Sep 29, 2024: The case against restarting Three Mile Island’s Unit-1


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TMI-20-005
 
February 19, 2020
 
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555-0001
 
Three Mile Island Nuclear Station, Unit 1
Renewed Facility Operating License No. DPR-50
NRC Docket No. 50-289
 
Three Mile Island Nuclear Station, Unit 2
Renewed Facility Operating License No. DPR-73
NRC Docket No. 50-320
 
Subject:          Response to Request for Additional Information Related to License Amendment Request for Proposed Changes to the Three Mile Island Nuclear Station Permanently                               Defueled Emergency Plan and Emergency Action Level Scheme
 



April 6, 2020

Kristine L. Svinicki, Chairman
U.S. Nuclear Regulatory Commission Office of the Chairman
Mail Stop O-16 B33
Washington, D.C. 20555-0001

Re: Three Mile Island Unit 2 License Transfer Dear Chairman Svinicki:

I am writing to you to express my serious concern regarding the proposed license transfer of the Three Mile Island Unit 2 (TMI Unit 2) nuclear power plant from GPU Nuclear Corporation to the EnergySolutions’ subsidiary TMI-2 Solutions, LLC (TMI-2 Solutions).

As you are aware, in 1979, the TMI Unit 2 power reactor had the worst nuclear accident in U.S. history. The TMI Unit 2 nuclear accident resulted in damage to the majority of the reactor core, released millions of curies of radioactive noble gases into the environs, and grossly contaminated the interiors of the containment and auxiliary buildings. Because of this, we understand there are very high radiation areas within TMI Unit 2 that present a grave risk to personnel that enter. Despite the limited entries into the containment building to remove damaged nuclear fuel in the 1980s, there are vast areas in the plant with unknown radiological conditions related to the TMI Unit 2 accident. I firmly believe TMI Unit 2 is the most radiologically contaminated facility in our nation outside of the Department of Energy’s weapons complex.

When it was announced that TMI Unit 1 was going to be permanently shut down, the Commonwealth’s residents and the Pennsylvania Department of Environmental Protection (DEP)) believed this to mean that TMI Unit 1 would enter into a SAFSTOR status for several decades and be decommissioned first. This would allow for the further decay of radioactivity within TMI Unit 2 and reduce worker exposure and possible environmental releases of radiation during clean up.

However, this understanding is no longer the case. With the announcement of GPU Nuclear Corporation planning to shed its responsibility for TMI Unit 2 to TMI-2 Solutions, we now understand that TMI-2 Solutions plans to immediately begin the decommissioning of TMI Unit 2 with the accrued $800 million in the financial assurance fund that GPU Nuclear Corporation and the NRC currently control. This leaves us with many questions and concerns, which I outline in more detail below, about what a license transfer of TMI Unit 2 will mean for Pennsylvania, the local environment, and the communities surrounding Three Mile Island.

Secretary
Rachel Carson State Office Building | P.O. Box 2063 | Harrisburg, PA 17105-2063 | 717.787.2814 | www.dep.pa.gov

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Nuclear Regulatory Commission - News Release
No: I-20-002 April 7, 2020
Contact: Diane Screnci, 610-337-5330 Neil Sheehan, 610-337-5331
 
NRC to Conduct Public Webinar on April 21 to Discuss Indian Point Nuclear Power Plant Decommissioning Topics
 
The Nuclear Regulatory Commission staff will hold a webinar for interested members of the public on April 21 regarding the decommissioning of the Indian Point nuclear power plant, located in Buchanan, N.Y.
 
The purpose of the webinar will be to provide key facts regarding the decommissioning process and how the NRC regulates such activities through on-site inspections and other reviews.
 
The webinar will begin at 1 p.m., Eastern Time. Participants will be able to view slides prepared by NRC staff and ask questions verbally and in writing via a web page set up to host the session. Online registration is required to take part. The meeting notice will contain information on how to access the webinar via phone bridge.
 
One of the two operating reactors at the plant, Unit 2, is scheduled to permanently cease operations in late April. The other, Unit 3, will be taken offline for the last time in April 2021. The Unit 1 reactor was permanently shut down in 1974 and has been in long-term storage since then, awaiting eventual decommissioning.
 
