IR 05000238/2024001
| ML25076A700 | |
| Person / Time | |
|---|---|
| Site: | NS Savannah |
| Issue date: | 03/20/2025 |
| From: | Eve E Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Koehler E US Dept of Transportation, Maritime Admin |
| References | |
| IR 2024001 | |
| Download: ML25076A700 (1) | |
Text
March 20, 2025
SUBJECT:
U.S. DEPARTMENT OF TRANSPORTATION, N.S. SAVANNAH - NRC INSPECTION REPORT NO. 05000238/2024001
Dear Erhard Koehler:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2545, Research and Test Reactor Inspection Program, at the Nuclear Ship (N.S.) Savannah berthed in Baltimore, Maryland. The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with ship personnel, a review of procedures and records, and ship walkdowns. The results of the inspection were discussed with you, and other members of the N.S. Savannah staff on February 6, 2025, and are described in the enclosed report.
Based on the results of this inspection, no violations of safety significance were identified.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. No reply to this letter is required. Please contact Andrew Taverna of my staff at (610) 337-5119 if you have any questions regarding this matter.
Sincerely, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.: 05000238 License No.: NS-1
Enclosure:
Inspection Report No. 05000238/2024001 w/attachment
cc w/Enclosure:
John Osborne, Licensing and Compliance Manager
ELISE EVE Digitally signed by ELISE EVE Date: 2025.03.20 12:13:15 -04'00'
EXECUTIVE SUMMARY
U.S. Department of Transportation
N.S. Savannah NRC Inspection Report No. 05000238/2024001
A routine announced decommissioning inspection was completed on December 31, 2024, at the Nuclear Ship (N.S.) Savannah, currently berthed at Pier 13, Canton Marine Terminal, Baltimore,
Maryland. On-site inspection activities were performed February 27-28, March 7, April 15-17,
June 4, July 29 - August 2, and November 7, 2024. The inspection included a review of the programs and activities associated with the N.S. Savannah while the vessel is undergoing decommissioning. The inspection consisted of observations by the inspectors, a review of procedures and records and ship walkdowns. The N.S. Savannah is classified by the NRC as a research and test reactor. The program for overseeing the decommissioning of research and test reactors is described in Inspection Manual Chapter (IMC) 2545, Research and Test Reactor Inspection Program. In addition to inspection activities, NRC held a hybrid public meeting for the sites license termination plan on May 8, 2024.
Based on the results of this inspection, no violations of safety significance were identified.
REPORT DETAILS
1.0 Background
The N.S. Savannah is the property of the U. S. Department of Transportation (DOT),
Maritime Administration (MARAD). The N.S. Savannah was designed, constructed, and operated as a joint research and development project of MARAD and the Atomic Energy Commission. The ship operated from 1961 until it was removed from service in 1970. In 1971, the ship was defueled, and various dismantling activities were conducted through 1976 to remove much of the radioactive material from the ship and to isolate radiologically contaminated systems. These activities included removing ion exchange systems and resins and most of the water from the primary, secondary, and auxiliary systems. A Possession Only license was issued in May 1976. The N.S. Savannah is a registered National Historic Landmark. At the time of this inspection, the N.S. Savannah was berthed in Baltimore, Maryland and was in active decommissioning. The program for overseeing the decommissioning of research and test reactors is described in IMC 2545.
2.0 Research and Test Reactor Decommissioning
a. Inspection Scope
The inspectors performed on-site decommissioning inspection activities performed 2/27-2/28, 3/7, 4/15-4/17, 6/4, 7/29-8/2, and 11/7, supplemented by in-office reviews and periodic meetings and calls during the inspection period. The inspection consisted of observations by the inspectors, discussions and interviews with site personnel, a review of procedures and records, and ship walkdowns.
The inspectors observed two shipments of radioactive material, consisting of four intermodal containers on two flatbed trucks in April 2024. The shipment contained dry active waste and metal piping in IP-1 (industrial package) containers. The inspectors observed the lifting and radiological survey of the containers, the transport vehicle safety inspections, and briefing of the drivers (under conditions of exclusive use transportation).
The inspectors observed the marking of the waste containers and the placarding of the transport vehicles. Inspectors observed additional shipments of radioactive material of four intermodal containers in November 2024.
The inspectors reviewed the two shipping packages for the four intermodal containers.
The inspectors reviewed walk-down waste storage areas to determine controls and labeling practices at the staging and storage areas. Inspectors reviewed work packages for the four intermodal containers.
