ML21084A229

Notification of Amended Post-Shutdown Decommissioning Activities Report Accordance with 10 CFR 50.82(a)(7), Revision 4

ML21084A229
Person / Time
Site:	Crane
Issue date:	03/17/2021
From:	Gerard van Noordennen TMI-2 Solutions
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21084A227	List: ML21084A229
References
TMI2-RA-COR-2021-0004
Download: ML21084A229 (134)

Text

. CONFIDENTIAL FINANCIAL INFORMATION TO BE wiTHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17 March-17, 2021 TM 12-RA-CO R-:2o'21-0004 10 CFR 50.51.

.. 1 O_ CFR 50:~2(a)(7).

U.S. Nucle~r Regul~tory_ Commission :

A TIN; Document Control Desk

. Washington, DC 2055fr0001 Subject Notification of "Amended Post-Shutdown Decommission.ing Activittes Report" (PSDAR) for Three Mil~ Island, Unit 2 *in Accordance with 10 CFR 50.~2(a)(7), __ Revision-4

• Three. Mile Island, Unit 2 NRC: Pos~ssion* Only' License No. DPR NRC Docket No.*50-320

References:

.. 1)° Letter TMl-19-112 from Halnon, G.H. (GPU:NucJear, Inc.), and Sauger J.

(TM1.:2 Solutions LLC), "Application for Order Approving License Transfer.

• and Conforming License Amendments/ (ML 1*9325C600) dated November.

,12, ;2019:.

2)

'Letter from USN~C to Sauger, J. (TMl-2 Soluti_ons, LLC), "Three Mile Island.Nucle*ar Station, Unit No. 2 - Issuance of Amendment No. 64 Re:

Order Approving Transfer of License and Conforming License Amendment

(~PIO L-2019-LLA-0257)," (ML20352A381) dated December 18, 2020.

• GPU Nuclear, Metropolitan Edison Company, _Jersey Central Power_ & Light Company, Pennsylvania Electric Company, and TMl:-2 Solutions, LLC, submitted an '.'AppliC;ation for Ord.er Approving Li99nse Transfer and Conforming *ucense Amendments" fo-r~Three *. *

• Mile lsran_d Unit.:2 (TMl-2) to the w. S,. Nuclear Regulatory C9mmission (NRC) for review -

in a letter dated November 12, 2019 (Reference 1) (the Application)~ The licen~-

application.was approved by the NRC in: Reference 2. TMl-2 Solutions became the.

TMl-2 licensee on Dee:ember 18, 2020, following 'ttje closing o(the transaction specified in the October 1 S, 2019 Asset Purchase arid Sale Ag~~ent-("The Closing") among.

the Applicants ("Purchase Agreemene) enclosed with the Application (Reference 1 ).

Joh/

. ;JI(~

UPON REMOVAL OF ENCLOSWRE 1A THIS DOCUMENilS UNCONTROLLED.

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17 TMl2-RA-COR-2021-0004 Page 2 of 3 This letter submits TMl-2 Post-Shutdown Decommissioning Activities Report (PSDAR)

Revision 4 to the NRC (Attachment 1). TMl-2 Solutions has developed this PSDAR for TMl-2 in accordance with the requirements of 10 CFR 50.82, "Termination of license,"

paragraph (a)(4)(i)., Enclosure 1A contains confidential commercial and financial information.

TMl-2 Solutions requests that the information provided in Enclosure 1A be withheld from public disclosure pursuant to 10 CFR 2.390, as described in the Affidavit provided in. A redacted version of Enclosure 1A, suitable for public disclosure, is provided as Enclosure 1 B.

In accordance with 10 CFR 50.91(b)(1), a copy of this submrttal has been sent to the Commonwealth of Pennsylvania.

This document contains regulatory commitments as noted in Attachment 3.

In the event that the NRC has any questions with respect to the content of this document or wishes to obtain any additional information, please contact me at 860-462-9707.

Sincerely Gerard van Noordennen Senior Vice President Regulatory Affairs TMI Solutions, LLC Attachments: - Three Mile Island Nuclear Power Station, Unit 2 Post-Shutdown Decommissioning Activities Report, Revision 4 (with Enclosures) - 10 CFR 2.390 Affidavit - List of Regulatory Commitments - Correspondence with Pennsylvania State Historic Preservation Office UPON REMOVAL OF ENCLOSURE 1A THIS DOCUMENT IS UNCONTROLLED.

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17 cc w/Proprietary

Enclosures:

Ted Smith, NRC Project Manager NRC Region I Administrator NRC Lead Inspector Director, Bureau of Radiation Protection, TMl2-RA-COR-2021-0004 Page 3 of 3 Department of Environmental Protection, Commonwealth of Pennsylvania Chief, Division of Nuclear Safety, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania UPON REMOVAL OF ENCLOSURE 1A THIS DOCUMENT IS UNCONTROLLED.

TMl-2 Service List cc:

Ken Robuck President and CEO Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and Chief Nuclear Officer Reactor D&D Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Mike Lackey Senior Vice President D&D Operations Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Gerard van Noordennen Senior Vice President Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Scott Baskett Project Director TMl-2 Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Daniel F. Stenger Hogan Lovells US LLP 555 13th[/ NW Washingfi,, D.C. 20004 Chairman, Board of County Commissioners, Dauphin County 112 Market Street

?1h Floor Harrisburg, PA 17101 Chairman, Board of Supervisors of Londonderry Township 783 S. Geyers Church Rd.

Middletown PA 17057

ATTACHMENT 2 TO TMl2~-COR-2021-0004 10 CFR 2.390 AFFIDAVIT THREE MILE ISLAND NUCLEAR POWER STATION, UNIT 2 NRC POSSESSION ONLY LICENSE NO. DPR-73

TMl-2 Solutions Proprietary Information Affidavit Affidavit of Gerard van Noordennen, Senior Vice President Regulatory Affairs, TMl-2 Solutions, LLC.

TMl-2 Solutions, LLC, is providing information in support of the TMl-2 "Post-Shutdown Decommissioning Activity Report' Revision 4, described in this letter. Enclosure 1A contains financial information, including proprietary aspects to the decommissioning of TMl-2, which constitute proprietary commercial and financial information, belonging to TMl-2 Solutions, that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390 and 10 CFR 9.17. Release of this information would cause irreparable harm to the competitive position of TMl-2 Solutions, LLC. This basis for this declaration is:

I.

This information is owned and maintained as proprietary by TMl-2 Solutions, LLC, II.

This information is routinely held in confidence by TMl-2 Solutions, LLC, and not disclosed to the public, Ill.

This information is being requested to be held in confidence by the NRC by this petition, IV.

This information is not available in public sources, V.

This information would cause substantial harm to TMl-2 Solutions, LLC, if it were released publicly, and VI.

The information to be withheld was transmitted to the NRC in confidence.

I, Gerard van Noordennen, being duly sworn, state that I am the person who subscribes my name to the foregoing statement, I am authorized to execute the Affidavit on behalf of TMl-2 Solutions, LLC, and that the matters and facts set forth in the statement are true to the best of my knowledge, information, and belief.

Gerard van Noordennen Senior Vice President Regulatory Affairs TMl-2 Solutions, LLC Sworn To And Subscribed Before Me This

/ Z Day of ~c/2.., cl~~

~brva:y:,i<I',,;i.o.;,,

,I JO-ANN LEWIS

~ NOTARY PUBUC I\\' COMMISSIOI EXPIRES FEB. 28. 2023 r

ATTACHMENT 1 TO LETTER NUMBER TMI2-RA-COR-2021-0004 THREE MILE ISLAND NUCLEAR POWER STATION, UNIT 2 POST -SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT (PSDAR)

REVISION4 THREE MILE ISLAND NUCLEAR POWER STATION, UNIT 2 NRC POSSESSION ONLY LICENSE NO. DPR-73

TABLE OF CONTENTS

1. INTRODUCTION.................................................................................................................. 1

2. BACKGROUND................................................................................................................... 2 2.1 Summary of Decommissioning Activities............................................................. 4

3. DESCRIPTION OF DECOMMISSIONING ACTIVITY................................................ 5 3.1 Phase 1a Decommissioning PlanninQ.................................................................... 8 3.1.1 Phase 1a Activitles.................................................................................................. 8 3.1.2 Phase 1 b: Debris Material Recovery and Source Term Reductlon........ 9 3.2 Major Decommissioning Activities.......................................................................... 10 3.2.1 License Termlnation............................................................................................... 10 3.2.2 Site Restoration....................................................................................................... 11 3.3 Decontamination and Dismantlement Activities................................................. 11 3.3.1 Major Decommissioning Activities................................................................... 11 3.3.2 Decontamination and Dismantlement Activities......................................... 14 3.3.3 Radioactive Waste Management....................................................................... 14 3.3.4 Removal of Mbced Waste...................................................................................... 14 3.3.5 Site Characterization.............................................................................................. 15 3.3.6 Groundwater Protection and Radiological Decommissioning Records Program...................................................................................................................... 15 3.4 Phase 3: Debris Material Management.................................................................. 16 3.5 Changes to Management and Staffing******************************************************************* 16 4.. SCHEDULE OF DECOMMISSIONING ACTIVITIES.................................................. 16

5. ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES.................................. 17

6. ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES.................19 6.1 Environmental Impact of TMl-2 Decommissionlng*******************************************21 6.1.1 Onslte/Offslte Land Use........................................................................................ 21 6.1.2 Water Use................................................................................................................... 22 6.1.3 Water Quallty************************************************************************************************************22 6.1.4 Air Quallty******************************************************************************************************************23 6.1.5 Aquatic EcoloQY....................................................................................................... 24 6.1.6 Terrestrial Ecology**************************************************************************************************26

TABLE OF CONTENTS (CONTINUED) 6.1.7 Threatened and Endangered Species.............................................................. 28 6.1.8 Radiological Occupational Dose

............................................................... 32 6.1.8.1 Phase 1 b Occupational Dose

............................................................... 32 6.1.8.2 Phase 2 Occupational Dose.......................................................................... 33 6.1.8.3 Public Dose........................................................................................................ 34 6.1.8.4 Conclusion.......................................................................................................... 35 6.1.9 Radiological Accidents.......................................................................................... 36 6.1.10 Occupational Issues............................................................................................ 38 6.1.11 Cost.......................................................................................................................... 39 6.1.12 Socloeconom ics.................................................................................................... 39 6.1.13 Environmental Justice......................................................................................... 39 6.1.14 Cultural, Historic, and Archeological Resources..................................... 40 6.1.15 Aesthetic Issues................................................................................................... 42 6.1.16 Noise

................................................................................................................ 43 6.1.17 Transportation....................................................................................................... 43 6.1.18 Irreversible and Irretrievable Commitment of Resources...................... 45 6.2 Environmental Impacts of License Tennlnation................................................. 45 6.3 Additional Considerations.......................................................................................... 45 6.4 Conclusions.................................................................................................................... 46

7. REFERENCES..................................................................................................................... 47 ENCLOSURES A Detailed Cost and Schedule Information (Proprietary) B Detailed Cost and Schedule Information (Non-Proprietary)

REVISION HISTORY Revision Revision Description Number 0

Initial Issue (June 2013).

1 Incorporated infom,ation to update Table 1 to 2012 dollars (November 2013 Changes are on Pages 1 2 14 and 15.

2 Incorporated infomiation resulting from 2014 Decommissioning Cost Analysis, revised information on the post-defueling monitored storage agreement, and incorporated various administrative clarifications.

(December 2015) Changes are on Pages 1, 2, 5 through 15, and 25.

3 Revised section I "Introduction" with general infom,ation pertaining to transfer of ownership of TMl-2 and accelerated decommissioning. Revised section II *Background" to include infomiation that addresses transfer of Possession Only License No. DPR-73 from FirstEnergy to TMl-2 Solutions; Revised section Ill "Description of Decommissioning Activities" to address activities following license transfer to TMl-2 Solutions, updated the project organization, and replaced decommissioning "periods" with decommissioning "phases." Revised section IV "Schedule of Decommissioning Activities,* and section V "Estimated Cost of Decommissioning Activities,* with updated detailed schedule and decommissioning cost infomiation. Changes are on pages throughout.

4 Revised to reflect transfer of license from GPUN to TMl-2 Solutions and transition of TMl-2 from its PDMS state to DEGON. Updated Section Ill to provide a description of decommissioning activities. Updated Section VI "Environmental Impacts" to present the results of the evaluation of potential environmental impacts upon TMl-2. Changes are on pages throughout therefore revision bars are not included.

1. INTRODUCTION to TMl2-RA-COR-2021-0004 Page 1 of 50 GPU Nuclear, Metropolitan Edison Company, Jersey Central Power & Light Company, Pennsylvania Electric Company, and TMl-2 Solutions, LLC, submitted an "Application for Order Approving License Transfer and Confom,ing License Amendments" for TMl-2 to the NRC for review in a letter dated November 12, 2019 (Reference 1). TMl-2 Solutions requested that the Order authorize the license transfer to take place at any time up to one year after date of issuance. The license transfer application was approved by the NRC in Reference 2. TMl-2 Solutions became the TMl-2 licensee on December 18, 2020, following the closing of the transaction specified in the October 15, 2019 Asset Purchase and Sale Agreement among the Applicants (the "ClosingD). TMl-2 Solutions maintains responsibility for all licensed activities at the TMl-2 site, including responsibility under the License to complete radiological decommissioning pursuant to NRC regulations. TMl-2 Solutions has developed this Post-Shutdown Decommissioning Activities Report (PSDAR) for TMl-2 in accordance with the requirements of 10 CFR 50.82, "Tem,ination of license," paragraph (a)(4)(i).

The TMl-2 Possession Only License No. DPR-73 (POL) ("License") is currently maintained by TMl-2 Solutions in accordance with the NRC approved SAFSTOR condition (a 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 Post-Defueling Monitored Storage (PDMS). GPU Nuclear has maintained TMl-2 in the PDMS state since the NRC provisions for cleanup were met on December 28, 1993.

This revision of the PSDAR has been prepared to reflect the transition of the TMl-2 facilities from PDMS to DEGON (a facility undergoing decommissioning).

By letter dated August 14, 2012, (Reference 3) GPU Nuclear infom,ed the NRC of the status of TMl-2 relative to the 1996 decommissioning n,1le changes in 10 CFR 50.51, "Continuation of license,D and 10 CFR 50.82, "Temiination of license.D The letter stated the intent to submit a PSDAR that describes the planned decommissioning activities, schedule, cost estimates, and the environmental impacts of the TMl-2 facility decommissioning. In a letter dated February 13, 2013, (Reference 4) the NRC stated that September 14, 1993 is considered the date of TMl-2's cessation of operations. The September 14, 1993 date coincides with the issuance of amendment 45, which converted the TMl-2 operating license into a POL (Reference 5).

The PS DAR is provided in accordance with the requirements of 10 CFR 50.82 and has been developed utilizing the applicable guidance of Regulatory Guide 1.185 "Standard Format And Content For Post-Shutdown Decommissioning Activities Report," Revision

1.

2. BACKGROUND to TMl2-RA-COR-2021-0004 Page 2 of 50 TMl-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 Unit 1, owned by Exelon Generation Company, LLC (Exelon), which has pem,anently ceased power operations and consistent with 10 CFR 50.82(a)(ii) removed the fuel from the reactor vessel, and the shutdown and defueled Unit 2 owned by TMl-2 Solutions.

TMl-2 is a non-operational pressurized water reactor that was rated at a core therm~I power level of 2772 megawatt-themial with a corresponding turbine-generator gross output of 959 megawatt-electric. TMl-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 steel-lined, 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. The TMl-2 cooling towers are located at the southern end of Three Mile Island adjacent to the TMl-2 turbine building.

GPU Nuclear was issued an operating license for TMl-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-to-secondary 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.

As a result of this accident, small quantities of spent nuclear fuel, damaged core material, and high level waste (collectively referred to as "Debris Materiain) were transported through the reactor coolant system and the reactor building. In addition, a small quantity of Debris Material was transported to the auxiliary and fuel handling buildings (AFHB). Further spread of the debris also occurred as part of the post-accident water processing cleanup activities.

The quantity of fuel remaining at TMl-2 is a small fraction of the initial fuel load; approximately 99 percent(%) was successfully removed in,qthe defueling. Additionally, large quantities of radioactive fission products that were re~sed into various systems and structures were removed as part of the waste processing activities during the TMl-2 to TMl2-RA-COR-2021-00Q4 Page 3 of 50 Cle~nup Program. Th~ clea*nup to meet the NRC post-accident safe storage criteria was completed and acc;epted by the N~C with TMI-?. entering into PDMS in Decem~er 1 ~3.

NUREG_-:0683,- the Programmatic E~vironmental Impact StatefTlent (PEIS) and its three

• Supplemen~ (References 6, 7,* 8, arid 9) provide ~n qyerall evaluation of.the environmental impacts that could result from decontamination ~nd c;iisposition of radioactive wastes begin*ning from when-plant conditlons were stabilizeq after th~ accident and continuing thro*ugh completion of the cleanup from the accident. A discussion *of the PEIS relative to -

TMl-2 environmental impacts is presented in Section*6 "Environmentar Impacts of qecomr:nissionirig Activities."*

Approximately*99°/4 of the fuel was remoyed and *shipped to the Idaho National Engineering and Environmental Laboratory (INEEL) under the responsibility of the U.S.

Department of Energy (O.OE).. The reactor coolant system was decontaminated to t~~

exte,:it pra.ctical to reduce radiation levels to as low as is reasonably achievable.

(ALARA). A?, part of the decon~mination effort, water was removed to th*e extent

• practical from the *reactor coolant system and the fuel transfer canal, and the fuel tran~fer tubes were* isolated. 'Radioactive wastes from the major clean-up activities have.

been shipped *off-site or* has be(3n p~~ka*ged and staged for shipment off-site.

Following the decontamination activities, only the reactor building and* a feY{ areas in the auxiliary and fuel handling 'buildings continued to have general area radiation *1evels *

• higher than those of an undamaged reactor facility nearing the end of its o~rati~g life.

'GPU Nuclear maintained TMl-2-in the PDMS'-state while.successfuJly operating TMl-1 until AmerGen (a joint_venture. be~n Philaqelph_ia Energy Company'and British*

.Energy) purchased the operating TMl-1 from GPU Nuclear in 1998. The sale of TMl-1 included the Ur:iit 1 buildings, structures, and.the majority of the site property; however,.

. GPU Nucl.ear maintained ownership of TMl-2.*

FirstEnergy acquired.GPU Nuclear *and ownership of TMl-2 in 2001 as part of a larger :

• acquisitio*n of GPU. In December 2003, Exelon* Corp. acquired*sole_ownership of TMl-1.*

A monitoring agreement betwe~mGPU Nuclear and Exelon provides for Exeion**.

• performing certain functions at TMl-2, on b~halfof GPU Nuclear, while TMl-2 is in PDMS.

These functions include maintenance and testing, radiol99ical and environmental

.~ntrols;.security and safety functions and licensing activities required by the PDMS Technic~I Specifications and PDM~ Final Safety Analysis Rep*ort. In December: 2020

• TMl:.2 $olutions ~cq*uired ownership of TMl-2, and with that the monitoring agreement

~tween *GPU Nuclear and Exelon is now petween TMl-2 Solutions and Exelon..

A 2004 cost an~lysis f9r decommissioning TM1.:.2 assumed a delayed DECO~ scenario, which deferred the decontamination and dismantling (D&D) activities at TMl-2 until they

• are: synchronized with TMl-1 such that the licenses*for.both units are terminated concurrentlt This scenario assumed a 10-year*dormancy period for TMI:-~, following the*

• . TMl-1 origil"ijll license expiration in 2014, with decommissioning. preparation to begin in 2024. The 1nltial*sche<;fule assumed deCOmrl]i.ssioning_ operations would begin in ~026 to TMl2-RA-COR-2021-0004 Page 4 of 50 and would be completed over a 10-year period with site restoration projected in 2036.

Since that time a 20-year extension to the TMl-1 operating license was granted by the NRC. This warranted a revision to the decommissioning cost analysis for TMl-2.

A 2014 cost analysis for TMl-2 evaluated a DECON scenario that assumes TMl-1 would commence decommissioning upon cessation of operations in 2034 and that the decommissioning programs for both units would run independently from each other.

PSDAR revision 2, section IV "Schedule of Decommissioning Activities," established the schedule for the decommissioning of TMl-2 to commence following the expiration of the TMl-1 Operating License on April 19, 2034, with TMl-2 license termination occurring in 2053. However, with the approval of the application and transfer of the License to TMl-2 Solutions, TMl-2 Solutions will assume all authorities provided for and responsibilities under the License, including possession, maintenance, and eventual radiological decommissioning of TMl-2 and associated buildings and structures. Thereafter, following completion of all necessary engineering and licensing actions, TMl-2 Solutions will move into DECON with the goal to accelerate the decommissioning of TMl-2.

TMl-2 Solutions will commence decommissioning of TMl-2 and will complete all activities necessary to terminate the License and release the TMl-2 site years ahead of the plan reflected in revision 2 of the PSDAR which presumes license termination occurring in 2053. Revised decommissioning schedule information was provided to the NRC in PS DAR Revision 3 (Reference 10). TMl-2 Solutions anticipates completing decommissioning of TMl-2 and releasing the TMl-2 site (except for an area potentially to be set aside for storage of Debris Material on the Independent Spent Fuel Storage Installation (ISFSI)) approximately 16.5 years after the license transfer-seventeen years earlier than the current schedule. Refer to Enclosure 1A, Figure 1A-1 for a detailed TMl-2 decommissioning schedule. A redacted version of the schedule suitable for public release is available in Enclosure 1 B, Figure 18-1. The schedule begins with the date of license transfer and ends with the estimated date associated with completing Phase 2.

2.1 Summary of Decommissioning Alternatives The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Volumes 1 and 2, Regarding the Decommissioning of Nuclear Power Reactors," (GEIS) (Reference 11 ). The three general methods evaluated are summarized as follows:

DECON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

SAFSTOR: After the plant is shut down and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that to TMl2-RA-COR-2021-0004 Page 5 of 50 permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

The decommissioning approach that has been selected by TMl-2 Solutions is the DE CON method. With the completion of the sale of TMl-2 to TMl-2 Solutions the plant will transition from the current PDMS state to DEGON. The decommissioning strategy for the project is to initiate prompt decommissioning with a project goal of achieving unrestricted release of the TMl-2 site, except for the ISFSI.

3. DESCRIPTION OF DECOMMISSIONING ACTIVITIES The objective of decommissioning TMl-2 is to safely perform all the activities associated with decontamination and dismantlement of the remaining plant SSC's and facilities in compliance with applicable federal, state and local rules and regulations.

The TMl-2 facility will remain in a PDMS condition prior to performing any major decommissioning activities1. The PDMS state was established following the accident to ensure 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 (Reference 5) and is governed by a PDMS Safety Analysis Report, PDMS Technical Specifications, and PDMS Quality Assurance 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 which owns and maintains the TMl-1 facility.

As discussed in the TMl-2 PDMS Safety Analysis Report:

There is no credible possibility of nuclear criticality.

1 As defined in 1 O CFR 50.2, "Defiriitions," a "major decommissioning activity" is "any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than Class C waste in accordance with 10 CFR 61.55."

to TMl2-RA-COR-2021-0004 Page 6 of 50 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.

TMl-2 Solutions holds title to and ownership of the TMl-2 power block; any TMl-2 improvements at the site; easements for other portions of the site; and any Debris Material, and high level waste within the TMl-2 facility. TMl-2 Solutions maintains responsibility for developing NRC compliant storage and disposal plans for any remaining Debris Material until title to the Debris Material is transferred to the DOE for disposal. Refer to Section 3.3.3 aRadioactive Waste Management" for a discussion related to disposal of low-level radioactive waste (LLRW). TMl-2 Solutions assumes responsibility for all licensed activities at the TMl-2 site, including responsibility under the license to complete radiological decommissioning pursuant to NRC regulations.

TMl-2 Solutions submitted a license amendment request (LAR) for NRC review (Reference 12) which proposes to remove or revise certain license conditions and technical specification (TS) requirements to reflect TMl-2 facility conditions during DE CON. The changes proposed the elimination of those TS no longer applicable based on current plant radiological conditions and updated safe fuel mass limits (SFML). Upon issuance, this proposed amendment will modify the 10 CFR Part 50 License and the TS to support entry into DECON.

After taking the necessary engineering actions and upon receipt of NRC approval of the LAR (Reference 12) thereby allowing major decommissioning activities to proceed, TMl-2 Solutions will commence decommissioning of TMl-2 and will complete all activities necessary to terminate the license and release the TMl-2 site. TMl-2 Solutions intends to substantially complete decommissioning of TMl-2 and release the site by 2037, except for a potential area set aside for storage of Debris Material on the ISFSI.

Decommissioning activities will be performed in accordance with approved programs and associated implementing procedures as required. Radiological and environmental programs will be maintained throughout the decommissioning process to ensure to TMl2-RA-COR-2021-0004 Page 7 of 50 occupational, public health and safety, and environmental compliance with all applicable laws and regulations.

The decommissioning of TMl-2 has been divided into multiple phases as described below and presented in Table 3-1.

Phase 1 is comprised of Phase 1 a and Phase 1 b. The focus of Phase 1 a is preparation for decommissioning which includes activities such as decommissioning planning, engineering and regulatory activities. The focus of Phase 1 b is Debris Material recovery and source term reduction, which includes the recovery, packaging, and storage of Debris Material and the reduction of the overall radiological source term at TMl-2 and the TMl-2 Site to levels that are generally consistent with a nuclear plant toward the end of its operational life that has not experienced a core-damage accident.

Phase 2 includes the decommissioning and dismantlement of the TMl-2 site to a level that permits the release of the site, except for an area potentially to be set aside for storage of Debris Material on the ISFSI and the License Termination Plan (L TP) as well as site restoration activities.

Phase 3 refers to the management of the Debris Material on the ISFSI, activities associated with Phase 3 include providing security and maintenance for the ISFSI as well as decommissioning the ISFSI.

Major decommissioning activities will occur under Phase 1 b and Phase 2.

Table 3-1 specifies the relationship between the Phases and the activities performed in each Phase. A description of the activities associated with each Phase is provided in the following sections.

Phase Phase 1 Phase 1a Phase 1b Phase 2 Phase 3 Table 3-1 Phase Activities Activities Planning, Engineering, Remediation Preparation for Decommissionino Debris Material Recovery and Source Tenn Reduction Typical Decommissioning and Dismantlement Site Remediation L TP and Site Restoration Debris Material Management to TMl2-RA-COR-2021-0004 Page 8 of 50 3.1 Phase 1a Decommissioning Planning While in Phase 1 a, (which is estimated to last approximately two years) TMl-2 will remain in a PDMS state during which preparations for decommissioning will occur.

Phase 1 a includes planning, engineering, and regulatory activities.

3.1.1 Phase 1 a Activities The types of activities performed during Phase 1a include the following:

Radiological and non-radiological characterization of the site and the surrounding environs.

Identification of transport and disposal requirements for radioactive waste and hazardous waste.

Development of program plans and procedures which governs the conduct of the decommissioning in areas such as Radiological Protection, Waste Management, Safety & Health, Environmental Management, Training, and QA.

Design and fabrication of temporary shielding.

Maintenance of contamination control envelopes.

Procurement of specialty tooling and equipment.

Procurement of radioactive waste shipping containers, specialized waste containers and boxes, casks, liners, and industrial packages for packaging.

Shipment of radioactive liquid waste Removal of non-contaminated components/materials/structures Removal of non-installed LLRW materials ISFSI and Dry Cask Storage System (DCSS) design.

Design, development, installation and maintenance of temporary facilities, or temporary modifications to existing facilities to support D&D activities such as:

Establishment of a temporary D&D electrical distribution system.

Establishment of a temporary material handling or packaging facility.

Repair and upgrade of the site infrastructure including roads, railroad spurs, bridges and facilities.

Design, and maintenance activities associated with restoration of cranes.

Establishment of a temporary liquid radioactive waste processing system.

to TMl2-RA-COR-2021-0004 Page 9 of 50 Establishment of temporary High Efficiency Particulate Air (HEPA) ventilation system(s) or maintenance of existing HEPA ventilation system(s).

Design, development, installation and maintenance of an interim Integrated Decommissioning Support Facility (IDSF).

Preparation of Phase 1a activities will require coordination with Exelon, in accordance with the existing PDMS Service Agreement conditions.

3.1.2 Phase 1 b: Debris Material Recovery and Source Term Reduction Following Phase 1 a TMl-2 will enter Phase 1 b. The purpose of Phase 1 b is to perform the activities associated with Debris Material recovery and source term reduction necessary to produce radiological conditions at TMl-2 that are generally consistent with a plant at the end of its useful life. Activities associated with Phase 1 b can commence following NRC approval of the TMl-2 Solutions issued LAR (Reference 12) that revises the License by deleting the TS, Limiting Conditions for PDMS, and Surveillance Requirements, that are not applicable during decommissioning. Phase 1 b will continue until remediation of the reactor building, and auxiliary and fuel handling building is complete, and Debris Material is packaged and stored on the ISFSI. Debris Material recovery and source term reduction activities that will be performed in Phase 1 b include:

Debris material recovery and source term reduction of the reactor coolant system including the reactor pressure vessel, steam generators, pressurizer, and piping.

Decontamination of locked High Radiation Areas Removal and disposition of material necessary to minimize occupational dose to workers while maintaining As Low As Reasonably Achievable (ALA.RA) requirements.

