Request
  • NRC Review & Approval TMI-2 Rad Buildings Demo 2032 2035 3
  • Auxiliary/Fuel Handling Building
  • Reactor Building

Non-Radiological Building Demo 2032 2034 2.5

  • Clean Building Demo Final Status Surveys 2033 2037 5

Field Waste Operations 2035 2037 1.5

  • Class B/C Waste Loadout Phase 2 Field Work Complete 2037 -

Phase - 3 FBM Management Fuel Bearing Material (FBM) Storage Period 2029 2052 32 B/C Waste Storage and Disposition 2029 2053 33 DOE Disposition/Transfer of FBM 2050 2052 3 ISFSI Decommissioning 2052 1 License Termination 2053

  • Completed Phase 3 (FBM Management) will commence following loading of the final cask containing TMI-2 FBM onto the TMI-2 ISFSI and will continue in parallel with, and following, the completion of Phase 2 until final disposal.

Final Status Survey (FSS) activities will commence after NRC approval of the License Termination Plan (L TP). FSS activities will be conducted as systems, structures and other commodities are available and continue until completion of Phase 2 work in 2037.

TMI-2 Solutions developed a storage and disposal plan for any remaining FBM until title to the FBM is transferred to the DOE for disposal. The long-term management of FBM is addressed in the TMI-2 Solutions "Plan for Management of Debris Material" (Reference 11) which is being reviewed and revised to reflect our commitment to achieving License Termination within the 60 years as allowed by NRC regulation.

The period of Department of Energy (DOE) disposition and transfer of the FBM is an assumption and will be validated when more certainty can be provided by the DOE. In the event DOE is unable to meet these dates, TMI-2 Solutions will take regulatory action to extend the 60-year period for achieving License Termination consistent with the regulations in place at the time of the Licensing Action.

The costs associated with Phase 3 are included in the Decommissioning Cost Estimate presented in Table 5-2 of PSDAR, Rev 6.

Page 3 of 14 Attachment 1 TMI2-RA-COR-2024-0014

RAI-b:

Table 5-1 shows that TMI-2 Solutions is planning on performing site restoration before final status survey. For impacted areas, final status survey compliance demonstration must occur before site restoration of the area.

Request: Please identify the activities or areas (impacted vs. non-impacted) and type of media (soil, buildings, sediment, metal, etc.) where TMI-2 Solutions is planning to conduct site restoration before final status survey and explain why it is technically feasible.

TMI-2 Solutions' Response:

As previously stated in the response to RAI-a, the term "Site Restoration" is sometimes associated with final site restoration or even.final grading. However, within the TMI-2 PSDAR, the term was also used to describe clean building demolition as it relates to the work breakdown structure of planned decommissioning activities. TMI-2 Solutions acknowledges that this was confusing in the context of accepted decommissioning terminology. TMI-2 Solutions will not conduct final site restoration or grading activities prior to FSS. As a point of clarification, there are no SSCs within the TMI-2 footprint that are categorized as non-impacted (as defined in NUREG-1575).

Upon completion of remediation and demolition activities in Phase 2, a FSS will be performed on any land areas, above-ground or below-ground structures, or buried piping that are part of the TMI-2 end state prior to license termination.

RAI-c:

Table 5-1 shows that final status survey will begin in 2036 and be completed in 2037.

Request: Please identify whether this work will be completed before (and therefore at risk), or after the License Termination Plan (LTP) application request is submitted for approval. If after, please be mindful that a LTP license application request (LAR) review can take a year or more to complete and the schedule presented, as well as the cost estimate, may have to be modified TMI-2 Solutions' Response:

The TMI-2 Solutions License Termination Plan (L TP) application request will be developed and submitted for NRC review and approval in the early stages of Phase 2. TMI-2 Solutions is aware that the L TP license application request (LAR) review can take a year or more to complete. Final status surveys will be performed throughout Phase 2 as remediation and demolition progresses in each SSC or land area, and not just in 2036 and 2037 as shown in Table 5-1 of the PSDAR submittal. This will minimize the risk that comes from performing FSS without an approved LTP. The table has been revised to reflect these changes. The revised table (labeled Table 4-1) is included in the response to RAI-a above.