The NRC is currently reviewing an application to transfer the license for the plant from Entergy to Holtec, which has proposed decommissioning the facility in a more accelerated manner.
 
Good Day:

I had a lengthy phone chat with a colleague who has performed many, many risk assessments for nuclear power reactor risk issues. I contacted him to see if it was possible to use existing computer models to evaluate the risk implications of deferring inspections of components, relaxing the limits on work hours, etc.

As I suspected, he explained how easy it was to do. The challenge is in defining the performance and/or reliability reduction from a deferred task or relaxed limit. I posed several examples to him and asked how the potential risk implications could be modeled. For the 17 motor-operated valves on Limerick Unit 1 that Exelon sought to defer in-service inspections, the failure of the MOVs to perform their safety function (to open in some cases and to close in other cases) could be doubled. The model will then calculate the chance of core meltdown, which can be compared to the baseline (i.e., no impairments) case to see how the deferrals impacted safety margins.

For the case of relaxing work hour limits, the chances of worker mistakes in the model can be increased by multiples of 2, 5, and 10 (meaning the chance of an operator failing to start a safety system when needed is twice, five-times, or ten-times higher) to gauge the sensitivity of safety to human performance.

And the models can easily consider multiple impairments -- all 17 MOVs not being inspected this refueling, work hour limits being relaxed, torus coating remediation being deferred, etc.).

The colleague also apprised me of something I'd not realized (except in hindsight). The operating reactors vary in design and age. The risk value of a 2-inch valve at Plant X can be vastly different from that 2-inch valve's risk value at Plant Y. Similarly, some plants rely more on operators performing safety tasks than others; thus, the safety implications of relaxing work hour limits affect reactor safety differently. The NRC issued blanket relaxations of work hour limits despite knowing that the impact at some reactors would be quite higher than at other reactors.

But to the colleague's awareness, neither the NRC nor any plant owner has evaluated the risk implications from any of the assorted deferrals, reliefs, and relaxations. When I pushed back on this assertion, the colleague pointed out that if assessments had been performed, either the request or the approval would have cited the results.

The risk models are routinely used by plant owners for things like monitoring safety margins during refueling as the equipment is removed from service for maintenance and later returned to service. The NRC routinely uses the models to determine which crayon to pull from the set to color violations and kill time until lunch.

In any case, I prepared the attached slideshow to reflect my understanding of the risk assessment models and how one can account for deferrals, reliefs, and relaxations -- that it, if one were actually a risk-informed regulator and not a risk-deformed pretender.

Feel free to pass along the slideshow.

Thanks,
Dave

Mr. Bryan C. Hanson
Senior Vice President
Exelon Generation Company, LLC
President and Chief Nuclear Officer
Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 – EXEMPTION FROM SELECT REQUIREMENTS OF 10 CFR PART 26 (EPID L-2020-LLR-0014 [COVID-19])

Dear Mr. Hanson: The U.S. Nuclear Regulatory Commission (NRC) has approved the requested exemption from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 26, “Fitness for Duty Programs,” Section 26.205, “Work hours.” This action is in response to your application dated April 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20093M206), which cited the March 28, 2020 (ADAMS Accession No. ML20087P237) letter from Mr. Ho Nieh describing a process to request expedited review of certain exemptions from 10 CFR Part 26 during the COVID-19 Public Health Emergency (PHE).
Nuclear Regulatory Commission - Press Release
No: II-20-007 April 6, 2020
Contact: Roger Hannah, 404-997-4417
 
NRC Schedules Virtual Meeting to Discuss Performance of Honeywell Facility
The Nuclear Regulatory Commission staff will discuss the results of a performance review of the Honeywell uranium conversion facility in Metropolis, Ill., during a virtual meeting scheduled for April 14.
 
The session will be held from 1-3 p.m., Eastern Time (12-2 p.m., Central Time) with NRC officials from the Region II office in Atlanta and the agency’s headquarters in Rockville, Md., as well as Honeywell officials at the facility in Metropolis. The meeting can be accessed by the public and media via Skype and NRC officials will be available following the formal portion of the meeting to answer questions. For individuals without access to Skype, a telephone conference call number will also be available.
 