Removal of piping and components no longer essential to support decommissioning operations.

Debris material recovery and source term reduction activities associated with the reactor building and reactor building basement, auxiliary building, and auxiliary fuel handling building.

Recovery, packaging, and storage of the remaining Debris Material.

Packaging and transportation of LLRW as required.

ISFSI and DCSS related construction to TMl2-RA-COR-2021-0004 Page 10 of 50 Section 3.3.1 "Major Decommissioning Activities" discusses activities that will be performed in Phase 1 b necessary to facilitate source term reduction and Debris Material removal.

The results of radiological surveys performed during Phase 1 b will be used to determine which SSCs are removed as part of Phase 2 decommissioning. Similarly, ALARA considerations may provide the basis to perform removal of SSCs in Phase 1 b.

3.2 Phase 2 Decommissioning Phase 2 includes the decommissioning, license termination and site restoration activities described below. Phase 2 is expected to be completed in 2037.

At the commencement of Phase 2 decommissioning, the TMl-2 facility will generally be in a similar radiological condition as would a plant at the end of its operational life.

The overall goal of Phase 2 is decommissioning of the TMl-2 site to a level that permits the release of the site, except for an area potentially to be set aside for storage of Debris Material on the ISFSI. Decommissioning activities that will be performed in Phase 2 include:

Removing, packaging, and disposing of any remaining radioactive components, structural elements, and equipment in preparation for structural demolition.

Demolishing all plant structures to nominally three feet below grade.

Backfilling the site to the existing grade elevation.

3.2.1 License Termination Also included in Phase 2 is the preparation and execution of the License Termination Plan (L TP) and site restoration activities. The L TP will be prepared in accordance with the requirements of 1 O CFR 50.82(a)(9) and will be prepared at least two years prior to the anticipated date of license termination. The L TP will include a site characterization, description of remaining dismantling activities, plans for site remediation, updated cost estimate to complete the decommissioning, any associated environmental impacts, designation of the end use of the site, and the procedures for the final radiation survey.

The L TP 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 (Reference 13), the L TP will use the guidance contained in NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIMt (Reference 14), 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 L TP is to TMl2-RA-COR-2021-0004 Page 11 of 50 approved, the final remediation of the site facilities and services can commence. These activities include, but are not limited to:

Removal of remaining plant systems, structures 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 reactor building and auxiliary fuel handling building, and any other contaminated facility.

Use of the NUREG-1575 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 L TP, and that the final status radiation survey and associated documentation demonstrate that the facility is suitable for release.

Phase 2 is expected to complete in 2037.

3.2.2 Site Restoration After the NRC terminates the license, site restoration activities will be performed. TMl-2 Solutions currently assumes that remaining clean structures will be removed to a nominal depth of three feet below the surrounding grade level. Affected area(s) would then be backfilled with suitable fill materials, graded, and appropriate erosion controls established.

Non-contaminated concrete remaining after the demolition activities may be used for backfilling subsurface voids or may be transported to an offsite area for appropriate disposal as construction debris.

3.3 GENERAL DECOMMISSIONING CONSIDERATIONS 3.3.1 Major Decommissioning Activities As defined in 10 CFR 50.2, "Definitions," a "major decommissioning activity" is "any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than Class C waste in accordance with 10 CFR 61.55."

Major decommissioniJ activities will take place in Phase 1 b and Phase 2. This includes the removal and disposal of contaminated and activated major components and to TMl2-RA-COR-2021-0004 Page 12 of 50 structures, leading to the tennination of the 10 CFR Part 50 operating license. The following discussion provides a general summary of the major decommissioning activities currently planned for TMl-2.

Prior to starting a major decommissioning activity, the affected components will be surveyed and plans developed to maintain occupational dose As Low As Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR Part 20 during decommissioning. Note the approaches described below may be altered for ALARA and/or cost efficiency purposes in accordance with the TMl-2 Radiological Protection Program.

The reconfiguration and modification of site structures and facilities will be perfonned to support decommissioning operations Modifications to the reactor building or other buildings to facilitate movement of equipment and materials, support the segmentation of the reactor vessel and reactor vessel internals, and for large component removal are described below.

A reactor building waste transfer corridor will be established. The waste transfer corridor will require construction of a new opening in the RB basement. The waste transfer corridor connects the RB basement to the turbine building. The waste transfer corridor will allow movement of demolition equipment and waste to and from the reactor building. The waste transfer corridor will involve structural modifications to the reactor building containment wall and the turbine building. This modification also includes establishing a waste transfer facility in the turbine building. This facility will be used to complete the waste packaging process and to decontaminate the waste containers in preparation for their transfer off site.

To facilitate equipment and waste transport into and out of the Reactor Building it will be necessary to remove the reactor building equipment hatch and expand the size of the hatch opening. The equipment hatch is approximately 8 feet deep and 23 feet in diameter and contains a personnel hatch. The existing access opening could be.

enlarged in multiple ways including squaring off the side and top to create a 25'-0" wide x 25'-0" height opening. This approach would take advantage of the flat face of the exterior 8'-0" thick wall. The existing opening can also be resized to accommodate larger dimensions.

Decontamination of components and piping systems, will be performed as required to control (i.e., minimize) worker exposure. The removal, packaging, and disposal of all piping and components that are no longer essential to support decommissioning operations will be perfonned. This includes the removal, packaging, and disposal of SSCs attached to the reactor vessel.

The segmentation effort required to prepare the Reactor Vessel Internals (RVI) for packaging will be perfonned under water. Mechanical segmentation technologies will be applied which includes use of slow rotating saw blades with a surface pattern that generates "easy to collect' shaped chips (no coiling).

to TMl2-RA-COR-2021-0004 Page 13 of 50 The RVI component will be placed on a volume reduction station (VRS) turntable where it will be cut to the appropriate size to fit into a liner. The equipment that will be used to perfonn the RVI segmentation is based upon the design of the equipment used for the Zion and San Onofre decommissioning projects and incorporates lessons learned from these projects. Water filtration and chip collection systems will be installed to keep dose rates low and visibility high during the project. Segmentation of each of the RVI will be done in accordance with a predetennined segmentation plan designed to maximize the packing factor in the designated containers.

In preparation of reactor vessel (RV) segmentation, the reactor cavity sealing surface around the RV will be removed to make the gap between bio shield and RV accessible.

The free-standing thennal insulation will be removed and disposed of. The RV nozzles will be cut and capped after the inside of the RV is cleaned and dewatered. Measures to cut and cap in-core instrumentation penetrations under the RV will be taken. If additional obstacles or recesses are present in the gap, they will also be removed. At this point the vertical cuts on the RV flange section will be perfonned.

Torch cutting equipment will be installed in the gap between RV and biological shield, supported by a frame capable of turning on its axis as an adaptation to the shielding plate.

Tenting of the cutting area will be used to add a layer of contamination control, as required. The packaging of segments can be performed in the reactor cavity deep end or on the operating floor as appropriate for the exposure rates associated with the segments. Once the RV has been cut and packaged except for the hemispherical bottom head (HBH), the inner part of the shielding plate will be removed and the same torch cutting equipment will be used to cut the RV support skirt after the HBH is attached to the polar crane. The HBH can either be disposed of in one piece or positioned in the refueling pool for manual separation into halves. If dose rates disallow for manual segmentation, a torch guide rack can perfonn the separation cut while the support skirt provides stability.

Other major decommissioning activities that would be conducted include the removal and disposal of the turbine, condenser, pressurizer, steam generators, reactor coolant piping, reactor coolant pumps and motors, spent fuel pool support equipment, and contaminated concrete or metals.

In addition to the reactor and large components discussed above, other plant components will be removed from the Reactor, Auxiliary Fuel Handling Building, Turbine Building, and associated support buildings radiologically surveyed and dispositioned appropriately.

to TMl2-RA-COR-2021-0004 Page 14 of 50 3.3.2 Decontamination and Dismantlement Activities The overall objective of D&D is to ensure that radioactively contaminated or activated materials will be removed from the site to allow the site to be released for unrestricted use. This may be accomplished by decontamination in place, off-site processing of the materials, or direct disposal of the materials as radioactive waste. A combination of these methods may be utilized. The methods chosen will be those deemed most appropriate for the circumstances.

LLRW generated from TMl-2 D&D activities will be managed in accordance with approved procedures and with the intent of complying with commercial disposal facility requirements. This includes the characterization of contaminated materials, packaging, transporting and disposal at a licensed LLRW disposal facility.

3.3.3 Radioactive Waste Management A major component of the decommissioning work scope for TMl-2 is the packaging, transportation and disposing of contaminated/activated equipment, piping, concrete, and soil. A waste management plan will be developed consistent with regulatory requirements and disposal/processing options for each waste type at the time of the D&D activities. LLRWwill be disposed of at EnergySo/utions Clive, Utah LLRW disposal facility assuming it meets the waste acceptance criteria(s) (WAC) for the facility. Class B and Class C LLRW will be disposed of at the Waste Control Specialists (WCS) facility in Andrews, Texas.

LLRW from TMl-2 will be packaged to meet Department of Transportation (Don criteria for shipment and transported by licensed transporters. The waste management plan will be based on the evaluation of available methods and strategies for processing, packaging, and transporting radioactive waste in conjunction with the available disposal facility options and associated WAC.

Transportation will be largely by railroad in standard and specialty bulk packages, such as intermodal containers, and gondola type rail cars.

3.3.4 Removal of Mixed Waste If mixed wastes are generated, they will be managed in accordance with applicable federal and state regulations. Mixed wastes will be transported by authorized and licensed transporters and shipped only to permitted and licensed facilities. If technology, resources, and approved processes are available, these processes will be evaluated to render the mixed waste non-hazardous.

3.3.5 Site Characterization to TMl2-RA-COR-2021-0004 Page 15 of 50 To supplement the plant historical knowledge base the TMl-2 Historical Site Assessment (HSA) and site characterization activities will be perfom,ed prior to and during the decommissioning process. The characterization will further the identification, categorization and quantification of radiological, regulated, and hazardous wastes.

Surveys will be conducted as required, to establish hazardous and radioactive material contamination levels and radiation levels throughout the site. This information will be used in developing procedures, surveys and sampling plans to ensure that hazardous, regulated, and radiologically contaminated areas are remediated and to ensure that worker exposure is controlled. As decontamination and dismantlement work proceeds, radiological surveys will be conducted to maintain a current site characterization and to ensure that decommissioning activities are adjusted accordingly.

As part of the site characterization process, a neutron activation analysis calculation study of the reactor internals and the reactor vessel will be performed Using the results of this analysis (along with benchmarking surveys}, neutron irradiated components will be classified (projected for the future D&D time-frame) in accordance with 10 CFR Part 61, "Licensing requirements for land disposal of radioactive waste." The results of the analysis form the basis of the plans for removal, segmentation, packaging and disposal.

Other SSC associated with the reactor vessel or reactor vessel internals may be classified as Debris Material based upon the type of material adhered to it. Disposal of these SSC's will be in accordance with applicable regulatory requirements.

3.3.6 Groundwater Protection and Radlologlcal Decommissioning Records Program Exelon manages the groundwater (GW) protection program for the TMI site in consideration of the site monitoring agreement between Exelon and TMl-2 Solutions in accordance with the Nuclear Energy Institute (NEI) Technical Report 07--07, "Industry Groundwater Protection Initiative - Final Guidance Document (Reference 15). This program is directed by procedures and will continue during decommissioning.

Records of leaks, spills and remediation efforts are retained and are retrievable to meet the requirements of 10 CFR 50. 75(g). These records are used to determine area classification for purposes of perfom,ing surveys.

Neither the monitoring results of the groundwater protection program nor events noted in 10CFR 50.75(g) reports indicate the presence of long-lived radionuclides in concentrations sufficient to preclude unrestricted release under 10 CFR 20.1402, "Radiological criteria for unrestricted use."

3.4 Phase 3: Debris Material Management to TMl2-RA-COR-2021-0004 Page 16 of 50 DOE retains ultimate authority and responsibility for disposal of Debris Material, pursuant to Standard Contract DECR01-83NE44477. However, there is currently no commercially available option for final disposition of Debris Material. It is likely that once Debris Material is removed from TMl-2 and packaged, DOE will not be in a position to take possession of this material. Therefore, an ISFSI is planned to allow for dry storage of all TMl-2 related Debris Material. Debris Material will remain on the ISFSI until it is transferred to the DOE. The ISFSI will be staffed by a security force. In addition, personnel will be assigned to maintain the ISFSI and comply with the ISFSI license commitments. Shipping of Debris Material will be performed when repositories for this type of waste are developed by the DOE or other disposal options are available.

Following the removal of the Debris Material the ISFSI site will be decommissioned, remediated, and surveyed per the NRG-approved License Termination Plan (L TP).

Following the final site survey and NRC approval, license termination will occur.

3.5 Changes to Management and Staffing Throughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. Staffing levels and qualifications of personnel used to monitor and maintain the plant during the various periods of decommissioning will be subject to appropriate Technical Specification and Emergency Plan requirements. These staffing levels do not include contractor staffing which may be used to carry out future debris material movements, plant modifications, and the D&D license termination site restoration work. Contractors may also be used to provide general services, staff augmentation, or replace permanent staff. The monitoring and maintenance staff will be comprised of radiation protection, radiological environmental monitoring program, plant engineering and craft workers as appropriate for the anticipated work activities.

4. SCHEDULE OF DECOMMISSIONING ACTIVITIES TMl-2 Solutions will commence decommissioning of the TMl-2 facility and will complete all activities necessary to terminate the License and release the TMl-2 site years ahead of the plan reflected in revision 2 of the PS DAR which presumes license termination occurring in 2053. Revised decommissioning schedule information was provided to the NRC in PS DAR Revision 3 (Reference 10). TMl-2 Solutions anticipates completing decommissioning of TMl-2 and releasing the TMl-2 site (except for an area potentially to be set aside for storage of Debris Material on the Independent Spent Fuel Storage Installation (ISFSI)) approximately 16.5 years after the license transfer-seventeen years earlier than the current schedule. Refer to Enclosure 1A, Figure 1A-1 for a detailed TMl-2 decommissioning schedule. A redacted version of the schedule suitable for public release is available in Enclosure 1 B-1. The schedule begins with the date of license transfer and ends with the estimated date associated with completing Phase 2.

to TMl2-RA-COR-2021-0004 Page 17 of 50 TMl-2 Solutions is responsible for developing a storage and disposal plan for any remaining Debris Material until title to the Debris Material is transferred to the DOE for disposal. The long-term management of Debris Material is addressed in the TMl-2 Solutions "Plan for Management of Debris Material" (Reference 16).

5. ESTIMATED COSTS OF DECOMMISSIONING ACTIVITIES As presented in PS DAR Revision 3, for estimated costs under an accelerated decommissioning approach, the updated decommissioning cost analysis completed in December 2018 (Reference 17) was utilized to obtain site-specific commodity quantities, and then EnergySo/utions applied its weights and estimated unit cost factors, which take into consideration the EnergySo/utions execution strategy and the methods and schedule discussed in Section 4 above, to arrive at an updated estimated cost to decommission TMl-2. EnergySo/utions also utilized the latest available industry experience (e.g., information from the Zion and La Crosse projects, and 25 years of experience in planning and engineering for other facilities, including complex decommissioning).

The cost estimate recognizes the present state of TMl-2 decontamination, contingency for unknown or uncertain conditions, the availability of 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 decommissioning cost analysis for TMl-2 has been summarized in Table 5-1. Detailed, proprietary cost and schedule information associated with the decommissioning of TMl-2 is presented in Enclosure 1A. Non-proprietary cost and schedule information suitable for public release is available in Enclosure 1 B.

This PSDAR will not be updated for minor changes in anticipated decommissioning costs. However, the status of TMl-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, TMl-2 Solutions, 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. TMl-2 Solutions 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. If future estimatedAcosts or funding levels change significantly, TMl-2 Solutions will make the necessary acifUstments to ensure that sufficient funds remain available for decommissioning.

to TMl2-RA-COR-2021 -0004 Page 18 of 50 Table 5-1 Three Mile Island Unit 2 Decommissioning Cost Summary **

(thousands of 2020 dollars)

Description Total Cost Planning & Transition 2,785 Engineering & Procedures 11,620 Site Upgrades & Preparations 35,923 Large Component & Building Source Term Reduction 64,367 Waste Packaging Transportation & Disposal 28,912 Other Direct Costs 42,1 25 Undistributed Costs

• 269,143 Performance Baseline 454,875 Contingency 91,477 PHASE 1 TOT AL - SOURCE TERM REDUCTION 546,351 Planning & Transition 3,848 Engineering & Procedures 6,410 Large Component Removal & Building Demolition 39,144 Waste Packaging, Transportation & Disposal 192,1 16 Final Surveys & License Termination 5,775 Site Restoration 27,559 Other Direct Costs 21,638 Undistributed Costs

• 148,806 Performance Baseline 445,296 Contingency 69,533 PHASE 2 TOTAL - DECOMMISIONING & LICENSE 514,830 TERMINATION TOTAL PROJECT 1,061,181

• Undistributed Costs may also be referred to as "Allocated Support Costs"

• • Does not include anticipated costs for long-term storage of Debris Material after Phase 2 until acceptance by the DOE (estimated to be $59.5 million dollars).

to TMl2-RA-COR-2021-0004 Page 19 of 50

6. ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ACTIVITIES To support the PSDAR environmental impacts review, the environmental effects of decommissioning activities planned for TMl-2, as currently understood, were evaluated to determine if potential environmental impacts are bounded by previously issued environmental impact statements. NRC regulation 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 site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." To determine if the estimated potential environmental impacts associated with TMl-2 decommissioning activities are bounded, the potential environmental impacts were compared to those evaluated in:

NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (Reference 11) (Referred to as the Decommissioning GEIS or GEIS), dated November 2002.

NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRG-Licensed Nuclear Facilities (Reference 18), dated July 1997.

Atomic Energy Commission, Final Environmental Statement Related to the Operation of Three Mile Island Nuclear Station, Units 1 and 2 (Reference 19)

(Referred to as the FES), dated December 1972.

NUREG-0112, Final Supplement to the FES Related to the Operation of Three Mile Island Nuclear Station, Unit 2 (Reference 20) (Referred to as the Final Supplement to the FES), dated December 1976.

NUREG-0683, Final 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 Volumes 1 and 2 (Reference 6), dated March 1981.

NUREG-0683, Supplement No. 1, Final Report, 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, Final Supplement Dealing with Occupational Radiation Dose, October 1984 (Reference 7), dated October 1984.

NUREG-0683, Supplement No. 2, Final Report, 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, Final Supplement Dealing with Disposal of Accident Generated Water, June 1987 (Reference 8), dated June 1987.

to TMl2-RA-COR-2021-0004 Page 20 of 50 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, Final Supplement Dealing with Post Defueling Monitored Storage and Subsequent Cleanup, August 1989 (Reference 9), dated August 1989.

As required, site-specific impact assessments were conducted for threatened and endangered species and environmental justice. Site-specific assessments were also perfonned for aquatic ecology, terrestrial ecology, and cultural and historic resources for decommissioning activities beyond the "operational area," as that tenn is defined in the Decommissioning GEIS (Reference 11 ). Although the TMl-2 site boundary is the area under the ownership and control of TMl-2 Solutions, for the purpose of assessing decommissioning environmental impacts, the operational area at TMl-2 is considered to consist of the larger Three Mile Island site, including the north end of Three Mile Island from the fence line encompassing the south parking area northward. The operational area also includes the North and South Access Roads and the junction with the mainline railroad at the North Access Road. This area encompasses the reactor and surrounding buildings, intake structure and discharge pipe, parking lots, laydown yards, landscaped areas, and transportation infrastructure. Excavation of fill within the site boundaries on Three Mile Island could potentially take place outside of the operational area.

The levels of s1gnrficance assigned to site-specific environmental impacts are classified as small, moderate, or large, as defined in the decomm1ss1oning GEIS (Reference 11 ).

TMl-2's decommissioning plans are consistent with the methods assumed by NRC in NUREG 0683, "Programmatic Environmental Impact Statement' and associated supplements (References 6, 7, 8, and 9) and the decommissioning GEIS (Reference 11 ). No unique site-specific features or additional unique aspects of the planned decommissioning have been identified beyond those discussed in the PEIS and the associated supplements. Also, TMl-2 Solutions has concluded that the environmental impacts associated with planned TMl-2 decommissioning activities are either bounded by the impacts addressed by previously issued environmental impact statements or are expected, based on site specific reviews, to be small. The only exception is the need to remove the TMl-2 structures that are eligible for registry as a National Historic Structure due to its age and historical significance. This effect on historical impacts is considered large and will be mitigated by preserving models, documents and photographs of the structures before they are taken down in consultation with the Pennsylvania State Historical Preservation Office (PA SHPO).

As presented in Section 3, "Description of Decommissioning Activities," administrative, regulatory and engineering planning will occur as part of Phase 1 a, while TMl-2 remains in PDMS. Upon entry into DEGON, Major decommissioning activities begin with Phase 1 b, which entails activities necessary to complete the cleanup from the March 28, 1979 accident (i.e., source tenn reduction and Debris material removal). Phase 1 b decommissioning activities are evaluated against the potential environmental impacts to TMl2-RA-COR-2021-0004 Page 21 of 50 analyzed in the PEIS. The objective of Phase 1 b decommissioning is to achieve building and equipment decontamination to the point where general area dose rates approximate those of an undamaged reactor nearing the end of its operating life. At the completion of Phase 1 b, TMl-2 will prepare for Phase 2 decommissioning which entails typical D&D activities. Decommissioning activities performed in Phase 2 are assessed against the GEIS.

6.1 Environmental Impact of TMl-2 Decommissioning The following is a summary of the reasons for reaching the conclusions that the environmental impacts of decommissioning TMl-2 are (1) bounded by the PEIS and supplements and the decommissioning GEIS or (2) site-specific, small, and bounded by other previously issued environmental impact statements, or (3) expected to be site-specific and small, apart from historical impacts. TMl-2 Solutions will notify the NRC in writing and seek appropriate environmental review in accordance with applicable NRC regulations before decommissioning activities occur that could significantly impact the environmental resource. Each environmental resource evaluated in the GEIS is addressed. As a general matter, since TMl-2 is not an operating nuclear facility it had lower generating capacity than the 1,000-MW reference pressurized water reactor (PWR) used in the GEIS to generically evaluate the environmental impacts of decommissioning, and its decommissioning impacts are therefore bounded by those assessments Further, no unique site-specific environmental features or unique aspects of the planned decommissioning activities have been identified other than the historical impact 6.1.1 Onsite/Offslte Land Use In Section 4.3.1 of the GEIS, the NRC generically determined land use impacts to be small for facilities having land-use changes only within the site boundary. For decommissioning that involves land use changes beyond the site boundary, the GEIS concluded that impacts could not be predicted generically and must be evaluated on a site-specific basis.

No offs1te land is expected to be needed to support TMl-2 decommissioning. On-site land is expected to be sufficient for decommissioning activities (e.g., laydown, staging, handling, temporary storage, processing, packaging, and shipping of waste and materials, personnel processing, and parking). Site restoration activities include backfill of excavations. The fill needed will be obtained from material (e.g., crushed concrete) resulting from onsite demolition. If additional fill is needed, it could be excavated from onsIte or, 1f more appropriate or practical, fill could also be purchased. The Pennsylvania Department of Environmental Protection (PADEP) regulates fill and has established criteria for clean and regulated fill and permitting requirements for beneficial reuse of regulated fill under its municipal and residual waste regulations (25 Pa. Code § 287.2 or 271.2). TMl-2 Solutions will comply with state regulations regarding the use of fill materials and will obtain permits as needed.

to TMl2-RA-COR-2021-0004 Page 22 of 50 TMl-2 Solutions has determined that onsite land to be used to support decommissioning at TMl-2 has been previously disturbed and decommissioning activities at TMl-2 would not result in changes in onsite land use patterns. After the site is released for unrestricted use, the land could continue as industrial use or be available for other nonindustrial uses.

TMl-2 Solutions concludes that anticipated onsite land use impacts are bounded by the GEIS.

6.1.2 Water Use The GEIS observes that quantities of water required during decommissioning are trivial compared to those used when a plant is operating. The GEIS mentions construction dust abatement and decontamination (flushing systems or pressure-washing components) as typical decommissioning water uses. NRC asserted in Section 4.3.2 of the GEIS that potential impacts of decommissioning on water use at all plants are neither detectable nor destabilizing and made the generic conclusion that impacts in all cases are small.

Onsite groundwater wells are provided by TMl-1, these wells supply water for domestic water consumption at TMl-2 which includes sinks, lavatories, and garden hose stations.

Since the shutdown of TMl-2 and entry into PDMS, the demand for 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 industrial water supply during operation.

Because TMl-2 Solutions expects water use dunng TMl-2 decommissioning to be much lower than water use during operational years, which is consistent with the statements made in the GEIS, and because there is nothing about TMl-2's design, location, configuration, operating history, or decommissioning plans that would alter or contradict this generic conclusion, TMl-2 Solutions concludes that decommissioning water use impacts for TMl-2 are bounded by the analysis in the GEIS.

6.1.3 Water Quality Decommissioning activities with potential for impacting surface water quality include Debris material removal, stabilization, large component removal, decontamination and dismantlement, and structure dismantlement. Stom,water runoff and accidental releases (spills) are the most likely sources of pollutants entering surface waters during decommissioning. The GEIS asserts that regulatory programs applicable to pem,itted substance releases plus the application of Best Management Practices (BMPs) for controlling stormwater runoff and erosion will render any change in surface water quality from decommissioning activities nondetectable and non-destabilizing. With respect to groundwater, the GEIS noted that demolishing concrete structures and storing rubble on site could result in changes (higher alkalinity) in local water chemistry, but the non-radiological effects of such changes on water quality would be non-detectable offsite at all nuclear power plants. Furthem,ore, Subtitle D of the Resource Conservation and to TMl2-RA-COR-2021-0004 Page 23 of 50 Recovery Act would apply to concentrated subsurface placement of demolition debris, which would limit water quality effects from using rubble and soil as fill material During TMl-2 decommissioning, compliance with permits and adherence to erosion and sediment controls, soil stabilization practices, structural practices, and pollution prevention measures would ensure that water quality impacts from decommissioning are small and temporary. Any land disturbing activities would be of relatively short duration, permitted and overseen by responsible regulatory agencies, and guided by PADEP approved Erosion and Sediment Control BMPs. TMl-2 Solutions will continue to comply wrth applicable regulations which require reporting of hazardous material spills All reasonable precautions will be taken to prevent or mitigate spills of hazardous materials. TMl-2 Solutions will comply with PADEP regulations regarding fill and obtain waste permits as needed. Groundwater movement at TM I-Nuclear Station (TMINS) is into the Susquehanna River. Groundwater at the station is prevented from migrating beneath the river to the mainland by the opposing flow of groundwater from higher land to either side of the river. If any localized alteration in the groundwater chemistry associated with the use of crushed concrete as clean fill were to occur, it would not impact offsite groundwater quality.

Demolition of TMl-2 structures and buildings and related earth-moving work (digging, grading, filling) has at least a limited potential to result in erosion and sedimentation that could affect water quality, but these kinds of construction activities routinely take place around operating nuclear power plants and are subject to th.e provisions of state-issued permits. Cofferdams with dewatering systems would be used to isolate the shoreline area and facilitate removal of the reinforced concrete intake structures. BMPs would be employed to limit erosion while these structures are being demolished/removed. After the intake structures have been removed, measures would be employed to prevent erosion. The existing riprap at the shoreline of the north end of the island that serves to mitigate erosion would be left in place.

In Section 4.3.3 of the GEIS, NRC concluded generically that for all facilities, decommissioning impacts to surface and groundwater quality would be small. Because there is nothing about TMl-2's design, location, configuration, operating history, or decommissioning plans that would alter or contradict this generic conclusion and TMl-2 Solutions would comply with regulatory and permit requirements to protect surface water and groundwater resources, TMl-2 Solutions has determined that impacts of decommissioning on water quality would be small and bounded by the analysis in the GEIS.

6.1.4 Air Quality The GEIS identified decommissioning activities that may affect air quality, including worker transportation to and from the site, dismantling of systems and removal of equipment, mwvement and open storage of material onsIte, demolition of buildings and structures, shj_pment of material and debris to offs1te locations, and operation of concrete batch plants. NRC considered the potential for adverse impacts from these activities, the greatest of which would be fugitive dust, for the range of decommissioning to TMl2-RA-COR-2021-0004 Page 24 of 50 plants and generically determined air quality impacts to be small.

During TMl-2 decommissioning, reasonable and appropriate control measures such as wetting of soil piles and concrete structure demolition by hammering, covering loads and staging areas, and seeding of bare areas would be implemented to control fugitive dust so that emissions do not extend offsite in compliance with PADEP regulations (25 Pa Code §123 2) PADEP requires general permits and permit conditions for portable engines and portable crushers and grinders under 25 Pa. Code §127.514, 127 611 and 127.631 Permits governing air emIssIons from the decommissioning activities and equipment would be obtained as required, and as needed, TMl-2 Solutions, will maintain existing air permits for equipment that will continue to be used during TMl-2 decommissioning The exhaust from commuting and shipping vehicles could affect air quality somewhat, but it is unlikely that air quality would be degraded sufficiently to be noticeable beyond the immediate vicinity of State Highway 441.