RAI-d:

PSDAR section 3.5 states that "[t]hroughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. In addition, Table 5-1 identifies a three-year planning and transition period between completion of Phase lb field work and building demolition that appears to start in Phase 2.

Page 4 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

Request: The NRC staff requests that TMI-2 Solutions explain its strategy to effectively reconstitute and train personnel needed to perform during active decommissioning after a three-year hiatus of active decommissioning. Explain the general change in the amount and intensity of active decommissioning during the three-year planning period from Phase 1 b and TMI-2 Solution's strategy to ensure that it will be ready to effectively implement essential programs (e.g., Radiation Protection) after the Phase 2 Planning and Transition stage is completed and during the building demolition.

TMI-2 Solutions' Response:

To add context to this request, consideration must be given to year-over-year Nuclear Decommissioning Trust Fund (NDTF) performance. Project schedule information associated with the PSDAR based on NDTF performance in 2022, showed a 17-year gap between decommissioning Phase 1B completion and the start of Phase 2. This same information, updated based on NDTF performance in 2023, reduced the gap between Phase 1B and the start of Phase 2 to 34 months. The expectation is that based on continued good performance of the NDTF coupled with prudent financial management of the NDTF, there will be no gap between the end of Phase 1B and start of Phase 2.

Recognizing that the PSDAR, Revision 6 submittal does show a 34-month gap between Phase 1B ending and the start of Phase 2, the following actions are planned:

  • If any appreciable gap ( one year or greater) exists between the end of Phase 1B and the start of Phase 2, there will be a reduction in force at the end of Phase 1B to minimize expenditures and only retain those key positions required to maintain safe and compliant oversight of TMI-2, as well as plan and develop work packages for Phase 2 preliminary work (first year of activity).
  • As with the transition from Phase lA to Phase 1B, the same strategy will be used to reconstitute an adequately trained work force to perform the scheduled Phase 2 activities. Approximately 3 months prior to initiating Phase 2 work, employees will be hired, trained/retrained, and mock-up activities associated with the scheduled Phase 2 activities will be completed. Positions hired will includes trades, radiation protection, engineering, training, supervision, and project management.
  • As described above, if a gap of one year or greater exists between Phase 1B ending and the start of Phase 2, no active decommissioning will occur during the gap period. Radiological programs will be maintained, despite the lack of active decommissioning. If the gap is less than a year, then decommissioning activities would continue but at a slower pace.

RAI-e:

Table 5-2, "Three Mile Island Unit 2, Decommissioning Cost Summary," identifies costs for decommissioning activities and identifies phases. The phases in Table 5-2, "Three Mile Island Unit 2 Decommissioning Cost Estimate," do not seem to relate to the phases in Table 5-1, thus making it difficult for staff, stakeholders, and the public to understand what is being done, when it is being done, and the associated cost.

Request: Please explain why the phases are different between Table 5-1 and Table 5-2. Reconcile the tables or provide a cross reference supplement table for ease of relationship of activities and cost.

Page 5 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

TMI-2 Solutions' Response:

Tables 5-1 and 5-2 in PSDAR, Rev 6, are intended to be high level descriptions of the schedule of decommissioning activities and a cost summary, respectively, and were not intended to be read together as an aligned pair. The schedule of decommissioning activities presented in Section 4 is a combination of activities and various work breakdown structures as a description of the types of activities that will be performed. Table 5-2 is a breakdown of costs for certain portions of the project which include the activities in Table 5-1 but are not categorized by the specific activities listed in Table 5-1. Please note that Table 5-1 has been updated and renamed Table 4-1 to coincide with the PSDAR Section it appears in.

The revised table is included in the response to RAI-a above.

RAI-f:

PSDAR Section, 3.1.2 "Phase lb: Fuel Bearing Material Recovery and Source Term Reduction" does not list fuel bearing material recovery and source term reduction activities that will be performed in Phase 1 b in a particular order.

Request: Given that the reactor building basement is currently only entered remotely through robotics, briefly explain the work sequence and strategy to accomplish fuel bearing material removal to ensure As Low As Reasonably Achievable (ALARA) and inform the NRC and the public the duration (start and end) of the removal of the 1% remaining.fuel bearing material.

