ML20122A058
| ML20122A058 | |
| Person / Time | |
|---|---|
| Site: | NS Savannah |
| Issue date: | 04/24/2020 |
| From: | Koehler E US Dept of Transportation, Maritime Admin |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML20122A058 (19) | |
Text
U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Ref: 10 CFR 50.75(f)(l); 50.82(a)(7) and 50.82(a)(8)(v)-(vii)
April 24, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Docket No. 50-238; License No. NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for Calendar Year (CY) 2019 The Maritime Administration (MARAD) hereby submits Revision O of the CY2019 Decommissioning Funds Status Report for the Nuclear Ship SAVANNAH (NSS) as Enclosure 1.
During a period where MARAD is soliciting bids on completing dismantlement and waste disposal, MA RAD respectfully requests that the subject sensitive source selection information be withheld from public disclosure in accordance with IO CFR Section 2.390 of the Commission's regulations (Application for Withholding). is the affidavit required by 10 CFR 2.390 requesting that Enclosure 3 be withheld from public disclosure. provides financial information of Sectfon 3.0, Financial Assurance Status Annual Report that MARAD has deteiwined should be withheldji*01i1 public disclosure as confidential inaterial. Enclosure 3 is considered commercial or financial information as discussed in IO CFR 2.390( d)( l ).
This leUer contains no new commitments. It revises one commitment regarding the site specific Decommissioning Cost Estimate (DCE). Instead of revising the DCE in 2020, the DCE is scheduled for full revision during preparation of the'License Termination Plan (LTP) submittal. The estimated date for submitting the LTP is CY202 I.
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 erhard.koehler(q)dot.gov.
Respectfully, Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal Enclosures 1 of22
Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Repo11 for CY2019, Revision 0 April 24, 2020 Enclosures I. STS-210, Decommissioning Funds Status Report for- CY2019
- 2. Affidavit for Withholding Enclosure 3
- 3. Section 3.0, Financial Assurance Status Annual Report (Confidential Information submitted under 10 CFR 2.390) 2 of22
Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for CY2019, Revision 0 April 24, 2020 cc:
Electronic copy NSS ESC NSS SRC MAR 610,612,615 Hardcopy, cover letter only MAR-600, 640,640.2 Hardcopy with all enclosures MAR-I 00, 640.2 (rt)
USNRC (Ted Smith, Katherine Warner)
USNRC Regional Administrator - NRC Region I MD Department of the Environment (Eva Nair)
EWK/jmo 3 of22
U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Submittal of Decommissioning Funds Status Report for CY2019 AFFIDAVIT I, Erhard W. Koehler, state as follows:
- 1. I am Senior Technical Advisor and Manager, N.S. SAVANNAH Programs and as such, I have been specifically delegated the function of reviewing the confidential financial information sought to be withheld from public disclosure in connection with nuclear power plant licensing, and am authorized to apply for its withholding on behalf of MARAD.
- 2. I am making this Affidavit in conformance with the provisions of IO CFR Section 2.390 of the Commission's regulations and in conjunction with the Application for Withholding requested in the cover letter.
- 3.
- The information sought to be withheld is contained in Section 3.0, Financial Assurance Status Annual Report, (Enclosure 3) and includes the entire contents of section 3 of STS-210.
Decommissioning Funds Status Report for CY2019. Through the combined effects of the information contained in Section 3.0, the report identifies the remaining balance of decommissioning funds at the conclusion of CY 2019.
- 4. The basis for proposing that Enclosure 3 be withheld is it that on March 4, 2020, prior to the submittal of this report, MARAD released its RFP for decommissioning and license termination services. The balance of decommissioning funds available at the beginning of CY 2020 represents the resources available to MARAD to award the contract arising from the RFP. This information thus constitutes source selection information as described in Federal Acquisition Regulations (FAR)
Part 2.10 I, whose disclosure could 'jeopardize the integrity or successful completion of the Federal agency procurement to which the information relates."
