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NUCLEAR

Mile Island
Three
GPU Nuclear,
Inc.
Nuclear Station
Route 441 South

Post Office Box 480
Middletown, PA 17057-0480
Tel 717-948-8461

June 28, 2013
TM1-1 3-041

10 CFR 50.51
10 CFR 50.82

Attn: Document Control Desk
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001

Subject:
Three Mile Island Nuclear Station, Unit 2
Docket No. 50-320, Possession Only License No. DPR-73
Post-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 submit
a post-shutdown decommissioning activities report (PSDAR) for Three Mile Island
Nuclear Station, Unit 2 (TMI-2). The letter also provided the date that GPUN
intended to use as the date of permanent cessation of operations for TMI-2.
By letter dated February 13, 2013 (Accession No. ML12349A291), the NRC
acknowledged GPUN's intended actions to be appropriate while noting that the
timing of the TMI-2 PSDAR submittal did not meet the requirement to submit a
PSDAR prior to or within two years of cessation of operations. This letter also
established the date of permanent cessation of TMI-2 operations to coincide with
License Amendment 45, dated September 14, 1993. The letter concluded that
GPUN's intent to restore compliance with a 2013 submittal of a TMI-2 PSDAR to
be of very low safety and security significance.
The attached PSDAR is provided to establish TMI-2 compliance with
10 CFR 50.82(a)(4), and recognizes September 14, 1993 as the established date
for permanent cessation of TMI-2 operations. The current decommissioning plan
will maintain TMI-2 in the post-defueling monitored storage state up to an
additional 20 years to coincide with the end of the TMI-1 Operating License in
order to synchronize decommissioning of TMI-1 and TMI-2.

 Three Mile Island Nuclear Station, Unit 2
TM1-1 3-041
Page 2
If there are any questions or if additional information is required, please contact
Mr. Gregory H. Halnon at (330) 436-1369.

President

Attachment:
Three Mile Island Nuclear Power Station, Unit 2 Post-Shutdown
Decommissioning Activities Report, June 2013

cc:

NRC Region I Administrator
NRC Senior Resident Inspector
NRC Project Manager
Director BRP/DEP
Site BRP/DEP Representative

 Attachment
TMI-13-041
Page 1 of 25

Three Mile Island Nuclear Power Station, Unit 2
Post-Shutdown Decommissioning Activities Report

June 2013

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TMI-13-041
Page 2 of 25

Table of Contents
SECTION

PAGE

I.

INTRODUCTION

3

II.

BACKGROUND

4

III.

DESCRIPTION OF DECOMMISSIONING ACTIVITIES

6

IV.

SCHEDULE OF DECOMMISSIONING ACTIVITIES

11

V.

ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES

12

VI.

ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES

15

VII. REFERENCES

25

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TMI-13-041
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I. INTRODUCTION
GPU Nuclear, Inc. (GPUN), acting for itself and for the Metropolitan Edison
Company, 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) in
accordance 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 in
accordance with the Nuclear Regulatory Commission (NRC) approved SAFSTOR
condition (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 postdefueling monitored storage (PDMS). GPUN has maintained TMI-2 in the PDMS
state 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 status
relative to the 1996 Decommissioning Rule changes specifically related to
10 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 planned
decommissioning activities, schedule, cost estimates, and the environmental impacts
of TMI-2 plant specific decommissioning. By NRC letter dated February 13, 2013, the
NRC stated that September 14, 1993 is considered the date of TMI-2's cessation of
operations.
The following PSDAR report is provided in accordance with the requirements in
10 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 the
environmental impacts associated with site-specific decommissioning
activities will be bounded by previously issued environmental impact
statements.
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 III
through V address the 10 CFR 50.82 requirements to describe and provide a