TMI-2 Solutions' Response:

The answer to this RAI involves technologies that are in proof-testing and may or may not be used in the strategies to accomplish removal of all FBM. The removal of FBM is underway and is expected to continue until early 2029.

As a point of clarification, the reactor building basement does not contain all of the remaining FBM. The

~ 1 % (i.e., ~ 1097 kilograms) of remaining FBM is spread across ~60 discrete systems, components, or cubicles. Each discrete quantity of FBM is evaluated per the FBM Management Program to develop a work sequence that removes FBM from its in-situ location, package it and implement Special Nuclear Material (SNM) Material Control and Accountability controls as appropriate for its intended disposal path. The work sequences are evaluated per the ALARA program to implement appropriate controls, oversight, and the upcoming scheduled work (in the form of a 4-week look-ahead) is provided weekly to theNRC.

As an example, basement cementitious material has ~ 1.3 kilograms of fuel, or ~ 28 grams of SNM.

Bounding calculations have shown cementitious material does not meet long term dry storage (i.e., ISFSI) requirements and the quantity of SNM is anticipated to meet acceptance criteria for Low Level Radioactive Waste (LLRW) disposal facilities (as class C material). The Project will implement SNM tracking actions during basement work via the associated work package invoking the procedures for accountability and will take samples of the material for 10 CFR 61 characterization. Associated activities are in the Project schedules.

RAI-g:

PSDAR section 3.5 states that the Department of Energy has the ultimate authority and responsibility for disposal of fuel bearing material pursuant to Standard Contract DECR0l-83NE44477 and that debris material will remain on the ISFSI until it is transferred to the Department of Energy.

Page 6 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

Request: The NRC staff requests that TMI-2 Solutions provide a copy of Standard Contract DECROJ-83NE44477 or other documentation to confirm that the Department of Energy is ultimately responsible for disposal of the fuel bearing material.

TMI-2 Solutions' Response:

Addendum A to the Standard Contract (DECR01-83NE44477) for TMI-2 specifically states that"... any damaged core material, if any, remaining after the completion of Contract No. 12355 will be covered by the provisions of this Standard Contract... ".

A copy of Addendum A to the TMI-2 Standard Contract is provided in Attachment 2.

RAI-h:

The first paragraph of PSDAR section 3.3. 7 states:

"Constellation manages the groundwater (GW) protection program for the TMI site in consideration of the site monitoring agreement between Constellation and TMI-2 Solutions in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document" (Reference 37). This program is controlled by procedures and will continue during decommissioning, and TMI-2 Solutions will ensure the GW protection program is properly managed for the site."

However, the PSDAR does not identify how the groundwater protection program responsibilities are separated between Constellation Energy Generation, the Three Mile Island Station, Unit 1 (TMl-1) licensee, and TMI-2 Solutions.

TMI-2 states in Attachment 2, List of Regulatory Commitments, of the March 24, 2024, submittal:

"The Groundwater Protection Program will continue for TMI-2 in accordance with NEI (Nuclear Energy Institute) Technical Report 07-07 during decommissioning." and "Scheduled completion date: Until replaced by the LTP groundwater monitoring program."

Request: Explain how TMI-2 Solutions will ensure that the groundwater protection program is properly managed for the "site" if Constellation Energy Generation manages the groundwater protection program. Provide a summary of the responsibilities that TMI-2 Solutions agreed to meet under the Constellation Energy Generation groundwater program.

Also, clarify if the "site" refers to the TMI-2 Solutions owned property, the site boundary as defined in the TMI-2 license, or the Three Mile Island Station Island.

If water spray is used as a decommissioning radiation control measure before the LTP LAR is submitted and approved, explain how TMI-2 Solutions intends to manage the runoff so as not to adversely affect the groundwater.

Explain whether the Constellation Energy Generation groundwater or the TMI-2 LTP groundwater monitoring program identified in Attachment 2 of the submittal will provide the groundwater data required for dose calculations for license termination.

Page 7 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

TMI-2 Solutions' Response:

Because TMI-2 Solutions-owned property is within TMI-1 (Constellation) owned property, Constellation's groundwater (GW) protection program encompasses TMI-2. The same aquifers (and therefore wells) are monitored within the Constellation program. This program is controlled by Constellation procedures and will continue during decommissioning and through license termination.

