ML23094A128

Us Dept. of Transportation, Maritime Admin - Submittal of Decommissioning Funds Status Report for Calendar Year (Cy) 2022

ML23094A128
Person / Time
Site:	NS Savannah
Issue date:	03/29/2023
From:	Koehler E US Dept of Transportation, Maritime Admin
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML23094A128 (1)

Text

i U.S. Department Office of Ship Operations 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)

March 29, 2023 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) 2022 The Maritime Administration (MARAD) hereby submits Revision O of the CY2022 Decommissioning Funds Status Report for the-Nuclear Ship SAVANNAH (NSS) as Enclosure 1.

This letter contains no new Regulatory Commitments .

.If there are any questions or concerns with any issue discussed in this submittal, please contact me at:

0: (202) 366-2631, M: (410) 776-8268, ancl/or e-mail me at erhard.koehler@dot.gov Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Operations Enclosures L

• Docket No~.50-238; License NS-1; N.S. SAVANN4H Submittal of Decommissioning Funds- Sta~us Report for CY2022, Revision 0 March 29; 2023 * -

Enclosures

1. STS-222, Decommissioning Funds Status Report for CY2022, Revision 0 2

Docket No. 50-238; License NS-1; N.S. SAVANNAH -

Submittal of Decommissioning Funds Status Report for CY2022, Revision 0 March 29, 2023 cc:

Electronic copy NSS ESC NSS SRC MAR 610, 612, 615 Hardcopy, cover letter only MAR-600, 640,640.2 Hardcopy w/ all enclosures MAR-100, 640.2 (rt)

USNRC (Tanya Hood, Andrew Taverna)

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

EWK/jmo 3

U.S. Department Office of Ship Operations 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 CY2022 STS - 222, DECOMMISSIONING FUNDS STATUS REPORT FOR CY2022 4

U.S. Department of Transportation Maritime Administration N.S. SAVANNAH DECOMMISSIONING FUNDS STATUS REPORT FOR CY2022 STS-2.22 Revision 0 Approved: & ~ - *

• _ *

• _ . : i __

Manager, N.S. SAVANNAHPrograms

• __ ___.n-a....,te: March 29, 2023

• Prepared by:

Nuclear Ship Support Services, LLC

SAVANNAH Technical Staff STS - 222, Decommissioning Funds Status Report For CY2022, Revision 0 Record of Revisions Revision Summary of Revisions 0 The original version of the Decommissioning Funds Status Report for CY2022 List of Effective Pages Page No. Rev. No. Page No. Rev. No. Page No. Rev. No.

1-10 0 Revision 0 2

SAVANNA.Ii Technical-Staff STS - 222, Decommissioning Funds StafuiR~port _For CY2022, Revision O

• Table of Contents

1.0 INTRODUCTION

4 2.0 DECOMMISSIONING STATUS, FUNDING AND SERVICES 4 2.1 Decommissioning Status 4 2.2 Decommissioning Funding 5 2.3 Primary Fixed Price Decommissioning Services 5 2.4 Other Decommissioning Services 6 3.0 STATUS OF DECOMMISSIONING FUNDS 6

- 4.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT 7 4.1 Report required by 10 CFR 50.82(a)(8)(v) 7 4.2 Report required by 10 CFR 50.82(a)(8)(vi) 8 4.3 Report required by 10 CFR 50.82(a)(8)(vii) 9 5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING 9 5.1 Annual Submittal ofNew Estimate 9 5 .2 Revised Decommissioning Cost Estimate (DCE) 10 6.0 TIME REMAINING TO COMPLETKDECOMMISSIONING 10

7.0 REFERENCES

10 Revision 0 3

.~_ *--..,;; -:

SAVANNAH Technical Staff

. STS ~ 222, D~coinmissioriing Fu~ds. Status.Report For CY2022, Revision*o****

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 (CY) 2022 reporting period.

This report incorporates the guidance contained in Regulatory Guide (RG) 1.159, Assuring the Availability ofFunds for Decommissioning Nuclear Reactors, Rev 1, Reference (a). The report is arranged in six sections following this introduction.