The inspectors reviewed the licensees organization and staffing to determine if they satisfy the license and technical specification requirements. The inspectors attended select meetings, including station management review committee meetings and plan-of-the-day meetings. Inspectors reviewed documentation and met with site personnel to discuss status of decommissioning and upcoming activities to determine if the site had conducted activities in accordance with regulatory and license requirements. The inspectors performed several site walkdowns to assess field conditions and decommissioning activities by evaluating material condition of structures, systems, and components, housekeeping, system configurations, and worker level of knowledge and procedure use and adherence. Additionally, inspectors conducted site walkdowns of controlled areas, to examine and evaluate radiological postings, and airborne and contamination controls. The inspectors observed select pre-job briefings and associated work activities, including but not limited to aggressive decontamination, and movement of intermodal containers.
The inspectors reviewed radiation work permits (RWPs), As Low As Reasonably Achievable (ALARA) work plans, work packages, Job Hazard Analysis (JHA), and procedures to determine if radiation work activities were effectively pre-planned to limit worker exposure. The inspectors observed radiation protection (RP) technicians performing work activities to determine if implementation of radiological work controls, training and skill level were sufficient for the activities being performed. The inspectors observed RP staff perform work activities and coverage including but not limited to:
- (1) aggressive decontamination work in the containment vessel (CV);
- (2) control of individuals entering and exiting controlled areas such as CV;
- (3) intermodal container movement;
- (4) Remedial Action Support Surveys (RASS) and Final Status Survey (FSS)activities. The inspectors reviewed calibration records and observed daily checks of the sites radiological instruments to determine if they were being used and maintained in accordance with the sites plan and procedures. Additionally, the inspectors observed staff donning and doffing required protective clothing and using portal exit monitors out of controlled areas. The inspectors reviewed the site dosimetry program and radiological dose records to determine if they were performed in accordance with the requirements.
The inspectors reviewed the sites self-assessment of the radiation protection program for the quarterly 2024 and 2023 reports. This was to determine if the program met the requirements by 10 CFR 20.1101(c) and recorded as required by 10 CFR 20.2102.
Additionally, to assess if the review of the program was being implemented along with any improvements cited.
The inspectors reviewed documents and discussed with ship personnel to evaluate if management performed audits and self-assessments, and to determine if issues were identified and corrected in accordance with the sites corrective action program (CAP).
The inspectors assessed the implementation and effectiveness of sites CAP by reviewing a sampling of issues, and conditions adverse to quality entered in the CAP.
Additionally, the inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations were of sufficient quality, and MARAD assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
b. Observations and Findings
The inspectors found that the vehicle inspections and driver briefings were comprehensive and met all requirements. The inspectors noted that the vehicle placarding was consistent with the information in the shipping documentation.
The inspectors found that the waste documented in both shipping packages had been appropriately characterized, classified, and prepared in accordance with regulatory requirements. The inspectors also determined radioactive waste shipped was properly classified, described, packaged, marked, and labeled, and was in proper condition for transportation. Additionally, the inspectors determined that radioactive waste shipments were conducted in accordance with DOT and NRC regulations.
The inspectors determined the site had adequate staffing for the current phase of decommissioning and that training programs had been effectively maintained. The inspectors verified that activities were performed in accordance with site programs and procedures. The inspectors determined that pre-job briefings were thorough and identified the significant potential hazards and management maintained a sufficient level of involvement.
The inspectors noted that during this inspection period, the site continued decommissioning and dismantlement activities in the CV. The inspectors noted that for the areas toured, the material condition and housekeeping was adequate. The inspectors noted through ship tours, document reviews, and observations of activities that the site conducted activities in accordance with regulatory requirements. The inspectors noted that workers were knowledgeable of and adhered to plant procedures and work plans, and pre-job briefings were thorough and highlighted specific safety concerns.
The inspectors determined that RWPs, JHAs, and ALARA plans were implemented as needed and were effective in limiting worker exposure and occupational dose was acceptable for the scope of the radiological work activities performed. The inspectors determined that RP staff effectively controlled work activities, used appropriate instruments for the surveys, and survey records were clear and complete. The inspectors verified that the site provided General Employee Training (GET) and instructed personnel in radiation safety. The inspectors determined the site dosimetry program was adequate and worker exposures were within regulatory limits. The inspectors verified that the annual review of the radiation protection program was performed in accordance with 10 CFR 20.1101(c) and recorded as required by 10 CFR 20.2102.
The inspectors determined that issues had been identified and entered into the CAP in a timely manner and the issues were effectively screened, prioritized, and evaluated commensurate with their safety significance.
c. Conclusions
No violations of safety significance were identified.
3.0 Inspection Procedure 83801, Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
a. Inspection Scope
The NRC contracted Oak Ridge Associated Universities (ORAU) to perform confirmatory surveys of the areas being considered for site release. From July 29 - August 1, 2024, the inspectors observed confirmatory surveys of the CV conducted by ORAU and observed site personnel conducting FSS. The inspectors observed gamma scanning measurements and the collection of metallurgical samples at various locations within the CV. The inspectors conducted interviews with cognizant site personnel to determine if Final Status Survey activities were conducted in accordance with the site requirements.
