ML20136A345

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Submittal of Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0
ML20136A345
Person / Time
Site: NS Savannah
Issue date: 05/07/2020
From: Koehler E
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20136A345 (13)


Text

0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Ref: 10 CFR 50.36a May 7, 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 Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 Pursuant to Technical Specifications 2.5.1 and 2.5.2, the Maritime Administration (MARAD) is required to submit an Annual Radiological Environmental Monitoring Report and an Annual Radioactive Effluent Release Report, respectively. MARAD hereby su9mits Revision Oto the Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports as 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 erhard.koehler@dot.gov.

; p l _ y _ ,- - - ~ ....- - - - - - -

Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal Enclosure JroZO

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Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports, Revision 0 May7,2020

Enclosure:

1. STS-212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports, Revision 0 2 of31

Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports, Revision 0 May7,2020 cc:

Electronic copy NSSESC NSS SRC MAR 610,612,615 Hardcopy, cover letter only MAR-600, 640, 640.2 Hardcopy with all enclosures MAR-100, 640.2 (rf)

USNRC (Ted Smith, Katherine Warner)

USNRC Regional Administrator - NRC Region I MD Department of the Environment (Eva Nair)

EWK/jmo 3 of31

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 Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 STS - 212, ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING AND RADIOACTIVE EFFLUENT RELEASE REPORTS FOR CY2019 4 of31

U.S. Department of Transportation Maritime Administration N.S. SAVANNAH ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING AND RADIOACTIVE EFFLUENT RELEASE REPORTS FORCY2019 STS - 212 Revision 0 Approved: ----TI'Diate: May 7, 2020 Manager, N.S. SAVANNAH Programs Prepared by:

TOTE Services, Inc.

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SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 RECORD OF REVISIONS Revision Summary of Revisions 0 The original version of the 2019 Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports LIST OF EFFECTIVE PAGES PaeeNo. Rev.No. PaeeNo. Rev.No. Pae:eNo. Rev.No.

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SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 Table of Contents 1.0 Introduction 4 2.0 Items Required by Technical Specifications 4 3.0 Annual Radiological Environmental Monitoring Report 4 3.1 TS 3 .4.2.1.c. Environmental Sample Analysis Surveys 5 4.0 Annual Radioactive Effluent Release Report 5 4.1 Summary of Quantities of Radioactive Liquid and Gaseous Effluents Released 5 4.2 Summary of the Quantities of Solid Waste Released 5 4.3 Process Control Program (PCP) Changes 5 4.4 Offsite Dose Calculation Manual (ODCM) Changes 6 4.4.1 Criteria and Justification for the Change to 4.4.2 6 5.0 References 7

\APPENDIX A. CY2019 Radiological Environmental Sampling Results 8 APPENDIXB. STS-005-020, Offsite Dose Calculation Manual (ODCM), Revision 1 9 7 of31 Revision 0 3

SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0

1.0 INTRODUCTION

This Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019are submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH (NSS) and covers the Calendar Year (CY) 2019 reporting period.

In accordance with the requirements of TS 2.5 Reporting Requirements, " ... the following reports shall be submitted prior to April 1 of each year in accordance with 10 CFR 50.4:

o Annual Radiological Environmental Monitoring Report.

o Annual Radioactive Effluent Release Report.

This report is arranged into four sections following the introduction. Section 2.0 provides the discussion of the various reporting items required by the Technical Specifications (TSs). Section 3.0 is the, Additional items required by the TS are also included in Section 2 as stated below~

2.0 ITEMS REQUIRED BY TECHNICAL SPECIFICATIONS The items specifically required to be included in these written annual reports are as follows:

a. TS 2.5.1, Annual Radiological Environmental Monitoring Report (see 3.0).
b. TS 2.5.2, Annual Radioactive Effluent Release Report (see 4.0).
c. TS 2.1.1, Changes to the Process Control Program (PCP) (see 4.1).
d. TS 2.2.1, Changes to the Offsite Dose Calculation Manual (ODCM) (see 4.2).

This report was reviewed by the Safety Review Committee at the meeting on February 27, 2020 and by the Executive Steering Committee members during its concurrence routing prior to submission of this report to the NRC.

3.0 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Per TS 2.5.1, the Annual Radiological Environmental Monitoring Report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the previous calendar year. The material provided shall he consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Section IV.B.2.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the previous calendar year pursuant to the ODCM.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in 1,1, supplementary report as soon as possible.

Note that TS 3.4.2, Annual Report specifically requires reporting one environmental monitoring item in the Annual Report. In addition to being reported in the Annual Report, the item is also reported here.

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SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 3.1 TS 3.4.2.1.C. 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. The environmental sample results indicate that any changes in the radiological conditions in the environment surrounding NSS are insignificant as compared to the samples taken shortly before the NSS arrived at Pier 13. Therefore, based on the results of the radiological environmental monitoring program, NSS operations at Pier 13 did not have any adverse effects on the health and safe!)'. of the public or on the environment in 2019.

Environmental samples were also taken at Philadelphia Ship Repair, Philadelphia, PA prior to the ship's arrival on September 10, 2019.

The results of the CY2019 Radiological Environmental Sampling Results are listed in Appendix A, CY2019 Radiological Environmental Sampling Results.

