ML080650347

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Us Department of Transportation, Maritime Administration - Annual Report for Cy 2007, Revision 0
ML080650347
Person / Time
Site: NS Savannah
Issue date: 02/28/2008
From: Koehler E
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML080650347 (17)


Text

0 U.S. Department Savannah Technical Staff 1200 New Jersey Ave., SE of Transportation Office of Ship Disposal Programs Washington, DC 20590 Maritime Administration Ref: 10 CFR 50.36(c)(5), 50.59(d)(2), 50.75(f)(1)

February 28, 2008 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. Savannah Annual Report for CY 2007, Revision 0

References:

(a) Letter from Mr. J. H. Eads (NRC) to Mr. E. W. Koehler (MARAD), dated October 19, 2006, NRC Inspection Report No. 50-238/2006-201 Pursuant to Technical Specification 3.4, the United States Maritime Administration (MARAD) is required to submit an annual written report. MARAD hereby submits Revision 0 to the CY 2007 Annual Report as Enclosure (1).

The annual report is also intended to meet the reporting requirements of 10 CFR 50.59(d)(2) to provide a summary of 10 CFR 50.59 evaluations for activities implemented under 10 CFR 50.59 and the reporting requirement of 10CFR 50.75(f)(1) to provide the status of decommissioning funding.

As noted in Reference (a), the CY 2004 and CY 2005 Annual Reports included no discussion of the results of occupational exposure indicated by personal dosimetry. These results are addressed in Section 3 of Enclosure 1.

This submittal contains no new Regulatory Commitments.

If there are any questions or concerns with any issue discussed in this report, please contact me at (202) 366-2631, and/or e-mail me at erhard.koeiler"@dot.gov.

Respectfully, Erhard W. Koehler Senior Technical Advisor, N.S. Savannah Enclosures

,LJ,,~~t65Df 14 i~-~6 5

Docket No. 50-238; License NS-I; N.S. Savannah Submittal of Annual Report for CY 2007, Revision 0 February 28, 2008

Enclosure:

1. Annual Report for CY 2007, Revision 0 2

Docket No. 50-238; License NS-1; N.S. Savannah Submittal of Annual Report for CY 2007, Revision 0 February 28, 2008 cc:

Electronic copy NSS ESC NSS RAC Division of Atlantic Operations MAR 615 Hardcopy, cover letter only MAR-600, 640, 640.2 Hardcopy w/ all enclosures MAR-100, 640.2 (rf)

USNRC (John T. Buckley, Mark C. Roberts)

USNRC Regional Administrator - NRC Region I MD Department of the Environment (Roland G. Fletcher; George S. Aburn, Jr.)

NC Department of Environment & Natural Resources (Beverly 0. Hall)

SC Department of Health & Environmental Control (Henry Porter; T. Pearce O'Kelley)

VA Department of Emergency Management (Michael M. Cline)

VA Department of Health (Leslie P. Foldesi)

EK/jmo 3

0 U.S. Department Savannah Technical Staff 1200 New Jersey Ave., SE of Transportation Office of Ship Disposal Programs Washington, DC 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. Savannah Enclosure I to Submittal of Annual Report for CY 2007, Revision 0 I

V In' 0~ -

U.S. Department of Transportation Maritime Administration Office of Ship Disposal Programs I-'

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N.S. SAVANNAH ANNUAL REPORT 2007 STS- 105 Revision 0 Approved: 28,2008 Manager, N.S. Savannah Programs Date Prepared by:

Sayres and Associates Corporation

Savannah Technical Staff License NS-I Annual Report 2007, Revision 0 February 28, 2008 RECORD OF REVISIONS Summary of Revisions The original version of the 2007 Annual Report License NS-1 Revision 0 2

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 LIST OF EFFECTIVE PAGES Page No. Rev. No. Page No. Rev. No. Page No. Rev. No..