Section 2.0 of this report provides decommissioning information relevant to the context of the financial reporting that follows. This includes descriptions of the NSS decommissioning status; the sources ofNSS decommissioning funding, and the decommissioning services procured by MARAD.

In accordance with the requirements of 10 CFR 50.75(:t)(l), 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 3.0 of this Decommissioning Funds Status Report includes the seven (7) reports required by 10 CFR 50.75(:t)(l).

In accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii), each power reactor that has already submitted its site-specific Decommissioning 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 4.0 of this Decommissioning Funds Status Report includes the reports required by 10 CFR 50.82(a)(8)(v)-

(vii).

Section 5.0 of this report provides information on regulatory commitments made by MARAD that are germane to decommissioning funding.

Section 6.0 notes the time remaining to complete decommissioning.

Section 7 .0 lists references.

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 FYs 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 expecte4 changes to content in the PS:OAR. If included, .this information is contained in Section 2.0 of this report.

2.0 DECOMMISSIONING STATUS, FUNDING AND SERVICES 2.1

• 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 tesultofLicense Amendment 15, the ship's status change4 from "Mothballed" to "Dismantlement."

Dismantlement is d~fined in Regulatory Gtii9-e:{RG) 1;86, Termination-of Operating License; for Nucleaf.

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.

Revision 0 4

.- SAVANNAH Technicai Staff ..

STS - 222, Decommissioning Funds *status Report For CY2022, Revision O- -

The NSS has been in an overall decommissioning status since permanent cessation of operations in 1971.

Prior to the onset of active decommissioning, MARAD maintained a baseline level of licensed activities, which, for budgetary purposes, was referred to as protective storage. These baseline activities continue in parallel with active decommissioning and will be maintained until the license is terminated. As described in Section 2.3, MARAD's protective storage activities, excluding layberthing and electricity, are segregated within the integrated services contract and have their own line of accounting.

2.2 Decommissioning Funding 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 to MARAD by Federal appropriations. In requesting funds to support NSS, MARAD distinguished baseline (protective storage) activities from dismantlement and license termination activities, and each received its own line of accounting within MARAD's Ship Disposal Program appropriation. Funds for baseline activities are requested and appropriated annually, and the funds are.

non-expiring. Funds for dismantlement and license termination are referred to as DECON-LT following the customary NRC definition of these terms. The DECON-LT funds were appropriated in FY 2017 and FY 2018 as described in the Annual Report/or Calendar Year (CY,) 2018, Reference (e). The DECON-LT funds are also available until expended. Although there are two lines of accounting that distinguish DECON,.LT from baseline activities, MARAD considers both lines to be sources of decommissioning funding and reports accordingly.

Table 1 - MARAD Appropriations Supporting Active Decommissioning (by Fiscal Year in thousands)

Account 2017 2018 2019 2020 2021 2022 2023 Protective Stora e 3,000 3 000 3 000 3,000 3,000 3 000 3 000 DECON-LT 24000 107 000 0 0 0 0 0 Annual Total 27,000 110,000 3,000 3,000 3,000 3,000 3,000 Cumulative Total 27000 137 000 140000 143 000 146 000 149 000 152 000 Notes:

• .Acth'.e Decommissioning began in CY 2017 1, with activities beginning in the 3Q of FY 2017.

• Both the FY 2017 and FY 2018 DECON-LT funds were included in the final omnibus appropriations acts that were passed in the 3Q of each year. Funds were not available beforehand.

• The President's FY 2024 Budget Request was submitted to the Congress on March 9, 2023. It includes protective storage funding at $3M. The appropriations for FY 2024 will be included in the CY 2023 repo~.

2.3 Primary Fixed Price Decommissioning Services On March 27, 2021, the Maritime Administration (MARAD) awarded a five-year integrated services contract2 to Nuclear Ship Support Services (NSSSN), LLC, of Seabrook, New Hampshire (Reference

[f]). This contract was awarded on a firm fixed price basis. The contract includes three (3) fixed price line items that provide for all primary decommissioning activities over the full period of performance.