The NRC staff assessed performance of the Honeywell facility during the period beginning Jan. 1, 2018 and ending Dec. 31, 2019, in safety operations, safeguards, radiological controls, facility support and other areas. Although the safeguards area was assessed, that information is not publicly available due to its sensitive nature. The NRC staff review determined that Honeywell continued to conduct its activities safely and securely, protecting public health and the environment.
 
The NRC does not have resident inspectors at the Metropolis facility, but fuel facility inspectors from its Atlanta regional office conduct periodic inspections of various aspects of the operation.
 
Because the review found that none of the program areas needed improvement and the facility is currently in a “ready-idle” status with a reduced amount of material on site, the NRC has adjusted its inspection program accordingly. That reduction in overall inspections will remain in effect for the next two years if the facility remains in “ready-idle” status.
 
A copy of the NRC letter to the company regarding the performance review is publicly available on the NRC website.
 
For virtual meeting access or telephone call-in information, please contact either Tom Vukovinsky at 404-997-4622 (email: Thomas.vukovinsky@nrc.gov) or Paul Startz at 404-997-4709 (email: Paul.startz@nrc.gov).
 
Document Title:
Limerick Generating Station, Units 1 and 2 - Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLR-0014 [COVID-19]).
Document Type:
Code Relief or Alternative
Letter
Document Date:
04/03/2020

Document Title:
Email re: Beaver Valley Power Station, Unit 2 - Verbal Relief for Snubbers - Delivered 4/4/2020 at 4:00 p.m. (EPID L-2020-LLR-0050)
Document Type:
Code Relief or Alternative
E-Mail
Document Date:
04/04/2020
Document Title:
Email re: Beaver Valley Power Station, Unit 2 - Verbal Relief for MOVs - Delivered 4/4/2020 at 4:00 pm (EPID L-2020-LLR-0049)
Document Type:
Code Relief or Alternative
E-Mail
Document Date:
04/04/2020
Document Title:
Beaver Valley Station, Units 1 & 2; Davis-Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 - Annual Notification of Property Insurance Coverage
Document Type:
Legal-Insurance/Indemnity Document
Letter
Document Date:
03/27/2020

Capitolwire: Text of Senator Muth’s April 1 press release.
 
Limerick Township, Pa. -- Senator Katie Muth (D-Berks, Chester, Montgomery) today renewed her call on Exelon to improve its commitment to worker and community safety during the refueling at the Limerick Generating Station in Montgomery County, and made a short list of requests of the corporate energy giant in a letter to senior executives.
 
“Thus far, Exelon has provided an inadequate pandemic response plan, withheld information from county and state officials, and failed to prioritize the safety of its employees, contract workers, community first responders, as well as all residents of the 44th senatorial district and entire region,” Senator Muth wrote. “This is grossly irresponsible as Exelon has brought at least 1,400 workers to the epicenter of Pennsylvania’s Covid-19 pandemic.”
 
In an effort to contain the spread of Covid-19 through Montgomery County and beyond, Senator Muth is asking Exelon to do the following:
• Provide a complete list of worker accommodations. A previously provided list is incomplete. This list will ensure that first responders are geographically aware of potential risk of exposure to Covid-19 and better inform hospitality employees of the need to take precautions in the cleaning and service of lodgings.
 
* Work with federal, state, and county officials to create and implement a 14-day, controlled quarantine protocol for all contracted workers. Exelon should continue to fully compensate workers during this time and cover all costs incurred by workers during the quarantine.
 
* Continue to work with federal, state, county, and local officials throughout the refueling process, particularly improving transparency with regard to care of employees displaying symptoms of Covid-19, as requested by Congresswoman Dean and Commissioners Arkoosh and Moscowitz.
 
“These requests are simply a call for corporate responsibility to ensure maximum preventative measures to ensure safety and reduce harm of both workers, their families, essential workers across the tri-county area,” wrote Senator Muth. “It is my understanding that the plan is for many of these workers to move onto additional refueling projects, such as the scheduled Beaver Valley refueling project in western PA, as well as at other nuclear facilities across the country, and without proper safety and quarantine measures, we are risking a massive spread of Covid-19 across this state and nation.”
 
“By fulfilling these requests for increased mitigation, Exelon has an opportunity to right its wrongs and previous negligence, and demonstrate a commitment to protecting the health and safety of workers, their families and the community at large,” she concluded.

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