In an April 6 letter to the U.S. Nuclear Regulatory Commission, DEP Secretary Patrick McDonnell expressed serious concerns about the plan to rapidly decontaminate the damaged Unit 2 reactor at the Three Mile Island Nuclear Power Plant in Dauphin County by TMI-2 Solutions and the transfer of responsibility and the facility’s permit from GPU Nuclear.

“"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.”

“Due to the TMI Unit 2 power reactor partial meltdown, it is our understanding there are still very high radiation areas within TMI Unit 2 that would present a grave risk to any personnel that enter.”

“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.”

“Given my stated concerns, I hope you and your fellow Commissioners will thoughtfully consider the unique aspects of the severely damaged TMI Unit 2 nuclear reactor and not approve a license transfer until all parties are satisfied that the decommissioning can be done safely.

“Equally important, we require firm legal assurances that financial resources are available to complete decommissioning once started, including bonding between the Commonwealth and licensee.

“I also expect no radioactive waste from TMI Unit 2 will be left on Three Mile Island.”

DEP also requested the NRC hold a local meeting to give the public an opportunity to ask questions about the decommissioning plan and its timetable for completion, after the current COVID-19 crisis is over.

Specific Concerns

Among the environmental and safety concerns outlined by Secretary McDonnell were--

-- Disposal Of Severely Contaminated Materials: Due to the severe contamination from the partial meltdown and the unknown radioactivity levels of materials that will need to be disposed, I request to know the following information related to how the radioactive waste from TMI Unit 2 will be handled:  Has the U.S. Department of Energy agreed to dispose of the TMI Unit 2 reactor vessel, which has a portion of the damaged nuclear fuel from the 1979 accident still fused inside?

-- Disposal Of Low-Level Waste/Will Any Remain Onsite: Are there volume and activity estimates of the Class B & C low-level radioactive waste that cannot be shipped to the EnergySolutions disposal site in Utah?  Has the low-level radioactive waste disposal site in Texas agreed to accept the Class B & C waste? Is there any greater than Class C low-level radioactive waste in TMI Unit 2? If so, will that remain onsite?

-- Disposal Of Very Low-Level Waste In PA Landfills: If asked by the licensee, will the NRC consider and approve very low-level radioactive waste to be disposed of in non-hazardous landfills in Pennsylvania?

-- Water Supply Protection: The TMI Unit 2 facility is in the middle of the Susquehanna River, a major water supply for the region that drains into the Chesapeake Bay. What environmental and pollution controls will be put in place to ensure no contamination of this critical water source?

-- Flood Control: What flood controls will be utilized during decommissioning to mitigate a worst-case flood scenario on the Susquehanna (e.g. a weather event similar to Hurricane Agnes in 1972 that produced 19-inches of rain in Pennsylvania)?

-- Environmental Surveillance: What increased environmental surveillance and pollution controls will the NRC require during clean-up of TMI Unit 2 to ensure any radiological releases are detected?

-- Who Will Cover Cleanup Cost Deficit: Given there is a significant disparity between the estimated cost to decommission TMI Unit 2 from the amount of funds currently available, what funding source will be used to cover the deficit?

-- Financial Assurances: Since the radiological conditions inside TMI Unit 2 are unknown, the actual cost to decommission it could be much higher than the current estimate of $1.2 billion. What legal and financial assurances will be put in place to address this potential?

-- Continuing Financial Responsibility: Who will the NRC require to retain financial responsibility to clean-up TMI Unit 2 after the license has been transferred?

-- Advisory Committee: Will the NRC require a local decommissioning advisory committee to be established to assure the clean-up of TMI Unit 2 is transparent to the public and local and state governments?

Click Here for a copy of the letter.

Public Comments

The Nuclear Regulatory Commission is now accepting comments on the proposed Unit 2 decommissioning plan until April 27.  Requests for a hearing on the application must be made by April 15.

Click Here for more details.

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