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schedule and cost estimate for the planned decommissioning activities.
Section VI provides the reasons for concluding that the activities planned for the
decommissioning 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 east
shore of the Susquehanna River in Dauphin County, Pennsylvania. The station
is comprised of two pressurized water reactors. The TMI Nuclear Station
includes 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 core
thermal power level of 2772 megawatt-thermal with a corresponding turbinegenerator gross output of 959 megawatt-electric. TMI-2 employed a two loop
pressurized water reactor nuclear steam supply system designed by Babcock
and Wilcox Corporation. The reactor coolant system is housed within a steellined, post-tensioned concrete structure (reactor building), in the shape of a right,
vertical cylinder with a hemispherical dome and a flat, reinforced concrete
basemat. A welded steel liner plate, anchored to the inside face of the reactor
building, serves as a leak-tight membrane.
GPUN was issued an operating license for TMI-2 on February 8, 1978, with
commercial operation declared on December 30, 1978. On March 28, 1979, the
unit experienced an accident initiated by interruption of secondary feedwater
flow.
The lack of secondary feedwater resulted in the reduction of primary-tosecondary heat exchange that caused an increase in the reactor coolant
temperature, creating a surge into the pressurizer, and an increase in system
pressure. The pressure operated relief valve (PORV) opened to relieve the
pressure, but failed to close when the pressure decreased. The reactor coolant
pumps were turned off and a core heat-up began as the reactor coolant system
water inventory continued to decrease resulting in a reactor vessel water level
below 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 the
southeastern assemblies and into the core bypass region. A portion of the fuel
material passed around the bypass region and migrated down into the lower
internals and lower head region, but overall reactor vessel integrity was
maintained throughout the accident.

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As a result of this accident, small quantities of core debris and fission products
were transported through the reactor coolant system and the reactor building. In
addition, a small quantity of core debris was transported to the auxiliary and fuel
handling buildings. Further spread of the debris also occurred as part of the
post-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 into
various 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 post
accident safe storage criteria was completed and accepted by the NRC with TMI-2
entering into post-defueling monitored storage in 1993.
NUREG-0683, "The Programmatic Environmental Impact Statement Related to
Decontamination and Disposal of Radioactive Wastes Resulting from the
March 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 for
environmental impact, and addresses the significant amount of decontamination
and waste removal that would normally be part of a decommissioning plan, which
were completed to achieve PDMS.
Approximately 99% of the fuel was removed and shipped to the Idaho National
Engineering and Environmental Laboratory (INEEL) under the responsibility of
the Department of Energy (DOE). The reactor coolant system was
decontaminated to the extent practical to reduce radiation levels to as low as is
reasonably achievable (ALARA). As part of the decontamination effort, water
was removed to the extent practical from the reactor coolant system and the fuel
transfer canal, and the fuel transfer tubes were isolated. Radioactive wastes
from the major clean-up activities have been shipped off-site or has been
packaged and staged for shipment off-site.
Following the decontamination activities, only the reactor building and a few
areas in the auxiliary and fuel handling buildings continued to have general area
radiation levels higher than those of an undamaged reactor facility nearing the
end of its operating life.
GPUN maintained TMI-2 in the PDMS state while successfully operating TMI-1
until AmerGen (a joint venture between Philadelphia Energy Company and British
Energy) purchased the operating TMI-1 from GPUN in 1998. The sale of TMI-1
included the Unit 1 buildings, structures, and the majority of the site property;
however GPUN maintained ownership of TMI-2. A monitoring agreement between
AmerGen and GPUN provides for AmerGen performing certain functions at TMI-2

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while TMI-2 is in PDMS on the behalf of GPUN. These functions include
maintenance and testing, radiological and environmental controls, security and
safety 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 larger
acquisition of GPU, and continued the monitoring agreement with AmerGen. In
December 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 they
are 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 assumed
decommissioning operations would begin in about 2026, and would be completed
over a 10-year period with site restoration projected in 2036. Since that time an
extension to the TMI-1 operating license has been granted warranting a revision to
the decommissioning schedule for TMI-2.
The NRC approved a 20-year extension to the TMI-1 Operating License by letter to
Exelon dated October 22, 2009. As a result, the TMI-1 Operating License has been
extended until April 19, 2034. The TMI-2 PSDAR establishes the schedule for the
decommissioning of TMI-2 to commence following the expiration of the TMI-1
Operating 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 plant
systems, components, structures, and facilities in a cost effective manner. The
decommissioning plan assumes that TMI-2 is effectively maintained in the
current 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 and
storage from TMI-1. The decontamination and dismantling activities at TMI-2 will
then be synchronized with the adjacent unit such that the licenses for both units
are terminated concurrently.
The decommissioning plan for TMI-2 involves activities to address the higher
source term materials to eliminate elements that would contribute to higher
worker exposure during activities that are typical of decommissioning an
operating plant at the end of plant life.