These line items include labor, materials, and services.associated with dismantlement and waste handling, -

packaging, transportation, and disposal. Except for electricity, the fixed price is inclusive of the factors described in Section 3.4 that are normally escalated on an annual basis. This service contract is intended to cover all remaining MARAD requirements to complete DECON-LT, except for those noted in Section -

• 1 MARAD's first phase of decommissioning forinally beg~ ~~'October l~-2017 (FY 2018).* In the six months preceding;-MARAD conducted ~- --

preliminary planning activities, constructed the CV portal, and acquired the bridge contract services to support Phase I using DECON-LT funds available beginning in the 3Q of FY 2017.

2 This contract is in the same general form and scope as previous Technical Support for Integrated Management of Licensed Activities contracts awarded by MARAD, and known by the acronym TSIM. Where it appears in this report, TSIM refers to the 2021 NSSSN contract.

Revision 0 5

. SAVANNAH Technical Staff.. . . .. . . . . . .,

. _STS .i.222, Decommissioninf~n~s Status Report For CY2022, Revision 0 2.4 below. Summary details of this fixed price contract, and its relationship to MARAD's appropriated funds and DECON-LT requirements are described in Reference (g).

2.4 Other Decommissioning Services The NSSSN integrated service contract is one of four (4) MARAD service contracts that support NSS decommissioning activities. The second major contract provides layberthing and utility services, and draws its funding from the annual protective storage appropriation. This contract includes all electricity consumed by NSS. Electricity is paid at market rates and remained stable throughout CY 2022 at an average of $0.18 per kWh. The second increment of a two-year phased rate increase approved by the Maryland Public Services Commission is scheduled to take effect in 2023. MARAD's FY 2023 spending plan and outyear budget projections account for this rate increase.

• The third contract is a technical support contract to provide engineering and independent oversight services. This contract is funded from the DECON-LT appropriation. The fourth service contract was awarded during CY 2022, as anticipated in Reference (g). It is also funded from the DECON-LT appropriation and provides supplemental field inspection and independent regulatory analysis and review services. Finally, the DECON-LT appropriation supports NSS-specific tasks issued to the agencywide public affairs and outreach support contract, as well as payroll and travel expenses for MARAD direct employees assigned to the project on a primary basis.

All payroll and contract obligations are combined and reported in Section 4.1. Obligations more accurately reflect the availability of funds and are reported as functionally equivalent to expenditures.

3.0 STATUS OF DECOMMISSIONING FUNDS This section provides a discussion of the seven items required by 10 CFR 50.75(t)(l), and incorporates the guidance contained in RGl.159. The overall intent of this reporting, as described in 10 CFR 50.75(a)/

is to demonstrate how a licensee will assl!fe that funds are available for decommissioning. Much of the reporting is forward-looking in nature. MARAD is presently engaged in the final phases of its decommissioning process and anticipates terminating its license in CY 2025. The firm fixed price contract sets a present limit on decommissioning costs out to license termination.

• 3 .1 The amount of decommissioning funds estimated to be required. .

a) Current licensed activities require approximately $3.00 million annually.

b) The revised site-specific Decommissioning-License Termination (DECON-LT) cost estimate is $137.1 million3*

3.2 The amount accumulated to the end of the calendar year preceding the date of the report.

As a Federal licensee, 10 CFR 50. 75(e)(J)(iv) allows funding for decommissioning activities to be obtained by appropriations when necessary. As previously described, MARAD has received fall fending to support its DECON-LT activities and continues ta receive annual appropriations to support its baseline activities. These fends are non-expiring. Section 2.2, Table 1 includes the cumulative amount offunds appropriated to MARAD. ,

3.3 A schedule of the annual amounts remaining to be collected.

3 Due to the fixed price nature of decommissioning services awarded in CY 2021, MARAD does not presently expect to require additional budgetary resources to complete DECON-LT. Consequently, MARAD has frozen the cost estimate at its CY 2020 reported value until the License Termination Plan (LTP) is completed and submitted to NRC. The question of future formula-based escalation of the decommissioning estimate will be addressed in the LTP.

RevisionO 6

SAVANNAH Te"cbnic~l Staff . . . . - .