TMI-2 Solutions is responsible for coordinating activities with Constellation to ensure the Constellation program accounts for any impact from the TMI-2 Decommissioning Project.

TMI-2 Solutions is in regular consultation with Constellation with regards to its GW program. For example, TMI-2 Solutions is working with Constellation on its updated 2024 Hydrogeological Investigation Report, which is used to assess the groundwater quality, observe present and future conditions/events that may adversely affect groundwater quality, and determine if new locations (and depths) need to be monitored and included in the groundwater protection program.

The TMI site refers to the TMI Station (including both TMI-1 and TMI-2 units).

TMI-2 Solutions will apply a spray or mist/fog to the areas to control dust. Because the equipment used creates such a fine mist, very little water is expected to contact or penetrate the soil beneath and adjacent to the demolition. No runoff from the misting/fogging activity is expected; however, to prevent runoff from precipitation from rain or snow, an erosion control plan will be used to contain the precipitation within the boundary of the demolition area. Additionally, an Open-Air Demolition technical support document will be developed to ensure that residual radioactivity within the structure being demolished (including any associated systems and components) are at levels that will not exceed the soil or groundwater release criteria.

The Constellation GW program is expected to be in place throughout the TMI-2 license termination.

A commitment was included in Reference 8 that stated, "The Groundwater Protection Program will continue for TMI-2 in accordance with NEI Technical Report 07-07 during decommissioning." The Commitment Scheduled Completion was "Until replaced by the L TP groundwater monitoring program." This commitment is canceled because the CEG Groundwater Protection Program for TMI-2 is performed in accordance with NEI Technical Report 07-07 and will continue throughout the TMI-2 decommissioning.

RAI-i:

The first bullet of PSDAR section 3.3.6, "Site Characterization" identifies that site characterization activities will be performed prior to and during the decommissioning process. However, it is not clear to the NRC staff, based on the rest of the information provided in this section, if this statement includes the open land areas and any remaining structures (such as piping, footers, or utilities) regarding characterization for license termination demonstration purposes. Licensees usually perform historical site assessments and scoping surveys in preparation for L TP planning. Although TMI-2 underwent initial decommissioning after the accident and the clean-up was documented, it is unclear whether the information and data covers areas besides the impacted buildings and whether the data are sufficient to use for LTP and unrestricted release compliance purposes given its age and pedigree (data quality).

Request: The NRC staff requests that TMl-2 Solutions identify its general characterization strategy to determine the radiological status of the site (any remaining subsurface structures and land areas) in preparation for the LTP LAR and throughout the NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (ML003761445) data life cycle.

Page 8 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

TMI-2 Solutions' Response:

Radiological characterization incorporates the results of investigations and surveys conducted to quantify the extent and nature of contamination at the TMI-2 licensed site. Radiological characterization data will be obtained throughout the entire data life cycle described in NUREG-1575 (MARSSIM) to meet three primary objectives:

  • Ensure that the Final Status Survey (FSS) provides the expected results.
  • Ensure that the radiological conditions and assumptions to be used in the L TP to derive site specific unrestricted release criteria for the TMI-2 decommissioning project are valid.
  • Support the evaluation of remediation alternatives and technologies.

The results of site surveys and analyses will continue to be used to identify areas of the site that require remediation, as well as to plan remediation technologies, develop waste classification and volumes, and estimate costs.

Initial characterization surveys are performed within the licensed site boundary on land, structures, and systems. The characterization surveys will focus on areas that will remain at the time of license termination (e.g., land, buried piping, building basements, etc.) to enable better planning for FSS and to verify initial classifications. The initial characterization survey will also be focused on SSCs that will be removed as part of the decommissioning process to better plan for the remediation, removal, and disposal options.

During the site characterization, the surveys of many inaccessible or not readily accessible subsurface soils and structural surfaces may be deferred. This is referred to as "continuing characterization."

Examples of these areas include soils under structures, concrete, or asphalt coverings; areas restricted by high dose rates; underlying concrete of the Containment, Spent Fuel Pool, and Transfer Canal; and interiors of embedded and/or buried pipe that may remain. Deferring characterization in these areas may be based on ALARA, safety, or accessibility. Areas that require continuing characterization will be listed in the L TP. As access is gained to these areas, additional characterization data will be collected, evaluated, and stored with previous radiological survey data. This data will supplement existing data to update both the types of radionuclides present and the variability in the radionuclide mix for both gamma emitting and hard-to-detect (HTD) radionuclides.