Demolition of the TMl-2 cooling towers may involve the use of explosives. The GEIS considered the use of explosives and stated in Section 0.1.3 that control measures would be implemented during demolition to keep releases, including those associated with fugitive dust, within regulatory limits regardless of the methods used during demolition. PADEP also regulates use of explosives (25 Pa. Code Chapter 211 ),

requiring their use to be designed to minimize hazards of noxious gas generation and flyrock (i.e., flying debris) as well as damages from ground vibration and airblast (i.e.,

airborne vibration energy). The necessary explosive use permit would be obtained and explosive use requirements and demolition industry BMPs would be implemented.

In Section 4.3.4 in the GEIS, NRC concluded that the impacts of decommissioning on air quality would be neither detectable nor destabilizing and that current and commonly used mitigation measures should be sufficient. Because (1) the air quality impacts from decommissioning activities at TMl-2 are expected to be temporary, localized, and small in magnitude, (2) reasonable and appropriate control measures would be employed, (3) the appropriate permits would be obtained, and (4) there is nothing about TMl-2 's design, location, configuration, operating history, or decommissioning plans that would alter or contradict the generic conclusion in Section 4.3.4 of the GEIS, TMl-2 Solutions concludes that air quality impacts from TMl-2 decommissioning activities are bounded by the analysis in the GEIS 6.1.5 Aquatic Ecology Aquatic resources may be directly or indirectly impacted by decommissioning act1v1ties.

Direct impacts to aquatic communities may result from shoreline or in-water construction or from dredging. Indirect impacts may result from construction-related erosion and stormwater runoff. These impacts are typically undetectable (or barely discernible) and do not destabilize any important attributes of the resources. The GEIS determined that such decommissioning activities within the operational areas of nuclear power plants, including removal of shoreline or in-water structures, would have only minor impacts on aquatic communities, provided all appropriate BMPs are employed. Therefore, the GEIS concluded generically that aquatic impacts from to TMI2-RA-COR-2021-0004 Page 25 of 50 decommissioning activities within a defined operational area would be small. However, the GEIS noted that if disturbance beyond the operational area is anticipated, potential impacts must be determined through site-specific analysis.

The aquatic resource of chief concern for decommissioning at TMl-2 is Lake Frederic, an impounded section of the Susquehanna River downstream of Middletown, Pennsylvania. The impoundment provides storage capacity for the York Haven Hydroelectric Project.

Biologists under contract to Metropolitan Edison, General Public Utilities Corporation, and Exelon conducted studies of Lake Frederic's aquatic communities over four distinct periods: (1) before TMl-1 and TMl-2 began operating (1970-1973), (2) during peak operation with one or two reactors in service (197 4-1979), (3) the period when both reactors were shut down, following the TMl-2 accident (1980-1985), and (4) following restart of TMl-1 (1986-1990). Differences in distribution and abundance of benthic organisms and fish between years were attributed to fluctuations in environmental variables (e.g., river flow and water temperature). Taken as a whole, the studies show that the Susquehanna River in the vicinity of Three Mile Island supports a healthy benthic macroinvertebrate community and a diverse assemblage of cool water and warm water fishes. There is no indication that pollution-tolerant species or groups predominate in Lake Frederic, or that sensitive or pollution-intolerant species have been excluded.

The decommissioning GEIS identified structure dismantlement as an activity that had potential for adversely affecting aquatic communities. Direct impacts are possible from shoreline or in-water construction or from dredging. Indirect impacts may result from construction-related erosion and stormwater runoff. These impacts are typically undetectable (or barely discernible) and do not destabilize any important attributes of the resources. The GEIS concluded generically that such decommissioning activities within the operational areas of nuclear power plants, including removal of shoreline or in-water structures, would have only minor impacts on aquatic communities, provided all appropriate BMPs are employed. Therefore, the GEIS concluded that aquatic impacts from decommissioning activities would be small.

The Final Supplement to the FES considered the effects of site preparation and construction on aquatic biota in the vicinity of TMINS. The NRC staff compared biological sampling data upstream and downstream of the intake-discharge area and found no major differences in parameters measured that could be causally related to construction activities. The staff concluded that construction impacts were temporary and localized to the intake-discharge area and did not result in any irreversible adverse impacts to the local or river-wide ecosystem. Impacts associated with decommissioning are expected to be similar and bounded by those experienced during the initial construction.

TMl-2 Solutions has determined that it may be necessary to obtain fill from outside of the operational area but within the boundanes of TMINS. In a discussion of controls to TMl2-RA-COR-2021-0004 Page 26 of 50 employed to limit construction impacts, the original FES noted that borrow pits were sited and engineered to ensure that eroded soil was carried toward the pit rather than toward the river. A similar strategy would be employed by TMl-2 Solutions during decommissioning should it be necessary to mine fill dirt from outside of the operational area. This should reduce the potential for impacts to aquatic biota from obtaining fill dirt from areas outside of the operational area. The ground disturbance would be governed by local and state NPDES regulations to minimize runoff and sedimentation to protect surface water resources as discussed in Section 6.1.3. If the excavation of fill dirt could impact wetlands or other water resources, 25 Pa. Code Chapter 105, Dam Safety and Waterway Management, as well as the Clean Water Act (CWA) Section 404 permit requirements would apply. Given that these activities outside the operational area would be conducted in compliance with applicable regulations to protect surface water quality, impacts to aquatic communities would be small.

In conclusion, TMl-2 Solutions has determined that impacts of TMl-2 decommissioning on aquatic resources, including those outside of the operational area, would be small.

Hence, TMl-2 Solutions concludes that such impacts are bounded by the analysis in the GEIS when they occur within the operational area Impacts associated with activities outside the operational area would be similar to those experienced during construction of the station and are bounded by the analyses in the FES and Final Supplement to the FES.

6.1.6 Terrestrial Ecology Section 4.3.6.4 of the GEIS maintains that "for facilities where habitat disturbance is limited to operational areas, the impacts on terrestrial ecology (i.e., plant and animal communities) are not detectable or destabilizing," primarily because most vegetation and wildlife habitat in the operational area was removed during plant construction, which causes the terrestrial habitat to be of low-quality during plant operation and decommissioning (Reference 11 ). NRC staff concluded that, "for such facilities potential impacts to terrestrial ecology are small" and no further mitigation measures are warranted. Site-specific analysis is only required of licensees when decommissioning activities are likely to occur outside of the operational area, or if protected species are inhabiting portions of the operational area at the time of decommissioning (see Section 6.1.7).

Terrestrial habitats in the vicinity of TMl-2 are described in the site-specific environmental assessments listed in Section 5.0, the 2005 Wildlife Habitat Council's Site Assessment and Wildlife Management Opportunities Report (Reference 21 ), and the more recent Three Mile Island Wildlife Management Plan (Reference 22). Before station construction, much of Three Mile Island (approximately 270 acres of high, level ground) was leased to a farmer who cultivated corn and tomatoes. Low-lying areas along the river were, depending on elevation and frequency of flooding, occupied by either bottom land hardwood forest or ¢,tream terrace hardwood forest. All farming on the island ceased in 1968 when constructl}Jn work began on TMINS.

to TMI2-RA-COR-2021-0004 Page 27 of 50 Approximately 200 acres of natural habitat remain on the island, mostly on its southern half. The Wildlife Management Plan describes three primary habitats in the southern half of the island: wetland, grassland, and forest land. Wetlands include forested riparian ("fringe'1 wetlands along the river's edge, former borrow pits (dug during construction) that now have the appearance and function of natural wetlands, and seasonal/ephemeral wetlands. Grasslands and meadows are found in the southern half of the island in some of the areas where crops were once cultivated. Three forest community types are present: bottomland hardwoods, stream terrace hardwoods, and black locust forest. The mix of upland and wetland habitats that developed over a period of 40 years now provide important habitats for an array of amphibians, reptiles, small and large mammals, songbirds, wading birds, and waterfowl.

As noted earlier in this section, NRG staff concluded in the decommissioning GEIS that when decommissioning activities are limited to operational areas impacts to terrestrial resources are expected to be small. Site-specific analysis is only required of licensees when decommissioning activities are likely to occur outside of the operational area.

TMl-2 Solutions has determined that it may be necessary to obtain fill from outside of the operational area but within the boundaries of the TMINS. Should this be necessary, every effort would be made to obtain fill from previously disturbed areas and avoid high-value habitats (wetlands, mature hardwood stands, grasslands). Earth-moving and digging activities associated with excavation of fill outside of the operational area could have both direct impacts (some smaller, less-mobile amphibians and reptiles could be crushed by equipment or buried by fill dirt) and indirect impacts (noise from heavy equipment could disturb birds and larger mammals in the vicinity). With several pieces of equipment operating simultaneously, noise levels can be relatively high at locations within several hundred feet of active construction sites. But construction noise attenuates rapidly over relatively short distances, particularly if dense vegetation is present. Based on noise levels known to elicit a startle response in wildlife (> 75 dBA),

the zone of disturbance generally extends only 400-800 feet from a construction site.

Any disturbance associated with excavating fill material would be temporary, measured in days or weeks or months rather than years, and would have no lasting impact on any ecologically important species. Excavation of fill and restoration activities would, to the extent practicable, be scheduled so as to minimize impacts to nesting birds in compliance with the Migratory Bird Treaty Act.

The FES and the Final Supplement to the FES summarized impacts of construction of station facilities on terrestrial communities. Impacts included permanent loss of native vegetation (wildlife habitat) and noise-related disturbance of wildlife. Impacts associated with excavating fill from outside the operational area to support the decommissioning activities would be similar to those observed during construction of the station and described in the FES (and Supplement) but less severe, because the area disturbed would be much smaller.

In the decommissioning GEIS, the NRC concluded that impacts from decommissioning on terrestrial resources are small provided these activities take place within the operational area, which is assumed to have minimal value as wildlrfe habitat. Outside of to TMl2-RA-COR-2021-0004 Page 28 of 50 a grassy (mowed) field and adjacent patch of woods between the North Access Road and northern end of the island and another small woodlot southeast of the TMl-2 cooling towers, the TMl-2 operational area contains very little wildlife habitat. This field and the patches of woods provide habitat for small mammals and songbirds that can tolerate relatively high levels of human activity and noise and are sometimes collectively referred to as "backyard wildlife." Most of the operational area is occupied by industrial facilities (buildings and cooling towers) and gravel-covered parking lots and equipment storage areas. A site-specific analysis was conducted of impacts of obtaining fill from outside the operational area and detennined impacts to terrestrial resources would be negligible, provided sensitive habitats are avoided and construction BMPs are employed. Impacts associated with activities outside the operational area would be similar to those experienced during construction of the station and are bounded by the analyses in the FES and the Final Supplement to the FES. Therefore, TMl-2 Solutions concludes that impacts of TMl-2 decommissioning on terrestrial resources are small and bounded by the GEIS and previous TMINS environmental impact statements.

6.1.7 Threatened and Endangered Species The GEIS lists stabilization, large component removal, decontamination and dismantlement (removal of contaminated soil), and structure dismantlement as activities with potential to impact threatened and endangered species. The GEIS did not make a generic detennination on the impact of decommissioning on threatened and endangered species but noted that impacts to these species are expected to be minor and non-detectable when activities are confined to the site operational area. Impacts are to be determined on a site-specific basis, paying particular attention to activities outside of the developed operational area. Noise and dust generation from construction activity and increased truck traffic, rather than direct impacts such as habitat destruction, are the primary concerns.

Six species are federally listed as endangered or threatened in Dauphin, Lancaster or York counties as shown in Table 6-1. No bog turtles, Northeastern bulrushes, Northern long-eared bats, dwarf wedgemussels, Indiana bats, or Atlantic sturgeons have been observed on or immediately adjacent to TMI.

to TMl2-RA-COR-2021-0004 Page 29 of 50 Table 6-1 Federally Protected Species in Dauphin, Lancaster, and York Counties, PA County Sclentlflc Name Common* Name

Dauphin, Aclpenser oxylinc!Jus Atlantic sturgeon Lancaster York Dauphin Sc/rpus Northeastern ancistrochaetus.

bulrush Lancaster A/asmidonta dwarf heterodon wedaemussel York Myotis sodalist Indiana bat

Dauphin, Myotls septentrionalis Northern -long-Lancaster eared bat Lancaster Glyptemys bog turtle muhlenbergil

• LE - Listed Endangered, LT - Listed Threatened

'"' PE - Pennsylvania Endangered, DL - Dellsted Data from Pennsylvan!a Natural Heritage Program, 2020b

. Federal Status*

State Status**.

LE PE LE PE LE PE LE PE LT PE LT PE With respect to con*sE}rvation efforts at TMINS, three species are particularly noteworthy:

bc;1ld eagle, peregrine falcon, and osprey.

Bald eagles first nested on Three Mile Island* in 201 O but were seen foraging in the area for two or three decades prior to this date. Bald eagles were delisted by the_ USFWS in 2007- (Federal Register Volume 72, No. 130, July 9,.2007) and were subsequently delisted by the Commonwealth of Pennsylvania in 2014 (44 Pa.B. 1429, March 15, 2014). Although no longer listed under the Endangered Species Act, they are fu.lly protected under another federal statute, The Bald and Golden Eagte Protection Act There are two active bald eagle nests on Three Mile Island, one in the wooded area at

. the northern end of the operational area, north of the North Access Road, and o*ne in a forested area south of the operational area. Bo~h nests have been active. for several years, notwithstanding their proximity to a busy, noisy industrial facility. The north nest is exposec;i to r:iois~ from commuting workers' vehicles that peaks during shift changes as well as noise from delivery/service vehicles. The south nest is adjacent to the South Access Road, which is used infrequently.by TMINS employees but was expqsed to high levels of noise and activity during refueling outages,. when the South Access Road is used by visiting *outage workers for 3-4 weeks. Giv.en that bald eagles have nested successfully on Three Mile Island since 2010 in spite of relatively high levels of disturbance (road noise, night lighting, public address system) associated with both normal plant operations and refueling outages, there is no reason to believe that a similar level of disturbance during decommissioning would prevent eagles from nesting

• or from rearing and fledging young.

Peregrine falcons first nested on the roof of the TMl-1 reactor building in 2002 and have

_produced two or three offspring annually since. Attempts to lure the nesting pafr. to either locations have been successful; however, a new nest has been observed on the TMl-2 reactor building several years ago, and efforts to rem_oye it have not been attempted.

Peregrine falcons are known to exhibit a high* degre~ of nest fidelity, returning to the to TMl2-RA-COR-2021-0004 Page 30 of 50 same breeding territory and nest location year after year. If the peregrine falcons continue to nest on the TMl-2 Reactor Building and present a risk of effecting the schedule for demolishing TMl-2 structures during the falcon nesting season, TMl-2 Solutions plans to contract with specialists prior to building demolition to determine the most feasible method to prevent the falcons from nesting on the structure without harming them and attempt to relocate their nesting site.

Ospreys have nested on the TMl-1 met tower since 2005. They also nest on two platforms erected on the south end of the island Ospreys were delisted by the Commonwealth of Pennsylvania in 2017 (47 Pa.B. 1467, March 11, 2017). They continue to be protected by the Pennsylvania Game and Wildlife Code (Title 34, Pennsylvania Consolidated Statutes), like all raptors in the Commonwealth, but are not afforded the same level of protection as listed (threatened or endangered) species.

No aquatic species listed by the Commonwealth of Pennsylvania or the USFWS (or proposed for listing by the USFWS) has been observed or collected in Lake Frederic and there is no protected or critical habitat present. Therefore, none of the decommissioning activities should affect a protected aquatic species. TMl-2 Solutions will consult with state and federal resource agencies before Major decommissioning activities in water commence to ensure that no listed aquatic species has been discovered in the intervening years and that no species previously documented in Lake Frederic has, in the intervening years, been afforded state or federal protection.

The American holly (//ex opaca), state listed as threatened, was observed in the southern portion of the island during a Site Assessment and Wildlife Opportunities Report carried out for TMl-1 license renewal. With the exception of the bald eagle, peregrine falcon, osprey, and American holly, no additional known occurrences of state-listed species are known on TM I.

Decommissioning activities with greatest potential for directly and indirectly affecting terrestrial plant and animal communities are those scheduled, when major reactor structures are to be demolished such as the TMl-2 cooling towers using either explosives or mechanical means. As discussed in Section 6.1.1, above, land within the operational area is sufficient to provide space for laydown yards, equipment or materials storage, temporary offices, and other decommissioning support areas or structures.

Current parking facilities have been adequate to support refueling and maintenance outages over the years and are assumed to be adequate to support decommissioning.

Because there is ample open space to support TMl-2 decommissioning operations, there would be no reason to clear any land outside of the operational area. Therefore, there would be no direct impacts to the habitat of any threatened or endangered species. Excluding the mining of fill dirt, all decommissioning activities will be confined to the operational area, which does contain a large (approximately 14-acre) field (met tower area) and two small (4-and 8-acre) patches of woods, but these habitats are adjacent to roads and facilities, thus exposed to a constant level of noise and human activity.

to TMl2-RA-COR-2021-0004 Page 31 of 50 Demolition qf the TM 1-2 powerblock structures and cooling towers appears more likely to disturb wildlife, including nesting eagles and peregrine falcons. Demolition of buildings and structures will likely involve large cranes, excavators, pneumatic hammers, concrete and rebar saws and other extremely noisy equipment. These demolition and dismantlement activities are likely to take several weeks or months at a time. Although birds and small mammals on Three Mile Island have apparently become accustomed to traffic noise, diesel generator startup noise, public announcement system noise, and an array of other industrial noises, they are not routinely exposed to noise from the heavy equipment used in demolition work. Taking down the cooling towers with explosives would appear to be less of a concern, because animals would be exposed to elevated sound and pressure levels for a very brief period, perhaps seconds. The cleanup of cooling tower rubble is expected to create more of a disturbance than the implosion/explosion.

All of the activities expected to generate high noise levels will take place in areas well removed from the highest-quality wildlife habitat on the island, the grasslands, wetlands, and forests in the southern portion of the island. As noted in Section 6.1.6, above, the zone of disturbance generally extends only 400-800 feet from a construction site. The northern eagle nest is approximately 2200 feet from the closest structure that will be demolished, the TMl-2 auxiliary building. TMl-2 Solutions will consult with appropriate state and federal resource agencies when a decision is reached on timing and method of cooling tower removal to ensure that agency concerns are addressed.

All decommissioning activities at TMl-2 (with the possible exception of mining fill material) will take place within the site operational area, which was disturbed during construction of the facility and contains only isolated patches of wildlife habitat. The potential impacts of mining fill material outside of the operational area on (non-protected) terrestrial resources were considered in,depth in Section 6.1.6 and could, depending on the site chosen, include (1) removal of vegetation, (2) displacement and/or elimination of smaller, less-mobile animals, and (3) noise or activity-related disturbance of birds and larger mammals. Any of the state-listed birds known to occur in the Three Mile Island vicinity could be disturbed by excavation work but would be expected to simply move away from the sources of disturbance (workers, vehicles, earth-moving equipment).

NRC has determined that potential impacts of decommissioning on threatened and endangered species must be evaluated on a site-specific basis. TMl-2 Solutions has determined that none of the planned decommissioning activities at TMl-2 would eliminate or degrade the natural habitat of any state or federally listed species. The TMl-2 reactor building, which has been used by nesting peregrine falcons for the last several years would be razed. Any indirect (disturbance-related) impacts from construction noise and human activity related to TMl-2 decommissioning would be localized, of short duration, and ecologically insignificant. Birds and mammals that are intolerant of noise and human activity are expected to simply avoid (or move away from) noisy construction sites. TMl-2 Solutions therefore concludes that adverse impacts to to TMl2-RA-COR-2021-0004 Page 32 of 50 threatened and endangered species from TMl-2 decommissioning activities would be small but addressed in accordance with appropriate regulations.

Based on the site-specific findings summarized In this section, TMl-2 Solutions concludes that TMl-2 decommissioning activities are not likely to adyersely affect any threatened or endangered species and will have no effect on any designated critical habitat. However, in the future, when TMl-2 decommissioning activities, such as demolition or disturbance of land areas that could affect a protected species have been finally determined and scheduled, TMl-2 will update the site specific assessment of environmental impacts to protected species in the PSDAR, as needed. To comply with its continuing obligation under 1 0CFR 50.82(a)(6) to assure that no decommissioning activity that would result in significant environmental impacts would be performed without NRC review, the results of the assessment would be provided to the NRC in accordance with applicable NRC regulations.

6.1.8 Radiologlcal The GEIS considered radiological doses to workers and members of the public in Section 4.3.8 when evaluating the potential consequences of decommissioning activities.

6.1.8.1 Phase 1 b Occupatlonal Dose Phase 1 b includes source term reduction and decontamination of the plant to the point where general area dose rates approximate those in an undamaged reactor facility nearing the end of its operating life. Phase 1 b is considered a continuation of the cleanup that was not completed prior to entry into PDMS. In other words, it meets the definition of the delayed cleanup alternative defined by NRC staff in PEIS Supplement 3 (Reference 9).

PEIS, Supplement 3, Table 3.18 "Occupational Radiation Dose Estimate for Delayed Cleanup" (Reference 9) provided estimated occupational dose ranges for remaining cleanup activities. The occupational radiation dose from placing the TMl-2 facility in PDMS, maintaining PDMS for 33 years, and then completing cleanup is estimated to be 1300 to 3300 person-rem. These doses are in addition to the occupational dose already received and the dose required to complete defueling.

As discussed in PEIS Supplement 3, the estimates were based on a task-by-task analysis of the work to be done and were presented as a range of values because of uncertainties in the cleanup process, the technology that will be available when post-storage cleanup is performed as well as the location and depth of penetration of the contamination. For example, it is not known if workers would need to enter the basement during decontamination, and if waste would have to be manually packaged when removed from the basement. A discussion of the methodology used to calculate the occupational doses is found in PEIS Supplement 3, Appendix H.

Phase 1 b is scheduled to start in July 2022, corresponding to approximately 33 years from the date of publication of PEIS Supplement 3 and has a scheduled duration of to TMl2-RA-COR-2021-0004 Page 33 of 50 approximately 6.5 years which makes it reasonable to assume an occupational dose estimate for remaining cleanup activities in Phase 1 b of 1,300 to 3,300 person-rem.

Since the 1979 accident, significant radioactive decay has occurred resulting in greatly reduced impacts of occupational dose to plant workers. The TMl-2 Radiation Protection Program and associated implementing procedures will incorporate ALARA principles into work activities to manage occupational dose to the workforce and minimize radiation exposure to the extent practicable. In addition, advances in technology since entry into PDMS will be implemented in order to manage occupational dose. Examples of technology and methods for consideration to achieve ALARA goals include robotics, remote dismantling of systems and components, remote visual monitoring and remote radiological monitoring.

LLRW will be disposed of at Energy Solutions Clive, Utah LLRW disposal facility assuming it meets the waste acceptance criteria(s) (WAC) for the facility. Class B and Class C LLRW will be disposed of at the Waste Control Specialists (WCS) facility in Andrews, Texas.

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 will be administratively controlled as specified in the Radiation Protection Program to a lower value to ensure that personnel do not exceed regulatory limits. TMl-2 Solutions will develop a Radiation Protection Program that addresses occupational dose administrative limits. The implementation of administrative limits ensures compliance with regulatory limits for occupational dose. 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 maintained ALARA. Dose estimates and tracking of accumulated occupational dose will be an integral part of the radiological work planning process during Phase 1 b. As planning for the Phase 1 b scope of source term reduction progresses, planners will develop detailed source term removal plans for each cubicle or component of the plant using current radiological survey data, plant drawings and walk down information.

TMl-2 Solutions has and will continue to evaluate occupational dose impacts as planning during Phase 1 a proceeds and as new data are collected during Phase 1 b activities. Administrative controls, as well as the use of advanced technologies will ensure that potential impacts of radiological dose to workers will be small.

6.1.8.2 Phase 2 Occupatlonal Dose The goal of Phase 1 b is to reduce source term and remove Debris material to the extent where general area dose rates approximate those in an undamaged reactor facility nearing the end of its operating life. Therefore, following the completion of Phase 1 b, decommissioning activities performed during Phase 2 represents an undamaged reactor decontamination and dismantlement. Because the ALARA program continues to reduce occupational doses, the 2002 GEIS is expected to bound occupational dose impacts for workers during Phase 2.

to TMl2-RA-COR-2021-0004 Page 34 of 50 In much the same manner as Phase 1 b, occupational dose to workers during Phase 2 will be limited to 5 rem/year TEDE as required by 10 CFR 20.1201 (a)(1 )(Q and will be administratively controlled to a lower value to ensure that personnel do not exceed regulatory limits. TMl-2 Solutions will develop a Radiation Protection Program that addresses occupational dose administrative limits. The implementation of administrative limits ensures compliance with regulatory limits for occupational dose. 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 maintained ALARA. Dose estimates and tracking of accumulated occupational dose will be an integral part of the radiological work planning process during Phase 2.

TMl-2 Solutions will continue to evaluate occupational dose impacts as planning for Phase 2 proceeds and as new data are collected during Phases 1 b and Phase 2 activities. Administrative controls, as well as the use of advanced technologies will ensure that potential impacts of radiological dose to workers during Phase 2 will be small.

TMl-2 Solutions has elected to decommission the TMl-2 facility using the DEGON method. It is expected that the occupational dose required to complete the

• decommissioning activities at TMl-2 will be within the range of the cumulative occupational dose estimates for decommissioning PWR plants of 560-1215 person-rem provided in Table 4-1 of the GEIS. At the commencement of Phase 2 decommissioning, the TMl-2 facility will generally be in a similar radiological condition as would a plant at the end of its operational life. Therefore TMl-2 is bounded by the PWRs evaluated in the GEIS. The Radiation Protection Program and associated implementing procedures ensures that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits. There are no unique characteristics at TMl-2 in Phase 2 that would invalidate this conclusion.

6.1.8.3 Public Dose Section 4.3.8 of the GEIS considers doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-15 of the GEIS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower.

The GEIS also concluded that the collective dose and the dose to the maximally exposed individual from decommissioning activities are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50.

Prior to the March 28, 1979 accident at Unit 2, there was no detectable radiological impact due to the normal operation of either unit. From March 28, 1979 on, there were some transient, low level increases in the immediate radioenvironment. The increases were limited to iodine-131 in air and milk, and the gamma immersion dose. The average incremental radiological doses associated with radioactivity increases along critical pathways were:

to TMl2-RA-COR-2021-0004 Page 35 of 50 Inhalation of airborne iodine-131 resulted in about 1.38 mrem to the adult thyroid; ingestion of iodine-131 in cows' milk resulted in about 0.67 mrem to the infant thyroid, and the gamma immersion dose resulted in about 2.4 mrem to the adult There were no detectable increases found in the local off-site radioenvironment due to the accident after April 12, 1979, for gamma immersion dose, May 19, 1979, for iodine-131 in cows' milk, and May 3, 1979, for iodine-131 in air.

The expected radiation dose to the public from TMl-2 decommissioning activities will be maintained within regulatory limits through the continued application of the TMl-2 Radiation Protection Program and associated implementing procedures as well as contamination controls combined with the reduced source term available in the facility.

Section 4.3.8 in the GEIS states that radionuclide emissions in gaseous and liquid effluents are reduced in facilities undergoing decommissioning A review of the Annual Reports of environmental monitoring at TM~2 for the years from 1979 through 2019 demonstrate that radioactivity levels in the offsite environment are not measurably increasing, and that the operation of TMINS had no adverse radiological impact on the environment. It is reasonable to expect that public doses during decommissioning would also be well within such limits. Therefore, TMl-2 Solutions concludes that the impacts of TMl-2 decommissioning on public dose are small and are bounded by the GEIS.

6.1.8.4 Conclusion TMl-2 Solutions concludes that radiological impacts of TMl-2 decommissioning are small for the following reasons:

During Phase 1b the TMl-2 Radiation Protection Program and associated implementing procedures will ensure that dose at the site boundary remain below regulatory limits. Implementation of these procedures take into account detailed work planning, and execution of the D&D work and support activities, including measures to maintain occupational dose ALARA and below the occupational dose limits in 10 CFR Part 20 during decommissioning.

At the conclusion of Phase 1 b decommissioning, and prior to the commencement of Phase 2 decommissioning, the TMl-2 facility will generally be in a similar radiological condition as would a plant at the end of its operational life. Therefore TMl-2 is bounded by the PWRs evaluated in the GEIS. The GEIS generic evaluation of radiological impacts applies to an undamaged PWR. Both occupational dose and public dose should be similar to those of other PWR plants, indicating that TMl-2 doses in Phase 2 are typical.

Deferred or delayed decommissioning as in the case of PDMS allows for A

radionuclides to decay over time, resulting in less dose at the time of

~

decommissioning.

to TMl2-RA-COR-2021-0004 Page 36 of 50 Public doses during TMl-2 PDMS operations have been well within the NRG-established public dose limits and are reasonably expected to decrease during decommissioning.

Therefore, TMl-2 Solutions further concludes that the radiological impacts of TMl-2 decommissioning are bounded by the analysis in the PEIS for Phase 1 b and by the GEIS for Phase 2.

6.1.9 Radlologlcal Accidents Section 4 3 9 in the GEIS examined a range of radiological accidents hypothetically possible during the decommissioning period. These included anticipated operational occurrences, nonnuclear fuel-related accidents, and nuclear fuel-related accidents.