4.0 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Per TS 2.5 .2, the Annual Radioactive Effluent Release Report shall include a summary of the quantities of 1) radioactive liquid and gaseous effluents and 2) solid waste released from the NSS. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

4.1

SUMMARY

OF QUANTITIES OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENTS RELEASED No radioactive liquid or gaseous effluents were released in 2019.

4.2

SUMMARY

OF THE QUANTITIES OF SOLID WASTE RELEASED No solid wastes were released in 2019.

4.3 PROCESS CONTROL PROGRAM (PCP) CHANGES Per TS 2.1, the PCP shall describe the administrative and technical controls for liquid and solid radioactive waste systems management. Changes to the PCP will be outlined in the Annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.1.1. Information to support the rationale for the change and the changed pages of the PCP or a statement there were no changes; There have been no changes to the PCP since it was reviewed by NRC as part of the approval of License Amendment 17, Reference (a).

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SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 4.4 OFFS/TE DOSE CALCULATION MANUAL (ODCM) CHANGES Per TS 2.2, the ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents; in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints; and in the conduct of the radiological environmental monitoring program. Changes to the ODCM will be outlined in the Annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.2.1 A complete copy of the ODCM with an accompanying criteria and justification for the changes or a statement there were no changes; There was one change to the ODCM after it was reviewed byNRC as part of the approval of License Amendment 17, Reference (a).

4.4.1 CRITERIA AND JUSTIFICATION FOR THE CHANGE TO 4.4.2 During a review by MARAD contractors, an error was noted in:

4.4.2 Gaseous Dose Assessment

a. Requirements Using the analysis of the particulate air sample, perform a dose analysis for any measurable radionuclides of NSS origin, using the following equation:

Deft= S.7x10-3 *t 2 ci/Ect i

Where:

Deff= Effective dose equivalent to a Member of the Public assumed to be exposed to the effluent release for the duration of the release (mrem)

Ci = concentration for radionuclide "i" in the effluent release (µCi/ml) t = duration of sampling (release) period (hours)

ECi = Effluent concentration value for radionuclide "i" from 10 CFR 20, Appendix B, Table 2, Column 1 (µCi/ml) 5.7xl0"3 = conversion factor (50 mrem effective dose [ECi value for I-year exposure] divided by 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> per year)

Specifically, In Revision 0, t = duration of sampling (release) period (minutes) [emphasis added]. The unit of time should have been hours. In Revision 1, the definition oft was revised to t = duration of sampling (release) period (hours)

There were no other changes. A complete copy of Revision 1 is attached as Appendix B, STS-005-020, Offsite Dose Calculation Manual (ODCM). It is a User Controlled copy.

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SA VANNAN Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0

5.0 REFERENCES

a. Letter from Mr. Theodore B. Smith to Mr. Erhard W. Koehler (MARAD), dated June 11, 2019, Issuance ofAmendment 17 to revise the Technical Specifications to revise the Radioactive Effluent Controls and make an Administrative Change 11 of31 Revision 0 7

SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 Appendix A CY2019 Radiological Environmental Sampling Results APPENDIX A. CY2019 RADIOLOGICAL ENVIRONMENTAL SAMPLING RESULTS Sample , Type of f:o-60. Cs-137 Sample Location Date sample

<MDA

<MDA [6.5E-02 Pier #13 Canton Marine Terminal, Sediment (minimum pCi/g (C)]

04/04/2019 Baltimore, MD NSS Stbd Side, Aft (A)(B) detectable activity) MDA=

1.26E-01 1.47£-01 pCi/g (C)

Pier #13 Canton Marine Terminal, Sediment 09/05/2019 <MDA Baltimore, MD NSS Stbd Side, Aft (A)(B)

MDA=

7.96£-02 Pier #13, Canton Marine Terminal, Sediment 4/04/2019 <MDA <MDA Baltimore, MD NSS Port Side, Forward (A)(B)

<MDA

[6.68-02 Pier #13, Canton Marine Terminal, Sediment pCi/g (C)]

09/05/2019 <MDA Baltimore, MD NSS Port Side, Forward (A)(B)

MDA=

8.82£-02 Pier #13 Canton Marine Terminal, Water(A) <MDA <MDA Baltimore, MD NSS Stbd Side, Aft 4/04/2019 Pier #13 Canton Marine Terminal, Water(A) <MDA <MDA Baltimore, MD NSS Stbd Side, Aft 09/05/2019 Pier #13, Canton Marine Terminal, Water(A) <MDA <MDA Baltimore, MD NSS Port Side, Forward 4/04/2019 Pier #13, Canton Marine Terminal, Water(A) <MDA <MDA Baltimore, MD NSS Port Side, Forward 09/05/2019 Table Data Notes (A) Calculated MDAs are a-posteriori values at the 95% confidence level.

(B) Activity is reported on a dry weight basis unless otherwise indicated in the case narrative and is decay corrected to the sample collect date.

(C) Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty) 12 of31 Revision 0 8

SAVANNAH Technical Staff STS - 212, Annual Radiological Environmental Monitoring and Radioactive Effluent Release Reports for CY2019, Revision 0 Appendix B STS-005-020, Offsite Dose Calculation Manual (ODCM)

APPENDIX B. STS-005-020, OFFSITE DOSE CALCULATION MANUAL (ODCM), REVISION 1 The following 18 pages are a complete copy of Revision 1 of STS-005-020, Offsite Dose Calculation Manual (ODCM).

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