1 0 2 0 3 0 4 0 5 0 6 0 7 0 8 0 9 0 10 0 11 0 12 0 13 0 Revision 0 3

Savannah Technical Staff License NS-l Annual Report 2007, Revision 0 February 28, 2008 Table of Contents

1.0 INTRODUCTION

5 2.0 ITEMS REQUIRED BY TECHNICAL SPECIFICATION 3.4.1 5 2.1 Status of the Facility 5 2.1.1 License Activities 5 2.1.2 Organization 6 2.1.3 Review of Other Technical Specifications Requirements 6 2.1.4 Decommissioning Planning Activities 8 2.1.5 Decommissioning Funding Status 8 2.1.6 SAVANNAH Emergency Radiological Assistance Team (SERAT) 8 2.2 Radiation Surveys and Monitoring Station Dosimeter Readings 8 2.2.1 2007 Radiation Survey Results in Radiologically Controlled Areas 8 2.2.2 Monitoring Station Dosimeter Results 10 2.3 Environmental Sample Analysis Surveys 10 2.4 Quarterly Intrusion Alarm System Checks 11 2.5 Radioactive Materials Removed by Releases, Discharges and Waste Shipments 12 2.5.1 Releases 12 2.5.2 Discharges 12 2.5.3 Shipments '12 2.6 Principal Maintenance Performed 12 2.7 Unauthorized Entry Into Radiation Control Areas and Corrective Actions Taken to Improve Access Control 12 2:7.1 Event Discussion 12 2.7.2 Improvements to Access Control 12 2.8 Inspection of Boundaries Containing Radioactive Materials 12 2.9 Summary of 2007 Occupational Exposure 12 3.0 Summary of Occupational Exposure 2004 and 2005 13

4.0 REFERENCES

13 Revision 0 4

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008

1.0 INTRODUCTION

In accordance with the requirements of Technical Specification 3.4.1, an annual written report shall be submitted prior to March 1 of each year.

This report is arranged into two sections. Section 2.0 provides a discussion of the nine items required by the Technical Specifications. Section 3.0 provides a discussion of optional issues.

2.0 ITEMS REQUIRED BY TECHNICAL SPECIFICATION 3.4.1 The report shall include the following:

a. The status of the facility;
b. The results of the radiation surveys and monitoring station dosimeter readings;
c. The results of environmental sample analysis surveys;
d. The results of quarterly intrusion alarm system checks;
e. The amount of radioactive materials removed from the N.S. Savannah (NSS) by releases, discharges, and shipments of radioactive waste material;
f. A description of the principal maintenance performed on the vessel;
g. Any unauthorized entry into radiation control areas by visitors or employees and corrective action taken to improve access control;
h. Any degradation of one of the several boundaries which contain the radioactive materials aboard the NSS; and,
i. Results of occupational exposure indicated by personal dosimetry.

2.1 STA TUS OF THE FACILITY As defined by Reference (a), the NSS has been permanently defueled and placed in a Mothballed condition. This state of protective storage was approved in Reference (b). During calendar year (CY) 2007, the ship was layberthed in three locations:

o' Colonna's Shipyard in Norfolk, VA (January 1-30);

o Pier 23 in Newport News, VA (January 30 to May 30); and, o BAE Systems Norfolk Ship Repair facility in South Norfolk, VA (May 30 - December 31).

While in layberth, maintenance, minor repairs and other activities to prepare for dry-docking and future layberth operations were completed. These are listed in Item 2.6. After funding issues for dry-docking were resolved in 2007, the dry-docking contract was awarded to BAE Systems in August 2007 and scheduled for January 2008. (Note: Actual, dry-docking commenced on January 19, 2008.)

The most significant change to the status of the NSS in 2007 was that MARAD personnel were routinely on board during normal workdays. The benefit of this change included the opportunity to perform frequent tours and inspections that facilitated the detection and correction of problems.

2.1.1 LICENSE ACTIVITIES MARAD completed two significant licensing actions in 2007:

MARAD submitted a license amendment request (LAR) 2007-001 to redefine RCAs, require visitors to be escorted and resolve conflicts resulting from implementation of the Decommissioning Quality Assurance Plan; and, Revision 0 5

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 MARAD submitted the Final Safety Analysis Report (FSAR), Rev. IV on May 1, 2007.

MARAD continued developing and implementing a prioritized procedure development program. The most significant of these were those associated with the radiation protection program.

An independent review of the NSS document control systemwas performed. It included: 1) recommendations to improve the document control program and 2) a draft procedure for administering the document control program.

2.1.2 ORGANIZATION In 2007, MARAD continued its on-going efforts of improving the technical capabilities of the Savannah Technical Staff (STS). This year, MARAD filled the following positions with nuclear and/or maritime experienced staff:

" Nuclear Advisor;

" First Engineer;

" Electrician; and,

" Two General Vessel Assistants.