NRC determined that many of these accidents had been previously analyzed in environmental reviews for the operation of the plant. The GEIS concludes that impacts of radiological accidents of all types applicable to decommissioning activities are small.

Given their potential to result in offsite doses, the GEIS considered spent fuel accidents of most concern for decommissioning. Once in dry cask storage, however, spent fuel management is no longer within the scope of decommissioning environmental review because NRC evaluated the environmental impacts of continued spent fuel storage for all nuclear power plants in NUREG-2157, "Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel" (Reference 23). Consequently, the only accidents of importance to offsite doses during decommissioning are those involving spent nuclear fuel in the spent fuel pool. Spent fuel pool accidents would no longer be applicable after the spent fuel is moved to dry cask storage There is no spent fuel being stored in a spent fuel pool at TMl-2. The TMl-2 facility is in a defueled condition; 99% of the fuel has been removed from the site and is being safely stored in an ISFSI at the Idaho National Laboratory. There are no design basis accidents (OBA) associated with TMl-2 and the capability to prevent or mitigate the consequences of a OBA are not applicable to TMl-2.

An unanticipated event and a radiological accident have been evaluated. The fire inside of containment unanticipated event is applicable in Phase 1 a (PDMS) and the High Integrity Cask (HIC) fire accident is applicable during decommissioning in Phase 1 b and Phase 2.

GPU Nuclear performed an unanticipated events analysis as presented in Appendix H, Section 8.2 of the PDMS Safety Analysis Report (SAR). The purpose of the analysis was to determine the unanticipated event that produces the bounding radiological dose at the site boundary during PDMS. This provides the measure upon which to ensure that any activity performed during PDMS will not exceed the radiological dose at the site boundary. The guidance of NUREG/CR-2601 "Technology, Safety and Costs of Decommissioning Reference Light Water Reactors following Postulated Accidents,*

(Reference 24) was used as the basis for the selection of the unanticipated events that were analyzed. The results of this analysis indicate that a fire in the reactor building to TMl2-RA-COR-2021-0004 Page 37 of 50 (RB) with the RB purge system in operation is the unanticipated event that produces the bounding radiological dose at the site boundary during Phase 1 a (PDMS). No major decommissioning activities will occur during Phase 1 a. Therefore, an unanticipated event involving a major fraction of the remaining inventory of radionuclides is not likely.

The fire inside of the RB with the RB ventilation and purge in operation was evaluated by the NRC as part of the Exelon request for exemption from portions of 10 CFR 50.47 and 10 CFR 50, Appendix E (Reference 25). Per the TMl-2 Fire Protection Program Evaluation (Reference 26) which was used as an input to the exemption request, the dose at the exclusion area boundary is 13.5 mrem expressed as a bone dose. Due to the isotopic mix (e.g., negligible amounts of iodine) and the nature of potential releases (i.e., particulate matter), a more restrictive basis (i.e., the critical organ) for comparison was selected for reporting dose for TMl-2 fires.

The results of the NRC evaluation confirm the conclusions presented in the PDMS SAR.

The TMl-2 facility would not have consequences that could potentially exceed the applicable dose limits in 10 CFR 100.11 and 10 CFR 50.67 and the dose acceptance criteria in Regulatory Guide 1.183 "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors~ (Reference 27). The analysis demonstrates that 365 days after permanent cessation of power operations, the radiological consequences of the analyzed unanticipated event will not exceed the limits of the EPA early phase Protective Action Guides (PAGs) at the Exclusion Area Boundary (EAB). The NRC approved the exemption request to eliminate offsite emergency response (Reference 28) in part based upon the FPPE (Reference 26). As stated in Reference 28 the NRC staff concluded that granting the requested exemptions to Exelon would provide reasonable assurance that an offsite radiological release will not exceed the limits of the EPA PAGs at the site's exclusion area boundary for remaining applicable design-basis accidents. The summary of the NRC analysis of this event relative to dose at the site boundary is presented in Reference 28.

After the issuance of Reference 28, the Fire Protection Program Evaluation (Reference

26) was revised and reissued as Revision 13 (Reference 29). Revision 13 of the Fire Protection Program Evaluation uses updated source term information which accounts for 26 years of decay (1992 through 2018) as well as accounting for additional loose contamination. Federal Guidance Reports 11 and 12 are applied for dose conversion factors.

The results presented in Reference 29 indicate that the fire inside of the RB with the RB ventilation and purge in operation remains the most limiting unanticipated event and that the dose at the exclusion area boundary is 12.4 mrem expressed as a bone dose which is less than 13.5 mrem as reported in Reference 28. The dose at the site boundary does not exceed the limits presented in 10 CFR 100.11 and the EPA PAGs.

Following Phase 1 a, TMl-2 will transition into Phase 1 b. Prior to performing any major decommissioning activities an analysis of credible accidents that may occur during Phase 1 b was performed in order to determine the limiting radiological dose at the site to TMl2-RA-COR-2021-0004 Page 38 of 50 boundary.

The results of the analysis indicate that a HIC fire is the event that could occur during decommissioning with the potential of maximizing dose at the site boundary. The HIC fire event is postulated to occur either inside or outside of containment. Outside of containment the release involves an unfiltered, ground level release that takes no credit for the operation of any SSCs to mitigate the consequences of the event. The dose at the site boundary associated with the HIC fire occurring outside of containment bounds the dose from the HIC fire inside of containment with the containment engineered access equipment hatch open, as well as with or without RB ventilation and purge system in operation and does not exceed the requirements of 1 O CFR 100.11 and the EPA PAGs. The dose at the EAB for a HIC fire occurring outside of containment is 975 mrem; the dose at the EAB for a HIC fire occurring inside of containment is approximately 490 mrem, which is still below the requirements of 10 CFR 100.11 and the EPA PAGs. Reference 12 provides a detailed discussion relative to the detemiination of the HIC dose.

There are no postulated accidents that can occur inside of the RB during Phase 1 b or Phase 2 that result in the dose at the site boundary exceeding the limits of 10 CFR 100.11 and the EPA PAGs including such times as when the containment engineered access equipment hatch is open. The D&D process includes many evolutions that will require the equipment hatch and other RB access points to be open to allow movement of equipment, waste, and other materials into and out of the RB. The Radiation Protection Program will identify the controls that will be implemented through procedures during D&D activities occurring inside of the RB. Implementation of these procedures take into account detailed work planning, and execution of the D&D work and support activities, including measures to maintain occupational dose ALARA and below the occupational dose limits in 10 CFR Part 20 during decommissioning.

TMl-2 Solutions concludes that radiological accident impacts of decommissioning activities at TMl-2 would be small and are bounded by the analysis in the GEIS. TMl-2 Solutions knows of no unique features or conditions at TMl-2 that would lead to a conclusion concerning radiological accidents different than that reached in the GEIS.

6.1.10 Occupational Issues Section 4.3.1 O of the GEIS concluded that impacts due to occupational issues would be small for all plants based on strict adherence to Occupational Safety and Health Administration (OSHA) safety standards, practices, and procedures.

TMl-2 decommissioning will be conducted under a comprehensive non-radiological safety and health program meeting OSHA, NRC, and TMl-2 Solutions procedural requirements. Historically, the nuclear power industry has lower rates of injuries and illnesses than other industries. Demolition of the TMl-2 cooling towers may involve the use of explosives. NRC cgnsidered the use of explosives during decommissioning and specifically mentioned the hazards of fugitive dust and noise levels from blasting in to TMl2-RA-COR-2021-0004 Page 39 of 50 Sections 0.1.3 and 0.1.14 of the GEIS. As discussed in Section 6 1.4, PADEP regulates the use of explosives, requiring their use be designed to minimize hazards to workers and the public. Blasting activities would take place under the control of licensed personnel and the blasting activities would be subject to state issued pennits that ensure the activity can be conducted safely. OSHA regulations for worker protection would also ensure that the appropriate worker protection programs such as a respiratory protection plan and hearing protection plan were in place.

The TMl-2 site-specific decommissioning plan poses no unique hazards from what was evaluated in the GEIS. Accordingly, TMl-2 Solutions concludes that anticipated impacts resulting from nonradiological occupational issues during TMl-2 decommissioning are small and thus bounded by the analysis in the GEIS.

6.1.11 Cost A site-specific decommissioning cost analysis is presented in Section 5.0. Section 4.3.11 of the GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act (NEPA) requirement. Therefore, a bounding analysis is not applicable.

6.1.12 Socioeconomics Section 4.3.12 of the GEIS evaluated changes in workforce and population changes, changes in local tax revenue, and changes in public services. The GEIS concluded that socioeconomic impacts are neither detectable nor destabilizing and that mitigation measures are not warranted. TMl-2 ceased operations in 1979 and has been maintained in a PDMS condition since December 1993 by a limited workforce provided by Exelon under a monitoring services agreement.

The results of the TMl-1 socioeconomic analysis state that impacts to socioeconomic resources as a result of TMl-1 decommissioning are small and bounded by the analysis in the GEIS (Reference 11 ). Considering TMl-2 has been in PDMS for approximately 27 years the impact upon socioeconomic resources while maintaining the PDMS condition are considered small relative to the results of TMl-1 socioeconomic analysis.

Furthennore, the workforce associated with TMl-2 decommissioning at its highest is small, approximately 135 individuals, as compared to the last two TMl-1 refueling outages (T1 R22 (2017) 936 contractors badged, T1 R21 (2015) 1705 contractors badged) and not expected to destabilize housing prices or impact tax revenues as discussed in the TMl-1 socioeconomic analysis. Therefore, based on the findings summarized above, TMl-2 Solutions concludes that impacts to socioeconomic resources from TMl-2 decommissioning would be small and thus bounded by the analysis in the GEIS.

6.1.13 Environmental Justice Section 4.3.13 of the GEIS determined environmental justice to be an environmental impact area for which no generic conclusion could be determined due to its site-to TMl2-RA-COR-2021-0004 Page 40 of 50 specific nature. Therefore, the GEIS indicates that site-specific assessments for each decommissioning nuclear power plant must be prepared.

Since TMl-2 occupies the same operational area as TMl-1, and in consideration of the proximity of TMl-1 to TMl-2, it is concluded that the results of the site-specific assessment of environmental justice prepared by Exelon (Reference 30) for TMl-1 is applicable to TMl-2.

The Exelon site-specific assessment of TMl-1 examined the geographic distribution of minority and low-income populations within a SO-mile radius of TMINS using the 2012-2016 American Community Survey 5-year estimates. Census block groups containing minority populations were identified and were concentrated in the larger metropolitan areas of Harrisburg, Reading, Lancaster, Lebanon, and York. The nearest minority population blocks are located southeast of Harrisburg, about 5-6 miles northwest of TMINS. Census block groups containing low-income populations were concentrated in the cities of Harrisburg, Reading, Lancaster, and York. The nearest low-income populations are located southeast of Harrisburg, about 5-6 miles northwest of TMINS.

The site-specific assessment performed for TMl-1, determined that decommissioning impacts to all resource areas would be small, indicating that the effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. Because no member of the public will be substantially affected, there can be no disproportionately high and adverse impact or effects on minority and low-income populations resulting from the decommissioning of TMl-1.

TMl-2 Solutions concurs with the results of Exelon's analysis and therefore concludes that the effects of decommissioning TMl-2 are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. Because no member of the public will be substantially affected, there can be no disproportionately high and adverse impact or effects on minority and low-income populations resulting from the decommissioning of TMl-2.

6.1.14 Cultural, Historic, and Archeological Resources Section 4.3.14 of the GEIS determined that potential effects of decommissioning on cultural, historical and archaeological resources would be small for all plants when the decommissioning activities are confined to the operational area. However, impacts outside the operational area "must be determined through site-specific analysis." TMl-2 Solutions anticipates that decommissioning activities will take place within the TMl-2 operational area, except for the possible excavation of fill from on site areas outside of the operational area to backfill the foundations of buildings and structures after demolition In Section 4.3.14.2 of the GEIS, NRC noted the potential for the nuclear facility itself to be potentially eligible for inclusion in the National Register of Historic Places (NRHP),

to TMl2-RA-COR-2021-0004 Page 41 of 50 especially if it Is older than 50 years and represents a significant historic or engineering achievement. TMl-2 is a typical mid-twentieth century light water reactor. The design, engineering processes, and construction of TMl-2 are unexceptional and lacking any major engineering innovations. The engineering drawings from the station will be archived by records management until decommissioning is complete.

TMl-2 was classified as a historic structure eligible for listing on the NRHP in 2010 (Reference 31 ). In Reference 32, TMl-2 Solutions acknowledged that TMl-2 is a historic site and that cultural resources exist on Three Mile Island and requested input from the State Historic Preservation Office (SHPO) regarding concerns that should be considered in the assessment. Reference 33 presents the SHPO response.

References 32 and 33 are provided in Attachment 4. TMl-2 Solutions is working with the SHPO to determine which documents, models and artifacts should be preserved and turned over to state historic collections.

Because TMl-1 and TMl-2 are located within the same operational area with virtually identical resources, TMl-2 Solutions benefits from previous historic and archaeological database searches. Information provided in Exelon's TMl-1 PSDAR (Reference 30),

reports locations of inventoried resources on the island and within an approximately 6-mile radius.

One archaeological site within the TMl-1 and TMl-2 operational area (identified on the NRHP as 36DA50) is believed to remain intact. The site is north of the access road at the northern end of the operational area. Its eligibility for listing on the NRHP is categorized as undetermined due to insufficient information, presumably due to uncertainty about its current condition.

Six archaeological sites are located on the central and southern portions of Three Mile Island outside the TMl-1 and TMl-2 operational area but within the TMINS property boundary. In 2016, one of these archaeological sites (36DA 100) was determined to be eligible for the NRHP. That site is at the south end of the island near the South Access Road. Another archaeological site (36DA98) is immediately south of the operational area in a location used for staging and soil borrowing during construction of the station, and it was likely removed by those construction activities. A third site (36DA51) has been determined to be not eligible for listing, and three more sites (36DA99, 36DA 101, and 36DA235) are considered unevaluated due to insufficient information.

Beyond Three Mile Island operational area, but within a 6-mile radius, there are 13 properties currently listed on the NRHP and 32 NRHP-eligible properties. One property, a section of the Pennsylvania Railroad Main Line linear historic district, lies 0.4 miles away from TMl-1 and TMl-2 and the remaining properties are more than 1 mile away.

Exelon developed a map assessing the archaeological potential of the entirety of Three Mile Island. The map depicts much of the island a~ either disturbed due to construction of the station or as having low potential due to dist~nce from river channels and reduced likelihood of deep, Holocene epoch alluvial deposits. The perimeter of the island, to TMl2-RA-COR-2021-0004 Page 42 of 50 including the northern end within the TMINS operational area where one site is located, and the southern end, where four sites occur, has high archaeological potential. Away from the shoreline, the southern end of the island has moderate archaeological potential, including areas adJoining the TMl-1 operational area along the South Access Road.

TMl-2 Solutions will use the Exelon Cultural Resources Protection Plan and Archaeological Resources Erosion Monitoring Plan, which will provide protocols for ensuring continued stewardship of cultural resources on Three Mile Island during the TMl-2 decommissioning project. In addition, procedures will provide direction and contact information should an unanticipated cultural resource be encountered.

It is anticipated that backfill for demolished building and structure foundations will be sourced from onsite demolition activities. If additional clean fill is needed, it could be obtained from onsite within or beyond the operational area. Prior to excavating backfill outside of the operational area, TMl-2 Solutions will evaluate the area's archaeological sensitivity and implement its protocols that will have been developed for the project to ensure continued stewardship of cultural resources on Three Mile Island.

Use of explosives for demolition of the natural draft cooling towers is anticipated and will be in accordance with applicable PA DEP regulations (25 Pa. Code §211) and best management practices and will seek to minimize the generation of fugitive dust, avoiding possible adverse effects to historic properties. PA DEP regulations for use of explosives also limit peak particle velocities to minimize ground vibration that could damage structures. Demolition of the natural draft cooling towers will be performed in accordance with regulatory limits, but also by use of innovative techniques that will be carefully planned, reviewed and executed under controlled conditions. The collapse of the towers is not expected to adversely affect currently identified historic properties.

Based on the findings discussed above, TMl-2 Solutions concludes that impacts of TMl-2 decommissioning to cultural, historical, and archaeological resources, including those from possible excavation of fill material within the TMINS boundanes but outside of the operational area, are large and that environmental impacts will be clearly noticeable and sufficient to destabilize important attributes of the resource.

6.1.15 Aesthetic Issues In Section 4.3.15 of the GEIS, the NRC singles out structure dismantlement and entombment as the only activities that may have impacts on aesthetic resources. The aesthetic impacts of decommissioning fall into two categories: (a) impacts, such as noise, associated with decommissioning activities that are temporary and cease when decommissioning is complete and (b) the changed appearance of the site when decomm1ss1oning is complete. NRC drew the generic conclusion that for all plants, the potential impacts from decommissioning on aesthetics are small and that the removal of structures is generally considered beneficial to the aesthetics of the site.

During TMl-2 decommissioning, the impact of noise and dust would be temporary and to TMl2-RA-COR-2021-0004 Page 43 of 50 controlled to minimize impacts. The appearance of TMl-2 will be altered as the buildings and structures are dismantled. There are clear views of the plant from the Susquehanna River and of the taller structures from the mainland. The visual intrusion during dismantlement would be temporary and would serve to reduce the aesthetic impact of the site. Therefore, TMl-2 Solutions concludes that the impacts of TMl-2 decommissioning on aesthetics are small and generally considered beneficial. Thus, such impacts are bounded by the analysis in the GEIS.

6.1.16 Noise Section 4.3.16 of the GEIS generically examined noise during decommissioning, concluding that noise impacts would be small.

Decommissioning activities would be comparable to the initial construction of the plant.

Section 4.3 of the operations phase Environmental Report (ER) for TMl-2 (Reference 34) characterizes the construction activity as normal sounds from heavy equipment and the work accompanying a large construction project. The ER notes that the remote location of the site minimizes the effect of noise on the public.

NRC also considered the higher noise levels of demolition methods including use of pneumatic drills or explosives and concluded that environmental effects may be minimized by proper scheduling due to the short duration and isolated use of such methods. The consideration of these higher noise activities in Section 0.1.4 of the GEIS did not alter NRC's conclusion that it is unlikely that the noise associated with most decommissioning activities will be of sufficient strength to be environmentally detectable or to destabilize the environment. In addition, PADEP has established regulatory limits for airblast (i.e., audible and in-audible airborne vibration energy) from the use of explosives, requires a PADEP-issued permit for blasting, and requires that blasting activities take place under the control of licensed personnel.

Decommissioning activities will be primarily limited to previously disturbed land surrounding the power block and isolated from both wildlife and members of the public.

The noise levels associated with the decommissioning activities are not expected to be any more severe than during the initial construction of the station or refueling outages and are not expected to present an audible intrusion on the surrounding community and environment. Higher noise levels may occur dunng the demolition of the cooling towers, but that activity will be limited In duration.

Therefore, because TMl-2 decommissioning activities are of the type previously considered by NRC and TMl-2 has no site-specific conditions that would alter the NRC's prior findings, TMl-2 Solutions concludes that the noise impacts from decomm1ss1oning activities would be small and thus bounded by the analysis in the GEIS.

6.1.17 Transportation In Section 4.3.17 of the GEIS, NRC states that its "... regulations are adequate to protect the public against unreasonable risk from the transportation of radioactive materials."

. to TMl~:-RA-COR-2021-0004 Page 44 of.50 Therefore,.the effects of transportation of radioactive waste on public health and safety are considered to be neither detectable nor destabilizing. TMl-2 will comply with NRC and Department pf Transportatiol"! regulations*for shipments of radioactive wast~ from TMl-2 decommissioning.

The GE.IS.analyzes radiological.shipments of waste from decommissioning and calculc;1tes incid_ent-free doses and la~nt cancer fatalities to crew, the*public along the route, and orilodkers.. The GEIS also calculates th_e collective dose for radiological.

. ~ccidents d_uring tran~portatiori. The calcul~ted impacts ar~ closely related to the distance shipped, volumes shipped, and activity levels. The.estimated volumes*of LLRW ass.ociated with TMl-2 decommissioning are summarized in Table 6-2 *using waste types fr.om _the GEIS._

TABLE 6-2 Estimated Radloactlve Waste Associated.with TMl-2 Decommissioning Waste Class Volume (cf)

Class A 4,200,000 Class B & C

• 17,000 Class A wastes ~ill be shipped to the Energy Solutions* disposar site_ in Uta.h and Class B and C-wastes will be shipped to the Waste:control Specialists facility in Andrews, Texas. Approximately 99% of all wastes will be shippe9.to the disposal site via rail. As. *

. stated in the GEIS "shipmerJt of spent fu~I by rail reduces the radiol99ical impacts.

• significantly (more than a factor.of 10 for shipments from the northeast tp Nevadc;1). :

.. Similar reductions would be expected in the radiological impacts of'the shipment Of LLW.

from decommissioning if shipments were m*acte by rail rather than by truck."

If ~diologic_al impa$ alone ~re*considerecl, the conclusions i_n the GEIS w9ulci'bound the impacts of transportation.of radioactive waste from TMl-2 deconimissioning.. The TMl-2 waste shipments wou!d travel shorter distances than were.analyzed in the GEi$.

For TMl-2, the volumes would be lower for both high-activify and low-:-activity wa~te tha*n

• the waste volumes NR_C conside~ in th*e GEIS a~alysis. *

• Section 4.3.17 of the. GEIS recogn_izes non-,:adiological impacts of transportation t9

. include increased traffic, wear and tear on area roadways, and in9reased traffic accidents from both radiological and noA-radiological transport, including that for:

hazar:ctous waste. NRC concluded that transporting materials to and from a decommissioning site wo*uld not significilntly impact the qve~II traffic volume or:.

compromise the safety of the. public. TMl-2 's waste shipments* are not expected to be

• Iarge enough in *number to have a detectabl~ or destabilizing effect on*traffic flow or road wear. The number qf workers during the de~mmissioning phases is expected to be below the number of temporary worke~ supporting Exelon during TMl-1 ref1:1eling outages*as noted in Section 6.1.12. Conseql!ently, challeng_es* to the existing*

to TMl2-RA-COR-2021-0004 Page 45 of 50 transportation infrastructure are not expected. Furthermore, the combination of radioactive shipments, non-radioactive shipments, and other transportation will occur over an extended time and will not result in significant changes to public safety or the transportation infrastructure.

The GEIS concludes that both non-radiological and radiological impacts of decommissioning transportation are small. No unique features or site-specific conditions are present at TMl-2 that would alter these NRC prior findings. Therefore, TMl-2 Solutions concludes that transportation impacts of TMl-2 decommissioning are small and thus bounded by the analysis in the GEIS.

6.1.18 lrreverslble and lrretrlevable Com mltment of Resources Section 4.3.18 of the GEIS generically concluded that the impacts of decommissioning on irreversible and irretnevable commitments of resources are small. Given that TMl-2 would be decommissioned to radiological standards for unrestricted release, the land will be available for other uses. Furthem,ore, the materials and fuel consumed during TMl-2 decommissioning would be minor. The decommissioning of TMl-2 would generate radioactive waste and non-radiological waste requiring land disposal. Land devoted to radioactive waste disposal sites or industrial landfills was not within the scope of the GEIS because such commitments are addressed in the licensing documents for the disposal sites. Therefore, TMl-2 Solutions concludes that the impacts of TMl-2 decommissioning on 1rrevers1ble and irretrievable commitments of resources would be small and thus bounded by the analysis in the GEIS.

6.2 Environmental Impacts of License Termination A license termination plan (L TP) for TMl-2 will be developed and submitted to the NRC approximately two years prior to the anticipated license termination date. The L TP will include a supplemental review of environmental impacts describing any new information or significant environmental change associated with the proposed termination activities.

Although the L TP, including a supplemental environmental review, need not be prepared and submitted until a minimum of two years prior to the anticipated license termination date, as required by 10 CFR 50.82(a)(9), the absence of any unique site-specific factors, significant groundwater contamination, unusual demographics, or impediments to achieving unrestricted release indicate that impacts resulting from TMl-2 license termination will be similar to those evaluated in NUREG-1496 (Reference 18).

6.3 Addltlonal Considerations The following considerations are relevant to concluding that TMl-2 decommissioning activities prior to license termination will not result in significant environmental impacts not previously reviewed:

Continued compliance with radiological release and dose regulatory limits and adherence to plant procedures for monitoring.

to TMl2-RA-COR-2021-0004 Page 46 of 50 Continued-site access control to minimize or eliminate radiation release pathways to the public.

Transport of radioactive waste in accordance with plant procedures, applicable Federal regulations, and the requirements of the receiving facility.

Continued adherence to ALARA principles during decommissioning and compliance with occupational dose limits.

Continued compliance with applicable regulations and permit conditions.

Continued storage of Debris Material in accordance with license conditions and plant procedures 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 TMl-2 facility has already been completed with approximately 99% of the fuel debris removed and shipped to INEEL.

Radiation protection techniques and technology have advanced since the plant entered PDMS in 1993 and are expected to significantly reduce occupational exposure.

6.4 Concluslon TMl-2 Solutions has performed an environmental review to evaluate environmental impacts associated with decommissioning activities; confirming that the anticipated or potential impacts are within the bounds of the NRC prepared PEIS (References 6,7, 8, and 9) during Phase 1 b as well as the generic impacts that NRC described in the GEIS (Reference 11 ).

This evaluation indicates that TMl-2 decommissioning activities fall within the range of decommissioning activities considered by NRC in the PEIS and GEIS. There are no unique aspects of the plant or the expected decommissioning techniques that would invalidate the conclusions of the PEIS or GEIS. The evaluation indicates that the impacts of TMl-2 decommissioning are bounded by the GEIS's assessment for those environmental issues for which NRC made generic determinations. For the areas where a site-specific assessment was required, the anticipated impacts from TMl-2 decommissioning were determined to be small and bounded by the plant's FES with the exception of the cultural, historical, and archaeological resources which is classified as large as discussed in Section 6.1.14. In addition, after decommissioning plans mature and before decommissioning activities occur that either could be potentially impactful to an environmental resource for which a site-specific assessment was required or would be otherwise inconsistent with those actions or activities described in the PSDAR, TMl-2 Solutions will notify the NRC in writing and seek appropriate environmental review in accordance with applicable NRC regulations.

7. REFERENCES to TMI2-RA-COR-2021-0004 Page 47 of 50

1. Halnon, G.H. (GPU Nuclear, Inc.), Sauger J. (TMl-2 Solutions LLC) letter TMl 112 "Application for Order Approving License Transfer and Conforming License Amendments," (ML19325C600) dated November 12, 2019.

2. Letter from USN RC to Sauger, J. (TMl-2 Solutions, LLC), "Three Mile Island Nuclear Station, Unit No. 2-Issuance of Amendment No. 64 Re: Order Approving Transfer of License and Conforming License Amendment (EPID L-2019-LLA-0257)," (ML20352A381) dated December 18, 2020.

3. Pace, D. L. (GPU Nuclear) to NRC letter, "Notification of Intent to Submit a Post-Shutdown Decommissioning Activities Report," (ML12235A227) dated August 14, 2012.

4. Camper, L. W. (NRC) to Pace, D. L. (GPU Nuclear) letter, "Three Mile Island Nuclear Station, Unit 2 (TMl-2) - Failure to Submit Post-Shutdown Decommissioning Activities Report - Non-cited Violation (Docket: 05000320),"

(ML12349A291) dated February 13, 2013.

5. 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.

6. NUREG 0683 "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," Volume 1 and Volume 2, dated March 1981.

7. NUREG 0683 Supplement 1, "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,"

(Occupational Radiation Dose), dated October 1984.

8. NUREG 0683 Supplement 2, "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," (Disposal of Accident-Generated Water), June 1987.

9. 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, (Post-Defueling Monitored Storage and Subsequent Cleanup) dated August 1989.

to TMl2-RA-COR-2021-0004 Page 48 of 50

10. Halnon, G.H. (GPU Nuclear, Inc.), "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 3 (ML20013E535) dated December 12, 2019.

11. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Volumes 1 (ML023470304) and 2 (ML023470323), Regarding the Decommissioning of Nuclear Power Reactors," (GEISY dated November 2002.

12. Letter TMl2-RA-COR-2021-0002 from van Noordennen, Gerrard (TMl-2 Solutions) "License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications," dated February 19, 2021.

13. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.179, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors,"

(ML19128A067) dated July 2019.

14. U.S. Nuclear Regulatory Commission, NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," (ML003761445) dated August 2000.

15. Nuclear Energy Institute (NEI) Technical Report 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document," August 2007.

16. van Noordennen, Gerard (TMl-2 Solutions) to USNRC, letter TMl2-RA-COR-2021-0003 "TMl-2 Solutions Plan for Management of Debris Material," dated March 15, 2021.

17. Halnon, G.H. (GPU Nuclear, Inc.), to USNRC, letter TMl-19-003 "Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2, (ML19087A153) dated March 28, 2019.

18. U.S. Nuclear Regulatory Commission, NUREG-1496, "Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRG-Licensed Nuclear Facilities," July 1997 (ML042310492).

19.Atomic Energy Commission, "Final Environmental Statement Related to the Operation of Three Mile Island Nuclear Station, Units 1 and 2," Dated December 8, 1972 (Included as Appendix B of Reference 16) (Referred to as the FES).

to TMl2-RA-COR-2021-0004 Page 49 of 50

20. NUREG-0112, "Final Supplement to the Final Environmental Statement Related to the Operation of Three Mile Island Nuclear Station Unit 2,"

December 1976 (ML080090250) (Referred to as the Final Supplement to the FES).