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TM1-13-041
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The decommissioning will focus on the use of both ultra high pressure water
sprays and mechanical decontamination methods for the removal of the
remaining high source term materials. Since the majority of the spent fuel has
already been removed from site and transferred to a DOE facility, there is no
need to construct an independent spent fuel storage installation (ISFSI) specific
to TMI-2. GPUN will explore two options for storage and transfer of the
remaining residual fuel and greater than class C (GTCC) waste. First, GPUN will
work with the DOE to obtain authorization to transport the remaining fuel and
GTCC 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 explore
an agreement with Exelon to have the remaining TMI-2 fuel and GTCC stored in
the TMI-1 ISFSI until a DOE geological repository becomes operational.
Based on the above overall plan, the decommissioning of TMI-2 has been
divided into the following periods:
" PDMS (SAFSTOR Dormancy)
*

Preparations for Decommissioning

" Decommissioning Operations
*

Non-radiological Restoration of the Site

The 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 that
activity.
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 risk
to the public health and safety. The PDMS state has been approved by the NRC
and is governed by a PDMS Safety Analysis Report, PDMS Technical
Specifications, and PDMS Quality Program.
The PDMS Technical Specification requirements to monitor and survey
radiological conditions have been established and maintained since 1993. Site
security is maintained as a contracted service by Exelon that owns and operates
TMI-1.

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TMI-13-041
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As 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 been
eliminated.

*

Water has been removed to the extent practical from the reactor
coolant system and fuel transfer canal, and fuel transfer tubes have
been isolated. The treatment and processing of accident generated
water has been completed.

*

Radioactive waste from the major cleanup activities has been shipped
off-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-1
operating license in 2034, and could extend until completion of the TMI-1 spent
fuel removal and storage campaign. In the event that circumstances dictate an
earlier shut down of TMI-1, the expected TMI-2 PDMS dormancy period will be
reduced, and the PSDAR will be revised to reflect a decommissioning schedule
that 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 and
facilities.

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In 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 major
components, 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 highly
radioactive waste and hazardous waste.

*

Develop procedures for occupational exposure control, control and
handling 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 the
period of decommissioning operations. Significant decommissioning activities to
be 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 number
of these activities may be coordinated with Exelon as they may be needed to
support 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 to
support removal and transportation activities, construction of
contamination control envelopes, and the procurement of specialty
tooling.
*

Procurement of shipping containers, cask liners, and industrial
packages for packaging.

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TMI-13-041
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0

Reconfiguration and modification of site structures and facilities as
needed to support decommissioning operations. This may include the
upgrading of roads and rail facilities to facilitate hauling and transport.

0

Decontamination of components and structures as required to reduce
source 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 vessel
internals. 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 service
structure 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 material
recovery and controlled disposal.

0

Removal of the free standing concrete and other internal structures in
the 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 be
prepared 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 the
decommissioning, any associated environmental concerns, designation of the
end use of the site, and the procedures for the final radiation survey. The LTP
will be developed following the guidance contained in Regulatory Guide 1.179,
"Standard Format and Content of License Termination Plans for Nuclear Power
Reactors." As described in Regulatory Guide 1.179, the LTP will use the
guidance contained in NUREG-1575, "Multi-Agency Radiation Survey and Site
Investigation Manual (MARSSIM)" to develop the final radiological survey plan
and survey methods. The use of MARSSIM to develop the final radiological
survey plan and survey methods will demonstrate compliance with the
requirements 10 CFR 20, Subpart E, "Radiological Criteria for License
Termination." Once the LTP is approved, the final remediation of the site

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facilities and services can commence. These activities include, but are not
limited to:
" Removal of remaining plant systems and components as they become
nonessential to the decommissioning program, or worker health and
safety (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 material
from the auxiliary and fuel buildings, and any other contaminated
facility.
Use of the NUREG-1 575 guidance ensures that the surveys are conducted in a
manner that provides a high degree of confidence that applicable NRC criteria
are satisfied. Once the final survey is complete, the results are provided to the
NRC. 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 for
release.
Period 4 - Site Restoration
Following completion of decommissioning operations, site restoration activities
will begin. Site restoration will involve the dismantling and disposal of any
remaining non-radiological structures. Restored areas of the site will be
backfilled, 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 DECON
approach. The schedule for decommissioning of TMI-2 is based on the
assumption that TMI-2 will be decommissioned with TMI-1 to achieve economies
of scale, by sharing costs between units, and coordinating the sequence of work
activities.
The high level schedule for decommissioning of TMI-2 assumes that the PDMS
SAFSTOR dormancy period will extend past the TMI-1 shutdown date to allow
for TMI-1 ISFSI construction and spent fuel removal and storage. Prior to
completion of the TMI-1 ISFSI program, the preparation for TMI-2
decommissioning will begin. As decommissioning approaches, schedule
variations to account for availability of waste disposal facilities and coordination