This increase in staffing along with staffing increases completed in CY 2006 continues to foster improvement in the physical and administrative aspects of the NSS programs.

2.1.3 REVIEW OF OTHER TECHNICAL SPECIFICATIONS REQUIREMENTS In accordance with the NSS Technical Specifications, the Review and Audit Committee (RAC) is specifically required to review the following items with or without a formal meeting:

a. Written reports of any deficiency discovered as a result of audits, on-the-spot checks, and evaluations to assure that all work is being done safely and in accordance with established procedures per TS 3.6.3; Any identified deficiency was documented in the Corrective Action Program. The Quality Assurance Manager provided a summary review of all completed CAR Resolution Documents at the December 2007 Annual Meeting.
b. Proposed changes as required by 10 CFR 50.59 per TS 3.6.4; This paragraph is intended, to meet the reporting requirement of 10 CFR 50.59(d)(2) to provide a brief description of any changes, tests, and experiments, including a summary of the evaluation of each.

No Changes, Tests or Experiments were proposed in 2007 that would require a 50.59 evaluation.

c. Proposed changes to Technical Specifications per TS 3.6.4; License Amendment Requests (LARs) and Responses to Requests for Additional Information on LARs were reviewed and approved prior to submittal.
d. Proposed changes or modifications to the vessel's controlled radiation area entry alarm system or containment vessel system per TS 3.6.4; The radiation area entry alarm system was improved during the year with the addition of new equipment to an existing system under a contract with ADT Security. ADT will now provide remote monitoring of all installed flooding, fire and intrusion alarms from one of its central ADT monitoring center. The old MOSCAD (Motorola Supervisory Control and Data Acquisition) radio system was deenergized and abandoned in place. The function of the Revision 0 6

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 MOSCAD was replaced with an ADT provided cellular phone system that dials out to the continuously manned ADT monitoring center system on receipt of any alarm condition. The ADT center then initiates notification to designated MARAD representatives. Post-modification testing confirmed that the alarms functioned as required, both locally and remotely.

There were no changes to the containment vessel system.

e. Substantive changes to radiation surveys or security surveillance procedures per TS 3.6.4; There were no substantive changes to radiation surveys or security surveillance procedures.
f. Reported violations of Technical Specifications per TS 3.6.4; There were no TS violations discovered in 2007.
g. Licensee Event Reports (LERs) per TS 3.6.4; There were no LERs during the reporting period.
h. Annual reports to the NRC per TS 3.6.4; The CY 2006 Annual Report and its Revision I were reviewed prior to their submittal on February 28, 2007 and March 23, 2007, respectively.
i. Proposals to access Restricted areas without HP direction per TS 3.3. 1; The RAC was briefed on the results of a survey conducted on October 2, 2007. The survey discovered and designated a new restricted area on the tank top deck starting at the top of the port and starboard ladders on the 14 foot flat that go down to the Tank Top deck. Restricted areas are defined in TS 3.3.1. The highest dose rate readings were found on a valve "nest" at the foot of the port ladder where the contact reading is 40 ýtR/hr and 7 p.R/hr general area. In addition, under the deck plates a contact dose rate reading on the charging system piping was 50 [tR/hr and 6 IpR/hr general area. The area was administratively posted as "Restricted Area -

Authorized Personnel Only." The current TS define a Restricted area as an area greater than 5 [tR/hr above natural background that may be entered only by employees, contractor personnel, escorted guests and official visitors.

The RAC agreed that the new Restricted area may be entered without health physics supervision.

by "GET trained" individuals and escorted visitors. NSS access procedures require all visitors to be escorted.

j. Surveys that re-designates areas as Unrestricted per TS 3.3.1; The RAC was briefed on the results of a survey conducted on August 17, 2007 in Cargo Hold 4.

The survey discovered that all of Cargo Hold 4 C-deck and the port side of D-deck could be re-designated as Unrestricted areas. The restricted area entrance on D-deck was moved to the locked door that prohibits access to the starboard side of D-deck. The RAC agreed with re-designating these areas as Unrestricted.

k. Procedures listed in TS 3.5; Procedures listed in TS 3.5 were reviewed prior to approval.

I. Grounding or sinking events per TS 3.6.5; There was no grounding or sinking event in 2007.

m. Events since the previous RAC meeting not discussed elsewhere per TS 3.6.; and, Revision 0 7

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 All notable events since the last meeting were discussed.

n. TS 3.7.1.7 Deviations from TS 3.7.1 Access Control Requirements All deviations generated in 2007 were reviewed prior to implementation.

