ML20079D788

Decommissioning Funding Status Report

ML20079D788
Person / Time
Site:	Crane
Issue date:	03/18/2020
From:	Halnon G GPU Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TMl-20-003
Download: ML20079D788 (10)

Text

(t;pu NUCLEAR March 18, 2020 TMl-20-003 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, License No. DPR-73 GPU Nuclear, Inc.

Thrue Milo band Nuclear Sta1Jon Route 441 South PDs1 Office Box 480 Middletown, PA 17057*0480 Toi 717*948-8461 10 CFR 50.75 10 CFR 50.82 Decommissioning Funding Status Report for the Three Mile Island Nuclear Station. Unit 2 Pursuant to 10 CFR 50.75 and 10 CFR 50.82, GPU Nuclear, Inc. is hereby submitting the following three reports to the Nuclear Regulatory Commission (NRC) for Three Mile Island Nuclear Station, Unit 2 for the year ending December 31, 2019. Attachment 1 provides a decommissioning funding status report based on the NRC formula described in 10 CFR 50.75(c). Attachment 2 provides a decommissioning funding status report based upon a site-specific decommissioning cost estimate (DCE). Attachment 3 contains a financial assurance status report as required by 10 CFR 50.82(a)(8)(v).

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Michael Casey, GPU Nuclear Responsible Engineer TMl-2 at (330) 472-8589.

Sincerely, Grego

. alnon President and Chief Nuclear Officer GPU Nuclear, Inc.

Three Mile Island Nuclear Station, Unit 2 TMl-20-003 Page2 Attachments:

1. Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula

2. Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report -

Site-Specific Decommissioning Cost Estimate

3. Three Mile Island Nuclear Station, Unit 2 Financial Assurance Status Report cc: NRC Region I Administrator NRC Project Manager TMl-20-003 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC Formula Page 1 of 3 This report reflects the FirstEnergy Corp. subsidiary ownership interests in the Three Mile Island Nuclear Station, Unit 2 as of December 31, 2019.

1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(b) and (c) (see Schedule 1):

Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

2. The amount accumulated in external trust funds:

Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

$253,900,951 126,950,476 126,950,476

$507,801.902 After Tax

$416,484,439 223, 146,819 259,856, 169

$899.487.427

3. There are no longer any funds being collected from the ratepayers.

4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:

Consolidated Ownership Interest in Unit Estimated Net Investment Rate Year of Site Restoration Completion 100%

2.00%

2053 Three Mile Island Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040.

5. There are no contracts upon which the owners/licensees are relying pursuant to 10 CFR 50.75(e)(1)(v).

6. There are no modifications to the licensee's current method of providing financial assurance since the last submitted report.

TMl-20-003 Page 2 of 3

7. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile Island Nuclear Station, Unit 2.

8. Mathematical rounding was performed during the development of the supporting calculations.

TMl-20-003 Page 3 of 3 Schedule 1 FIRSTENERGY CORP.

Calculation of Minimum Financial Assurance Amount December 31, 2019 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 Pennsylvania Regions Labor (L) = Northeast Energy (E) = National Waste Burial (B) = Generic For PWR Unit L=

E=

B=

PWR Escalation Factor=

Adjustment Factor 3.04 2.348 12.853 Ratio 0.65 0.13 0.22 Escalation Factor1 1.976 0.305 2.828 5.109 Base Amount for PWR between 1200 MWt and 3400 MWt = ($75 + 0.0088P) million (P = power level in megawatts thermal = 2772)

($75 + 0.0088(2772)) million =

$99,393,600 Escalated Amount for unit1 =

99,393,600 x

5.109

=

$507.801.902 Owner/Licensee 1 Ownership Pennsylvania Electric Company 25%

$126,950,476 Jersey Central Power & Light Company 25%

$126,950,476 Metropolitan Edison Company 50%

$253.900.951 FirstEnergy Corp. Consolidated 100%

$507.801.902 Note 1: Mathematical rounding was performed during the development of the supporting calculations.