S~S"' 222, Decommi,ssionmg*~unds Status Report For CY2022, Revision 0 Annual collection offunds is not applicable to the NSS. As a Federal licensee, 10 CFR 50. 75(e)(l)(iv) allows funding for decommissioning activities to be obtained by appropriations when necessary. As noted above, the project is fully funded.

3.4 The assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decomw.,issioning funds, and rates of other factors used in funding projections.

Based on the discussions in sections 2.3, 2.4 and 3.2, MARAD believes the intent of 50. 75(a) has been met, and consequently has temporarily deferred the formula-based escalation ofthe decommissioning estimate. Refer to 3.f above and its associated footnote 3 regarding resolution of the escalation calculation for CY 202] and beyond. Please note that the LTP was not submitted during CY 2022, so that both Section 3.1 and footnote 3 continue to apply.

There are no rates ofearnings on decommissioning funds.

3.5 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 JO CFR 50. 75(e)(l)(iv) method.

• 3.6 Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

There have peen no modifications to MARAD 's financial assurance methodology, which is limited to the use ofFederal appropriations. Please see the response in Section 4.1 below for more detail.

3.7 Any material changes to trust agreements.

Not applicable because MARAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(l)(iv) method. Consequently, no trust agreements exist.

4.0 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.

4.1 Report required by 10 CFR 50.82(a)(8)(v)

(A)

1. The amount spent on decommissioning, both cumulative and over the previous calendar year, Within the context ofprotective storage as a decommissioning baseline, all the appropriated funds spent by MARAD in CY 2022 and preceding years have been for decommissioning pur:poses. MARAD 's budget requests through FY2023 provide for the baseline protective storage component of cost. This strategy provides sufficient resources to MARAD to maintain the NSS if there is an. interruption in the DECON-LT project for any reason.

During the CY 2022 reporting period, MARAD obligated approximately $8 million, .ofwhich approximately $3.9M were sourced from the DECON-LT appropriation, and the balance from the annual protective storage appropriation. The cumulative DECON-LT obligations since CY 2017 are appfQ~{inately $109.3 million. . - ..

2 .. The remaining.balance* of miyd~~ormn:issioning funds, and For the DECON-LT line ofaccounting, after subtracting the total obligated funds through the end of CY 2022 ($109.3 million)from the total appropriatedfunds ($131 million), the remaining balance of decommissioning funds is $21. 7 million at the beginning of CY 2023.

Revision 0 7

. SAVANNAH Tecb.ni~afSta.ft . . . . .

• ~TS :.. 222, Decolllmissiomng Funds Status Report For CY2022; Revision 0

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; Subject to any negotiated change orders, the total costs to complete the decommissioning activities contained in the TSIM contract have a value of$59,690,687.54 as ofDecember 31, 2022. The awarded amount as ofDecember 31, 2022, was $52,942,906.34. The, difference of

$6,747,781.20 is the value of the outyear baseline items in performance years 3 through 5 ofthe contract, which will be funded by the annual protective storage appropriations in FYs 2023 thru 2025.

The estimated cost oflayberthing and utility services through the projected License Termination timeframe is $1.6 million, which will also be funded by the annual protective storage appropriations in FYs 2023 thru 2025.

The TSIM contract figures in the first paragraph include the value ofchange orders and contract modifications issued through December 31, 2022. At the time of this report submittal, there are several pending requests for equitable adjustment (REA} which are still subject to negotiation.

The face value ofthe actual a,nd projected REAs is about $2. OM Actual figures haye been determined to be procurement sensitive by the Contracting Officer. Any contract modifications that arise from settlement ofthese REAs will be fonded from the DECON-LT appropriation, and their value will be included infuturefands status reports. For the purposes of this report, MARAD will use the face value ofthe REAs as an upper estimate offature DEGON-LT costs in this category. In addition, MARAD estimates that an additional $1.5M will' be obligated to the TS/M T&M contract line item over the course of the contract.

The estimated fature costs for MA.RAD support contracts, payroll, travel and public affairs activities through the projected license termination is $3.4 million. In FY 2023, "'14RAD will execute an interagerzcy agreement (/AA} with NRC to cover projectedfee recoveries out the .

license termination. The estimated value ofthe IAA is $0.5.M'. Together with the TSIM obligations noted above ($3.5M},. the current estimate of.future DECON-LT obligations is approximately $7.4 million.