2.1.4 DECOMMISSIONING PLANNING ACTIVITIES The following significant activities were completed in CY 2007:

" The Engineering Management and Oversight Services (EMOS) contract was awarded to AREVA NP (later novated to AREVA Federal Services, LLC); and,

" The FY '09 budget was developed and submitted.

2.

1.5 DECOMMISSIONING FUNDING

STATUS The following is intended to meet the reporting requirement of 10 CFR 50.75(f)(1 ). The N.S. Savannah and its nuclear reactor are federally owned facilities, represented by the United States Department of Transportation, acting by and through the Maritime Administration. As such, funding for the decommissioning find disposal of the NSS reactor and nuclear systems components and waste must be provided by appropriations from the United States Congress. MARAD maintains no funding reserve, nor does it accumulate or collect funds. As allowed by 10 CFR 50.75(e)(1)(iv), MARAD will obtain funds for decommissioning when necessary. Appropriated funds for FY 2008 are $4.7 million and are sufficient to support long-term layberthing following the current'dry-docking. In 2009, $3.0 million is requested to continue activities required to bring the nuclear facilities into compliance with current SAFSTOR standards as compared to the Mothballed standards of 1974-1976. At the $3.0 million level, SAFSTOR preparation work will extend to 2011. Thereafter and until 2023, funding can be reduced to a level commensurate with maintaining the facility and license in a SAFSTOR condition.

2.1.6 SA VANNAH EMERGENCY RADIOLOGICAL ASSISTANCE TEAM (SERAT)

The SERAT Team conducted a training exercise on July 20, 2007. Training included a ship tour and hands-on equipment re-familiarization.

2.2 RADIA TION SUR VEYS AND MONITORING STATION DOSIMETER READINGS A routine radiological surveys program was implemented. Radiological survey measurements were taken in various non-Radiological Controlled Areas and Radiological Controlled Area. All non-Radiological Controlled Areas were insignificant as compared to background radiation levels except as described in 2.1.3.i.

2.2.1 2007 RADIATION SURVEY RESULTS IN RADIOLOGICALLY CONTROLLED AREAS General Area Highest General Area Highest Radiation levels Radiation Contamination Contamination AepRhr (micro- Level pR/hr Level Level R/hr) (micro-R/hr) (DPM/1OOcm 2) (DPM/100cm 2)

Reactor Compartment 1.0 1.0, <1000 <1000 Cupola Level Reactor Compartment

  • 15 at open hatch Upper Lvel t 1.0 to Reactor <1000 <1000 Upper Level vessel Revision 0 8

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 General Area Highest General Area Highest Radiation levels Radiation Contamination Contamination Area pR/hr (micro- Level pR/hr Level Level R/hr) (micro-R/hr) (DPM/1OOcm 2) (DPMI/I 00cm 2)

Reactor Compartment 1.0 -1.5 1.5 <1000 <1000 Forward Middle Level Reactor Compartment Aft <1.0 1.0 <1000 <1000 Middle Level 120,000 on contact with Reactor Compartment 0.2 pipe 7 ft in <1000 4041 inside Lower Level overhead; drum 10,000 @ 30 cm.

Reactor Vessel Ist Level 03-2.5 2.5 <1000 <1000 Reactor Vessel 2 nd Level 0.6-1.5 2.5 along DrumSteam <1000 <1000 7.3 on contact Reactor Vessel 3 rd Level 0.7-2.0 with Port Steam <1000 <1000 Generator Reactor Vessel 4th Level 0.7-. 1.8 1.8 along Port <1000 <1000 side of Reactor 250 on contact Port Charge Pump Room 5.0 - 35 with pump <1000 <1000 suction line Starboar-d Charge Pump 100 on contact Room 6.0 - 20 with pump <1000 <1000 suction line 25 on contact Hot Chemistry Lab 1.5 with sink drain <1000 <1000 trap 30 on contact with Steam Health Physics Lab 3.0 Generator <1000 <1000 Primary Side Samples Port Stabilizer Room 1.0 - 4.5 6.0 Knee level <1000 <1000 Revision 0 9

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 General Area Highest General Area Highest Area Radiation levels Radiation Contamination Contamination itR/hr (micro- Level pR/hr Level Level R/hr) (micro-R/hr) (DPM/100cm 2 ) (DPM/100cm 2 )