- 5. Public Disclosure of the information sought to be withheld is likely to cause substantial harm to N.S.
SAVANNAH (NSS) as follows:
MARAD is soliciting competitive proposals to complete decommissioning and license termination activities. MARAD has determined that publicly announcing the remaining balance of decommissioning funds could negatively impact the acquisition process by encouraging cost offers to be inflated to match that balance.
- 6. Pursuant to the provisions of paragraph 10 CFR 2.390(b )( 4), the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i) The financial information contained in Enclosure 3 has been held in confidence by MARAD.
(ii) To the best of my knowledge, the financial information contained in Enclosure 3 is of a type customarily held in confidence by MARAD. The basis for requesting withholding of Enclosure 3 follows:
The information constitutes source selection ii1formation as described in Part 2.10 I of the FAR.
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Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for CY2019, Revision 0 April 24, 2020 (iii) MARAD will transmit Enclosure 3 in confidence and expects the Commission to receive it in confidence. *
(iv) The information in Enclosure 3 is based on Federal accounting system data which is not publicly available.
(v) Public disclosure of the information sought to be withheld may cause substantial harm to the competitive position ofMARAD by jeopardizing the integrity of the ongoing procurement.
I I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this 24th day of April 2020.
Respectfully, e7 ?~;!';__/- - - - - - -
Erhard W, Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal 19 of22
0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Submittal of Decommissioning Funds Status Report for CY2019 STS - 210, DECOMMISSIONING FUNDS STATUS REPORT FOR CY2019*
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U.S. Department of Transportation Maritime Administration N.S. SAVANNAH DECOMMISSIONING FUNDS STATUS REPORT FOR CY2019 STS - 210 Revision 0 Approved: <!_ ~(..._-------.- Date: April 24, 2020 Manager, N.S. SAVANNAH Programs Prepared by:
TOTE Services, Inc.
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SAVANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 Record of Revisions Revision Summary of Revisions 0 The original version of the Decommissioning Funds Status Report for CY2019 List of Effective Pages Page No. Rev. No. Page No. Rev. No. Page No. Rev. No.
1-12 0 6 of22 Revision 0 2
SA VANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 Table of Contents
1.0 INTRODUCTION
4 I. I Decommissioning Status 4 1.2 Decommissioning Funding Sources 5 2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT 6 3.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT 8 3.1 Report required by 10 CFR 50.82(a)(8)(v) 8 3.2 Report required by 10 CFR 50.82(a)(8)(vi) 9 3.3 Report required by 10 CFR 50.82(a)(8)(vii) 9 4.0 PROJECT FUNDING 10 5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING 11 5.1 Annual Submittal of New Estimate 11 5.2 Revised Decommissioning Cost Estimate (DCE) 11 6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING 12
7.0 REFERENCES
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SA VANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0
1.0 INTRODUCTION
This Decommissioning Funds Status Report is submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH (NSS) and covers the calendar year 2019 (CY2019) repo1ting period. This repo11 incorporates the guidance contained in Regulatory Guide (RG) 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Reference (a). The report is arranged in five sections following this introduction.
In accordance with the requirements of 10 CFR 50.75(f)(I ), each power reactor that has already closed is required to report annually the status of its decommissioning funds to the Nuclear Regulatory Commission (NRC) on a CY basis. Section 2.0 of this Decommissioning Fund*s Status Report includes the seven (7) reports required by IO CFR 50. 75(f)( I).
In accordance with the requirements of IO CFR 50.82(a)(8)(v)-(vii), each power reactor that has already submitted its site-specific Decommiss\oning Cost Estimate (DCE) is required to provide a financial assurance status report annually to the.NRC on a CY basis. MARAD submitted a summary of its DCE with its Post Shutdown Decommissioning Activities Report (PSDAR), Rev 1, Reference (b). Section 3.0 of this Decommissioning Funds Status Report includes the reports required by 10 CFR 50.82(a)(8)(v)-
(vii).
Section 4.0 of this report provides specific information regarding the funds made available to and expended by MARAD during the reporting period.