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TMI-13-041
Page 12 of 25

with Exelon and vendors will be incorporated. It is not expected that these
variations will impact the overall completion schedule.
The schedule for decommissioning of TMI-2 has been developed in order to
achieve the termination of license by September 14, 2053. This termination date
ensures compliance with the NRC requirement to complete decommissioning 60
years 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 that
TMI-2 license termination be allowed beyond September 14, 2053, GPUN will
notify the NRC to request consideration of an exemption to the 60-year
requirement as defined in 10 CFR 50.82(a)(3). As noted in letter from the NRC
to GPUN dated February 13, 2013, the equivalent to the certificate of
cessation of operations was determined to be the NRC's issuance of TMI-2
License Amendment 45, converting the TMI-2 operating license to a possession
only license. This amendment was granted on September 14, 1993 and
establishes that date as the date that TMI-2 is considered to have submitted
certification of permanent cessation of operations. Upon receipt of NRC
termination of license, site restoration activities will commence. It is estimated
that the site restoration will take approximately one year to complete thereby
rendering the Three Mile Island site restored to greenfield status in 2054.
Major milestones established for decommissioning of TMI-2 are listed in the table
below.
MAJOR DECOMMISSIONING ACTIVITY
TMI-2
TMI-1
TMI-2
TMI-2
TMI-2

PDMS SAFSTOR Dormancy
Shutdown
Decommissioning Preparation
Decommissioning Operations
Site Restoration

DATES
1993- 2043
April 19, 2034
2043- 2044
2044 - 2053
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 analysis
was first updated in 2004 and has been further refined to reflect current
assumptions pertaining to disposition of the nuclear unit and relevant industry
experience 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-2
decontamination, contingency for unknown or uncertain conditions, the availability of

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low and high level radioactive waste disposal sites, and site remediation
requirements. The methodology used to develop the cost estimate follows the basic
approach developed by the Atomic Industrial Forum (now the Nuclear Energy
Institute) in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power
Plant Decommissioning Cost Estimates." The method uses a unit cost factor
approach, including application of work difficulty adjustment factors to develop
decommissioning activity costs, and incorporates local information related to labor
rates, as well as latest available industry experience. The unit factor method
provides a demonstrable basis for establishing reliable cost estimates. The detail
provided in the unit factors, including activity duration, labor costs (by craft), and
equipment and consumable costs, ensures that essential elements have not been
omitted.
The estimate presented herein is based upon the most recent update to the site
specific cost estimate completed by TLG Services in January 2009, and provided
to the NRC as part of the 10 CFR 50.75(f)(1), "Reporting and record keeping for
decommissioning planning," submittal on March 29, 2010 (Accession No. ML
100960464).
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 until
the expiration of the TMI-1 operating license in 2034 and will be coordinated with
post-shutdown activities for TMI-1. For the purpose of this cost estimate the
integration of site security and the final site radiological survey between the two
units 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 includes
the 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 fuel
was 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 other
systems and structures. This residual material will be removed as radioactive
waste. Therefore, the cost of managing irradiated fuel is not reflected within the
estimates to decommission the TMI-2 site.
It is expected that there will be some wastes, (GTCC waste) generated in the
decommissioning of TMI-2 that are not suitable for shallow land burial and
therefore cannot be shipped for disposal until a high level waste repository is
made available by DOE. Although the material is not classified as high-level