Port Booster Pump Area 15 -35 00 oncontact <1000 <1000 with piping Starboard Stabilizer Room 1.5 2.5 Walkway <1000 <1000 Stateroom B-i Rad Waste 5.0 8.0 <1000 <1000 Storage Area Fan Room B Deck 1.0-2.0 2.0 <1000 <1000 Cold Chemistry Lab Area 20-5.0 35 on contact <1000 <1000 C Deck with the floor 4000 on contact 5139 inside Sample Room D-Deck 25- 150 with overhead <1000 sample sink line Gas Absorber Room 150 on contact 6.0-25 with Rad <1000 <1000 D-Deck monitor 150 on contact Cargo Hold D Deck <1.0 - 6.0 behind aft deck <1000 <1000 plates along Port side Hold Deck Aft of Reactor 50 on contact space port side 5.0-7.0 with piping N/A N/A under the deck (see Item 2.1.3.i) plate 2.2.2 MONITORING STATION DOSIMETER RESULTS In addition, thirty-six (36) permanently placed thermoluminescent dosimeter (TLD) monitoring stations are dispersed throughout the non-radiological controlled areas of the NSS and in those areas of the NSS that are routinely occupied. Fixed point radiation surveys are performed during TLD change outs.

Results from the TLDs from all monitoring stations indicated that readings were insignificant as compared to the background radiation levels. No fixed point radiation dose rate exceeded 5 [LR/hr (micro-R/hr).

2.3 ENVIRONMENTAL SAMPLE ANALYSIS SURVEYS Environmental water and sediment samples were taken adjacent to the ship at various times during the calendar year as required by TS and ship's movement. These samples were sent to the off-site laboratory facilities of GEL Laboratories LLC, Charleston, SC for analysis. In addition as a comparison, a water and sediment sample was taken prior to the ship arrival at Revision 0 10

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 the BAE shipyard berth. The environmental sample results indicate-that the radiological conditions in the environment surrounding NSS are insignificant as compared to expected background conditions. Therefore, based on the results of the radiological environmental monitoring program, NSS operations did not have any adverse effects on the health and safety of the public or on the environment in 2007.

2007 RADIOLOGICAL ENVIRONMENTAL SAMPLING RESULTS Sample Location Sample Type of Co-60 Cs-137 Date sample NSS Port Side 23rd Street Newport News, 05/30/2007 Sediment (A) 4.95E-02 4.48E-02 VA pCi/g (B) pCi/g (B)

BAE Shipyard Norfolk, VA Pre-arrival 05/30/2007 Sediment (A) 6.53E-02 pCi/g (B) 6.OOE-02 pCi/g (B) 6.99E-02 pCi/g (B) 7.84E-02 pCi/g (B)

BAE Shipyard Norfolk, VA NSS Port side 10/02/2007 Sediment (A)

BAE Shipyard Norfolk, VA NSS Stbd side 10/02/2007 Sediment (A) 5.97E-02 5.69E-02 pCi/g (B) pCi/g (B)

BAE Shipyard Norfolk, VA Pier 6 Pre- 4.15E+00 3.72E+00 arrival pC1/L (B) pCi/L (B)

BAE Shipyard Norfolk, VA NSS Port Side 10/02/2007 Water 2.33E+/-00 2.26E+00 pCi/L (B) pCi/L (B)

BAE Shipyard Norfolk, VA NSS Stbd 10/02/2007 Water (C18E+00 2.05E+00 Side pCi/L (B) pCi/L (B) 3.93E+00 4.15E+00 BAE Shipyard Norfolk, VA NSS Port Side 10/02/2007 Liquid (C)' pCi/L (B) pCi/L (B)

BAE Shipyard Norfolk, VA NSS Stbd 10/02/2007 Liquid (C) 4.05E+00 3.88E+00 Side pCi/L (B) pCi/L (B)

(A) Sediment samples are reported on a dry weight basis and are decay corrected to the Sample Collect date (B) Calculated MDA as an a-posteriori values at the 95% confidence Level (C) Water was decanted off of sediment samples 2.4 QUARTERLY INTRUSION ALARM SYSTEM CHECKS Routine security surveillances were conducted as required and the Key and Seal log was reviewed on a quarterly basis. No deficiencies were noted.