TMl-20-003 Three Mile Island Nuclear Station, Unit 2 Decommissioning Funding Status Report - Site-Specific Decommissioning Cost Estimate Page 1of4

1. Decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c) are based upon a site-specific decommissioning cost study, 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018:

NRC License Termination

$1,353,638,075

2. The amount accumulated in external trust funds as of December 31, 2019:

Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

3. There are no longer any funds being collected from the ratepayers.

After Tax

$416,484,439 223, 146,819 259,856,169

$899.487.427

4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:

Consolidated Ownership Interest in Unit Estimated Rate of Escalation in Decommissioning Costs Estimated After-Tax Rate of Return Year of Site Restoration Completion 100%

0.00%

2.00%

2053 Three Mile Island Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040.

All costs are based on a site-specific decommissioning cost study, 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018, then escalated to 2019 dollars using an escalation factor of 2.78% as documented in Escalation Analysis for Three Mile Island Unit 2, dated February 2015.

5. There are no contracts upon which the owners/licensees are relying pursuant to 10 CFR 50.75(e)(1)(v).

6. There are no modifications to the licensee's current method of providing financial assurance since the last submitted report.

TMl-20-003 Page 2 of 4

7. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile Island Nuclear Station, Unit 2.

8. Site-Specific Cost Analysis Assumptions 10 CFR 50.75(e)(1)(i), states, in part, that:

A licensee that has prepaid funds based on a site-specific estimate under 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate.

In accordance with Regulatory Guide 1.159, Revision 2, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, a facility specific analysis may be used to demonstrate the adequacy of decommissioning funds, provided that:

NRG-required cost estimate for decommissioning costs, as defined in 10 CFR 50.2, is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2).

The site-specific radiological decommissioning cost estimate is $1,353,638,075, which is greater than the 10 CFR 50.75(c) cost estimate of $507,801,902. The analysis assumes a 2 percent yearly rate of return. The analysis also assumes a period of safe storage. The cash flows were contained in a decommissioning cost estimate that was prepared for Three Mile Island Nuclear Station, Unit 2. The cash flow analysis assumes the yearly expenses are incurred at the beginning of year.

Schedule 1 provides the site-specific analysis. The analysis values are in 2019 dollars.

The analysis is based on TMl-2 transitioning from Post-Defueling Monitored Storage status to decommissioning in 2040 and includes expenditures for license termination costs only.

9. Mathematical rounding was performed during the development of the supporting calculations.

10.

References:

A. 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018 (Accession No ML19087A153)

B. Escalation Analysis for Three Mile Island Unit 2, 2013 Site-specific Decommissioning Cost Estimate, February 2015 (Accession No. ML15086A337)

TMl-20-003 Page 3 of 4 Schedule 1 FIRSTENERGY CORP.

Funding Analysis December 31, 2019 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 Estimated Net Investment Rate Estimated Escalation Rate Estimated After-Tax Rate of Return Qualified Trust Balance on December 31, 2019 Non-Qualified Trust Balance on December 31, 2019 Total Beginning Year Balance Deposits Earnings 2019 899,487,427 2020 899,487,427 17,918, 187 2021 913,827 530 18,204,989 2022 928,454,435 18,497,527 2023 943,373,877 18,795,916 2024 958,591 709 19, 100,273 2025 974,113 898 19,410,716 2026 989,946,530 19,727,369 2027 1,006,095,814 20,050,355 2028 1,022,568,085 20,379,800 2029 1,039,369 801 20,715,834 2030 1,056,507 551 21,058,589 2031 1,073,988,056 21,408, 199 2032 1,091,818, 172 21 764,802 2033 1, 110,004,889 22, 128,536 2034 1,128,555,341 22,499,545 2035 1, 147,476 802 22,877,974 2036 1, 166, 776,692 23,263,972 2037 1, 186,462,580 23,623,692 2038 1,204,808,268 23,962,039 2039 1,222,063,996 24,307,154 2040 1,239,664,838 24,437,628 2041 1,246,319,040 23,877,509 2042 1,217,752,935 21,976,858 2043 1,120,819,761 20,000,716 After-Tax 2.00%