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waste, the DOE has indicated they will accept this waste for disposal at the future
high-level waste repository. However, the DOE has not developed an
acceptance criteria or disposition schedule for this material, and numerous
questions remain as to the ultimate disposal cost and waste form requirements.
For purposes of the cost estimate, it is assumed that GTCC waste will be
packaged and disposed of as high-level waste, at a cost of $25,000 per cubic
foot (in 2008 dollars). It is also assumed that the DOE will accept the GTCC
material in a timely manner so as not to affect the TMI-2 decommissioning
schedule. No additional costs are included for the temporary storage of GTCC
material.
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 funding
will continue to be reported to the NRC in accordance with 10 CFR 50.75(f)(1) and
10 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 earnings
used in funding projections. Additionally, GPUN, in accordance with 10 CFR
50.82(a)(7), will inform the NRC in writing (with a copy sent to Pennsylvania),
before performing any decommissioning activity inconsistent with or making any
significant schedule change from those actions and schedules described in the
PSDAR, 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 CFR
50.82(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 expected
future cost of decommissioning. In the event that future estimated costs or funding
levels change significantly, GPUN will make the necessary adjustments to ensure
that sufficient funds remain available for decommissioning.

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TABLE 1
TMI-2 DECOMMISSIONING COST SUMMARY
(Thousands based on 2008 dollars)
Decontamination
Removal
Packaging
Transportation, Off-site Waste Processing,
and Disposal
Program Management
Miscellaneous Equipment
Insurance and Regulatory Fees
Other Decommissioning Costs
Total Decommissioning Costs
(Based on 2008 Dollars)
VI.

$ 31,577
$149,523
$ 17,232

$ 204,189
$371,633

$ 23,169
$ 17,868
$ 29,694
$ 844,885

ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES

10 CFR 50.82(a)(4)(i) requires that the PSDAR include "a discussion that provides
the reasons for concluding that the environmental impacts associated with the sitespecific decommissioning activities will be bounded by appropriate previously issued
environmental impact statements ... " The potential environmental impacts
associated with the proposed decommissioning activities for TMI-2 were compared
with similar impacts given in the PEIS related to post-accident cleanup activities
resulting from the March 28, 1979 accident; and with NUREG-0586, "Generic
Environmental Impact Statement on Decommissioning of Nuclear Power
Facilities," dated August 1988 and Supplement 1, Volumes 1 and 2, dated
November 2002 (collectively known as GELS) on decommissioning and radiological
criteria for license termination. The following discussion provides the comparison.
PEIS
The 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, and
4. Packaging, handling, shipment, and disposal of radioactive wastes

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These activities were used in the evaluation of the alternatives to GPUN's
proposed action of delayed decommissioning. As described in the PEIS, the
NRC evaluated seven alternatives relative to delayed decommissioning. The
NRC concluded (except for the no action alternative, which was not considered
acceptable) that no alternative was found to be superior to GPUN's proposal
from an environmental impact perspective.
Of the seven alternatives evaluated in the PEIS (except for the no action
alternative) as well as the proposed GPUN's delayed decommissioning plan, the
NRC concluded that each alternative could be conducted in conformance with
applicable regulatory requirements and implemented without significant impact to
the human environment. Hence, it is reasonable to conclude that the activities
described for the TMI-2 decommissioning will be accomplished with no adverse
environmental impacts based upon the following:
" The activities to be performed for decommissioning are equivalent to
the activities performed during the post-accident cleanup evaluated in
the PEIS,
" The radiation control techniques and decontamination methods since
the post TMI-2 accident cleanup have improved,
*

No site-specific activities pertaining to TMI-2 decommissioning would
alter the conclusions of the PEIS,
" Radiation dose to the public will be minimal, and
•

Radiation dose to decommissioning workers will be maintained ALARA
according to 10 CFR Part 20.

As noted in the PEIS, the outcome of completing the clean-up activities at TMI-2
would result in many areas decontaminated to the point where general area dose
rates approximate those in an undamaged reactor facility nearing the end of its
operating life.
GElS
The remaining decommissioning activities for the delayed decommissioning of
TMI-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 NUREG0586 to evaluate the environmental impacts of decommissioning, and is likewise
smaller than a number of PWRs that were evaluated in NUREG-0586,
Supplement 1.