Revision 0 I1I

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 2.5 RADIOACTIVE MATERIALS REMO VED BY RELEASES, DISCHARGES AND WASTE SHIPMENTS No radioactive materials were removed from the ship as described below:

2.5.1 RELEASES There were no releases.

2.5.2 DISCHARGES There were no discharges.

2.5.3 SHIPMENTS There were no shipments.

2.6 PRINCIPAL MAINTENANCE PERFORMED Principal NSS maintenance activities performed during the period included the following:

" Installed a new security gate system at the top of the gangway;

" Added ADT security equipment to the existing security system as detailed in 2.1.3.d above;

" Sampled ballast tank water in all tanks except those in the lower reactor compartment, frames 99 - 126;

" Painted numerous interior areas of the ship

" Removed oil from cargo machinery Deck Houses

" In order to facilitate emergency personnel egress from the Reactor Compartment (RC), changed the locking mechanisms for RC doors from a lock and chain to an inside chain secured by a threaded chain link instead of a lock. Locking mechanisms for the B - deck RC door and deck hatches were not changed.

" Throughout the accommodation spaces, removed un-encapsulated asbestos found in overhead ceiling panels, joiner bulkheads and pipe insulation.

2.7 UNAUTHORIZED ENTRY INTO RADIA TION CONTROL AREAS AND CORRECTIVE ACTIONS TAKEN TO IMPROVE A CCESS CONTROL No unauthorized entries were made into any Radiation Control Area in the previous year.

2.7.1 EVENT DISCUSSION None 2.7.2 IMPROVEMENTS TO ACCESS CONTROL None 2.8 INSPECTION OF BOUNDARIES CONTAINING RADIOACTIVE MA TERIALS The results of the annual inspections required by Technical Specification 3.7.6 was conducted in December 2007.

There was no notable change in the condition of the primary and auxiliary systems since the last inspection.

2.9

SUMMARY

OF 2007 OCCUPATIONAL EXPOSURE As a result of the N.S. Savannah being in the Mothballed state of protective storage, no individual is expected to receive in one year from sources external to the body, a dose in excess of 10% of the limits specified in 10 CFR 20.1201. Twenty individuals were monitored with TLD and Self reading dosimetry Revision 0 12

Savannah Technical Staff License NS-1 Annual Report 2007, Revision 0 February 28, 2008 during their entries into radiological controlled area. All personnel received zero dose from occupational sources during the monitoring period. Therefore, MARAD has no requirement under 10 CFR 20.1502, "Conditions requiring individual monitoring of external and internal occupational dose" to reasonably anticipate that there is a need to "monitor exposure to radiation and radioactive materials at levels sufficient to demonstrate compliance with the occupational of dose limits." Likewise, MARAD has no requirement under 10 CFR 20.2106, "Records of individual monit6ring results" to maintain records of doses when an individual is not required to be monitored.

3.0

SUMMARY

OF OCCUPATIONAL EXPOSURE 2004 AND 2005 As noted in Inspector Follow-up Item (IFI) 50-238/2006-201 -01 (Reference c), occupational exposure data for 2004 and 2005 was not submitted in their respective Annual Reports. Two other deficiencies noted in the IFI, Radiation Survey Results for 2005 and Quarterly Intrusion Alarm System Checks for 2004 and 2005, were reported as required in the 2006 Annual Report.

In 2004, no activities were conducted that required an individual to be monitored.

In 2005, the Scoping Characterization Project was the only activity conducted that would require individuals to 'be monitored. During that activity, seventeen (17) individuals were monitored. Seven (7) individuals received zero (0) to one (1) mR, six (6) individuals received 40 to 85 mR and four (4) individuals received 130 - 220 mR. The highest dose was 217 mR received by one individual. The exposure to all individuals was significantly less than 10% of the limits in 10 CFR 20.1201.

Reporting the summary of occupational exposure for 2004 and 2005 addresses the remaining deficiency noted in IFI 50-238/2006-201-01.

4.0 REFERENCES

a. Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974
b. Letter from Mr. Robert W. Reid (NRC) to U.S. Department of Commerce, Maritime Administration, dated May 19, 1976, No Title [Issuance of Amendment 8, Possession-only License]
6. Letter from Mr. J. H. Eads (NRC) to Mr. E. W. Koehler (MARAD), dated October 19, 2006, NRC Inspection Report No. 50-238/2006-201 Revision 0 13