Section 5.0 of this report provides information on regulatory corµmitments made by MARAD that are germane to decommissioning funding. Section 6.0 notes the time remaining to complete decommissioning.
Because the Federal fiscal year (FY) does not align with the CY, each annual decommissioning funds status report will include information from at least the two FY s that directly provide funds for expenditure during the reporting period. In most years, prior to the submission of the report on (or about) March 31, the President will submit a budget request to the Congress for the upcoming FY. Given that NSS activities are funded on an annual basis, the President's budget request is an early, although not definitive, indicator of future NSS funding. Since future funding can impact the decommissioning schedule described in the PSDAR, MARAD includes this public information, to the extent that it may be available, for context and in partial satisfaction of the 10 CFR 50.82(a)(7) requirement to notify the NRC of expected changes to content in the PSDAR.
1.1 Decommissioning Status The NSS holds a Possession-only license that was modified by License Amendment 15 (Reference c) to allow dismantlement and disposal. As a result of License Amendment 15, the ship's status changed from "Mothballed" to "Dismantlement."
Dismantlement is defined in Regulatory Guide (RG) 1.86, Terinination of Operating Licenses for Nuclear Reactors, Reference (d). This 1974 RG describes the now outmoded Dismantling option of decommissioning. MARAD understands RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12, 2016 and that its withdrawal does not impact the NSS licensing basis.
MARAD uses the words 'active decommissioning' and 'dismantlement' interchangeably.
On March 4, 2020, prior to the submittal of this report, MARAD issued a Request for Proposals (RFP) to seek decommissioning and license termination support services. Certain information contained within this report is Source Selection Information as described in Part 2.10 I of the Federal Acquisition Regulations, and has been requested for withholding from public disclosure.
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SA VANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 1.2 Decommissioning Funding Sources MARAD is a modal agency of the United States Department of Transportation (DOT). It is a Federal licensee as defined by the NRC. As such, funds for decommissioning and termination of the NSS license are provided by Federal appropriations. As described in the Decommissioning Funds Status Report for Calendar Year (CY) 2018, Reference (e), the NSS Decommissioning project is fully funded.
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SAVANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT .
This section provides a discussion of the seven items required by 10 CFR 50.75(f)(l ), and incorporates the guidance contained in RGI .159. The reporting requirements and corresponding MARAD information are provided below.
2.1 The amount of decommissioning funds estimated to be required.
a) Current licensed activities require approximately $3.00 million.
b) The revised site-specific DECON-License Termination cost estimate is $130. 7 million'.
2.2 The amount accumulated to the end of the calendar year preceding the date of the report.
Accumulation offunds is not applicable to the NSS. As a Federal licensee, JO CFR 50. 75(e)(l)(iv) allowsfundingfor decommissioning activities to be obtained by appropriations when necessary. As noted above, the project is fully funded.
2.3 A schedule of the annual amounts remaining to be collected.
Annual collection offunds is not applicable to the NSS. As a Federal licensee, JO CFR 50. 75(e)(l)(iv) allowsfundingfor decommissioning activities to be obtained by appropriations when necessary. As noted above, the project is fully funded.
2.4 The assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.
The 2019 revised site-specific DECON-License Termination cost estimate escalation for disposal of low level radioactive waste is 12. 9%. Transportation cost estimate escalation is (-) 10.2%.
Electric Power estimate cost escalation is (-)0.93%. All other industrial tasks cost estimate escalation was 3.18%.
Escalation factors were determined referencing NUREG 1307, Revision 17 (Waste Disposal costs) and by direct datafr0111 Bureau ofLabor Statistics from http://www.bls.gov/data/, Series ID for the latest 2019 values available:
- 1. *Wpu0543 (Industrial electric power)
- 2. Wpu0573 (Light fuel oils)
- 3. CIU2010000000210l (Total compensation, private industry, Northeast region).
Based on the above factors, the DECON -License Termination cost estimate escalation rate from 2018 to 2019 is 4. 7%.