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Decommissioning activities are identified in Appendix E of NUREG-0586,
Supplement 1. No activities planned for TMI-2 deviate from the activities listed in
terms of environmental impact. A deviation exists in terms of the variables
associated with transuranic fuel and higher source terms. However, these
variables are addressed through controlled decontamination and dismantlement,
and following NRC regulations associated with dose. So long as
decontamination and dismantlement are performed within the guidelines of the
regulations regarding release of effluents, occupational dose, and offsite dose;
and GTCC waste is contained in approved shipping containers; the
decommissioning activities at TMI-2 are directly comparable to the activities
evaluated in the GELS.
NUREG-0586, Supplement 1, Section 4.3, "Environmental Impacts from Nuclear
Power Facility Decommissioning," provides a listing of 18 issues pertinent to the
decommissioning of a reactor. A discussion of these issues follows.
1. Onsite/Offsite Land Use
The GElS concluded that the impacts on land use are not detectable or small for
facilities 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 during
decommissioning. Therefore, it can be concluded that the impacts on land use
are bounded by the GELS.
2. Water Use
Since the shutdown of TMI-2 and the entry into the PDMS state, the demand for
potable water has decreased significantly below the demand during operation.
The operational demand for cooling water, makeup water, and service water has
ceased. The demand for water needed to conduct plant decommissioning
activities (flushing piping, hydro-lasing, dust abatement, etc.) will be less than the
demand for water supply during operation. Hence, the impacts on water use are
bounded by the GELS.
3. Water Quality - Non-Radiological
Programs and processes designed to minimize, detect, and contain spills will be
maintained throughout the decommissioning process. Federal, state and local
regulations, and permits pertaining to water quality will remain in effect, and no
significant changes to water supply reliability are expected. Therefore, the
impact of TMI-2 decommissioning on water quality is bounded by the GELS.

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TMI-13-041
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4. Air Quality
There are many types of decommissioning activities that have the potential to
affect air quality. These activities are listed in the GElS and evaluated from the
perspective of the ability to mitigate consequences of activities through the use of
high efficiency particulate filters. In addition, the release of any effluents must be
controlled to keep contaminated material within the NRC's regulatory limits. For
the 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 that
could potentially affect air quality. Therefore, the impact of the TMI-2
decommissioning on air quality is bounded by the GELS.
5. Aquatic Ecology
GPUN does not anticipate disturbance of lands beyond the current operational
areas of the plant. No alteration to the shores of the Susquehanna River will
occur. All activities within the current operational areas of the plant will be
conducted in accordance with required permits. Therefore, the impacts of
decommissioning TMI-2 on aquatic ecology are bounded by the GELS.
6. Terrestrial Ecology
Terrestrial ecology considers the plants and animals in the vicinity of Three Mile
Island as well as the interaction of those organisms with each other and the
environment. Evaluations of impacts to terrestrial ecology are usually directed at
important habitats and species, including plant and animals that are important to
industry, recreational activities, the area ecosystems, and those protected by
endangered species regulations and legislation. GPUN does not anticipate
activities to be conducted that would disturb habitat beyond the operational areas
of 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 are
bounded by the conclusions in the GELS, which concludes the impact to be small.
7. Threatened and Endangered Species
Of the state or federally listed endangered or threatened animal and plant
species, only the bald eagle, the osprey, the peregrine falcon, and American
holly were identified to have a presence on or near the island.
The bald eagle has recently been removed from the endangered species list but
remains protected by two other federal laws. The Bald and Golden Eagle
Protection Act and the Migratory Bird Treaty Act became effective in 2007. Bald

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eagles have become relatively common along the Susquehanna River and have
been known to nest in Dauphin, Lancaster, and York counties. Occasionally they
have been observed on Three Mile Island, but there are no known nests on the
island. There is a bald eagle nest located approximately 20 miles south, near
Holtwood Dam.
The Susquehannah River and the associated environment and wetland areas in
the vicinity of Three Mile Island are used by many migratory and resident bird
species. Osprey and peregrine falcon nests are known to occur on Three Mile
Island. 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 not
used it. Peregrine falcons have nested on the TMI-1 Reactor Building since
2002. A nest box designed for peregrine falcons was placed on the TMI-2
reactor building in 2002, but the birds have not used it. Exelon regularly monitors
the osprey and the peregrine falcon nests on Three Mile Island. The American
holly, state-listed as threatened, has been recorded on the TMI-1 property.
Should the situation change and the identified species routinely be found in or
around any of the TMI-2 buildings or property, it is GPUN's intent to notify the
NRC and the Pennsylvania Department of Environmental Protection to evaluate
the impact of decommissioning activities.
8. Radiological Occupational Dose
It is anticipated that low-level radioactive waste removed from TMI-2 will be
disposed of at approved waste disposal sites, and that the disposal at local
commercial landfills will be minimized in favor of low-level radioactive waste
disposal to reduce the risk of inadvertent release of radiological material.
Radiation dose to the public is expected to remain below levels comparable to
when TMI-2 was operating, through the continued application of radiation
protection and contamination controls combined with the reduced source term
available in the facility.
It is anticipated that an occupational dose estimate for the decommissioning of
TMI-2 will be performed prior to the start of decommissioning activities based on
confirmed 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 be
administratively controlled to a lower TEDE limit to ensure that personnel doses
do not exceed regulatory limits. It is also anticipated that administrative practices
will result in equitable distribution of dose among available qualified workers to
ensure collective dose to the work force is kept ALARA.