21. Wildlife Habitat Council, "Site Assessment and Wildlife Management Opportunities Report for Exelon Corporation's Three Mile Island Generating Station," October 2005.

22. Exelon Corporation, TMI Environmental Department, Three Mile Island Wildlife Management Plan," 2015.

23. U.S. Nuclear Regulatory Commission, NUREG-2157, Vol. 1, "Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel,"

September 2014 (ML14196A105).

24. NUREG/CR-2601 "Technology, Safety and Costs of Decommissioning Reference Light Water Reactors following Postulated Accidents" (ML14023A051), dated December 1990.

25. Gallagher, Michael P. (Exelon Generation Company, LLC) to USNRC, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," (ML19182A104), dated July 1, 2019.

26. 990-3017, Three Mile Island Unit No. 2 Fire Protection Program Evaluation, Revision 12, dated May 18, 2018.

27. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.183, Revision 0, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors,"dated July 2000 (ML003716792).

28. SECY-20-0041, "Request by Exelon Generation Company, LLC for Exemptions from Certain Emergency Planning Requirements for the Three Mile Island Nuclear Station," (ML19311C763) dated May 5, 2020.

29. 990-3017, "Three Mile Island Unit No. 2 Fire Protection Program Evaluation, Revision 13, dated February 2, 2020.

30. Gallagher M.P. (Exelon Nuclear.), "Three Mile Island Nuclear Station, Unit 1 -

Post-Shutdown Decommissioning Activities Report," Revision 1 (ML19095A041) dated April 5, 2019.

. to TMl2-RA-COR-2021-0004 Page 50 of 50

31. Pennsylvania State Historic Preservation Office, 2018, "Ct1ltural Resources Geographic lnfom,ation System [CRGIS]," Available at https://gis.penndot.gov/CRGIS, A~sed Septen,be~ 16, 2020.

32. Letter TMl2-2020-003 fr:om van Noordennen G. (TMl-2 Solutions_LLC) "Three

. Mi)e Island Nuclear Station Unit 2 Decommissioning Project; Request for _.

Information on Historic and Archaeological Resources/ dated September 24, 2020.

33. Mclearert D.C. (Pennsylvania State Historic Preservation Office), dated October 26, 2020; *_

34. Metropolitan Edison Company, Jersey Central Power & Light Company, and Pennsylvania Electric Company, Three Miie Island Nuclear Station Unit 1 and

.. 2, Environmental Report -Operating License Stage,".1971.

ATTACHMENT 1 TO TMl2-RA-COR-2021-0004 ENCLOSURE 1 B DE.TAILED COST AND SCHEDULE*INFORMATION (NON-PROPRIETARY INFORMATION)

. THREE MILE ISLAND NUCLEAR POWER STATION, UNIT 2 NRC POSSESSION ONLY LICENSE NO. DPR-73.

Year 2019 2020

.2021 2022 2023

-2024 2025 2026 2027 2028

.2029 2030

~P31 2032 2033 2034 2035 2036 2037 2038 2039 2040 Total License TABLE 18-1 Three Mlle Island Unit 2

• B, Enclosure 1 B

. TMl2-RA-COR-2021-0004 Page 1 of 1 Estlm~ted Annual Spending (thousands of 20~0 Dolla~)

Debris Site Termination

• Material Restoration Total 8,502 8,502 29,148 2,270 31,418 48,166

.. *3,488 51,654*

59,240 11,849

. 71,089 69,610 9,157 78,767

• 69,799 8,286 78;085 67,252 11,187 78,439 53,600 11,187 64,787*

51,555 4,497 56,052 31,233 31,233 32,272 32,272 46,086 332*

46,418 52;238

. 5~456 57,694 58,633 6,246 64,879

.*. 100,010

.5,864

. 105,874*

• 101,162

• 7,147 108,309 79,500 3,212 82,712 11,355 1,642 12,997' 969,362

• 61,921 29,899 1,061,181

Three Mile Island - Unit 2 Project Schedule Description PHASE 1 - Source Term Reduction license Transfer Approved Contract Closing & Asset Transfer Planning, Engineering & Regulatory Phase 1 Long Lead Procurement Infrastructure Upgrades & Modifications Containment Opening Ready Rad Building Source Term Reduction Waste Packaging, Transport & Disposal Reactor Vessel Source Term Reduction Large Component Source Term Reduction Phase 1 Source Term Reduction Complete Phase 1 Complete PHASE 2 - Decommissioning & License Termination Phase 2 Planning Phase 2 Long Lead Procurement Infrastructure Upgrades & Modifications Reactor Vessel Removal Waste Packaging, Transport & Disposal Large Component Removal Clean Building Demolition Rad Bldg Interior/ Systems D&D Rad Building Open Air Demolition Final Site Surveys & license Termination Site Restoration Phase 2 Complete FIGURE 1B-1 B, Enclosure 1 B TMl2-RA-COR-2021-0004 Pa e 1 of 1 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Page 1 of 1

• ATTACHMENT 3 TO TMl2-RA-COR-2021-0004*

LIST OF REGULA TORY COMMITMENTS THREE MILE ISµND NUCLEAR POWER STATION, UNIT 2 NRC_POSSESSION ONLY LICENSE NO. DPR-73 to TMl2-RA-COR-2021'-0004 Page 1 of 2 The following list identifies those actions committed to by TMl-2 ~olutions in this letter and Attachment 1 ("Three Mile Island Nuclear Power Station, Unit 2 Post-Shutdown Decommissioning*Activities Report"). Any other actions discussed In the submittal represent intended or plan'ned actio'ns by TMl~2 Solutions. They are described only as information and are* not Regulatory Commitments. Please notify Gerry van Noordennen. Senior Vice* President, Regulatory Affairs; TMl-2 Solutions, at 860-462-9707 of any questions regarding this document or associated Regulatory Commitments.

TYPE SCHEDULED REGULA TORY COMMITMENT ONE-TIME. CONTINUING COMPLETION

. *ACTION COMPLIANCE DATE A waste mariagement plan will be X

Prior to generating developed consistent With regulatory waste from Major

. requirements and disposal/processing D&D activities options for.each waste type at the time of the D&D activities.

As par:t of the site characterization process, X

Prior to removal, a neutron activation analysis calculation segmentati0n, study of the reactor internals ~nd the reactor*

packaging and.

vessel will be performed..

disposal of RV/RVI The Groundwater Protection Program will X

Until replaced by the continue for TMl-2 in accordance with N*EI L TP groundwater Technical Report 07-07 during.

monitoring program deco mm issioniriQ.

TMl-2 Solutions will notify the NRC in writing X

As needed and seek appropriate environmental r_eview in accordance with applicable NRC regulations before decommissioning activities occur that could significantly impact the environmental resource, as*

needed.

TMl-2 will update the site-specific X

As needed assessment of environmental impacts to prote.cted*species in the PSDAR as needed.

To comply with its continuing obligation under 1DCFR 50.82(a)(6) to' assure that no decommissioning activity that would result fn significant environmental impacts would be performed without NRC review, the results of. the. assessment would be provided to t~e NRC in aQCordance with applicable NRC requlations.

REGULA TORY COMMITMENT If the peregrine falcons continue to nest on the TMl-2 Reactor Building during the falcon ne$ting season, TMl-2 Solutions plans to cqntract With specialists prior to building demolition to determine the most feasible method to prevent the falcons from nesting on the structure without.harming*them and attempt to relocate their nesting site.

TMl-2 Solutions will consult with state and federal resource agencies before Major decommissioning activities in water commence to ensure that no listed aquatic species has been discovered in the intervening yea*rs and that no species -

pr!;lviously documented in Lake Frederic has*, in the intervening years, been afforded state or federal protection, TMl-2 Solutions.will consult with appropriate state and federal resource agencies when a decision is reached on timing and method of cooling tower removal to ensure that agency concerns-are addressed.

TMl-2 Solutions will develop a Radiation

• Prote~on Program that addresses occupational dose administrative limits. to TMl2-RA-COR-2021-0004 Page 2 of.2 TYPE SCHEDULED ONE-TIME CO.NTl~UING COMPLETION ACTION COMPLIANCE DATE X

Prior to demolishing structures coinciding with falcon nesting season X

Prior to performing Major decommissioning

• activities in *water X

Prior to.cooling tower removal X

Prior to assuming RP program responsibilities from Exelon

ATTACHMENT 4 TO "J:'Ml2-RA-COR-2021-0004 CORRESPONDENCE WITH PENNSYLVANIA STATE HISTORIC PRESERVA llON OFFICE THREE MILE ISLAND NUCLEAR POVVER STATION, U"'IT 2 NRC POSSESSION ONLY LICENSE NO: DPR-73

'LETTERS Letter 1Ml-2020-003*Th~ee Mil~ Island Nuclear Station Unit 2 Decommissioning* Project; Request for Information on Historic *and Archaeologic_al Resources," dateg Sep~ember 24, *2020.

McLearen*D.C. (Pennsylvania State Hl~torlc Preserv~tlo*n Office),

dated October 26, 2020

_September 24, 2020 Andrea MacDonald

- ~

TMl-2 SOLUTIONS Deputy-State Historic Preservation Officer Pennsylvania Historical and Museum Commission

• state-Historic Preservation Office Commonwealth Keystone Building, Second Floor 400 North Street Harrisburg, PA, 17120-009.3 1Ml2-2020,-003 Subjecf:

Three Mile Island Nuclear Station Unit 2 Decommissioning Project; Request for Information on Historic and Archaeologica, Resources

Dear Ms. MacDonald:

Three Mile Island Nuclear Station Unit 2 (IMI-2) is peqnanently shut down after e}f:.periencing a partial melt down on March 31, 1979. Following ~ediate emergency response, a 10-year cleanup effort safely dispositioned the-plant into its current long-term storage condition, termed. post-defueling monitored storage (PDMS). After 28 years in PDMS, the owners and U.S. Nuclear Regulatory Commission (NRC) license holder-of TMl-2, GPU Nuclear, made.a decision to sell the TMI-2 property to TMI-2 Solutions (a subsidiary of the parent company Energy Solutions) for dismantlement and decommissioning of the plant TMI-2 Soluti<;>ns is preparing a Post-Shutdown Decommissioning.Activities Report (PSDAR) for submittal to the NRC. Although the NRC's review of the PS DAR involves no federal action.that would map date NRC

--consultation with the Advisory Council on Historic Preservation (ACHP) pursuant to _Section 106 of the NHPA (54 U.S.C. § 306108; 36 CFR 800.16(y)), the PSDAR must include.an updated assessment of potential impacts of decommissioning on cultural, historical and archaeological resources. Accordingly,

'!MI-2 Solutions is preparingthe*required as.5eSSDlent in support of the TMI-2 PSDARand the purpose of this letter-is twofolci:' (1) to-acknowledge that 1MI-2 is a historic site and !hat cultural resources exist o~

_ Three Mile Isliµid and (2) to request input from the State Historic Preservation Office (SHPO) regardmg

• concerns that should be considered in the assessment.

The purpose of the TMI-2 decoininissioning project is to dismantle the TMI-2 structures; therefore, TMI-2 Soll!_tions recognizes th~t the enyiroJl!Ilen~ impact to this historic site cannot be avoided. As such, TMI-2 Solutions respectfully requests SHPO.'s guidance in this matter. As discussed during an Augu_st 28, 2020 conference call with your office, TMl-2 Solutjons is prepared to initiate a National Historic Preservaticn Act Section 106 consultation, which will be part of ~e later formal consultation required by the NRC as part ofits environmental review of the 1MI-2 decommissioning project to this letter describes the TMI~2 decommissioning project and summarizes TMI-2 -Solutions' updated review of cultural and historic resources in the site vicinity. AB this asse~ment indicates, 1Ml-2 Solutions does not expect 1MI~2 decommissioning activities to adversely affect cultural resources.

Page I of7

~

TMl-2 SOLUTIONS However, 1MI-2 Solutions requests your review of the 1MI-2 decommissioni~g project activities and would apprec!ate receivin~ your input by November 27, 2020, detailing any concerns you may have about the effects or TMI-2 decommissioning activities on cultural -resources, or confinnµig that 1MI-2

• decommissioning activities are unlikely to adversely affect cultural resour~. Receiving-y.our input by November 27, 2020 will support our current PSDAR preparation schedule. 1MI-2 Solutions will include a copy of this l~er and your response with the 1MI-2 PSDAR _

If you have any questions regarding this letter, please contact Kim Anthony at (562)706-1553 or by email, kmanthony@energysolutions.com.

Si!lcerely, Gerry van Noordennen Senior Vice President; Regulatory Affairs -

Energy Solutions cc:

Scott Baskett, TMI-2 Solutions Greg Halnon, GPU Nuclear Mike Lackey, Energy Solutions

-Kini Ant4ony; TMI-2 Solutions Enclo~re 1: TMI-2 ~roject Description & Historic Resources Review:

Page2 of7

~**

TMl-2 SOWTIONS TM 1-2 project Descdption & Historic Resources Review Contents 1MI-2 Deconnnissioning Project Description am Summary of Cultural and Historic Resources ~view.~ 3 Identification of Historic ~d Archaeological Resources............................ *:............... :.... :................ 6 Deco

... A...

dMi.

..6 mn11ss1orung ctiv1ties an tigati~n..................................................................................

Attachments................ :...................'.......... :..........................................,..................................... 7 References............... :................................................................................. '................................ 7 TMl-2 Decommissioning Project Description and S~mmary of Cultural and Historic Resources. Review Three Mile Island ('IMI) is located in the Susquehanna River in Dauphin County,.Pennsylvania, and is ore of the largest of a group of several islands in the river about 1 Q miles southeast of Harrisburg and approximately 2.:5 miles south of Middletown. Three 'Mile Island Nuclear Station was comprised of two pressurized water reactors-1MI Unit 1 (TMI.~ 1) reactor, which is owned by Exelon Generatioi:i. C?mpany, LLC (Exelon), has permanently ceased power operations; and TMI-2, which is owned by GPU Nuclear, Inc. (GPU Nuclear), and partially melted down in 1979.

The Three Mile Island Nuclear Station(1MINS) site encompasses approximately 440 acres including Three Mile Island and adjacent islands on the north end, a strip of land on the mainland along the ~ern shore of the river, and tl)e area on the eastern shor~ of Shelley Island that is within the exclusion area ( a 2, 000--foct radius fro~.a point equidistant between the centers of the 'IMI-1 and 1MI-2 r~tor buildings). lMI-2

• structures are located on the northern part of Three Mile Island. Un~eveloped land on the island is fouzyj

. south of the TMINS facilities. Most of this undeveloped land lies below the IO-year flood level. The

. southern part of the island also contains wetlands formed from borrow pits created during co~ction of

'1MINS.

• lMI-2 started co~ercial operations in 1978. On March 28, 1979, the TMI-2 reactor experienced an accident initiated by an interruption.of water from the secondary feedwater pumps to the~ generators that remove heat from the reactor core.

Page3 of7

~

TMl-2 SOLUTIONS After the. March 1979 accident, approximately 99% of the fuel was removed and shipped to the Idaho National Engineering and Environmental Laboratory (now called Idaho National Laboratory) under the responsibility of the U.S. Department of Energy (DOE). Radioactive wastes from the major cleanup activities were ei~er shipped off~ite or packaged and staged for shipment offsite.

Toe* quanti~ of fuel remaining at 1MI ~2 is a small fraction ( ~*1 % ) of the initial fuel load. Additionally, large q'uaritities of radioactive fi~ion products released.into varirus systems and structures were rem~ved as prt of waste processing activities. TMI-2 entered into a-long-term, safe and stable storage condition termed post-de-fueling monitored storage (PDMS) in December 1993; where it r~ains. After 28 yea:rs in PDMS, 1MI-2 is in the early planning stages of decommissioning.

In November 2019, GPU Nuclear, Metropolitan Edison Company, Jersey Central Pqwer & Light Company,

• Pennsylvania Electric Company, and 1MI-2 Solutions, LLC (1MI-2 Solutions) submitted an Application for Order Approving Lie~ Transfer and Conforming License Amendments for 1MI-2 to the U.S. Nucleir R(?glllatory Commission (NRC). The application proposed to transfer the po~on only license (POL) of 1MI-2 from GPU Nuclear to TMI-2 Solutions. Upon approval of the application and transfer of the PO~

• 1MI-2 Solutions will assume all authorities provided for and responsibilities unde~ the POL, including possession; maintenance, and eventual decommissioning of1MI-2 and associated buildings and structures.

The TMI-2 structures are intermingled with those of1MI:-1; however, t_hed~mmissipning of TMJ-2 Eni

• 1MI-1 are independent actions.

In the Generic Environmental Impact Statement on DeconimlssioningofNuclear F~cili?es (NUREG-0586, Supplement 1) (Reference 1 ), Section 4.12, confinement.of decommissioning activitj.es to the "operational area" was considered to.be a key discriminator for ecological and cultural impacts,: with only small impocts expected to occur within the operational area NUREG 0586 Supplement 1 defines th_e term "operational area" as follows: *

"The operational area is defined as the portion of the plant site where most or all of.the:site activities ocair, such as*reactor operation, materials and equipment storage, parking, su~ion operation, facility service.,

and maintenance. Th.is includes areas within the protected area fences, the _intake,* discharge, cooling, am asso~iated 'structures as* well as surr~unding paved,* graveled, maintained landscape, or other maintained areas."

Current planning anticipates that 1MI-2 decommissioning activ:ities will be limited to the TMI-2 operational area, except for the possible excavation of fill_ from onsite areas outside of the operation~ area to backfill the.foundations of buildings and structures after *demolition. Figure 1 depicts the TMINS site location and the approximate 1MI-2 operational area boundary.

Page4of7

LEGEND c::J 0

~

TMl-2 SOLUTIONS I

STRUCTURE FOOTPRINT 2000 FT EXCLUSION AREA DAM FEATURE ASH LADDER c::J THREE MILE ISLAND SITE BOUNDARY TRANSMISSION LINE CATCH BASIN STORM YARD DRAIN EXISTING RAIL TRACK PROPOSED NEW RAIL TRACK 1

o 250500 PROJECT LOCATION: DAUPHIN COUNTY PENNSYLVANIA THREE MILE ISLAND NUCLEAR STATION UNIT2 PNDl*71355' SITE MAP Figure 1. Three Mile Island Nuclear Station site location and approximate Unit 2 (TMl-2) operational area boundary outlined in red.

Page 5 of7

~

TMI-2 SOLUTIONS Identification of Historic and Archaeological Resources Because 1MI-i and 1MI-2 are located within the same operational area with virtually identical resources, 1MI-2 Solutions benefits from previous historic and archaeological database searches. Referenced here is information provided by Exelon' s 1MI-1 PS DAR (Reference 2), which reports locations of inventoried resources on the island and within an approximately 6-mile radius. Data came from plant docurnentatioo and the Pennsylvania State Historic Preservation Office (PA SHPO).

One archaeological site within the 1MI-l and 1MI-2 operatiooal area (identified on the NRHP as 36DA50) is believed to remain intact. The site is north of the access road at the northern end of the operational area Its eligibility for listing on the NRHP is categorized as undetermined due to insufficient informatioo, presumably due to uncertainty about its current condition.

Six archaeological sites are located on the central and southern portions of Three Mile Island outside the 1MI-1 and 1MI-2 operational area but within the TMINS property boundary. In 2016, one of these archaeological sites (36DA 100) was determined to be eligible for the NRHP. That site is at the south end of the island near the South Access Road. Another archaeological site (36DA98) is immediately south of the operational area in a location used for staging and soil borrowing during construction of the station, and it was likely removed by those construction activities. A third site (36DA51) has been determined to be rot eligible for listing, and three more sites (36DA99, 36DA 101, and 36DA235) are considered unevaluated due to insufficient information.

Beyond Three Mile Island operational area, but within a 6-rnile radius, there are 13 properties currently listed on the NRHP and 32 NRHP-eligible properties. One property, a section of the Pennsylvania Railroo:l Main Line linear historic district, lies 0.4 miles away from 1MI-l and 1MI-2 and the remaining properties are more than 1 mile away. These properties are listed in Table 1 of Reference 4.

As a specific update to Exelon's 2019 review, TMI-2 Solutions is aware that in 2010, TMI-2 was classified as a historic structure eligible for listing on the National Register of Historic Places (NRHP) (Reference 3}

The Cultural Resources Geographic Information System (CRGIS) Report is included herein as Attachment

1. Furthermore, the Historic Resources Survey Form (Attachrnent2) provides a historical evaluation oftre 1MI-2 accident.

Decommissioning Activities and Mitigation TMI-2 Solutions will develop a Cultural Resources Protection Plan and an Archaeological Resources Erosion Monitoring Plan, which will provide protocols for ensuring continued stewardship of cultural resources on Three Mile Island during the 1MI-2 decommi~ioning project. In addition, project-specific policies and procedures will provide direction and contact information should an unanticipated culti,rra resource be encountered.

It is anticipated that backfill for demolished building and structure foundations will be sourced from on&te demolition activities. If additional clean fill is needed, it could be obtained from onsite within or beyond the operational area. Prior to excavating backfill outside of the operational area, 1MI-2 Solutions will evaluate the area's archaeological sensitivity and implement its protocols that will have been developed for Page 6 of7

~

TMl-2 SOWTIONS the project to ensure continued stewardship of cultural resources on Tirree Mile Island. Again, should an unanticipated discovery be made, TMI-2 Solutions procedures will be in place to address how a discoveiy should be managed.

Use of explosives for demolition of the natural draft cooling towers is anticipated and will be in accordmce with applicable PA DEP regulations (25 Pa Code §211) and best management practices and will seek to minimize the generation of fugitive dust, avoiding possible adverse effects to historic properties. The PA DEP regulations for use of explosives also limit peak particle velocities to minimize ground vibration that could damage structures. Demolition of the natural draft cooling towers will be performed in accordance with regulatory limits, but also by use of innovative techniqoos that will be carefully planned, reviewed in!

executed under controlled conditions. The collapse of the towers is not expected to adversely affect currently identified historic properties.

Attachments : Cultural Resources Geographic Information System Report (CRGIS) : Historic Resource Survey Form. Pennsylvanian Historical and Museum Commission, Bureau for Historic Preservation References

1. U.S. Nuclear Regulatory Commis.sion. 2002. Generic Environmental Impact Statement on-Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1, Office ofNuclear Reactcr Regulation, Washington, D.C., dated November 2002 (ADAMS Accession Nos. ML023470304 (Vol 1) and ML023470323 (Vol 2))

• 2. Exelon Generation. 2019. Tirree Mile Island Nuclear Station, Unit 1 -

Post-Shutdown Decommissioning Activities Report (ADAMS Accession No. MLI 9095A041)

3. Pennsylvania State Historic Preservation Office, 2018, "Cultural Resources Geographic Information System [CRGIS]," Available at https://gis.penndotgov/CRGIS, Accessed September 16,2020

4. Exelon. 2019.

Three Mile Island Nuclear Station Unit 1 Decommissioning, Request for Information on Bistoric and Archaeological Resources (Letter to PA State Historic Preservatioo Office, dated January 17, 2019)

Page? of7 Historic Resource Information

CRGIS Report Page 1 of2 Historic Resource Information

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Associated Event: Three Mile Island Partial Meltdown

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CRGIS Report Historic Reso~Daf~

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N.atlonal Register lnfonnation Acreage: 1 2.3 I Attachments

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9/16/2020 Historic Resource Survey Form

Historic Resource slvey Form PENNSYLVANIA HISTORICAL AND MUSEUM COMMISSION Bureau for Historic Preservation ER# _ _____ _

Name, Location and Ownership (Items 1-6; see Instructions, page 4)

HISTORIC NAME Three Mile Island Unit 2; TM I-Unit 2 CURRENT/COMMON NAME Three Mile Island-Unit 2; TMI-Unit 2 STREET ADDRESS Route 441 LOCATION Susguehanna River, 10 miles south of Harrisburg MUNICIPALITY Londonderry Township COUNTY Dauphin TAXPARCEL#/YEAR __

USGSQUAD __

OWNERSHIP X Private 0 Public/Local O Public/County O Public/State O Public/Federal OWNER NAME/ADDRESS FirstEnergy Corporation owns TMl2 CATEGORY OF PROPERTY O Building O Site O Structure O Object XX District TOTAL NUMBER OF RESOURCES 5 Function (Items 7-8; see Instructions, pages 4-6)

Historic Function Industry/Processing/Extraction Current Function Vacant/not in use Subcategory Energy Facility Subcetegory Architectural/Property Information (Items 9-14; see Instructions, pages 6-7)

ARCHITECTURAL CLASSIFICATION

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EXTERIOR MATERIALS end STRUCTURAL SYSTEM Foundation Walls Roof Other Structural System Concrete WIDTH __

(feet) or __ (# bays)

DEPTH __

(feet) or _

(# rooms)

ZIP..llQ5Z Perticuler Type Nuclear power reactor Perticuler Type STORIES/HEIGHT 190 feet

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Property Features (Items 15-1-7; see Instructions, pages 7-8)

Setting Industrial and natural landscape Andlary Futures Aauge ll,3 (round to nearest tenth)

Histqrical Information (Items 18-21; see 1n7ge*B)*~

YearConmuctlonBeg;ln ~

Oarca Yureonieleted ___ area

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Date of Major Additions, Alterations

__ Lo drca.______,____-D Orea Buis for Dating X Documentary 0 Physical Explain Corporation records a'nd NEC state this Is the construction date CulturaJ/Ethnk AfflOatlon(s) --

Associated lndlvldual(s) --

Aaodated Event(s) Three Mile Island Partial Meltdown Archltect(s} --

Bullder(I) __

Submission Information (Items 22-23; see Instructions, pa,ge BJ_

Previous Survey/Determinations Not Eligible-July 25, 1g83

• SHPO Threats XX None O Neglect O Publlc Development Explain __

0 Private Development D Other

__ OClrca This iUbmlulon Is related to II D non-profit g 111111: a ppUcatlon D NHPA/PA Hlstofy Code Project Review D *business tax Incentive Oother Preparer Information (Items 24-30; see Instructions, page 9)

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• T1tle Cheryl L Nagle, Historic Preservation Speclallst Date Prepared December 2009 - February 2010 Project Name TMI - Unit 2 Org1nlzation/Compny e.J::iMb Mlllng Address 400 North Street, Harr!sbur:g PA 1zuo Email chn~le@state,"a.us 03/08 PA Historic Resource Survey Form 2

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National Register Evaluation (Item 31; see Instructions, page 9)

(To be completed by Su,wy Director, Agency Consultant, or for Project Reviews ONLY.)

0 Not Eligible (due to O lack of significance and/or O lack of Integrity)

X Eligible Area(s) of Slgr.tlcance ~

Criteria Considerations.!i..

Period of Significance March 28, 1919:April 4, 1929 0 Contrtbutes to P*otentlal or Eligible District Dfstrlct Name Bibliography (Item 32; dte major references consulted. Attach additional page if needed. See Instructions, page 9.)

See Attached Additional Information The following must be 5ubmitted with form. Check the appropriate box as each piece Is completed and attach to form with paperdlp.

03/08 0 Narrative Sheets-Descrlptlon/lntegnty and H lstory,Slgnlficance (See lnstructlons, pages 13 *litl D Current Photos (See Instructions, page 10) 0 Photo List (See Instructions, page 11)

D Site Map (sketch site map on 8.5X11 page; Include North arrow, approximate scale; label aU resources, street names, and geographic features; show exterior photo locations; See Instructions, page 11) 0 Floor Plan (sketch main buUdlng plans on 8.SJ(ll page; Include North arrow, scale bar or length/width d1menslon5; label rooms; show Interior photo locatlons; See lnstructlons, page 11) 0 USGS Map (submit orlglna~ photocopy, or download from TopoZone.com; See Instructions, page 12)

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4 Photo List (Item 33>

Photographer name Chetyj L. Nagle Date February iz, 2010 Location ~lectronlc Images Stored PHMC, N:drtye Photo#. Photo Subjacl:/DeKriptlc 1

Basement of Turbine Building 2*

Basement of Turbine Building, Showing Condensers 3

Condensate Vessels 4

Condensate Pump Heads 5*

Unit Substation 6

First Floor ofTurblne Building 7

Second Floor of Turbine Building; Showing Generator Top 8

Second Floor of Turbine Building, Showing Turbine 9

Auxiliary Building 10 Unit 2, Cooling Tower A from roof ofTurbine Building 11 Unite 2, Cooling Tower B from roof of Turbine Building 12 Feed Water Pumps 13 Unit 2 Control Room 114 Unit 2 Control Room 15 Unit 2 Control Room 16 Unit 2 Control Room 17

~Valve Open" light on control panel In Unit 2 Control Room 03/08 ER# ______________ _

Camera Facing PA Historic Resource Survey Form 4

03/08 Three Mile Island, Unit 2 Three Mile Island, Visitor Center Key#

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079154 ER# ________________ _

Recent (199os-2ooos} Aerial of Three Mile Island Aerial of Three Mile Island, 10 April 1979 ACR Identifier 540012; The National Archives PA Historic Resource Survey Form 6

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Physical Description and Integrity (Item 3s>

Due to Homeland Security issues, portions of this HRSF may need to be redacted after it has been evaluated for National Register eligibility (Note: this only includes the two site plans obtained from ER File 2007-1737-043). Any data, plans or photographs which have been obtained from various Internet sources or books, will remain in the HRSF, for they have been previously published for public consumption. The preparer received verbal approval to take pictures on the February 17, 2010 field view and to publish them within this HRSF. Pertinent background information in regards to the complete site and TM I-Unit 1 will be included when necessary for context. The generating station will be referred to as TMI, and the reactor units respectively as TMI-Unit 1 and TM I-Unit 2.