There are no rates of earnings on decommissioning funds.
2.5 Any contracts upon which the licensee is relying pursuant to paragraph (e)(l)(v) of this section.
Not applicable because MARAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(l)(iv) method.
2.6 Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.
There have been no modifications to MARAD 's financial assurance methodology, which is limited to the use of Federal appropriations. Please refer to the response in Section 4.1 below for more information.
1 MAR.AD does not presently expect to require additional budgetary resources due to formula-based escalation of the decommissioning estimate.
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- 2. 7 Any material changes to trust agreements.
Not applicable because MARAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(J)(iv) method Consequently, no trust agreements exist.
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SA VANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 3.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT This section provides a discussion of the 10 items required by 10 CFR 50.82(a)(8)(v)-(vii). The reporting requirements and corresponding MARAD information are provided below.
3.1 Report required by 10 CFR 50.82(a)(8)(v)
(A)
I . The amount spent on decommissioning, both cumulative and over the previous calendar year, Within the context ofprotective storage as a phase of decommissioning activities, all the funds spent by MARAD in CY2019 and preceding years (FY2005 - present) have been spent for decommissioning purposes. MARAD 's budget requests through FY2020 have continued to provide for a baseline protective storage component of cost. This strategy is designed to provide sufficient resources to MARAD to maintain the NSS if there is an
- interruption in the decommissioning-license termination project for any reason.
During the CY 2019 reporting period, MARAD obligated approximately $.IIJlmillion.
The cumulative obligations since CY 2017 are approximately $.Jllmillion.
- 2. The remaining balance of any decommissioning funds, and After subtracting the total obligated funds ($lfllmillion) from the total approp_riated funds ($137 million 2), the remaining balance to complete decommissioning is sflll million at the beginning of CY 2020.
- 3. The amount provided by other financial assurance methods being relied upon; None. MARAD, as a Federal licensee, relies solely on the JO CFR 50. 75(e)(J)(iv) method (B) An estimate of the costs to complete decommissioning, reflecting any difference between actual and estimated costs for work performed during the year, and the decommissioning criteria upon which the estimate is based; MARAD 's CY 2019 site-,<,pec[fic DECON-License Termination cost estimate is $130. 7 million based on escalation from the 2018 estimate (see Section 2.4 above for the escalation basis).
This estimate is effective as of December 2019. The estimate of the costs to complete decommissioning (e.g., procure fixed price decornmissioning and license termination services) is $l'i million based on the follm,ving:
(C) Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report; and There have been no modifications to MARAD 's financial assurance methodology, which is limited to the use of Federal appropriations.
2 Includes the FY 2017 and 20 I 8 decommissioning appropriations of $131 million. and FY 2018 and 20 I 9 protective storage appropriations of $6 million (based on DECON formal project start date of Oct I, 2017). Does not include the FY 2020 protective storage appropriation, or requested/projected futtire year appropriations.
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SAVANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 (D) Any material changes to trust agreements or financial assurance contracts.
Not applicable because MARAD, as a Federal licensee, relies solely on the 10 CFR 50. 75(e)(l)(iv) method.
3.2 Report required by JO CFR 50.82(a)(8)(vi)
If the sum of the balance of any remaining decommissioning funds, plus earnings on such funds calculated at not greater than a two percent real rate ofreturn, together with the amount provided by other financial assurance methods being relied upon, does not cover the estimated cost to complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion.
Not applicable to MARAD.
3.3 Report required by 10 CFR 50.82(a)(8)(vii)
After submitting its site-specific DCE required by paragraph (a)( 4)(i) of this section, the licensee must annually submit to the NRC, by March 31, a report on the status of its funding for managing irradiated fuel.