Characterization surveys will be designed and executed using the guidance provided in NUREG-1575 (MARSSIM) and NUREG-1757, Volume 2, "Consolidated Decommissioning Guidance -

Characterization, Survey, and Determination of Radiological Criteria."

RAI-i:

PSDAR sections 6.1.3, "Water Quality" and 6.1.5, "Aquatic Ecology" discuss stormwater runoff and its impact on the environment. In PSDAR section 6.1.9, "Radiological Accidents" TMI-2 Solutions notes that"... TMI-2 Solutions will use inorganic, thus non-combustible, media for processing water at TMI-2." Also, in Table 5-1, TMI-Solutions identifies "Field Waste Preparations" with a sub-bullet titled, "Liquid Radwaste & Water Processing."

Page 9 ofl4 Attachment 1 TMI2-RA-COR-2024-0014

Request: The NRC staff requests TMI-2 Solutions describe its wastewater processing strategy throughout decommissioning to include whether TMI-2 Solutions plans to collect and process stormwater and runoff from decommissioning activities. Clarify whether TMI-2 Solutions has or will have a wastewater processing system on site for decommissioning and if so, what water and waste it plans to send through it.

TMI-2 Solutions' Response:

The Water Management Strategy for the D&D Project has several elements. Water used on the Project (for Fuel Transfer Canal (FTC), Spent Fuel Pool (SFP) fill-up, decontamination, dust suppression, etc.)

will start as either demineralized water (DI) or processed water from activities. Water used in the reactor building (RB), auxiliary/fuel handling building (AFHB), Decommissioning Support Building (DSB)

(decontamination, dust suppression, etc.) outside of the FTC will be moved to SFP-A via existing building sumps. The water in the SFP-A will be processed using the EnergySolutions advanced liquid water processing system (ALPS).

Processed water may be re-used as needed by the project in place of DI water to manage the total volume of water being used for the Project. The ALPS will be located in the AFHB, near the SFPs and will be able to be aligned to the FTC or SFP-A for supply and return. There will be pre-filters to address particulates/ fines / solids via a back washable filter located in both the FTC and SFP-A. A solids pre filter will be used prior to processing by ALPS.

Spent water processing media will be managed as either Class A waste or treated and placed in long-term storage as FBM, depending on the contamination removed. If media contains FBM, it will be dewatered and treated with a vacuum thermal desorption method to destroy / liberate organics and made suitable for long-term storage in the ISFSI Dry Cask Storage System (DCSS). Treatment of media containing FBM will be in the fuel handling building (FHB) prior to loading into DCSS containers.

Water chemistry via collected samples will be used to monitor for corrosion, water clarity, radionuclide and biological growth. Verification sampling and trending will be conducted via the Off-Site Dose Calculation Manual (ODCM) processes.

Water ingress at TMl-2 has historically been collected in basement sumps. All radiological sump water (AFHB, RB, DSB) and Station Blackout (SBO) sump water will be moved to the SFP-A and processed with ALPS. In general, non-radiological sump water will be sampled, processed and used as decontamination water or moved to the SFP or FTC to maintain proper volumes as needed.

Total water volume will be managed to operating levels in the SFP and FTC. Reductions in waste levels and disposal of water will be via bulk evaporation.

Stormwater will be controlled/routed such that it will not encounter radiological material that would create a radiological release. Any radiological release that occurs outside the collection systems will be contained and removed via tanker trucks for disposal or dried with an absorbent (inorganic) media and removed via solids containers ( e.g., Intermodals, Sealands, Dump Trailers).

Page 10 of 14 Attachment 1 TMI2-RA-COR-2024-0014

RAI-k:

Previous decommissioning scenarios assumed that the license termination for TMI-1 and TMI-2 occurred concurrently (PSDAR Section 2, Background). These scenarios became invalid once TMI-2 Solutions took possession of the TMI-2 license in December 2020 and transitioned into DECON after NRC approval of license Amendment No. 67 in March 2023.