The inspectors observed performance of RASS and FSS. Inspectors reviewed instruments used in support of RASS and FSS activities and observed instrument source and background checks. Additionally, inspectors reviewed calibration records of the instruments in use for RASS and FSS. Inspectors observed how instruments were stored and maintained at the site. Inspectors observed the use of In Situ Object Counting System (ISOCS) equipment.
Inspectors reviewed documentation that included procedures, survey records, and the license termination plan. Additionally, inspectors reviewed dosimetry including environmental. Inspectors walked down areas of the ship after FSS was completed to observe isolation controls to prevent unwanted access.
Inspectors reviewed training and qualifications of personnel tied to RASS and FSS for the site. Inspectors reviewed documentation that included final status surveys, overview of Multi-Agency Radiation Survey and Site Investigation Manual (MARRSIM), and license termination process.
b. Observations and Findings
Inspectors determined that the procedures that govern RASS and FSS were appropriate and implemented in a manner that provides reasonable assurance the site does not pose undue risk to public health and safety. This included chain of custody, access control to FSS areas, survey data collection and data management, survey quality assurance requirements, and records retention requirements.
Radiological instruments used in support of RASS and FSS were determined to be appropriate. Their selection and calibration were appropriate for the radionuclides of concern (ROC) and the Derived Concentration Guideline Levels (DCGLs).
The site did not have any environmental releases. However, environmental results were reviewed for both water and sediment. Including area occupational radiological exposure results. The review of these results were below regulatory limits, and vendors used to analyze samples and dosimetry were determined to be accredited.
Inspectors determined that the licensee developed survey and sampling plans that were appropriate to the area remediated consistent with the sites classification of the survey unit. Additionally, the required percentage of the area to be surveyed was adequate, and the method to determine background radioactivity was appropriate. The quality controls of assessing and reporting of survey results were determined to be appropriate.
Inspectors determined individuals tasked with performing surveys were qualified to conduct surveys for RASS and FSS. Additionally, inspectors determined these surveys were performed in accordance with applicable procedures and plans.
ORISE conducted confirmatory surveys as an independent entity to assess the adequacy of licensees final status survey results. The NRC identified areas to be surveyed and sampled, worked with ORISE to determine what type of survey would be conducted, and developed a plan to perform measurements and sample collection. The NS Savannahs technicians collected samples as directed by the NRC for the confirmatory survey. The results of the survey and an evaluation of the licensees FSS package will be prepared later in 2025 or early 2026. The NRC relies, in part, on the confirmatory surveys to assess the adequacy of licensee surveys to demonstrate residual radioactivity levels meet the release criteria. NRC headquarters will evaluate the FSS reports provided by the licensee.
c. Conclusions
No violations of safety significance were identified.
4.0
Exit Meeting Summary
On February 6, 2025, the inspectors presented the inspection results to Erhard Koehler, Senior Technical Advisor, N.S. Savannah. No proprietary information was retained by the inspectors or documented in this report.
SUPPLEMENTAL INFORMATION
ITEMS OPEN, CLOSED, AND DISCUSSED
None
PARTIAL LIST OF DOCUMENTS REVIEWED
Work package WP-2021-196-010 signed 3/6/2024
NSS-FSSP-SYS-114-03-00 WP 2024-042 RC Void Tank
NSS-FSSP-SYS-114-04-00 WP 2024-042 Fresh Water Shield Tank
Intermodal Lift 12 20241106
FSS and RASS instrument calibration records
QSA-2024-001, 1ST QUARTER, 2024 Annual Radiation Protection Program Assessment
NSSS-FSS-TM-01, Module 1, Fundamentals Review
Final Status Survey Training
SRC Management and Admin FSS Training Roster
CAR Resolution Document 2024-43
STS-005-019, Chain of Custody for Samples, Rev. 3
SIC-MA-Q-21, ALARA Review Committee, Rev. 0
STS-007-011, Emergency Planning Drills, Rev. 0
October 2023 Water and Sediment SIC results
Environmental Air Sample Analysis (6 months)
4th Quarter Area Radiation Exposure reports
4th Quarter Occupational Radiation Exposure reports
SRC Qualifications
N.S. Savanah Metallurgical Samples
STS-002-011, Work Control Process, Rev. 14
Work Order, WP-2023-042, Perform Final Status Survey (FSS)
FSS Package, NSS-FSSP-STR-110-00-00
FSS Package, NSS-FSSP-STR-103-00-00
FSS Package, NSS-FSSP-SYS-116-02-00
Radiological Surveys
041620241230 & 041620241245
Shipping Packages
NSS-24-05/0633-01-0011 and NSS-24-04/0633-02-0015
Corrective Action Reports (CAR)
24-61, 2024-59, 2024-58, 2024-57, 2024-56, 2024-55, 2024-47, 2024-46, 2024-44, 2024-43,
24-42, 2024-40, 2024-39, 2024-37