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The decommissioning activities dose will be maintained within the regulatory
limits, and as such, is consistent and within the conclusions of the GElS
9. Radiological Accidents
The likelihood of a large offsite radiological release that impacts public health and
safety with TMI-2 in the PDMS state is considerably lower than the likelihood of a
release from the plant during power operation. This is because the majority of
the potential releases associated with power operation are not relevant after the
fuel has been removed from the reactor.
GELS, Supplement 1 also considers the possibility of a zircalloy fire. This
accident is not relevant to TMI-2 in the current PDMS condition with
approximately 99% of the fuel material having been removed from the site and
sent to INEEL.
The potential for decommissioning activities to result in radiological releases not
involving spent fuel (that is, releases related to decontamination and
dismantlement activities) will be minimized by use of procedures designed to
minimize 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 Issues
GPUN will continue to maintain appropriate administrative controls and
requirements to ensure occupational hazards are minimized and that applicable
federal, state and local occupational safety standards and requirements continue
to be met. GPUN has reviewed the occupational hazards and injuries in the
GElS and concluded that they are not unique or different than activities
performed during construction and cleanup of TMI-2. Therefore, the impact of
decommissioning TMI-2 on occupational issues is bounded by the GELS.
11. Cost
Decommissioning costs for TMI-2 are discussed in Section IV of the PSDAR
report. The GElS recognizes that an evaluation of decommissioning cost is not a
National Environmental Policy Act requirement. Therefore, a bounding analysis
is not applicable.

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12. 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 of
TMI-2 is bounded by the GElS analysis of socioeconomic effects on the
shutdown and decommissioning of an operating unit.
13. Environmental Justice
Executive 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 or
environmental effects because of federal actions.
Because the activities of the decommissioning plan create the potential for
additional work opportunities, the decommissioning of TMI-2 could have a
positive impact on environmental justice by providing job opportunities for lower
income or minority populations around the area.
The decommissioning activities are bounded by the evaluation of the post
accident clean up activities relative to socioeconomic and environmental justice.
GPUN concludes that the employment opportunities created by
decommissioning will have a positive impact on environmental justice and that
no further evaluation of detrimental impacts is required.
14. Cultural, Historic, and Archeological Resources
The PEIS makes no mention of cultural, historic or archeological resources on
Three Mile Island. In addition, GPUN expects that most decommissioning
activities will be conducted within the protected areas of the site. As stated in the
GELS, where disturbance of lands beyond the operational areas is not
anticipated, the impacts on cultural, historic and archeological resources are not
considered to be detectable or destabilizing. GPUN has concluded that the
impact of decommissioning TMI-2 on cultural, historic, and archeological
resources to be bounded by the GELS.

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15. Aesthetic Issues
The impact of decommissioning activities on aesthetic resources will be
temporary and remain consistent with the aesthetics of an industrial plant. After
the decommissioning process is complete, site restoration activities will result in
structures being removed from the site and the site being backfilled, graded and
landscaped 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 the
GELS.
16. Noise
General noise levels during the decommissioning process are not expected to be
any more severe than during refueling outages and are not expected to present an
audible 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 expected
to present an audible intrusion on the surrounding community. Therefore, GPUN
has concluded that the impact of decommissioning TMI-2 on noise is bounded by
the GELS.
17. Transportation
The GElS states that NRC regulations are adequate to protect the public against
unreasonable risk from the transportation of radioactive material and that the
effects of transportation of radioactive waste on public health and safety are
considered to be neither detectable nor destabilizing. The NRC analysis further
determined that their consideration of the existing data for decommissioning
methods and transportation modes should bound the transportation impacts for
all decommissioning options for pressurized water reactors and boiling water
reactors.
For the decommissioning of TMI-2, the transportation modes assumed are
shielded container removal by rail or truck. The reactor vessel internal
components are expected to be transported in spent fuel casks by rail. Other
highly 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 to
require shipment in shielded truck casks. The low level radioactive wastes
requiring controlled disposal are expected to be sent to a waste processor or a
low-level radioactive waste disposal facility via railroad.