The final disposition and status of the Atomic Energy Commission's nuclear fuel utilized by the NSS is described in the September 21, 1973, Operations Report and also in Section 1.3.1 of the Final Safety Analysis Report as follows:
- Thirty six spent fuel elements (Core I and Ia) were shipped.from Galveston, TX to the US Atomic Energy Commission (AEC) - Savannah River Plant, Aiken, SC in nine shipments from October 4 through December 21, 1972 via a lowboy trailer using the Piqua/Elk River Shipping cask.
The IO CFR 50.82(a)(8)(vii) report must include the following information, current through the end of the previous calendar year:
(A) The amount of funds accumulated to cover the cost of managing the irradiated fuel; MARAD is storing no irradiated nuclear jitel and, therefore, has no accumulated funds to cover such costs.
(B) The projected cost of managing irradiated fuel m1til title to the fuel and possession of the fuel is transferred to the Secretary of Energy; and MARAD is storing no irradiated nuclear fuel and, therefore, has no need to project such costs.
(C) If the funds accumulated do not cover the projected cost, a plan to obtain additional funds to cover the cost.
MARAD is storing no irradiated nuclear fuel and, therefore, has no need to obtain additional fonds to cover such cost.
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SA VANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019; Revision 0 4.0 PROJECT FUNDING As noted in section 1.2 above, the NSS decommissioning project is fully funded. The congressional appropriations in FY 2017 and FY 2018 fully funded the NSS Decommissioning Project by appropriating
$131.0 million. Annual appropriations to support baseline licensed activities and vessel layberthing also contribute to project funding. MARAD takes annual appropriations into account only after such appropriations are enacted. At the conclusion of FY 2019, total project funding was $137.0 million.
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SAVANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING There are two (2) recurring commitments regarding decommissioning funding that are reported on in each annual Decommissioning Funds Status Report. The resolution of any one-time commitments will be described as required. The recurring commitments are described in the following sections.
5.1 Annual Submittal of New Estimate In Reference (f), MARAD made a regulatory commitment that was subsequently revised as follows:
Submit a new estimate annually by either revising the site specific estimate based on .
circumstances that affect its underlying assumptions, or by using cost escalation factors no smaller than those in the most recent revision to NUREG 1307.
Effective with this submittal, the commitment is revised as follows:
The CY2019 estimate is provided in Sections 2.1 and 2.4 of this report.
5.2 Revised Decommissioning Cost Estimate (DCE)
In Reference (f), MARAD made the following regulatory commitment:
The site specific DCE will be revised at least every five (5) years.
Effective with submittal of this report, the commitment is revised as follows:
The site specific DCE will be revised in the License Termination Plan.
The site specific DCE is scheduled for full revision in 2020; however, MARAD has begun preparation of the License Termination Plan (LTP) submittal which is required to include an update to the DCE. The estimated date for submitting the LTP is CY202 I; therefore, the 2020 fu II revision to the DCE will be deferred to the 2021 LTP.
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SAVANNAH Technical Staff STS - 210, Decommissioning Funds Status Report For CY2019, Revision 0 6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING The license tennination deadline for the NSS is December 3, 2031, 3 based on the Permanent Cessation of Operations milestone date of December 3, 1971. Decomrhissioning is scheduled to be complete well within the allowed 60-year license termination period.
J December 3, 1971 is the de facto date of permanent cessation of operations date based on completing the reactor defueling that date by tensioning the reactor vessel head with six studs.
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7.0 REFERENCES
- a. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision I, October 2003
- b. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated December 11, 2008, Submittal of Post Shutdown Decommissioning Activities Report, Revision I
- c. Letter from Mr. John B. Hickman (NRC) to Mr. Erhard W. Koehler (MARAD), dated April 23, 2018, Nuclear Ship SAVANNAH - Issuance OfAmendment 15 to revise the License to allow Dismantlement and Disposal
- d. Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974
- e. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated March 28, 2019, Submittal of Decommissioning Funds Status Report for Calendar Year (CY,) 2018
- f. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated March 31, 2011, Submittal of Decommissioning Funds Status Report for CY 2010 and updated Governmental Statement of Intent for Decommissioning Financial Assurance 17 of22 Revision 0 13