Request: Please explain TMI-2 Solutions' strategy for termination of the TMI-2 license given that the licensed boundaries currently include the TMI-1 site which recently permanently shut down and entered SAFSTOR. Please identify if TMI-2 Solutions intends to request a partial site release after Phase 2 is complete and what the remaining site will include (ISFSI only vs other). Jf the site corifiguration will be

/SFSI only, please identify when the /SFSI will be decommissioned. Update Table 5-1, as appropriate.

TMI-2 Solutions' Response:

TMI-2 property obtained during the License Transfer includes specific portions of the Three Mile Island property (See Exhibit L - TMI-2 Site from the Purchase and Sale Agreement showing TMI-2 property transferred attached to this submittal as Attachment 3). TMI-2 will work with the current owner of property located outside the TMI-2-owned property to develop a plan to coordinate the decommissioning and subsequent license termination actions to meet the 60-year limitation. This may include certain licensing actions including a License Amendment Request to better define the properties owned by TMI-2 Solutions and the potential for requesting a partial site release after completion of Phase 2 activities and scope. TMI-2 understands that the specifics of the coordination plan must be communicated to the NRC in accordance with 50.82(a)(7) once finalized.

For the ISFSI, TMI-2 will be using a storage location inside the TMI-1 ISFSI Security Zone for the long term storage ofFBM and associated Debris Material from the accident. This material will be transferred to the DOE under obligations of the DOE standard contract (see answer to RAI-g). The ISFSI will be decommissioned after the DOE receives the material. As the date of transfer to the DOE is not known, a specific timeline for decommissioning the ISFSI cannot be provided. An update to the NRC will be provided in accordance with 50.82(a)(7) as the DOE activities are finalized. TMI-2 assumes the DOE will accept the ISFSI material in enough time for TMI-2 to subsequently decommission the ISFSI and complete license termination prior to exceeding the 60-year regulatory limit.

RAI-1

TMI-2 Solutions states on page 25 that the cooling towers may be demolished using explosives.

Request: Please identify the radiological status of the cooling towers. Jfthe cooling towers are non impacted, then identify what funds will be used for planning, removal and waste management of these structures.

TMI-2 Solutions' Response:

The TMI-2 cooling towers have not yet had a full characterization performed. It is expected that they are non-impacted. Once the cooling towers are shown to be free of radiological contamination, future planning, removal, and waste management will be characterized as a Site Restoration expense and could only be paid from the Decommissioning Trust Fund after TMI-2 receives a Site Restoration Exemption.

The cooling towers are planned to be demolished during Phase 2.

Page 11 of 14 Attachment 1 TMI2-RA-COR-2024-0014

RAI-m:

PSDAR Section 3.3.4, "Radioactive Waste Management" states that "Class Band Class C LLRW will be stored in an onsite storage area until it can be transported and disposed of at the Waste Control Specialists (WCS) facility in Andrews, Texas, or other options available at that time."

Request: Please identify where this waste will be temporarily stored on site and any associated decommissioning planning related to building the storage area and its cost. Clarify whether the storage area discussed in PSDAR Section 3.3.4 for this type of waste is the proposed Interim Waste Storage Facility identified in PSDAR Section 3.3.1, "Decommissioning Preparation Activities."

Does TMI-2 Solutions anticipate any Greater than Class C waste resultingfrom decommissioning and if so, what is TMI-2 Solutions' strategy to address it? If Greater than Class C waste is anticipated, please update the decommissioning cost estimate, if necessary.

TMI-2 Solutions' Response:

Class Band Class C LLRW will be stored in On-Site Storage Containers (OSSCs) on the Turbine Building (TB) Operating Deck as stated in PSDAR Section 3.3.1 also referred to as the Interim Waste Storage Facility (IWSF). Forty ( 40) OSSCs have already been purchased, delivered, and placed on the TB Operating Deck. Waste stored in the IWSF will remain on the TB Operating Deck until such time this facility is no longer available for storage. At that time, the stored waste will be transferred for offsite disposal or relocated to a different onsite IWSF. The costs associated with any required relocation is addressed within contingencies factored into the Decommissioning Cost Estimate (DCE).

TMl-2 Solutions does not anticipate generating any Greater than Class C waste. Only Class A, B, and C waste are planned to be generated outside of the designated FBM material (DOE standard contract waste) earmarked for long-term storage on the ISFSI pad.