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The transportation impacts of decommissioning are dependent on the number of
shipments to and from the plant, the types of shipments, the distance the
material is shipped, and the radiological waste/fixed waste quantities and
disposal plans. The estimated number and volume of shipments from the plant
will be much smaller than shipments to the plant during decommissioning. The
shipments from the plant would be primarily radioactive wastes and nonradioactive 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 to
protect the public against unreasonable risk from transportation of radioactive
materials. In addition, shipments of waste from the site are not expected to result
in measurable deterioration of affected roads or a destabilizing increase in traffic
density.
Therefore, GPUN has concluded that the impact of decommissioning TMI-2 on
transportation is bounded by the GELS.
18. Irreversible and Irretrievable Commitment of Resources
Irreversible commitments are commitments of resources that cannot be
recovered, and irretrievable commitments of resources are those that are lost
for only a period of time.
Uranium is a natural resource that is irretrievably consumed during power
operation. After the plant is shutdown uranium is no longer consumed. The use
of 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 for
unrestricted use after license termination, land is not considered an irreversible
resource. The only irretrievable resources that would occur during
decommissioning would be materials used to decontaminate the facility (for
example, rags, solvents, gases, and tools) and the fuel used for
decommissioning 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 on
irreversible and irretrievable commitment of resources is bounded by the GELS.

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Additional Considerations
While not quantitative, the following considerations are also relevant to
concluding that decommissioning activities will not result in significant
environmental impacts not previously reviewed.
Significant cleanup of the TMI-2 facility has already been completed with
approximately 99% of the fuel removed and shipped to INEEL.
Decontamination has been completed to the extent that further major
decontamination programs are not justified on the basis of worker dose.
Prior to decommissioning, TMI-2 will be maintained in accordance with the NRC
approved PDMS mode governed by the associated PDMS Technical
Specifications, PDMS Quality Assurance Program, and PDMS Final Safety
Analysis Report. As such, TMI-2 will be maintained in a condition of stability and
safety such that there is minimal risk to public health and safety.
Radiation protection techniques used at the time of decommissioning are
expected to improve over current practices and should ensure reduction in
occupational exposure.
Site access control processes during decommissioning are expected to reduce
the 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 be
bounded by the previously issued environmental impact statements, specifically
the PEIS, and the GElS and its supplement. This is principally due to the
following reasons:
*

The postulated impacts associated with the decommissioning method
chosen 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 reached
in the PEIS, and the GElS and its supplement.

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VII.

REFERENCES

1. Pace, D. L. (GPU Nuclear) to NRC letter, "Notification of Intent to Submit a
Post-Shutdown Decommissioning Activities Report," dated August 14, 2012
2. Camper, L. W. (NRC) to Pace, D. L. (GPU Nuclear) letter, "Three Mile Island
Nuclear Station, Unit 2 (TMI-2) - Failure to Submit Post-Shutdown
Decommissioning Activities Report - Non-cited Violation (Docket: 05000320),"
dated February 13, 2013
3. Masnik, M. T. (NRC) to Long, R. L. (GPU Nuclear) letter, "Issuance of
Amendment 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, 1993
4. 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," Supplement 3, dated August 1989
5. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile Island
Unit 2," dated September 2004
6. TLG Services, Inc., "Decommissioning Cost Analysis for Three Mile Island
Unit 2," dated January 2009
7. Robinson, J. E. (NRC) to Gallagher, M. P. (Exelon Generation Company,
LLC) letter, "Issuance of Renewed Facility Operating License No. DPR-50 for
the Three Mile Island Nuclear Station, Unit 1," dated October 22, 2009
8. NUREG-0586, "Generic Environmental Impact Statements on
Decommissioning and Radiological Criteria for License Termination," dated
August 1988, and Supplement 1, Volumes 1 and 2, November 2002