Three Mile Island Nuclear Generating Station (TMI) is located in Londonderry Township, Dauphin County, Pennsylvania, approximately 10 miles southeast of Harrisburg. The station is built on an island in the Susquehanna River, in the center of the Susquehanna River basin, consisting of 370 acres, of which approximately 200 acres are occupied by the Three Mile Island Unit-1 (TM I-Unit 1) and Three Mile Island Unit-2 (TMI-Unit 2) facilities.

1 The remaining 170 acres are covered by fields, forested land, and wetlands with several intermittent ponds. Depending on the source, the name is either derived from the size of the island (three miles long) or the fact that TMI is located three miles downriver from Middletown, Pennsylvania. TMI-Unit 2 occupies approximately 12.3 acres.

The island contains prehistoric and historic Native American and Euro-American cultural resources; PHMC site file records include Sites 36DA0051, 36DA0098, 36DA0096, 36DA0097, 36DA0099, 36DA0052, 36DA0050, 36DA0235, 36DA0100, 36DA0101. The utility company, Metropolitan Edison purchased the Three Mile Island and adjacent islands in 1924 from the York Haven Power and Water Company. York Haven had purchased Three Mile Island from James Duffy in 1904, who until then had a tobacco plantation on the island. During the twentieth century, the land was leased to farmers. Between "1957 and the start of construction [TMI], 270 acres of land was leased on the island for farming of corn and tomatoes. The island hosted 70 cabins, picnic facilities, two fireplaces, two restrooms, a drinking water well, and a boat ramp. No access roads or bridges were connected to the island. All access was by boat or barge. No electrical service was supplied to the island."

2 TMI is a nuclear generating station, which when finished, contained two reactors.3 There were two cores, two turbine systems, and two sets of cooling towers; and each unit had a separate control room; in addition there were numerous outbuildings that either unit shared or used separately. TMI-Units 1 and 2 shared the Station Blackout Diesel Generator Building (extant) and Fuel Handling Building (extant) 1TMI-Unit 1 site encompasses several properties that total approximately 440 acres, including the physical plant location on 200 acres of the 370-acre Three Mile Island; St. John's Island and Evergreen Island, together totaling 31 acres; a 6.4 acre section of Shelley Island, which is part of the western half of the TMl-1 Exclusion Area; and a 32-acre strip of and east of Three Mile Island along the eastern shore of the Susquehanna River.

2United States Atomic Energy Commission, "Final Environmental Impact Statement for Three Mile Island," 1972.

1 "A nuclear reactor uses nuclear fission to generate heat to boil water and power steam turbines. Nuclear reactors are characterized as light-water or heavy-water units. Two types of light-water reactors are in widespread use: the boiling-water reactor (BWR) and the pressurized-water reactor (PWR). Both use similar fuel, consisting of long bundles of 2 to 4 percent uranium dioxide fuel pellets stacked in zirconium -alloy cladding tubes. The PWR is a two-loop system that uses high pressure to maintain an all-liquid-water primary loop. Energy is transferred to the secondary steam loop through two to four steam generators." Douglas C. McVarish, American Industrial Archaeology: A Field Guide (Walnut Creek, CA: 2008), 182.

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Metropolitan Edison, a subsidiary of General Public Utilities, began construction of TMl-1 in 1968.

TM I-Unit 1 is a pressurized water reactor, designed by Babcock and Wilcox, built by United Engineers and Constructors, with Gilbert Associates as the design engineers, with a net generating capacity of 850 MWe.

TMI-Unit 1 came online on April 19, 1974, and began commercial operation on September 2, 1974. It utilizes two hyperbolic natural draft cooling towers for dissipating heat from the plant steam cycle.

Metropolitan Edison, a subsidiary of General Public Utilities, began construction of TM I-Unit 2 in 1969.

TMI-Unit 2 was a pressurized water reactor designed by Babcock and Wilcox, built by United Engineers and Constructors, with Burns and Roe as design engineers, with a net generating capacity of 906MWe.

The unit received its operating license on February 8, 1978 and began commercial operation on December 30, 1978. TMI Unit-2 facilities included the following :

03/08 Two 370-foot tall concrete cylindrical Natural Draft cooling towers (extant)

Concrete control room with bullet-proof windows, reinforced steel doors and a horseshoe-shaped panel which stretches 40 feet along three walls (extant)

Turbine (electric power generating) building (extant)

Cylindrical, domed concrete 190-foot-high reactor building, also known as the containment building (extant)

Concrete fuel handling building (extant)

Water pretreatment building (not extant).

The two units of the Three Mile Island nuclear power plant from the southeast.

Source: Nuclear Regulatory Commission Special Inquiry Group, "Three Mile Island, A Report to the Commissioners and to the Public," Volume 11 1980.

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The Visitors' Center (extant), where MetEd conducted the news conferences was located across the street on the corner of PA Route 441 (River Road) and Pecks Road; the Three Mile Island Training Center, which contains a simulator room, is currently located directly behind the center's building. The Visitors' Center is no longer open to the public.

Boundaries While the accident occurred at TMI, which houses both TM I-Unit 1 and TMI-Unit 2 and their auxiliary buildings, and the site itself continues to function in its original capacity as an energy facility, the resource and its subsequent boundary is only the TMI-Unit 2 and its specifically designated auxiliary buildings.

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Integrity h o

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TM I-Unit 2 as a district retains Ull\\14iiiii~ fl integrity, for it has been in non-operating status since the accident. While between 1985 and 1990 an extensive program to defuel the reactor vessel and decontaminate the facility occurred (it included the removal of some 100 metric tons of damaged uranium fuel and 50 metric tons of damaged structural material from the reactor pressure vessel and the removal of the top layer of contaminated concrete inside the containment building), and the unit was placed in post-defueling monitored storage (which is "a safe, inherently stable condition") in December 19931 no significant dismantlement has occurred.4 The significance of the TM I-Unit 2 district is reflected by its integrity of location, setting, feeling, association, materials, and design. The district retains integrity of location, as it is the location of the nuclear generating station where the event occurred. The district retains integrity of setting, for not only do the buildings and infrastructure remain, the physical environment surrounding the unit remains intact since the facility is still operating as a nuclear plant.

The district retains integrity of association, which is the direct link between an important historic event and a historic property. The TM I-Unit 2 was the place where the event and activity took place. The physical features in this district have structural, functional, and material integrity and retain their quality of association with the events of the day and the following week.

The district retains integrity of design. All of the original buildings (except for the water treatment plant) built during its construction, and during its use, retain their spatial relationship; and continue to reflect their historic functions and technologies as well as aesthetics.

The district retains integrity of materials. No buildings were renovated after construction.

The most significant resources - the cooling towers, reactor building and control room, were constructed with materials and technology needed to house this type of industry, and there have been no changes to these resources in terms of materials.

There has been removal of equipment, such as reactor piping, steam generator, water pumps, and such in the various structures. While the removal of the equipment that was the "heart" of the unit has been 4United States Nuclear Regulatory Commission, "Three Mile Island-Unit 21" http:J/www.nrc.gov/info-finder/decommissioning/power-reactor/three-mile-island-unit-2.html, Accessed 20 November 2009. Per the NCR, the current radiological decommissioning cost estimate is s831.5 million."111*** -***M?

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removed in part due to contamination and requirements of "monitored storage," it is still possible to get a sense of the overall feeling and association of a nuclear power plant.

In an effort to demonstrate integrity, the preparer has included historic and current photographs side by side when possible.

TMI Unit-2 Cooling Tower A Photo 1 0 TMI Unit-2 Cooling Tower 8 Photo 11 Note removal of bases of the cooling towers as compared to histori c photograph.

03/08 Oblique [view of) TMI [Three Mile Island], April 11, 1979 Arc Identifier 540028; The National Archives PA Historic Resource Survey Form 12

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Basement of Turbine Building Photo 1 Basement of Turbine Building, Condensate Pump Heads Photo 4 PA Historic Resource Survey Form 13

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Turbine Building, 1

• Floor Photo 6 The yellow painted lines represent where equipment used to stand Reactor piping; April 03, 1979 ARC Identifier 540035; The National Archives Turbine Building PA Historic Resource Survey Form 14

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Feed Water Pumps, Turbine Building Photo 12 (In historic photograph below, these pipes are too the far right)

High Pressure Turbine, in TMI Unit 2 Turbine Building Source: Nuclear Regulatory Commission Special Inquiry Group, "Three Mile Island, A Report to the Commissioners and to the Public,"

Volume 1, 1980.

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TMI-Unit 2 Control Room Photo 13

• • All of the knobs, switches, instrument panels are extant. Black plastic covers have been placed on top of all non-fun ct ioning portions (Som e are still used to monitor Unit 2)

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President Jimmy Carter and Mrs. Carter in the control room of the TMl-2 reactor... accompanied by Harold Denton, director of the the NRC's Office of Nucelar Reactor Rgulation and James R. Floyd, supervisor of TMl-2 operations.

Jimmy Carter Library, photo nr nlc10137.16a 03/08 PA Historic Resource Survey Form 17

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TMI-Unit 2 Control Room Photo 15 TMI supervisors confer in the Unit 2 control room during the accident www.threemileisland.or9/downloads/221.pdf PA Historic Resource Survey Form 18

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TMI-Unit 2 Control Room, Photo 16 TMI-Unit 2 Control Room, Photo 17

• • • "Valve Open" light on Control Panel (red labeling) is the one involved in the incident Ml-Unit 2 Control Room, Photo 14 03/08 PA Historic Resource Survey Form 19

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Unit Substation, Photo 5 2nd Floor Turbine Bldg, Turbine, Photo 8 Misc. Auxiliary Buildings, Photo 9 03/08 PA Historic Resource Survey Form 20

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TMl*Unit 2 cooling towers (background), and both unit's containment buildings TMI Unit -2 Containment (reactor) building from the northwest.

The Fuel Handling Building is the adjoining concrete building on the left; the Turbine Building is the gray structure on the right NARA, RG 220 Binder DE 9040025, Image 21, 3-31-79.

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TMI Visitors Center Copyright Jeffrey J. Kitsko, 2003 www.pahighways.com 03/08 Key#__J **

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TMI Training Complex Copyright Jeffrey J. Kitsko, 2004 www.pahighways.com Signs by South Bridge, t:ornoff Highway 441, April 06, 1979 ARC Identifier 540013; The National Archives PA Historic Resource Survey Form 22

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History and Significance (Item 39)

The subject of this HRSF is TM I-Unit 2 and the events that occurred the week of March 281 1979 through April 41 1979. March 28th, 1979 is the date that the "worst nuclear power accident in the United States" occurred, and on April 41 19791 then Pennsylvania Governor Richard L. Thornburgh appeared on the "Today Show" and stated the threat of an immediate catastrophe had end~.

Brief overview of nuclear power plants in the United States While the atomic age originated in Illinois when Enrico Fermi and other scientists at the University of Chicago on December 21 1942 achieved the first nuclear chain reaction, the U.S. commercial nuclear industry was born in Pennsylvania. 5 The Shippingport Nuclear Power Station in Beaver County, Pennsylvania was the first commercial central electric-generating station in the United States to use nuclear energy for peacetime uses. The reactor went on line December 2 1 1957 (was in operation until October 1982.)

By the end of 1962, there were four operating reactors in the United States. 6 The United States is the world's largest supplier of commercial nuclear power, with thirty-one states having commercial nuclear power plants. Nearly one-third of the nation's total capacity is located in just four states - Illinois, Pennsylvania, and North and South Carolina. Pennsylvania ranks second, behind Illinois, in total nuclear capacity and nuclear generation. "Of the 253 nuclear power reactors originally ordered in the United States from 1953 to 2008, 48 percent were canceled, 11 percent were prematurely shut down, 14 percent experienced at least a one-year-or-more outage, and 27 percent are operating without having a year-plus I

5Energy Information Administration Official Energy Statistics from the U.S. Government, "Pennsylvania Nuclear Industry,"

http:l/www.eia.doe.gov/cneaf/nudear/page/at a glance/states/statespa.html. Accessed 9 November 2009. "In a dramatic high-tech display, ground was broken in 1954 during dedication ceremonies by President Dwight D. Eisenhower, who also opened it on May 261 1958, as part of his "Atoms for Peace" program. Shippingport is located on the Ohio River about 25 miles from Pittsburgh. The reactor plant was designed by the Westinghouse Electric Corporation in cooperation with the Division of Naval Reactors of the Atomic Energy Commission. The design effort had been redirected to peace-time power generation from a large-scale light water reactor for a proposed aircraft carrier. Constructed to advance nuclear fission technology in 9eneral, the plant was flexible in accommodating cores of different types. Various manufacturers with different designs and materials for components were used. Water in the primary system, heated by nuclear fission, flows to the heat exchanging system, which absorbs the heat. This heat turns water in the secondary system, a relatively low pressure system, to steam. This steam is sent to the turbine generator to drive the turbine. The first power at Shippingport was produced on December 18, 1957, and was fed into the grid for the Pittsburgh area. On December 2, 19771 the first U.S. light water breeder reactor went to full power at Shippingport." http://www.asme.org/Communities/Hjstory/Landmarks/Shippingport Nuclear Power.cfm. Other stations (extant and not extant) in Pennsylvania include: The Peach Bottom Atomic Power Station, in York County which is still in service. Unit 1 was an experimental helium-cooled graphite-moderated reactor (1966-1974). Two other units, General Electric boiling water reactors, placed on-line in 1974, are still in operation. The Beaver Valley Power Station, near Shippingport, it has two Westinghouse pressurized water reactors. The Limerick Generating Station, Limerick Township, Montgomery County, which has two General Electric boiling water reactor units, cooled by natural draft cooling towers. Site and plans were announced in 1969 by PECO (now Exelon). Community protests and other delays pushed construction to 1974.

Commercial operation began in 1986 and 1990. The Susquehanna Steam Electric Station, Salem Township, Luzerne County, which has two General Electric boiling water reactors. The Saxton Nuclear Generating Station, Bedford County, which began operations in November 1961 and was shut down May 1, 1972.

6Walsh, 24.

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outage. Thus, only about one fourth of those ordered, or about half of those completed, are still operating."7 As of 2009, the U.S. Nuclear Regulatory Commission had received applications for permission to construct 18 new nuclear power reactors. 8 Perception of nuclear power in Pennsylvania before the accident In the late 1960s to mid 1970s, there was public opposition by Pennsylvanians to at least three nuclear propositions. The 1968 AEC-backed Plowshare nuclear engineering proposal, 'Project Ketch," a "feasibility pilot project for the creation of more than a thousand natural gas storage caverns deep under the Appalachian Highlands... these caverns were to have been forrried by underground explosions of fifty-kiloton nuclear bombs" created so much opposition that the proposal was abandoned.9 In 1969, "a site on the north branch of the Susquehanna River was proposed for a demonstration liquid metal fast br~eder reactor until local residents mobilized enough political support to defeat the project."

10 There was a 1975 defeat of energy parks in Pennsylvania, when "a consortium of four Pennsylvania utilities proposed... to construct one to five 10,000 to 20,000 megawatt coal-fire9 and nuclear e_nergy parks in rural areas of the state before the year 2000. The plan envisioned groups of up to twenty 800 to 1,200 megawatt electrical fossil fueled units and-nuclear reactors on a single site."

11 In addition, at least two citizen groups developed during this time, including "a broad based cluster of Pennsylvania and New Jersey environmental, consumer, and local citizens' organizations [who] formed

-the Environmental Coalition on Nuclear Power (EACNP).

12 The Three Mile Island Alert was formed in 1977, which was a "non-profit citizens' organization dedicated to the promotion of safe-energy alternatives to nuclear power and is especially critical of the Three Mile Island nuclear plant."

Yet it appears that the majority of Pennsylvanians living around Three Mile Island did not oppose its construction or the idea _of nuclear power. On April 19, 1968, the Atomic Energy Commission issued a non-contested permit to Metropolitan Edison for its construction of the station, and "preliminary hearings were virtually devoid of rancor; there were no charges of landgrabbing, no residential dislocations."13 In

addition, "Before the accident, there seems to have been more awe of the plant than hatred or fear.

One man, who later became a leader in the anti-restart movement, told us that he, like many residents, was proud of the technological achievement that the nuclear plant represented. Prior to the accident, he took all of his visitors to Three Mile Island. He described leading tours past the plant and making comparisons and allusions to the pyramids of Egypt."14 7 Al Gore, Our Choice: A Plan to Solve the Climate Crisis (Rodale Books, 2009), 157.

8U.S. NRC, "Combined License Applications for New Reactors," http://www.nrc.gov/reactors/new-reactors/col.html 9 Walsh, 30.

10 Walsh, 30.

uwalsh, 30.

12 Walsh, 30. Concentrated on license hearings (since came Into the fray after construction permits had already been issued for most of the nuclear plants).

13Nudear Regulatory Commission Spedal Inquiry Group, *Three Mile Island, A Report to the Commissioners and to the Public/

Volume 1, 1980. 2.

""Goldsteen, 14.

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Protest of nuclear power in the United States before the accident Historian Thomas Wellock traces the birth of:the anti-nuclear movement to the 1958 controv~rsy 9ver the plans* to build. the first commercially viable nuclear *power plant at San Francisco's Bodega Bay..

Furthermore, the environmental movement used the National Environmental Policy Act of 1969 to raise questiqns about the consequences of nuclear power on the ecology of local areas. Prior to NEPA, for example, there was no legal basis for opposing the construction of a nuclear plant becaus~ of

• environmental issues such as thermal pollution. "15 In the lanqmark Calvert Cliffs federal court ruling of 1971,."environmental impact statements became required before the AEC coul~Ussue a const~ction permit."16 By 1975, Forbes Magazine was reporting that "the anti-nuclear coalition has been remarkably successful... and has* certainly slowed the expansion of nuclear power:"

The Three Mile fsland Unit-2 Accident The narrative below explaining the TM I-Unit 2 accident and subsequent events has been taken directly from the U~lted States Nuclear Regulatory Commission's Fact Sheet on the Three Mile Island accident.

Summary of Events

• "The accident began about 4:00 a.m. on March 281 *1979, when the plant experienced a

• failure in the secondary, non-nuclear section of the plant. The main feedwater pumps stopped running, caused by either a mechanical or electrical failure, which prevented the steam generators from removing heat. First the turbine, then the reactor auton:,atlcally

• shut down. lmmediately,.the pressure in the primary system (the nuclear portfon of the.

plant) began to increa~e. In order to prevent that pressure from becoming excessive, the pilot-operated relief valve (a valve located at the top of the pressurizer) opened. The valve should* have closed when the pressure decreased by a certain amount, but it did not.

. Signals available to the operator faited to show that the valve was still open. As a_ result, cooling water poured out 9f the stuck-open valve.and caused the core of the reactor to overheat.

As coolant flowed from the cqre through the pressurizer, the instruments available to reactor operators provided confusing information. There was no instrument that showed

• the level of coolant in the core. Instead, the operators judged the level of _water in the core by the level in the pressurizer, and since it was high, they assumed that the core was properly cqvered with coolant. In addition, there was no clear sig*nal that the pi_lot-operated relief valve was open. As a result, as alarrl'!s rang and warning lights flashed, the operators did.not realize that the plant was experiencing a loss-of-coolant accident. _They.took a series of actions that made conditions worse by simply reducing the flow of coolant thro~gh the core.

Because adequate cooling was not available, the nuclear fuel over~e-~ted to tbe point at which the zirconium cladding (the long metal tubes which hold the nuclear fuel pellets) ruptured arid the fuel pellets began to melt. It was later found that about one~half of the 15walsh, 27.

,6 Walsh, lJ.

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core melted during the early stages of the accident. Although the TMl-2 plant suffered a severe core meltdown, the most dangerous kind of nuclear power accident, it did not produce the worst-case consequences that reactor experts had long feared. In a worst-case accident,.the melting of nuclear fuel would lead to a breach of.the walls of the containment building and release massive quantities of radiation to the environment. But this did not occur as a result of the three Mile Island accident.

• The accident caught federal and state authorities <;>ff-guard. They were concerned about the small releases of radioactive gases that were measured off-site by the late morning of -

March 28 and even more concerned about the potential threat that the reactor posed to the surrounding population. They did not know that the core had melted, but they immediately took steps to try to gain control of the re_actor and ensure adequate cooling to the core. The NRC's regional office in King of Prussia, Pa., was notified at 7:45 a.m. on March 28. By 8:00, NRC Headquarters in Washington, D.C., was alerted and the NRC Operations Center in Bethesda, Md., was activated. The regional office promptly dispatched the first team of inspectors to the site and other agencies, such as the Department of Energy and the Environmental Protection Agency, also mobilized their response teams. Helicopters hired by TM l's owner, General Public Utilities Nuclear, and the Department of Energy were sampling radioactivity in the atmosphere above the plant by midday. A team from the Brookhaven National Laboratory was also sent to assist in radiation monitoring. At 9:15 a.m., the White House was notified and at 11:00 a.m., all non-essential personnel were ordered off the plant's premises.

• ay the evening of March 28, the core appeared to be adequately cooled and the reactor appeared to be stable. But new concerns arose by the morning of Friday, March 30. A significant release of radiation from the plant's auxiliary building, performed to relieve pressure on the primary system and avoid curtailing the flow of coolant to the core, caused a.great deal of confusion and consternation. In an atmosphere of growing uncertainty about the condition of the plant, the governor of Pi:!,, Richard L. Thorn burgh, consulted with the NRC about evacuating the population near the plant. Eventually, he and NRC Chairman Joseph Hendrie agreed that it would be prudent for those members of society most vulnerable to radiation to evacuate the area. Thorn_burgh announced that he was advising pregnant women and pre..:school-age children within a 5-mile radius of the plant to leave the area.

Within a short time, the presence of a large hydrogen bubble in the dome of the pressure vessel, the container that holds the reactor core, stirred new worries. The concern was that the.hydrogen bubble might burn or even explode and rupture the pressure vessel. In that event, the core would fall into the containment building and perhaps cause a breach of containment. The hydrogen bubble was a source of intense scrutiny and great anxiety, both among government authorities and the population, throughout the day on Saturday, March 31. The crisis ended when experts determined on Sunday, April 1, that the bubble could not burn or explode because -of the absence of oxygen in the pressure vessel. Further, by that time, the utility had succeeded in greatly reducing the size of the bubble.

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03/08 Impact of the Accident I

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The accident was caused by a combination of personnel error, design deficier:1cies, and component failures. There.is no doubt that the accident at' Three Mile Island permanently changed both the nuclear industry and the NRC. Public.fear and distrust lncreasedLNRC'~

regulations and oversight became broader and more robJ:!_st, and management of the pfants was scrutinized more carefully. The problems identified from careful analysis of the events during those days have led to permanent and sweeping chan.ges in how NRC regulates its licensees - which, in tum, has reduced the risk to pu~lic health and safety.

Here are some of the major changes which have occurred since the accident:

• Upgrading and strengthening of plant design and equipment requirements. This includes fire protection, piping systems, auxiliary*feedwater systems, containment building isolation, reliability of individual components (pressure relief valves and electrical circuit b_reakers), and the ability of plants to shut down automatically; Identifying human performance as a critical part of plant safety, revamping operator training and staffing requirements, followed by improved instrumentation and controls for operating the plant, and establishment of fitness~for-duty programs for plant workel'$ to guard against alcohol or drug abuse; Improved instruction to avoid.the confusing signals that plagued operations during the accid~;

Enhancement of emergency preparedness to Include immediate NRC notification requirements for plant events and an NRC operations center that is staffed_ 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*a day. Drills and response plans are now tested by licensees several times a year, and

. state and locai agencies participate in drills with the Federal Emergency Management Agency and NRC; Establishment of a program to integrate NRC observations, findings, and conclusions about licensee performance and man~gement effectiveness Into a periodic, public report; Regular analysis of plant performance by senior NRC*managers who identify those

• plants needing additional ~ula~ory attention; Expansion of NRC's resident inspector program ~ first authorized in 19n -whereby at least two inspectors live nearby and work exclusively* at each plant in the U.S. to provide daily su~eillance of licel')see adherence to NRC regulations; Expansion of performance-oriented as well as safety-oriented inspections, and the use.

• _ of risk assessment to identify wlnerabilities of any plant to severe accidents; Strength~ning and reorganization of enforcement as a separate office within the NRC; **

The establishment of the Institute of Nuclear Power Operations (INP(?), the industry's own "policing' group, and ~rmatio!'l of what is now the Nu~ear Energy Institute to PA Histocic Resource Survey -Fonn 27

provide an unified industry approach to generic nuclear regulatory issues, and interaction with NRC and other government agencies; The installing of a_dditional equipment by licensees to mitigate accident conditions, and monitor radiation levels and plant status; Employment of major initiatives by licensees in early identification of important safety-related problems, and in collecting and as$essing relevant data so lessons of exp_erience can be shared and quickly acted upon; and expansion of NRC's international activities to share enhanced knowledge of nuclear safety with other countries in a number of important technical areas. "17 Significance "The accident at the Three Mile Island Unit 2 (TMl-2) nuclear power plant near Middletown, Pa., on March 28, 1979, was the most serious in U.S. commercial nuclear power plant operating history, even though it led to no deaths Qr injuries to plant workers or members of the nearby community. But it brought about sweeping changes involving emergency response planning, reactoroperator fraining, human factors engineering, radiation protection, and many other areas of nuclear power plant operations. It also caused the U.S. Nuclear Regulatory Commission to tighten and heighten its regulatory oversight. Resultant changes in the nuclear power industry and at the NRC had the effect of enhancing safety. The sequence of certain events - equipment malfunctions, design-related problems and worker errors-led to a partial meltdown of the TMl-2 reactor core but only very small off-site releases of radioactivity."18 While the accident at TMI Unit-2 was not the first, the last, the largest, the smallest, the most expensive, or the deadliest "industrial" or even "nuclear" accident in the nation's histo-ry, it occurred with devastating effect to the confidence of Pennsylvania residents, in addition to the nation, towards the nuclear energy industry and its leadership and oversight, including the federal government during the event and well into the future.

MetEd formally declared the first ever "State of General Emergency at a nuclear power plant in the United States on March 28, 1979.

Even after all the assurances of the nuclear energy community that nuclear stations were safe...

Dr. Herbert Kouts, head of the Division of reactor Safety research told the Associated Press on January 14, 1974 "the preliminary results... suggest there will nl;!ver be a major accident in a nuclear power plant."19 AEC officials "claimed... a person has about as much chance of dying from an atomic reactor accident as being struck by a meteor.":z.

0

_ 17 United States Nudear Regulatory Commission, MBackgrounder on the Three Mlle Island Accident," 11 August 2009, http://www.nrc,goy/reading-rmldoc-collect1ons/fact-sheets/3ml!e-isle,html, Accessed 19 November 2009.

18 United States Nuclear Regulatory Commission, MBackgrounder on the Three Mile Island Accident," 11 August 2009, http:llwww.nrc.goy/reading-rm/doc-coHectjons/fact-sheets{3mlle-isle,html, Accessed 19 November 2009.

19 Walsh, 28.

03/08 PA Historic Resource Survey Fonn 4

~

28

I "

ER# _____

... An accident did occur.

President <;:arter's "President's Commission on the Accident at Three Mile Island," formed two weeks after the accident, found that "to prevent nuclear accidents as serious as Three Mile Island, fundamental changes will be necessary in the organization, procedures, and practices-and above all-in the attitude of the Nuclear Regulatory Commission and, to the extent that the institutions we investigated are typical, of the nuclear industry.

1121 Steven Reed, State Representative, June 20, 1979 stated in regards to re-opening Unit 1, and the possibility of re-opening Unit 2.

111 must warn you all, citizens and collected officials alike, not to fall prey to that type of f9lly. To believe once again people wh_o have systematically misled us, misrepresented their position, misstated and distorted and warped the facts and withheld the facts -

something they are doing up and including this date-I cannot believe that we could even give thought to placing credibility in their continued assurances for public safety after an accident happened that was not supposed to happen in the first place, according to them.'!,2 2 Middletown minister on Sunday Pray for "all those who have come to our town from far away to keep us informed of developments... even if their reports are contradietory.1123 Governor Richard Thornburgh -

"I've often noted that I had little time to be personally frightened during the accident because of the constant press of the responsibility for the well being of nearly a quarter of a million central Pennsylvanians. The high points of my concerns were largely due to false or misleading information conveyed to the general public which required countermanding from my office. For example, the *bogus evacuation recommendation from the NRC on Friday morning, March 30; the so-called "bubble" in the reactor reported on Saturday evening, March 31; and various news accounts exaggerating the potential for a nuclear meltdown throughout the incident. As a result of TMI, my level of skepticism about nuclear power was substantially raised and, like niost Americans, I no longer took for granted the fact that this source of electric power was as risk-free as its promoters had indicated in its early years. This attitude has, I believe, resulted in a number of changes that make today's operating nuclear facilities much less risky than those in operation prior to the TMI accident."24 Oran Henderson, director of Pennsylvania Emergency Management Agency 20 Walsh, 28.