RAI-n:

The PSDAR states, on page 42 of 52, that the NRC planned to initiate a consultation under Section 106 of the National Historical Preservation Act.

Request: The NRC staff requests that the PSDAR be updated to identify that this consultation has occurred and update the cost estimate to account for any commitments that TMI-2 Solutions made that will require TMI-2 Solutions resources specific to radiological decommissioning.

TMI-2 Solutions' Response:

As discussed on a clarification call on 7/11/2024, the PSDAR Section 6.1.14 should be replaced by the following:

6.1.14 Cultural, Historic, and Archeological Resources In Section 4.3.14.2 of the GEIS, the NRC states that impacts to cultural, historical, or archaeological resources are considered detectable if an activity has a potential to have a discemable adverse effect on the resources. The impacts are destabilizing if the activity would degrade the resource to the point that it would be of significantly reduced value to the future generations, such as physically damaging structures or artifacts or destroying the physical context

Page 12 of 14 Attachment 1 TMI2-RA-COR-2024-0014

of the resource in its environment. The NRC also states that the nuclear facility itself could be potentially eligible for inclusion in the National Register of Historic Places (NRHP). In this case, appropriate mitigation would be developed in consultation with the State Historic Preservation Office (SHPO). Under the National Historic Preservation Act (NHP A), mitigation is determined through the Section 106 process, which seeks to accommodate historic preservation concerns with the needs of Federal undertakings through consultation among the agency official and other parties with an interest in the effects of the undertaking.

A Historic Resource Survey Form (HRSF) was completed by the Pennsylvania Historic and Museum Commission (PHMC) in 2010 which stated that the TMI-2 Historic District above ground resource (Key No. 156047) is eligible for the NRHP under Criterion A (properties significant for their association with event that have made a significant contribution to the broad patterns of history), and under Criterion Consideration G (properties that have achieved significance within the last 50 years), with a period of significance from March 28, 1979-April 4, 1979 (Reference 58). A map of the TMI-2 Historic District above-ground resource as well as a boundary survey map depicting TMI-2 Solutions-owned parcels were provided to the NRC in a letter dated January 20, 2023 (Reference 59). In a letter dated July 28, 2023 (Reference 60), the PA SHPO confirmed that the TMI-2 Historic District resource remains individually eligible for listing in the NRHP.

The removal, dismantlement, and disposal of contaminated systems, structures, and components, as well as the eventual and necessary physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal. However, given the exceptional historical significance of the TMI-2 facility, the eventual and necessary physical demolition of the TMI-2 Solutions-owned buildings previously deemed eligible for the NRHP is an adverse effect that requires mitigation to be developed in consultation with the PA SHPO and other consulting parties per 36 CFR 800. In accordance with the guidance set forth in the Decommissioning GEIS, TMI-2 Solutions submitted a LAR for NRC review of 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 NRHP (References 59

& 61 ). In a letter dated March 31, 2023 (Reference 62), the NRC stated that, in order for the NRC to conduct its review and to allow appropriate mitigation to be developed, the NRC would initiate consultation for this undertaking under Section 106 of the NHP A.

The Section 106 consultation resulted in development and approval of a Programmatic Agreement that was incorporated to the TMI-2 License as part of the LAR approval received August 9, 2024.

Based on the above, TMI-2 Solutions concludes that the potential environmental impacts regarding historical, cultural, and archaeological resources have been adequately reviewed and addressed by the NRC Environmental Impact Statement supporting the LAR approval.

Page 13 of 14 Attachment 1 TMI2-RA-COR-2024-0014

The final two paragraphs in the section have been added / revised to address the current situation of the Section 106 review of the project.

The costs associated with implementing the PA are not yet finalized as the timeframe for performing all actions to satisfy the PA activities cannot be known until the site is further decommissioned. The total costs of the PA activities are expected to be very minor, considering the full cost of decommissioning and are included in contingency funding of the Project. The specific activities regarding the donation of the TMI-2 Main Control Room (MCR) Panels and the Reactor Building Model are expected to be non radiological costs, anticipating the MCR Panels are not contaminated. The final plans, logistics, and timing will be determined in conjunction with the entity receiving the items at a later date. TMI-2 Solutions is in regular communications with the Pennsylvania State Historical Preservation Organization (SHPO) and the Pennsylvania State Historical Museum on meeting the intent of the PA.

