Pennsylvania’s top environmental official on Monday expressed continued concerns about the adequacy of funding to complete decommissioning of the partially melted-down reactor Unit 2 at the Three Mile Island nuclear power plant.
Pennsylvania Department of Environmental Protection Secretary Patrick McDonnell submitted a follow-up to an early April letter to the U.S. Nuclear Regulatory Commission as it considers transferring the license for TMI-2 from owner GPU Nuclear Corp. to a subsidiary of nuclear services firm EnergySolutions.
The new letter also arrived less than two weeks after McDonnell’s agency filed a petition to formally intervene in the federal agency’s review of the November 2019 license transfer application.
Federal approval is necessary for GPU Nuclear (a subsidiary of Ohio power company FirstEnergy Corp.) to sell the reactor to TMI-2 Solutions, which would then assume all responsibility for decommissioning and ownership of the trust fund that will pay for the work. The companies hope to seal the deal by the end of 2020. EnergySolutions estimates it can complete decommissioning within 16 years.
“After review of the Application, it is unclear to the Department where the ultimate responsibility and liability lie should TMI-2 Solutions fail to have enough funds set aside for decommissioning and associated activities and then cease to exist,” McDonnell wrote in his April 27 letter.
The question of financial assurance is the sole contention the state agency submitted for consideration by the Nuclear Regulatory Commission, in its April 15 intervention petition: “After reviewing the material contained in the Application, the Department does not believe the record contains the necessary information to determine the ‘financial qualifications of the applicant’ and for the Commission to find, as it must, that the license transfer application would, if approved, provide ‘adequate protection to the health and safety of the public.’”
In an April 6 letter to NRC Chairman Kristine Svinicki, Pennsylvania’s environmental chief raised concerns about financial responsibility, environmental protection, and radioactive waste management at Unit 2. The agency on April 23 said it could not address the issues discussed in the letter while adjudicating the intervention petition.
However, GPU Nuclear President Gregory Halnon and EnergySolutions President John Sauger did respond directly to McDonnell in writing on April 13.
An attachment to the executives’ letter acknowledges that the current value of the decommissioning trust for Unit 2, $892 million, is well under the nearly $1.1 billion estimated price tag for the cleanup job.
But “it is important to recognize that the cost estimate represents the cost to decommission the facility over many years in the future,” it says. “Over time, even presuming a conservative 2% estimate of fund growth above inflation, the current 2019 [nuclear decommissioning trust can satisfy the roughly $1.05 billion decommissioning cost estimate.”
EnergySolutions is also committing a funding backstop of up to $100 million for decommissioning, according to the companies. Beyond that, theSalt Lake City firm has added contingency funding for each major decommissioning operation, plus a $50 million contingency not applied to any specific job.
McDonnell on Monday had questions about the terminology cited by GPU Nuclear and EnergySolutions in their letter: “It is unclear what the ‘financial assurance instruments valued at up to $100 Million’ are and what the phrase ‘up to’ means.”
The Department of Environmental Protection’s intervention filing with the NRC also questioned whether the decommissioning trust could accrue the necessary $200 million “over the 16-year anticipated decommissioning process.”
The two-reactor Three Mile Island nuclear power plant was built on a plot of land in the middle of the Susquehanna River, about 10 miles from the Pennsylvania capital of Harrisburg.
About three months after beginning operations, Unit 2 partially melted down in March 1979. It never started up again, leaving behind a highly contaminated facility. Ninety-nine percent of spent-fuel debris was subsequently transported to the Department of Energy’s Idaho Site for storage, Halnon and Sauger noted.
Three Mile Island Unit 1 operated from 1974 to September 2019. Owner Exelon has said it plans to place the reactor into SAFSTOR mode, under which final decommissioning can be delayed for up to 60 years.
Sauger and Halnon emphasized EnergySolutions’ experience in nuclear decommissioning. The company has managed projects in Arkansas, Illinois, and Wisconsin. It is part of the team (with AECOM) heading the $4.4 billion decommissioning of the San Onofre Nuclear Generating Station (SONGS) in California.
EnergySolutions and GPU Nuclear sought to allay other concerns raised by McDonnell in his first letter, including regarding local input on cleanup at the property. Once it assumes ownership of the reactor, TMI-2 Solutions plans to establish a “Citizens Awareness Panel” that could offer feedback on progress of decommissioning.
Even given the plant’s location on the Susquehanna River, it is protected against flooding, according to the companies’ attachment. It stands above the flooding level produced by the devastating Hurricane Agnes in 1972, and flood barriers have been placed at all external entrances to contaminated areas of the plant, they said.
Radioactive monitoring and controls are also in place, GPU Nuclear and EnergySolutions said.
In his letter this week, McDonnell requested additional information, including: the flood control plan for the site from GPU Nuclear and EnergySolutions; the radiological characterization study report for the reactor, prepared by a contractor for the two companies; and confirmation from the NRC that the Energy Depart,ent has committed in writing to take possesion of the damaged fuel now stored in Idaho.
In the intervention petition, the Department of Environmental Protection also requested additional time to seek a hearing on the financial assurance issue. The deadline should be set no less than one month after DEP reopens its physical offices, which are closed to curb the spread of COVID-19, the petition says. “The Department may elect to not pursue a hearing if, through further discussions with these parties, it is satisfied that the record before the Commission is complete in accordance with the” federal Atomic Energy Act.
For the NRC, there is no distinction between an intervention petition and a request for a hearing. Such a filing is intended to allow the petitioning party to raise issues for the record in an agency licensing proceeding.
The Harrisburg watchdog organization Three Mile Island Alert also filed an intervention and hearing petition on April 15.
There was no word Thursday on the NRC’s schedule for ruling on the petitions, a spokesman said.