0.00%

2.00%

899,487,427 After-Tax 899.487.427 Ending Withdrawal1*2*3 Balance 899,487,427 (3,578,084) 913,827,530 (3,578,084) 928,454,435 (3,578,084) 943,373,877 (3,578 084) 958,591, 709 (3,578,084) 974,113,898 (3,578,084) 989,946,530 (3,578 084) 1,006,095,814 (3,578,084) 1,022,568,085 (3,578,084) 1,039,369,801 (3,578,084) 1,056,507,551 (3,578,084) 1,073,988,056 (3,578,084) 1,091,818, 172 (3,578,084) 1, 110,004,889 (3,578,084) 1,128,555,341 (3,578,084) 1, 147,476,802 (3,578,084) 1, 166, 776,692 (3,578,084) 1, 186,462,580 (5,278,004) 1,204,808,268 (6,706 312) 1,222,063,996 (6,706,312) 1,239,664,838

( 17, 783,426) 1,246,319,040 (52,443,613) 1,217,752,935 (118,910 032) 1,120,819,761 (120,783,957) 1,020,036,520 TMl-20-003 p

4 f 4 age 0

Beginning Year Balance 2044 1,020,036,520 2045 863,403,824 2046 703,550,170 2047 541,711,265 2048 502,860,316 2049 460,618,835 2050 387,062,469 2051 321 953,697 2052 255,249,227 2053 185, 178, 175 20545 150, 118 251 Deposits Ending Earninas Withdrawal1*2*3*4 Balance 16 929,487 (173,562, 182) 863,403,824 13,795,101 (173,648, 756) 703,550, 170 10,621,790 (172,460,694) 541,711,265 9,860,006 (48,710,956) 502,860,316 9,031,742 (51,273,222) 460,618,835 7,589,460 (81, 145,827) 387,062,469 6,312,818 (71,421,589) 321,953,697 5,004,887 (71, 709,357) 255,249,227 3 630 945 (73,701,996) 185, 178, 175 2 943,495 (38,003,419) 150, 118,251 2,831, 145 (8,560,991 )

144,388,406 (1,353,638,075)

( 1) reflects Safstor method from Energy Solutions Scenario 2 Safstor 1, withdrawals assumed to be made in the beginning of the period (2) There were no funds withdrawn from the decommissioning trust fund for years 2013, 2014, 2015, 2016, and 2017 (3) In 2018 $312,743.81 was withdrawn from the decommissioning trust fund for Decommissioning Planning, in 2019 $76,788.96 was withdrawn from the decommissioning trust fund for Decommissioning Planning (4) Withdrawals based upon a site-specific decommissioning cost study, 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018, then escalated to 2019 dollars using an escalation factor of 2.78% as documented in Escalation Analysis for Three Mile Island Unit 2, dated February 2015 (5) 2054 costs cover potential unresolved license termination invoices and costs from the previous years.

TMl-19-003 Three Mile Island Nuclear Station, Unit 2 Financial Assurance Status Report Page 1of1

1. Formal decommissioning has not started at Three Mile Island Nuclear Station, Unit 2. A special disbursement of decommissioning trust funds occurred in 2005 for $416,400.00.

Notification of this use of decommissioning funds was made to the NRC by letter dated February 1, 2005 (Accession No. ML050380143). $312,743.81 was spent on decommissioning planning activities in 2018 and $76,788.96 was spent on decommissioning planning activities in 2019.

2. Decommissioning funds estimated to be required are based upon a site-specific decommissioning cost study, 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018, then escalated to 2019 dollars using an escalation factor of 2.78% as documented in Escalation Analysis for Three Mile Island Unit 2, dated February 2015:

NRC License Termination

$1,353,638,075 As noted on Attachment 2, Schedule 1, FirstEnergy Corp. Funding Analysis dated December 31, 2019.

3. The amount accumulated in external trust funds as of December 31, 2019:

Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

4. There are no longer any funds being collected from the ratepayers.

After Tax

$416,484,439 223,146,819 259,856, 169

$899.487.427

5. There are no modifications to the licensee's current method of providing financial assurance since the last submitted report.

6. There were no amendments to the trust agreements for the above-mentioned owners of Three Mile Island Nuclear Station, Unit 2.

7. Mathematical rounding was performed during the development of the supporting calculations.

8.

References:

A 2018 Decommissioning Cost Estimate for FirstEnergy, Three Mile Island, Unit 2, dated December 12, 2018 (Accession No ML19087A153)

B. Escalation Analysis for Three Mile Island Unit 2, 2013 Site-specific Decommissioning Cost Estimate, February 2015 (Accession No. ML15086A337)