"The TMI kind of an accident we had here was one that we really hadn't planned on. The assumption was that the level of safety attained by the nuclear power plants was more than adequate to meet the needs. Also they never spenf too much time on it. As far as our 21 Report of the President's Commission on the Acddent at Three f:,,f ile Island-The Need for Change: The Legacy of TM/, 19791 7.

22 Del Tredrcr, 49.

23 Hampton, 64.

2

~ Richard Thornburgh, "Governing In a Nuclear Crisis," March 29, 1999. hJtp;lldlscu~s.washjngtonpo~t-~om/wp-srv/zforum/99/thqqil;>u_rQho3_29_. htm.

03/08 PA Historic Resource Survey Fann 29

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priorities of planning were concerned, we were more concerned with flash floods, tornadoes, chemical spills. So we had not devoted the degree of attention to a nuclear power plant that the lessons of TMI had pointed out we should have. And not only the state government but the federal government and local governments were all caught, I won't say napping, but we were caught short.1125 NRC, 2009 "The TMl-2 accident had the greatest impact on nuclear generation of any single event in history."

The accident also showcased the role of citizen protest groups for "the partial meltdown at TMI had raised serious questions about the safety of these reactors in the minds of most Harrisburg politicians, including Governor Dick Thornburgh, thus facilitating their subsequent siding with citizen protest groups on ma} public safety issues. Most importantly, the proximity of the accident site to the state capital provided easy access to lawmakers and other state officials for politically active citizens."26 Crowd at rally. Anti-nuke rally in Harrisburg [Pennsylvania] at the Capitol. April 091 1979; ACR Identifier 540017; The National Archives Demonstrators' signs. Anti-nuke rally in Harrisburg [Pennsylvania] at the Capitol April 091 1979; ARC Identifier 540020; The National Archives 25 Robert Del Tredici, The People of Three Mile Island (San Francisco: Sierra Club Books, 1980)1 34.

26 Walsh,48.

03/08 PA Historic Resource Survey Form 30

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TMI-Unit 2 meets National Register Criterion A for its association with the events that occurred during March 28, 1979 through April 4, 1979, which on local, state and national levels constitute historic events that have made a sign ificant contribution to the broad patterns of our history. In connection with the events of that week, TMI Unit-2 is significant in the area of Industry. The district is exceptionally significant in the history of the United States as the location of events that immediately influenced the lives of the residents of the Commonwealth of Pennsylvan ia, profoundly influenced the awareness (or lack of) millions of Americans in regards to nuclear power, and for its role in symbolizing those events for Americans. Images, interviews and first-hand accounts were broadcast and recorded by the media as well as by the general public. Today, people from all over the world come to see the site of the nation's worst nuclear accident. 27 In 1983, PHMC evaluated Three Mile Island, Key# 079154 (the entire site) for National Register of Historic Places eligibility. The comments of the staff at that time concluded that not enough time had passed since its construction or the event for the significance of this site to be evaluated or viewed without prejudice.

It is the opinion of the preparer, now thirty-one years later; it is now possible to evaluate the event's significance without prejudice. Therefore, the district meets the requirement of National Register Criteria Consideration G that a property achieving significance within the last 50 years must be of exceptional importance. The accident was the catalyst for nuclear reform. Within two weeks of the event, actions in the form of analyzing the event occurred. Within months, the events and actions had been fully determined. In addition to the numerous primary resources (see list at end of HRSF) that document the event, there has been secondary documentation within the last twenty years that can attest to the effect this event has had on the nuclear energy industry and the nation.

17In 1999, a Pennsylvania Historical and Museum Commission historical marker was placed along State Highway 441, sout h of the TMl-1 Visitor Center sign, to commemorate the 20 th anniversary of the accident, the marker reads: "NUCLEAR ACCIDENT AT THREE MILE ISLAND On March 28, 1979, and for several days thereafter - as a result of technical malfunctions and human error - Three Mile Island's Unit 2 Nuclear Generating Station was the scene of the nation's worst commercial nuclear accident.

Radiat ion was released, a part of the nuclear core was damaged, and thousands of residents evacuated the area. Events here would cause basic changes throughout the world's nuclear power industry. "

03/08 PA Historic Resource Survey Form 31

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Comparisons The purpose of this HRSF is not to compare Three Mile Island to other nuclear stations for its significance, rather what and how the event that occurred at TMI Unit-2 itself is significant. Therefore, the comparisons used are similar in nature for the reaction and awareness they created in terms of regulation, legislation, response, local leadership, protest and news coverage. In addition, since the event is being presented as having National significance, the comparisons are not confined to similar events in Pennsylvania.

The Cuyahoga River Fire, 1969 (Ohio)

The Cuyahoga River which had been referred to in the 1880s by Cleveland Mayor Rensselaer R. Herrick as "a sewer that runs through the heart of the city," continued to be a dumping ground for the pollutants produced by the industrial era well into the 1960s. On June 22, 1969, an oil slick and debris in the Cuyahoga River caught fire for approximately one-half hour in Cleveland, Ohio. Months later Time magazine reported on the event and stated, Some River! Chocolate-brown, oily, bubbling with subsurface gases, it oozes rather than flows. "Anyone who falls into the Cuyahoga does not drown,"

Cleveland's citizens joke grimly. "He decays"... The Federal Water Pollution Control Administration dryly notes: "The lower Cuyahoga has no visible signs of life, not even low forms such as leeches and sludge worms that usually thrive on wastes."

It is also -- literally -- a fire hazard."28 1960s - Source: Plain Dealer file Interestingly, no photograph of the actual fire exists, and when the Times article ran they used a photo from the 1952 fire. By then the "fire had begun to take on 'mythic status, and errors of fact became unimportant to the story's obvious meaning."

28Ohio History Central, "Cuyahoga River Fire," http:llwww.ohiohistorycentral.org/entry,php?rec=161t2, Accessed 24 November 2009.

03/08 PA Historic Resource Survey Form 32

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While the river had caught on fire previously in 18681 18831 18871 19121 1922, 19361 19411 1948 and 1952, many credit the half-hour 1969 fire "as being a catalyst for Congress to finally pass the Clean Water Act in 1972 and for the creation of agencies like the Environmental Protection Agency."29 While the city voters had just approved a uoo million bond issue in November 1968 for the cleanup of the river, it was Mayor Carl Stokes (the first black mayor of a major American city) that was the "true catalyst for taking the fire beyond Cleveland to a national stage."30 Former Cleveland City Utilities Director Ben Stefanski recalled "We didn't realize that the river had even burned until the next morning... We already had national reporters here viewing and reviewing what he was doing with the city and it just so happened that the fire was there and they were there and they wanted to know what he would do about stopping the pollution in the river and stopping the fires that had occurred for the last 50 years, some of them really big fires.

Stefanski said that up until then, most city workers, city officials and even the media and the public weren't all that interested in air or water pollution.

But Stokes was a quick study... he saw the problem of pollution and understood what the ramifications were on the city.

He also understood the possible solutions and he was able to articulate this to the press and later to Congress. Even though he was not an expert on water pollution, he was the mayor of a major city that was affected by a polluted river.

So he gave real context and meaning to what the problems really were."31 Jonathan Adler, environmental historian and law professor at Case Western Reserve University stated "the fire did contribute a huge amount to the new environmental movement and it put the issue in front of everyone else, too. Water pollution became a tangible, vivid thing - like it had never been on a national level."32 Sierra Club President Adam Werbach stated in a 1997 CNN interview "I mean a river lighting on fire was almost biblical. And it energized American action because people understood that that should not be happening."33 29Damon Sims, "Cuyahoga River Fire 40 Years Ago Ignited an Ongoing Cleanup Campaign," The Plain Dealer, http;//www.cleveland.com/science/index.ssf'2oo9/o6/cuyahoga riyer fire 40 years a.html, Accessed 11 November 2009.

30 Sims.

31 Sims.

32 Mike Rose, "Cuyahoga River Fire Galvanized Clean Water and the Environment as a Public Issue," April 12, 2009, The Plain Dealer, http://blog.cleveland.com/metro/2009/04/cuyahoga_river_fire_galvanized.html, Accessed 13 January 2010.

33 Rose.

03/08 PA Historic Resource Survey Form 33

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Love Canal, 1978 (New York)

The Love Canal site is located in the City of Niagara Falls, Niagara County, New York. In the 1890s, private developer William T. Love with backing from financiers proposed a canal, a large industrial complex and city to be constructed. Due to an economic depression and technological advances in electrical power, the funding and need for Love's industrial utopia disappeared by 1910. From 1942 -1952, Hooker Chemicals and Plastics used the partially dug canal as a landfill for the disposal of over 21,000 tons of various chemical wastes, including halogenated organics, pesticides, chlororbenzenes and dioxin. In 19531 the landfill was covered over, and sold to the Niagara Falls Board of Education. Land near the covered landfill was residentially developed (including an elementary school). During the 1960s and 70s, problems with odors and residues began as the water table rose, bringing contaminated groundwater to the surface. In April 1978, the New York Department of Health Commissioner, Robert Whalen, declared the Love Canal a threat to human health and in August, declared a health emergency at Love Canal, closed the elementary school, and recommended temporary evacuation of pregnant women and children who lived nearest to the site. A week later, on August 7, 1978, Governor Hugh Carey announced the state would purchase some of the homes closet to the site (Ring 1, later also Ring 2); at the same time President Jimmy Carter approved emergency financial aid for the Love Canal area (a first time occurrence for and event other than a "natural" disaster) and ordered the Federal Disaster Assistance Agency to assist the City of Niagara Falls.34 "Amid this setting, individuals (most notably Lois Gibbs, Dr. Beverly Paigen, and Sister Margeen Hoffmann, OSF) and local neighborhood (such as the Love Canal Homeowners Association) and community groups (such as the Ecumenical Task Force of the Niagara Frontier) became concerned about the situation. Their primary concern was the actual extent of the chemical contamination and its impact on the health of Love Canal residents. Second, and perhaps more important, was the lack of readily available information to explain the science: the levels of uncertainty, political and corporate agendas, manipulation of the media -- in general an overall paucity of reliable information that would answer the simple question, "Is it safe?" 35 Protest march by Love Canal families carrying effigies and signs with the message "Dioxin Kills"

c. 1978. New York State Department of Health Collection, State University of New York at Buffalo

)/,Eckardt C. Beck, "The Love Canal Tragedy," EPA Journal (January 1979), http://www.epa.gov/history/tooics/lovecanal/01.htm.

Accessed 19 November 2009: "Background Information," Love Canal Collections, University at Buffalo, the State University of New York, htto;//library.buffalo.edu/soecialcollections/loyecanal/about/background.oho. Accessed 19 November 2009.

35 "Background Information."

03/08 PA Historic Resource Survey Form 34

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"Love Canal was the first hazardous waste disposal case to draw national attention, and thus remains a landmark case. Congress drew on information from the Love Canal case when it debated and passed the Comprehensive Emergency Response, Compensation and Liability Act (CERCLA - also known as the "Superfund" Act). The Love Canal court battles actually provided one of the first tests of the new law."36 ove ana Ask Those Who Really Know! !

Ask the V ictims of L ove C anal why they need immediate permanent relocation and why some will refu se to leave their motel rooms once funds are cut off Ask the innocent V ictims of corporate profits, Hooker and Government negligence.

The rusons art S1mple We cannot I ad normal life, we C,.,,01 b Off!* p C..MOt !IM no<

Mtause ol C01twninl1 Ir L C 11 led sob 1Kiool11dlt.,._two **doteddtltto

.,... """

• llollll O'

r..,e lilt II $~ "'

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ti

• SI "* olblttllltltffl Love Canal Homeowners Association's full-page newspaper ad (produced in response to Hooker's ads) stating reasons why Love Canal victims need help from the government October 18, 1979, Penelope D. Ploughman Love Canal Collection, State University of New York at Buffalo 36Mark A. Zaremba, "love Canal - An Introduction," Online Ethics Center for Engineering and Research, http:llonlineethics.org/CMS/enviro/envirocases/lcanal.aspx. Accessed 19 November 2009.

03/08 PA Historic Resource Survey Form 35

ER# _ ___ _ ___________ _

Glossary Cladding

• The thin-walled metal tube that forms the outer jacket of a nuclear fuel rod. It prevents the corrosion of the fuel by the coolant and the release of fission products in the coolants. Aluminum, stainless steel and zirconium alloys are common cladding materials.

Emergency feedwater system

• Backup feedwater supply used during nuclear plant startup and shutdown; also known as auxiliary feedwater.

Fuel rod

• A long, slender tube that holds fuel (fissionable material) for nuclear reactor use. Fuel rods are assembled into bundles called fuel elements or fuel assemblies, which are loaded individually into the reactor core.

Containment

• The gas-tight shell or other enclosure around a reactor to confine fission products that otherwise might be released to the atmosphere in the event of an accident.

Coolant

• A substance circulated through a nuclear reactor to remove or transfer heat. The most commonly used coolant in the U.S. is water. Other coolants include air, carbon dioxide, and helium.

Core

• The central portion of a nuclear reactor containing the fuel elements, and control rods.

Decay heat

• The heat produced by the decay of radioactive fission products after the reactor has been shut down.

Decontamination

• The reduction or removal of contaminating radioactive material from a structure, area, object, or person.

Decontamination may be accomplished by (1) treating the surface to remove or decrease the contamination; (2) letting the material stand so that the radioactivity is decreased by natural decay; and (3) covering the contamination to shield the radiation emitted.

Feedwater

• Water supplied to the steam generator that removes heat from the fuel rods by boiling and becoming steam. The steam then becomes the driving force for the turbine generator.

Nuclear Reactor

• A device in which nuclear fission may be sustained and controlled in a self-supporting nuclear reaction.

There are several varieties, but all incorporate certain features, such as fissionable material or fuel, a moderating material (to control the reaction), a reflector to conserve escaping neutrons, provisions for removal of heat, measuring and controlling instruments, and protective devices.

Pressure Vessel

• A strong-walled container housing the core of most types of power reactors.

Pressurizer* A tank or vessel that controls the pressure in a certain type of nuclear reactor.

Primary System

• The cooling system used to remove energy from the reactor core and transfer that energy either directly or indirectly to the steam turbine.

Radiation

• Particles (alpha, beta, neutrons) or photons (gamma) emitted from the nucleus of an unstable atom as a result of radioactive decay.

Secondary System* The steam generator tubes, steam turbine, condenser and associated pipes, pumps, and heaters used to convert the heat energy of the reactor coolant system into mechanical energy for electrical generation.

Steam Generator

• T e heat exchanger used in some reactor designs to transfer heat from the primary (reactor coolant) system to the secondary (steam) system. This design permits heat exchange with little or no contamination of the secondary system equipment.

Turbine* A rotary engine made with a series of curved vanes on a rotating shaft. Usually turned by water or steam. Turbines are considered to be the most economical means to turn large electrical generators.

03/08 PA Historic Resource Survey Form 36

Key # ______ _

ER# ___

SGT LEGEND 5Gfl"OISOll'f1 n.1N--

, ICILIH(S ~

L~'ttrMtimlll'IIOl ITIIGIIG ~

r.o.¥.S.

u.c.

ILP.S

~

Ml I STEAM GENERATOR REPLACEMENT PROJECT FAC ILIT IES STUDY-ATTACHMENT FACIL ITIES LAYOUT DRAWI NG

/

Cooling Tower A, Unit 2

/

Cooling Tower B, Unit 2 Reactor Building, Unit 2 rf Unit 2 Mechanical Draft Cooling Tower.

(Basin/foundation only)

~

Intake Screen & Pump House, Unit 2 (Robotics staging, maintaining, decontaminating and training - Mockup & Test facility - now used for Unit 1)

Control Building, Unit 2 t:::> Turbine Building; Coagulator Buil*-

foundation only (previously Unit 2's water pre treatment building)

Date Unknown, but most likely 19gos-2ooos

-1 ER# ______________ _

Key#_

03/08 PA Historic Resource Survey Form 8

/

Cooling Tower Unit 2

/

Cooling Tower Unit 2

/

Reactor Building, Unit 2

~

Service Water Post Cooling Tower Unit 2

~

Intake Screen Pump House Unit 2 Control Building, Unit 2 c:;::> Turbine Building, Unit 2 Original station construction 1965-71

Repository Trtle Author Catalog#

Resource State Archives Records of Special Commissions RG-25 Pennsylvania Commission on Three Mlle Island Nuclear Power Plant Reports and plans prepared at the request of Governor Richard Thornburgh by department of Pennsylvania's government regarding the acdclent at Three M0e Island. Information provided varies with somewhat according to the nature of each department but generally Includes date of report, descrtptlon of actions taken or proposed actions and Department Files 1979-1980 (3 boxes 25.169 recommendations for the future.

Newspaper dippings, press releases, telegrams, and memoranda chronlcRng unfold Ing daOy events during the first thlrty-0ays after~

accident. lnduded Is a SlDTimary of the events occurring during the first thirty days and Western Union telegrams sent to Governor Richard

__::.-~-..

Thornburgh from concerned citizens urging Immediate evacuation of the First Thirty Days, 1979 (2 boxes)25-138 area surrounding the plant.

Legislative subcommittee reports, memoranda, and notes concerning the economk Impact, emergency management, environmental, health, and legal aspects of the Three M0e Island accident. Subjects addressed are reactions of department heads addressed and programs for recovery.

The sertes was created In the office of Wlnlam W. Scranton who served as Leglslatfve Subcommittee Reports 1979-1980 (1 box 25.139 Pennsylvania's Lieutenant Governor during the accident.

Miscellaneous reports generated by various federal and state government commissions concerning the accident at Three Mne Island. These ~

testimony of Governor Richard Thornburgh, the General Public Utflltl Economk Impact Report, Three MRe-lsland 1 Hearings, Nudear Regulatory Commission reports, and the report of the Pennsylvania Commlsskm on MlsceUaneous 1979-1980 (4 boxes' 25-14 Three Mlle Island.

PubRcatlons, memoranda, reports, and newspaper dippings concerning the Three Mlle Island Accident. Many of these provide a general overview of the accident and of the nuclear Industry In general lndudlngnudear terrorism, the national nuclear debate, public opinion surveys In Pennsylvania regarding the Three Mlle Island Accident and Its aftermath, Press Related Publications 1970-1981 (3 boxes'25-414 and financial fallout Including property tax lmpllcatlons.

Publications and reports coUected by the Commission on various aspects of the nuclear Industry and the Three Mlle Island nudear faclllty. Jhe reports were Issued by the Presklent's Commission on the Acdclent at Three Mfie Island, Pennsylvania government agencies, and private experts In nuclear technology. Specific subjects Include Information on how*a nuclear reactor works, the Technkal Staff Analysls Report on the Radiation Health Effects Task Group, and hwestlgatlve reports on the Three Mlle Island ac-ddent and local governments. Among these are the Report submitted by Commission Chairman John Kemeny, a 1977 Interim acceptance plan for physical security at nuclear power plants, a 1979 Cumberland County evacuation plan, and a 1979 Dauphin County action and response plan. Also present are news editorials; Legal Aspects 09 Three MUe Island Accident, and the Nuclear Regulatory Commission an Publications and Reports 1977-1981 (9 boxes25-142 for deanup Operations at Three Mlle Island Unit 2.

Transcripts of the proceedings of the President's Commission on Three Mlle Island that was created by President Jimmy Carter that met from April 25 - October 22, 1979. This commission consisted of a panel of experts who were charged with Investigating the causes and making recommendations In the aftermath of the nuclear accident at Three MDe Island. The type of Information provided Is date of hearing, names of those present, transcripts of the testimony and recommendations Transcripts and Proceedings 1979 (8 boxes'25-143 considered.

A graduate of North Carolina State conege and a former Dupont

• Corporation* engineer, Harold R. Denton was Director of the United States Nuclear Regulatory Commfsslon during the 1979 accident at the Three Mfie Island nuclear power plant Denton served as the chief of operations at the site during and after the crisis, keeping the public Informed about what had happened and what measures were being taken to correct the Harold & Lucinda Denton Papers MG471 situation.

Correspondence received by Harold and Lucinda Denton relating to the accident at Three M~ Island. Consists prlmarlly of letters and cards from the general public expressing their views on the accident and Denton's handtlilg of It, Invitations and acknowledgements for speaking engagements, and letters from strangers and acquaintances concerning travel and leisure activities during the Dentons' stay In central Pennsylvania. Many of the letters express gratitude for Denton's handling of the crisis, though some correspondents sought answers to questions General Correspondence 1979-1984 (2 boxes' 471.1 or criticized the public health hazards posed by nudear power plants.

Official correspondence sent or received by Harold Denton concemln.

the accident at Three Mlle Island and Its aftermath. Correspondents Include D. F. Bunch, Chief of the Program Support Branch of the Nudear Regulatory Commission, Ben Rush, Executive Director of the Energy Research Institute, Richard Pontz of the Fund-Raising Counsel for Philanthropic Institutions, Fred Young of The Hearst Corporation, F.

Marshall Rock, Jr.. Director of the Pen~lvanla House Select Committee, Raymond Reedy, Mayor of Lititz, and Peter H. Kostmayer of the United States House of Representatives. Also present a~ two White House press releases dated September 9, 1980 designating Harold Denton a "Dlstlngulsh,ed Executive" for outstanding performance In handllng the Three Mlle Island accident. Finally, there are several-eoples to Harold Official Correspondence 1978-1981 (1 folder 471-2 Denton of correspondence oasslng between others.

Reports Issued by the U. S. Nuclear Regulatory Commission and the Reports 1979-1981 (5 volumes and 1 folder 471.3 Department of Energy In the wake of the Three MRe Island acdclent..

copy of an artlCJe by Cym L Colmar emmea "KISIC A Pragmaoc De Mlmnus Approach" that appeared In the January 26, 1979 Issue of Science, offlclal journal of the American Association for the Advancement of Science, A,coPY of article entitled Chronology of Events at Three Mlle Island" In the April 4, 1979 Issue of THE NEWS, Mexico Oty1 copy of article entitled "Lawsuits Begin A Burden of Proof" In AprH 8, 1979 Issue of the Philadelphia Inquirer, A copy of the Aprl 16, 1979 Issue of the Harrisburg Patriot News with lead article entitled "The Agony of Newspaper and magazine artldes and newsletters the Atom" by Staff Writer Pat Carroll;, A Copy of a May 1, 1979 newsletter entitled Access to Energy, A Pro-Science, Pro-Technology, Pro-free Enterprise Monthly 1979-1999 (3 folders 471.5

~.......... _.,., i:,,,,,1,1=,-,J~,1-,

A photocopy of an article by Mike Gray entitled "What Really Happened at Three Mlle Island" that appeared In the May 17, 1979 Issue of RoUfng Stone:,A Copy of newspaper entitled Energy News Digest of Nudear Hazards versus Alternative Energies dated February 28, 1980 published by the Energy Awareness Center of Woodstock, New York:,A Copy of a Newspaper and magazine artlcles and newsletters newspaper dated July, 198o entitled TMJToday'that was published by the 1979-1999 (3 folders' 471.5 Three Mlle Island Nuclear Power Station.

A copy of the December 6, 1983 newsletter entitled The Energy DaRy published In Washington, D. C. *,Media Update A Summary of the Important Newspaper Artldes Regarding Three Mlle Island for the week of April 6, 1989:,A copy of article entitled "TMI Ten Years Later, Stnl a Center of Nuclear Debate" In the March 20, 1989 Issue of USA Today;Copy of an article entitled "TMI It Touched the Way We Lived" In March 24, Newspaper and magazine articles and newsletters 1989 Issue of Lancaster Intelligencer Journal; Three MRe Island 10 Years 1979-1999 (3 folders 471.5 After," Centre Daffy Tunes, March 26, 1989.

People Magazine ( elated AprD 23, 1979 and Marth 24, 1980), featuring articles on Harold Denton. A copy of the February 1980 Issue of Susquehanna Magazine containing a blographlcal sketch on Harold Denton. Life Magazine, May 1979 containing an article entltled 9 Crisls In the World of Nuclear Pewee After Tine Mne Island, Big Questions About Safety and the Future.* The New Yorker,~

19, 1981 containing an article entitled "A Reporter at Large, Nuclear Waste"

• t-1;

  ;,;L, Fred C. Shapiro. Newsweek, June 27, 198 3 containing artlde entitled "The Lessons Learned at Three Mle Island" by Eileen KeerdoJa, Sylvester Monroe and Mary Lord.

Magazines 1979-1999 ( 1 box 471.8

Atari Connection, Fafl 1983 containing an artlcle entitled "Nuclear Troubleshooter Stays Sharp with Scram Video Game Imitates Life" by Paul Cohen.Nudear News, A Publlcatlon of the American Nudear Society, March 1985 containing an article entitled "The Nudear Construction Predicament - Part 1 A Regulator Responds to an Interview with the NRC's Harold Denton" by John Graham. Three copies of George Magazine, March 1999 containing an article entitled "Nightmare at Three Mlle

!~land" by Harold Denton. U.S. News and World R~ March 29, 1999 contalnblg an article entitled "When the World Stopped, Twenty Years Magazines 1979-1999 ( 1 box 471,8 After the Three Mlle Island Accident the Debate Still Rages Contemporary news cipplngs concerning the Three Mlle Island accldet, mounted on white sheets of paper. The newspapers from which the dippings were taken lndude The State of Columbia, South carollna, Harrisburg Evening News, Lancaster New Era, Lititz Record Express, Harrisburg Sunday Pat.riot News, Rocky Mountain, North Carolina Telegram, The Detroit News, The Miami Herald, The Plain Dealer, The Mounted News dippings, 1979 and undated (1 folder 471.1 Kansas City Times, Washington Post and Washlrutton Star.

Photocopies of contemporary newspaper articles concerning the Three Mlle Island acddent. Most of the articles are dated April and May, 1979 Photocooles of News Oloolngs, undated (1 folder' 471.11 and are from newspapers all over the United States Bumper stickers and miscellaneous advertising for purchasing bumper stickers, Three Mne Island Creamy Mushroom Dressing, collector's edition TMI lamps, and tours of the TMI countryside. Also present Is an ~

to the Denton family to attend an evening treasure hunt at Hersheyp TMI Memorabilia, undated (1 folder 471.12 on May 9, 1980.

Video tapes of Pennsylvania Cable News Network. Interviews of the 20th Anniversary Press Conference of Harold Denton held on March 25;1999 and of related PCN broadcasts entitled "Remembering Three Mlle Island,"

"Three Mlle Island and Media Relations" and "Three Mlle 1s1ancl Call-fn Program." Also present Is a video tape for a WJTF program on Three M De Island and original audio tapes of Historian Ken Wolensky's Interviews with Harold Denton and retired General Public UtD!tfes President Robert Long that were conducted on March 25 and March 26, 1999 respectively.

Video and Audio Tapes, 1999 (1 box) 471.14 lranscrtpts are present for the latter two Interviews.

Publications and reports coDected by the Commission on various aspects of the nuclear Industry and the Three Mlle Island nuclear facfllty. The reports were Issued by the President's Commission on the Accident at Three Mlle Island, Pennsylvania government agencies, and private experts In nudeat technology. Specific subjects Include lnfonnatlon on how a nuclear reactor works, the Technical Staff Analysis Report on the Radiation Health Effects Task Group, and Investigative reports on the

!Three MBe Island accident and local governments. Among these are the Report submitted by Convnlsslon Chafnnan John Kemeny, a 1977 Interim acceptance plan for physical security at nuclear power plants, a 1979 Cumberland County evacuation plan, and a 1979 Dauphin County action and response plan. Also present are news editorials, Legal Aspects of!

Three Mlle Island Accident, and the Nuclear Regulatory Commission Pan Publkatlons and Reports 1977-1981 (9 boxes25-142 for aeanup Operations at Three Mlle Island Unit 2.

Transcripts of the proceedings of the President's Commission on Three MDe Island that was created by President Jimmy carter that met from AprH 25 - October 22, 1979. This commission consisted of a panel of experts who were charged with Investigating the causes and making recommendations In the aftennath of the nuclear accident at Three Mlle Island. The type of Information provided Is date of hearing, names of those present, transcripts of the testbnony and recommendations Transcripts and Proceedings 1979 {8 boxes 25.143 <Onsldered.

A graduate of North caroffna State College and a former Dupont

• Corporation engineer, Harold R. Denton was Director of the United States Nuclear Regulatory Commission durtng the 1979 accident at the Three MUe Island nuclear power plant. Denton served as the chief of operations at the site during and after the crisis, keeping the public lnfonned about what had happened and what measures were being taken to correct the Harold & Lucinda Denton Papers MG471 situation.

Dkk Thornburgh Papers MG4O4 PA Governor Three Mne Island 4-2742-box 6 1979 -flies contain letters, telegrams, cUoDlrulS and resolutions Three M0e Island 4-2743 box 7 _

1979 Three Mlle Island 4-2744 box8 1980 Three Mlle Island 4-2745 box9 1981-1982 Three Mlle Island 4-2746 box 10 1983 Subject Correspondence/Sampled 4-3276 box 861 School Children, TMI Letters, 1986 Alan B.K. Rabinowitz, Deputy Executive Assistant for Word Processing Center/Mass Ma Dings (Unemployment Compensation, Correspondence 4-3325 box 1309 TMI, Others)

Richard A. Snyder Collection, MG373 MG373OO1OOOO2 OOOOCoo2513153 Subject FIie, 1963-1984 9

Nudeac TMI-PA Emergency, 30 Folders.