(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 ofFederal appropriations. *

(D) Any material.changes to trust agreements or financial assurance contracts.

Not applicable because-MA.RAD, as a Federal licensee, relies solely on the 10 CFR 50.75(e)(l)(iv} method.

4.2 Report required by_JO CFR 50.82(a)(8)(vi)

If th~ sum of the-balance of cmy r~maining decommissfoning fun~, plus earning~ on such funds

• calculated at hot *~~t~tthari a :two percent real *rate of rehun, together w-ith ilie am9uiifprovided by other firiancial assurance methods being relied upon, -~oes not cover the estimated cost to -

4 Between December 31, 2022, and the date of this report, the estimated cost of the IAA increased to $I.OM. This amowit wlll be reported in the LTP and accounted for in the CY 2023 Decommissioning Funds Status Report.

Revision 0 8

SAVANNAH Techµical Staff .

STS - 222, Decommissioning Funds Status Report For CY2022, Revision 0 complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion.

Not applicable to MARAD.

4.3 Report required by 10 CFR 50.82(a)(8)(vii)

After submitting its site-specific DCB 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.

MARAD neither possesses nor manages irradiated fuel. Nuclear fuel employed on NSS, or intended for but not used on NSS, was provided by the Atomic Energy Commission (AEC).

Custody of the spent fuel was transferred from MARAD to the AEC in 1972. The final disposition and status of the spent fuel is described in the September 21, 1973, Operations Report and also in Section 1.3.1 ofthe Updated Final Safety Analysis Report as follows:

Thirty six spent fuel elements (Core I and Ia) were shipped from (the NSS maintenance facility in) 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 10 CFR 50.82(a)(8)(vii) report must include the following information, current through the end of the previous calendar year:

(A) The amount offunds accumulated to cover the cost of managing the irradiated fuel; MARAD is storing no irradiated nuclear fuel and, therefore, has no accumulated funds to cover such costs.

(B) The projected cost of managing irradiated fuel until 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 funds to cover such cost.

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 .ofNew Estimate In Reference (g), MARAD revised a regulatory commitment as follows:

• .. The CY2019 estimate is provided in Sections 2.1 and 2A of thisreport.

As described in Sections 2.3 and 4.1, decommissioning the NSS is fully funded. Therefore, providing a revised estimate after CY2021 is no longer necessary given that additional funding is available to address currently unforeseen future expenses.

Revision 0 9

.SAVANNAH ~edini~al St~ff.

STS ~ 222; Decommissioning Funds Status ReJ:)()rt*For CY2022, Reyisi6n O

• 5.2 Revised Decommissioning Cost Estimate (DCB)

In Reference (g), MARAD revised a regulatory commitment as follows:

The site specific DCE will be revised in the License Termination Plan.

In 2022, MARAD continued developing the License Termination Plan (LTP) submittal which is required to include an update to the DCE. Instead of providing a DCE, Chapter 7 of the LTP will include a discussion similar to the fixed priced discussion in Section 2.0. The revised estimated date for submitting the LTP is CY2023.

6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING The license termination deadline for the NSS is December 3, 2031, based on the Permanent Cessation of Operations milestone date of December 3, 1971. Decommissioning is scheduled to be complete well within the allowed 60-year license termination period. 5

7.0 REFERENCES

a. Regulatory Guide 1.159, Assuring the Availability ofFunds for Decommissioning Nuclear Reactors, Revision 1, October 2003

b. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),

dated December 11 1 2008, Submittal ofPost Shutdown Decommissioning Activities Report, Revision 1

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 rJllow Dismantlement and Disposal

d. Regulatory Guide L86, 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 February 27, 2019, Annual Report for CY2018, Revision 0

f. Letter from Mr. Erhard W. Koehler (MARAD) to U.S; Nuclear Regulatory Commission (NRC),

dated April 30, 2021, Notification ofManagement Contract Award

g. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated April 24, 2020, Submittal ofDecommissioning Funds Status Report for Calendar Year (CY,) 2019 5 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 Revision 0 10