Page 14 of 14 Attachment 2 TMI2-RA-COR-2024-0014

Attachment 2

Addendum A to the TMI-2 Standard DOE Contract

1 Page Follows APPENDIX A NUCLEAR Pa~~R REACTOR(S) OR OTHE~ FACILil._ S COVERED

Purchaser. ____.::,G:.:PU::_:.NU:.::.:::CL::EAR=~CO:::!RP:::..:::O~RA~T::.ll~O~N-------------

Contract * 'Number/Cate DE-CR01-83NE44477 I __ Jun-e...... 2""1..,,_19...,s.._J.._ ___ _

Reactor/Facility Nar.le THREE KILB ISLAND NUCLEAR STATION. UNIT 2

Location :

Street __ R_o_u_t_e_4_4l_So_u_th _______________ _

City __ M_i_d_dl_e_s_to_wn ________________ _

County/State __ D_a_u..;.ph_i_n ______ / __ P_en_ns ___ yl_v_an_ia ____ _

Zip Code 17057

Capacity (MWE) - Gross __ 9_3_0_MWE ____ _

Reactor Type :

BWR D

PWR @

Other (Identify) --------------~-----

Facility Description An electric generating station utilizing a Pressurized Water Reactor as the power source.

Date of Convnencement of Operation _______ _

(actual or estimated)

TMI-2 began commerciai operation on December 30, 1978. The initial core loading was severely damaged in the TMI-2 accident which occ urred on March 28, 1979. This damaged core material will not covered by the provisions of the Standard Contract referenced above, but will be covered by the provisions of DOE Contract No. DE-SC07-83ID12355. At pre s ent, a return to service date for TMI-2 has not been established, but an evaluation of this date will be made once the damaged fuel has been removed.

All nuclear fuel used in future generation at TMI-2 as well as any damage d core material, if any, remaining after the completion of Contract No. 12355 will be covered by the provisions of this Standard Contract. The fee for disposal of any such remaining damaged core material under the Standard Contract will be negotiated by GPU Nuclear and DOE in accordance with the requirements of the Nuclear Waste Policy Act.

  • NRC L 1 cens a I: ____ D_PR_-....;7..;;;3 ____ _

By Purchaser:

~\\':}_-~\\l\\'1.Mffiit Nuclear Fuel Resour ce s Manager J une 23, 1983 Attachment 3 TMI2-RA-COR-2024-0014

Attachment 3

Site Map

Asset Purchase and Sale Agreement - Exhibit L - TMI-2 Site

1 Page Follows

Attachment 4 TMI2-RA-COR-2024-0014

Attachment 4

Revised List of Regulatory Commitments for PSDAR R6

1 Page Follows Attachment 4 TMI2-RA-COR-2024-0014

LIST OF REGULATORY COMMITMENTS

The following list identifies those actions committed to by TMI-2 Solutions in this submittal and replaces the list of actions committed to by TMI-2 Solutions in Reference 8. Any other actions discussed in the submittal represent intended or planned actions by TMI-2 Solutions. They are described only as information and are not Regulatory Commitments.

TYPE REGULATORY ONE-TIME CONTINUING SCHEDULED COMMITMENT ACTION COMPLIANCE COMPLETION DATE As part of the site characterization X Prior to removal, process, a neutron activation segmentation, analysis calculation study of the packaging and reactor internals and the reactor disposal ofRV/RVI vessel will be performed.

TMI-2 Solutions will consult with X Prior to removal of appropriate state and federal the TMI-2 owned resource agencies during the and controlled planning process for removal of the buildings and TMI-2 owned and controlled structures buildings and structures to ensure that agency concerns are addressed.

TMI-2 Solutions will ensure processes are in place such that any potential impacts to terrestrial or aquatic species, as well as any threatened or endangered species observed on or near the TMI operational area, are avoided.

TMI-2 Solutions will develop an X Prior to structural Archaeological Resources Erosion demolition or ground Monitoring Plan which will provide disturbances outside protocols for ensuring continued the operational area stewardship of cultural resources on Three Mile Island.

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