MG373OO1OOOO2 0000F066g13153 carton25 9

Three Mlle Island (TMI) 2 Folders, 1983-84 Records of the Public Utility Commission RG-37 Documents relating to the Investigation of the Three Mlle Island Nuclear Plant acdclent of March 28, 1979 and the financial consequences resulting from It. Included In this series are docket case flies, residential petitions, testimony and exhibit files, hearing transcripts; Three Mlle lsl_and Un.

daUy flow documents, and pre-Incident, Incident and post-Incident documents, such as testhnony and hearing transcripts, exhibits, correspondence, petitions, orders, and reports. Also found are related case Items, Including Publlc Utility Commission Docket Number 1-Secretary's Bureau 790404308, Pennsylvania Publk Utility v. MetropoDtan Edison Company Three MUe Island Investigation Records and Pennsylvania Electric Company, and Three Mlle Island Unit 1 docket 50 1968-1988 (22 cartons 37.3 89 documents Records of the Energy Office RG-63 Flndln-g Aid not onlfne as of yet

-Records of the PA Emergency Management Agency RG-69

Records Include minutes, agendas, reports, m;µiuals, lists of members, transcripts and correspondence. There are minutes for special meetings, meetings that pertained to an hnmedlate cllsaster or other pressing Issue.

Special meeting minutes are not accompanied by an agenda and after 1972, the CoWlCil stopped printing out separate agendas altogether.

Meeting topics lnduded floods, radiation, school and community fallout shelters, emergency supplies, personnel, budgets and droughts. Major crises mentioned are the Cuban Missile crisis, Three Mlle Island, 1974 national trucker strike, 1977 flooding and the 1979-1980 drought. Also 69.1, Cartons

!nduded are letters of appointment from the Governor and General Minutes and Agendas, 1591-1985 (3 cartons, 1 box) 2&3 Assembly.

Records of the Department of Health RG-11 Nothing soecffic. In any "title" Records of the Department of General Services -

Commonwealth Media Services RG-20 "Governor Dick Thornburgh discusses the 1979 TMI Disaster during a 1986 National Publk Radio Show" {Recorded off-air of WITT-FM) (1 tape),

"Governor Dick Thornburgh on TMI Disaster, National Public Radio, 1986

{Recorded off-air ofWITF-FM, Harrisburg) (1 tape), "Governor Dick Audio Tapes of Gov. Thomburgh's Interviews, 1986 20.39 Thornburgh on TMI, Natlonal Public Radio, 1986" (1 tape)

Video Tapes, 1980-1986 1070 -Voooo1T 3-27.1980 Dauphin County, Governor, Denton/Thornburgh TMI Press

• Conference 1073 -Vooo63T 7.g.1981, Dauphin County, Governor, TMI aeanup Proposal 1075 -vooo92T-Vooo93T 8.10.1981, Governor, NGG-TMI Statement 1076 - V00112T-Voo114T Governor, TMI deanup-US Senate Hearings State Library

Accident at the Three MRe Island nuclear power plant

[mlcrofom,J: oversight hearings before a task force US Congress.House.

• of the Subcommittee on Energy and the Environment Committee on Interior of the Committee on Interior and Insular Affairs, and Insular Affairs.

House of Representatives, Ninety-sixth Congress, first Subcommittee on Energy Forum Room 116 session._. Hearings and the Environment OS Microfiche 1979 us Congress.Senate.Commit Adequacy of nuclear powerplant security: hearing tee on Environment and before the Subcommittee on aean Air and Nuclear Publk Works.

Regulation of the Committee on Environment and Subcommittee on Clean y 4-P Public Works, United States Senate, One Hundred Air and Nuclear 96/10 S.HRG.103-Third Congress, first session, March 19, 1993. Hearings Regulation 57 1993 Answers to frequently asked questions about cleanup activities at Three Mlle Island, Unit 2[TMI Program Office, Office of Nuclear Reactor Regulation, US Y3,N Nuclear Reactor Regulation 88,0/0732/rev.1 1984 Calculations to estbnate the margin to failure In the TMl-2 vessel (mlcroffim Stickler,LA v 3.N 8a 25/6196 1994

.CMI Defense aspects of the Three MDe Island nudear US Congress.House.

accident hearings before the Military Installations and Committee on Am,ed Facilities Subcommittee of the Committee on Armed Services. Subcommittee services, House of Representatives, Ninety-six on MIUtary lnstaDatlons Congress Hearings and Fadlftles CJS8o H201-7 1980 US. Congress.House.

Committee on Energy and Commerce. S subcommittee on Oversight and aeanup efforts at Three Mlle Island Hearings investigations CIS 82 H36'1-67 1g82 Eldam, Gregory R. and J.

Thomas Horan, prepared_

Color photographs of the Three Mlle Island Unlt 2 for the US Department E1.28GEND-reactor containment bufidlnE of Energy 008/v.1 1g81 Crfsls contained The Department of Energy at Three Cantelon, PhDlp L and E1.28 Mfle Island A History Robert C. Williams DOE/EV/10278-T1 1g80

Division of Epldemiolog yResearch, Crisis evacuation during the Three MOe Island nuclear PA Dept of Goldhaber, Marilyn K.

acdclent The TMI population reglstr) Health and James E. Lehman N68sP P4 1g83 Cumberland County radiological emergency response Cumberland County plan for Incidents at the Three MDe Island Nuclear Office of Emergency Power Stations Preparedness 1981 US. Congress.

House.Committee on Interior Insular Affairs.

Current status of the Three Mlle Island nuclear Subcommittee on Energy generating station, units 1 and 2 Hearings and the Environment CIS 83 H441-27 1983 Dauphin County Dauphin county radiological emergency response plan Emergency Management for Incidents at the Three MRe Island Nudear Station Agency 1987 Demanding democracy after Three Mlle Island Goldsteen, Raymond L 363-1799 G578d 1991 Democracy In the shadows citizen moblllzatlon In the wake of the accident at Three Mlle Island Walsh, Edward J.

1363.179 W168d 1g88 Effects of the accident at Three MRe Island on 1981.Prepared for Dfvlslon of Safeguards, Fuel Cyde and Environmental residential.,, -.--*,:, values and sales Gamble, Hays Bentley v 3.N 8a 25/2063 Research, Office of Nuclear reirulatory Research Evaluation of nuclear facility decommissioning 1984. Prepared for Division of Engineering Technology, Office of Nuclear projects Doerge, D.H.

Y 3.N 8a 25/3884 re~latory Research Evaluation of publlc relations strategy In the US nuclear energy Industry after Three Mlle Island Lawrence, Patricia H.

13-75402 1995 Evaluation of the Three MHe Island unlt2 reactor 1983. Prepared for DMslon of Waste Management, Office of Nudear building decontamination process Dougherty, D.

Y 3.N 8a 25/3381 Material ~fety and Safeguards, US Nuclear Regulatory Commission final report on a social survey of Three Mlle Island area resklents Brunn, Stanley D.

621-483 B897 1979 US.Congress.House.Com mlttee on Interior and Insular AffalrsSubcornmltte on Financial lmpncatrons of the accident at Three Mne Energy and the Island Hearings Environment GS81 H441-27 1g81

US.Congress.Senate.Com Financing the cleanup of the Three Mne Island nuclear mlttee on Energy and powerplant Hearings Natural Resources CIS 82S311-17 1982 Governor Dick Thorn burgh's proposal to finance the deanup of Three Mlle Island Health-related behavioral Impact of the Three Mlle 1980. Submitted to the TMI Advisory Panel on Health Research Studies of Island nudear Incident Houts, Peter S.

the PA Department of Health Health -related economic costs of the Three-Mlle Pennsylvania State 1981. Submitted to the Division of Eplcfemlologlcal Research, PA Island Accident University Department of Health Impact abroad of the accident at the Three MUe Island 1980. Prepared for the Subcommittee on Energy, Nuclear Pronteratlon, Nuclear Power-Plant as so 54<>2-13 and Federal Services of the Committee on Governmental Affairs

• US.Congress.Senate.Com mlttee on Environment and Publlc Works.

Subcommittee on Clean y 4-P Air and Nudear 96/10 SHRG.103-Implementation of section 507 of the dean Air Act Hearings Regulation 60 1993 In the US District Court for the Middle District of PA In re Three MUe Island Dtlgatlon, cMI action no. 79-0432 KFP380.A8 15 1985 US Nuclear Regulatory Commfsslon, Office of Investigation Into the March 28, 1979, Three MUe Inspection and Island accident -

Enforcement Y 3-N 88 10/0600 1979

, Lancaster County radiological emergency response plan for Incidents at the Three Mlle Island Nuclear Station Lebanon County radiological emergency response plan for Incidents at the Three fv111e Island Nuclear Station Management weaknesses affect Nuclear Regulatory

- Commission efforts to address safety Issues common US.General Accounting GA 1.13 RCED to nuclear power plants Office.

149 The meltdown, or The bologna merchants fiction Kelsllng, WOiiam 813.54 K268m 1990 Meltdown a race against nuclear disaster at Three juvenile Mlle Island a reporter's story literature Hampton, WUborn 363-1799 H189m 2001

Steward/Gazlt Productions for the Meltdown at Three Mlle Island video American Experience 363-179 M495 PA Commission to Study and Evaluate the COnsequences of the Incident at Three Mlle News releases Island PY T5312.15/4 1979 Nudear plant terrorism Portzllne, Scott D.

363-32P839n 1994 Nuclear Property Insurance Act of 1981 [mlcroform]:

hearing before the Committee on Environment and US.Congress.Senate.Com Public Works, United States Senate, Ninety-seventh mftteeonEnvfronment

Congress, and Public Works.

as 82 s321-33

. 1982 US.Congress.House.Com N udear safety-three years after Three Mlle Island mlttee on Government

[mtcroform ]: joint hearing before certain Operations.Environment, subcommittees of the Committees on Government Energy, and Natural Operations and Interior and Insular Affairs, House o1 Resources Representatives, Ninety-seventh Congress Subcommittee as 82 H401-33 1982 People of Three Mlle Island/interviews and photos Del Tredlcl, Robert 974-831 D388p 1980 Programmatic environmental bnpact statement related to decontamination and disposal o1 radioactive wastes resulting from March 28, 1979 accident, Three Mlle Island Nuclear Station, Unit 2, US Nuclear Regulatory docket no. 50-320: draft supplement deaITng with Commission. Office of post-defuellng monitored storage and subsequent Nuclear Reactor cleanup Regulation Y 3.N 8a 10/0683 1988 Report In response to NRC staff recommended requirements for restart of Three Mlle Island Nuclear Station unit 1 Met Ed/GPU?

PY T5312.2 R311 1979?

Responses of Impacted popuf_atlons to the Three MUe Island nuclear reactor accident an Initial assessment Barnes, Kent 363.179 R312 1979

Selections from the Harrisburg papers on the ten-mile rule: selected documents In docket no. 50-289 ncense Pennsylvania Institute no: DPR-50 petition under 10 CFR 2.206, Including 0().

for aean Air before the 94-03 to obtain an emergency evacuation plan for the Nuclear Regulatory people of Hanisburg Commission 363-179 Se.48 1994 The social and economic effects of the accident at Three Mlle Island: findings to date Flynn, C. B.

Y3 N 8a 25/1215 1980. Preoared for US Nuclear Regulatory Commission Social responses to technological dlsastec the accident at Three MDe Island thesis Richardson, Bradley B.

84-27626 1984 The socio-economic Impacts of the Three Mlle Island Governor's Office of accident final report Polley and Planning 363-3497 P384s 1980 The Status of recommendations of the President's Commission on the Accident at Three MOe Island: a US Nuclear Regulatory ten-year review Commission v 3.N 8a 10/1355 1989 Studies of nudear hazards and constitutional !av, Webb, Richard E.

621-4835 W383s 1996 The Three MOe Island accident diagnosis and prognosis*

Toth, LM.ed 363-179 T4132 1986 Three Mlle Island: a nuclear crisis In historical perspective Walker, J. Samuel 363.1799 W153t 2004 Three Mile Island a Teader's guide to selected government pubDcatlons and government-sponsored 363-179016 research publlcatlons bibliography Hassler, Peron, H278t 1988 Wood, M. Sandra and Three Mlle Island a selective annotated blblJograph~ bibliography Suzanne m. Shultz 363.179 W85t 1988 Staley, John C and Roger 974-831 T 413Z Three Mlle Island, a time of fear R. Seip St, 1979 The Three MOe Island accident a case study c1f life event appraisal thesis Goldsteen, Raymond L 83-27775 198~

621.483509748 Three Mlle Island Stephens, Mark St44t 1980 The Three Mlle Island crisis: psychologlcal, social, and economic Impacts on the surrounding population Houts, Peter S.

363.179 H819t 1988 Three Mne Island Mental health findings Bromet, Evelyn PPW1.2T53,m 1980 The Three MOe Island nuclear accident continuing Comfort, Louise and policy Issues, dllemmas and strategies Carrie Mnler 363.1799 C734t 2003

Three Mlle Island proloro.ie orepIT01n1e Martin, Daniel

, 363.3497 M363t 1980 Governor's Office of Three Mile Island sodo-economlc f:mpact study Polley and Planning PY 1'7_12.2 T531m 1979 Three Mlle Island sourcebook annotations of a disaster Starr, PhRlp 363,179T413 1983 Three MDe Island the most studied nuclear accident report to Comptroller General of GA 1.13 EMO Bo-In history Congress the United States 190

. 1980 Three Mile Island turning point Keisling, WIUJam 621,483 T413 1980 Three Mlle Island's Impact on training In the nuclear lndustr)E a study of the Commonwealth Edison Company thesis Hossbach, Greg R.

95-20158 1994 US. TMl-2Lessons TMl-2 Lessons Learned task force final report Learned Task Force Y 3.N Ba 10/0585 1979 TMI lessons learned better protection for the publk and the envlroMle!lt Commonwealth of PA PEP 192.2 T626L 2004 TMI questions & answers Commonwealth of PA PEP 192.2 T626q 2004 The TMI 2 stol)C challenge, change, conclusion GPU 363.179T4133 1988 TMI 25 years latec the Three Mile Island nudear power plant accident and Its Impact Osff, Bonnie A.

363.1799 054t 2004 Voices from Three Mile Island the people speak out Leppzer, Robert, ed.

363.179V87 198o The warning accident at Three Mile Island Gray, Mike and Ira Rosen 363.179 G793w 1982 The willingness-to-pay for protection the case of the accident at Three ft.1ile Island thesis Slaysman, Kenneth s.

84-09099 1983 US Nuclear Regulatory Commission. Division of Title list publicly_ available documents Three Mile Technical Information

, Y3.N Ba Island Unit 2, docket 50-320 bibliography and Document Control 10/0568 1979

Further Information on the TMI 2 accident can be obtained from sources llsted below. The documents can be ordered for a fee from the NRC's PubJJc Document Room at 301.415-4737 or 1.800.397-4209, emall

-~.a*.

pdr.resource@nrc.gov. The PDR Is located at 11555 Rockville Pike, US Nuclear Rockvllle, Maryland, however the malllng address Is U.S. Nudear Regulatory Regulatory Commission, Publlc Document Room, Washington, D.C. 20555.

Commission A glossary Is also provided below.

NRC Annual Report* 1979, NUREG-0690,

Population Dose and Health Impact of the Accident at the Three Mne Island Nuclear Station NUREG-0558 "Environmental Assessment of Radiological Effluents from Data Gathering and Maintenance Operation on Three Mlle Island Unlt.2,"

NUREG-0681 "Report of The President's Commission on The Accident at Three Mlle Island," October, 1979 "Investigation Into the March 28, 1979 Three Mlle Island Accident by the Office of Inspection and Enforcement,"

NUREG-0600 "Three MUe Island, A Report to the Commlsslonel'5 and to the Public," by Mitchell Rogovfn and George T.

NUREG/CR-1250, Frampton Vols. 1-11, 1980 "Lessons learned From the Three Mlle Island* Unit 2 Advisory Panel, n NUREG/CR-6252 "The Status of Recommendations of the President's Commission on the Accident at Three MUe Island," (A ten-year review),

NUREG-1355

• "NRC Views and Analysis of the Recommendations of the President's Commission on the Accident at Three Mile Island,"

NUREG-o632 "Environmental Impact Statement related to decontamination and disposal of radioactive wastes resulting from March 28, 1979 accident Three MRe Island Nuclear Station, Unlt2,"

NUREG-0683 "Answers to Questions About Updated Estimates of Occupational Radl~n Doses at Three Mlle Island, Unit 2,"

NUREG-1060 "Answers to Frequently Asked Questions About Oeanup Activities at Three Mfle Island, Unit 2,"

NUREG-0732

Dickinson College I htto //www.threemRelsland.org/resource _ center/lndex.php Interviews with administrative assistant, attorney, bookkeeper, clergy, college administrator, conege student, Cumberland County clerk, emergency services employee, government agency employee, government offida~ homemaker, milltary officer, newspaper editor, Audio physician, etc. 1979 A Report to the Met-Ed Community Number 1-4 Met-Ed 1979 Rambo, Sylvia H. Chlef Ovll Action No. 1 CV-88-1452 (Order & Judgment Judge 6/7/1996 General Publk Utilities Control Room Operators Nuclear Jun-79 Looking Beyond the Lessons A Utility Manager's Perspective Clark, Phlllp R.

Apr-84 President's Commission Emergency Preparedness, Gorlnson, Stanley M.

TK 1344-P4-U578 Emergency Response Chief Counsel 1979 Oct-79 President's Commlsslon Report of the Emergency Preparedness and Response Task Force Dynes, Russell R. Head Tl< 1344.P4 U812 Oct-79 President's Commission Report of the Public's Right to Information Task Force Rubin, David M. Head TK 1344-P4 U813 Oct-79 President's Commission Reports of the Publk Health Kemeny, John G.

and Safety Task Force Chairman Tl< 13n U5 1979h Oct-79 President's Commission Repo~ of the Technical Kemeny, John G.

Assessment Task Force Vol 1 - 4 Chairman TK 1345.H37 U54 Oct-79 President's Commission Role of the Managing Utmty Gorlnson, Stanley M.

and Its Suppliers Chief Counsel Tl< 1345-H37 U54 Oct-79 President's Commission The Need for Oiange The Kenleny, John G.

Legacy of TMI Chairman Tl< 1345.H37 U54 Oct-79 Radiation and Health Effects A Report of the TMl-2 General Public Utfiltles Accident and Related Health Studies Nuclear Corporation 19g6 Report of the Governor's Commission on Three MRe Scranton, MIiam W.

Tl< 1345-H37 Island Chairman P46x l/l6/1g8o The Dicklnsonlan 1979 The Patriot 1979 The Sentinel 1979 The TMl-2 Oironkle The History and Lessons of Three General Publk Utilities MRe Jsland Unit Two Nuclear 1995

General PubUc Utilities The TMl-2 Story Nudear 1979-5-25 General Publlc Utllltles The TMl-2 Stof"ll Challenge, Change, COnduslon Nudear 1988 Three Mlle Island A Report to the commissioners and Rogovln, Mitchell, to the Public Vol.1-II Director January 1980 Golclsteen, Raymond L Trust and Its Relationship to-Psychological Distress and Karen Goldsteen, JSTOR The Case of Three Mfle Island John K. Schorr Pofltlcal PsycholOily, Vol 13, No. 4 (December 1992), pp. 693-717.

Some Publ\\c Helath Lessons from Three Mlle llsand A Case Study In Chaos Macleod, Gordon K.

Amblo, Vol 10, No. 1 (1981), PP. 18 Nudear Uablllty after Three Mlle Island Wood, William C.

The Journal of Risk and Insurance, Vo. 48, No. 3 (Spetember 1g81), p..

464-The Nuclear Regulatory Commfsslon and the Politics Publk:Admlnlstratlon Review, Vol. 42, No. 4 (July-August 1g82), pp. 355*

of Regulatory Refonn Since Three Mlle Island Temples, James R.

362.

Some Social and Political Dimensions of Nudear The American Polltfcal Science Review, Vol 75, NO. 1 (March 1981), pp. 132-Power Examples from Three Mfle lslantl Kelkln, Dorothy 142.

Resource MobDfzatlon and attzen Protest In Communities arouncfThree Mlle Island Walsh, Edward J.

Social Problems, Vol. 29, No.1 (October 1g81), pp.1-21.

Chisholm, Rupert F. and The Effects of Social Support on Nuclear Worker Stanfslav V. Kas~ Uoyed Responses to the Three Mlle Island Accident Mueller Journal of Occupational Behaviour, Vol. 7 No. 3 (July 1986), pp.179-793.

Women's Gendered Experiences as Long-Tenn Three Culley, Marci R. and Holly Mlle Island

• LAngeklque Gender and Society, Vol. 17 No. 3 (June 2003), pp. 445-461

• Differential Paths to Polldtal Actlvlslm comparisons Cable, Sherry, and of Four Mobilization Processes after the Three Mfle Edward J. Walsh, Rex H.

Island Acddent Warland Social Forces, Vol 66 No. 4 (June 1988), pp. 951-969.

Talbott, Evelyn O. and Ada O. Youk, Kathleen P.

McHugh, Jeffrey D. Shire, Alm!n Zhang, Brian P.

Mortality amoung the Residents of the Three MDe Murphy, Richard A.

Environmental Health Perspectives, Vol. 1081 No. 6 (Jun., 2000), pp. 545-Island Accident Area 1979-1992 Engbert 552 The Nature and Predictors of Job Related Tension In -a Chtsholm, Rupert F. and Crisis Sltu-atlon Reactions of Nuclear Workers to the Stanlslav V. Kasi, Brenda The Academy of Management Joumal, Vol 26, No. 3 (Sep., 1g83), pp. 385-Three MDe Island Accident Eskenazi 405

Three Mne Island Fact, Frame and Fiction Malmshelmer, Lonna M.

American Quarterly, Vol 38, No. 1 (Spring, 1986), pp. 35-52 Carter Nuclear Ucenslng*Refonn versus Three Mlle PubHus, Vol 10, No. 1, The State of American Federallsm, 1979 (Winter, Island Sylves, Richard T.

1980), pp. 69-79 large Three Mlle Island (TMl-2) Recovery and collection of Penn State Unverslty Decontamination Collection videos http /twww.nbrarles.psu.edu/tml/

Museum Exhibits Smithsonian National Museum of American History http //amerlcanhlstory.sLedu/tml/lndex.htm

"111-Penl).sylvania State Historic Preservation Office PENNSYLVANIA HISTORICAi; AND MUSEUM COMMISSidN October 26, 2020_

Geny van Noordennen

• Senior Vice President; Regulatory Affairs Energy Solutions 209 South Main Street, Suite 1700 Salt Lake City Utah 84111

-Kim Anthony cmanthony@energysolutlons.com

Dear Mr. van Noordennen,

The PA SHPO is in re~ipt of your letter requesting information on historic and archaeological resources on. Three Mile Island. As Three Mile Island Nuclear Station Unit 2 was permanently shut down after experiencing a partial melt down in 1979, after 28 years, the owners have decided to sell the property. In preparation, a Post-Shutdown Decommissioning Activities Report (PSDAR) is required to be submitted to the U.S. Nuclear Regulatory Commission (NRC) for review. While this NRC review does not constitute a federal action that would trigger Section 106 of the National Historic Preservation Act (NHPA), Energy Solutions is_ rea9hing out to the PA SHPO for information regarding historic and/or archaeological resources on the islano that

• should be considered in the PSDAR assessment.

Three Mile Island i_s located in.the Susquehanna River in Londondeny Township, Dauphin County, Pennsylvania. The Three Mlle Island Nuclear Station site encompasses approximately -

440 acres including the Three Mile Island and adjacent islands on the north end, a strip of land on the mainland along the eastern shore of the river and the area on ttie eastern shore of Shelly Island.

Archaeologlcal Resources In spite of the development of the nuclear facility operations in the mjddle-north portion _of the island, and some significant ground disturl;>ailce from borrow facilities elsewhere on the property,.

there are still some significant and potentially significant archaeological resources remaining. A total of ten archaeological site numbers have been assigned on Three Mlle Island. Sites on the island are listed below with brief comments. Additional details are available in Three Mile Island Generating station Unit 1 Cultural Resoumes Protection Plan dated 12/13/2011 which includes background research and results of on-the-ground reconnaissance by consultants Heberling Associates in 2009.

Froni north to south, the sites are as follows:

36DA50: Excavations at this site near the northern tip of the island, were undertaken In the 1970s by PHMC archaeologists. Herberling Associate's field views suggested that some of the site may remain _intact north of the previous plant construction. The site contains remains of pre-

. contact Native American camp sites and likely has other, deeply buried components..

36DA96: There is little Information about this pre-contact camp site which is assumed to have been 'totally destroyed by plant construction.

36DA97: Again; little information Is available but the site is believed to have been destroyed -

during construction of the plant.

CommonwealthKeystoncBuilchng I 400NorthStreet I 2ndFloor I Harrisburg,PA17120 I 717.783.8947

• Kim Anthony, October 26, 2020 36DA52: This site was recorded based on surface collections made by local informants.

Although there is a specific mapped location for this site, the artifacts recorded for it appear to have come from scattered locations across the island. -

36DA98: This site was located in the middle of the island and little information is available.

36DA51: Known from local informants, there is scant information about this site other than its

~tion and mention of unspecified organic materials being found:

36DA235: This site contains the extensive above ground ruins of a.19th-and early 20th-century tobacco farm on the wooded southeastern edge of the island. It includes foundations, walls, pits, wells, a silo _and other features. Historic records indicate this location was first used in the* late 1700s. The site has good integrity and is potentially an important historical archaeological resource.

36DA99: This Native American site is recorded as a long, oarrow strip along the southwest edge of the island where artifacts have been found on the eroding banks; however, the location also includes areas excavated inland from the banks in the 1960s and 1970s.

36DA 100: As pointed out in the Heberling report, there is a "somewhat arbitrary distinction" among sites 36DA99, 36DA 100 and 36DA 101. They are continuous along the river bank from 36DA99 south to the tip of the island and extend northward again f,:om the island's southeast tip.

Recent excavations due to a regulated fish passage project on the southwest edge of the island determined the site eligible for the National Register of Histc;>ric Places, with concurrence by PA SHPO 36DA 101: Contiguous with 36DA 100, the site was tested by the PHMC in 1967. Both pre-contact and historic components were present. The site is potentially National Register eligible. In 1998, Steven Warfel excavated a 19th-century burial here. A vest buckle and buttons found with the remains suggested a date between 1860 and 1880.The burial was reinterred in a higher location*

30 feet northeast of its original location.

This burial was almost certainly associated with the historic tobacco farm, remnants of which are located at *site 36DA235 to the north. This site should be considered especially sensitive due to the presence of the pre-contact materials, the rei,r1terred historic burial and the _possibility of an unrecorded ~mily cemetery.

Our primary recommendation is to avoid ground disturbances (for example, removal of fill) in the vicinities of sites 36DA99-101 and 36DA235, and other areas that have-1) not been tested 2) not investigated to confirm condition or 3) are not obviously cut and filled or otherwise deeply disturbed. We recommend that your cultural resources consultants provide you-with an updated evaluation of the island to include thorough background search, field visits and further-consultation with the SHPO. We look forward to working with agencies, _consultants, tribes and other consulting parties during the upcoming Section 106 consultation.

Above Ground Resources One of the first steps involves identifying resources that may be within or historically associated with the property. These resources may already be known or they mafbe found through a survey of the area.

The known historic resource, Three Mile Island Unit 2 (TMl-2) Key# 156047, is eligible for the National Register of Historic Places (NRHP), under Criterion A for its association with events that occurred during March 28, 1979 through April 4, 1979, under Criteria Consideration G ar:id with a boundary of approximately 12.3 acres.. Specific buildings, structures and elem~nts were not necessarily mefttioned in the Historic Reso4rce Survey Form (HRSF) on file. Therefore,

Kim Anthony, October 26, 2020 additional survey or documentation may Qe needed to better inventory the historic resource. For instance:

Liberty Lane on the mainland either crosses over or under the NRHP eligible Pennsylvania Railroad: Main Una (Philadelphia to Hanisburg), Key# 105675. It appears that there is a railroad branch/spur on the Island. Research should be undertaken to determine if it is historically related to the PRR, and/or which entity constructed it and in what time period,

_and If it would contribute to the PRR or to TMl-2, Key# 156047.

Three Mile Island Visitors Center - research should be undertaken to determine if it would contribute to TMl-2, Key# 1°?6047, or if it has significance on its own.

In addition, there may be other unknown or unsurveyed properties on the Three Mile Island, for exan:iple:

Red Hill Dam - research should be undertaken to see if the dam was constructed at least

• 50 years ago and has significance as a property type, or if it is historically related to TM 1-2, Key# 156047 or Three Mile Island.

Three Mile Island, Key# *079154 -when the island was surveyed initially, it was not at

. least 50 years of age. Does the entire site, as a nuclear power site (not as the site of the event in 1979), have significance as such. This would include Unit #1 as it began operation in 197 4, and will reach 50 years of age in the year 2024.

If you need further information concerning archaeological issues please consult Doug Mclearan at dmciearen@pa.gov or (717) 772-0925. If you need further information on above*

ground resources please consult Cheryl Nagle at chnagle@pa.gov or (717) 772-4519.

SincereJy,

~-&~

Douglas C. Mclearan,* Chief Division of Envir~mmental Review