ML24094A050
| ML24094A050 | |
| Person / Time | |
|---|---|
| Site: | NS Savannah |
| Issue date: | 04/01/2024 |
| From: | Koehler E US Dept of Transportation, Maritime Admin |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML24094A050 (1) | |
Text
I U.S. Department of Transportation Maritime Administration ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
' Office of Ship Operations 1200 New Jersey Ave., SE Washington, DC 20590 Ref: 10 CFR 50.75(f)(l); 50.82(a)(7) and 50.82(a)(8)(v)-(vii)
April 1, 2024
SUBJECT:
Docket No. 50-238; License No. NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for CY2023 The Maritime Administration (MARAD) hereby submits Revision O of the CY2023 Decommissioning Funds Status Report for the Nuclear Ship SA VANNAH (NSS) as Enclosure 1.
This letter contains no new Regulatory Commitments. Please note that the report discusses two open commitments that are tied to the License Termination Plan (LTP). MARAD submitted its LTP on October 23, 2023, and believes these commitments may be closed when the LTP is approved by NRC, provided that such approval does not reject the arguments advanced by MARAD.
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, and/or e-mail me at erhard.koehler@dot.gov Enclosures
~-ly, ___ ~L--------
Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Operations
Docket No~ 50:.238; License NS-1; N.S. SAVANNAH Submittal of Decommiss\\oning Funds Status Report for CY2023, Revision 0 April 1, 2024 Enclosures
- 1. STS-225, Decommissioning Funds Status Report for CY2023, Revision 0 2
Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of DecomQtissioning Funds Status Report for CY2023, Revision 0 April 1, 2024 cc:
Electronic copy NSSESC NSS SRC MAR 610, 612, 615.
Hardcopy, cover letter only MAR-600, 640,640.2 Hardcopy w/ all enclosures MAR-100, 640.2 (rt)
EWK/jmo USNRC (Tanya Hood, Andrew Taverna)
USNRC Regional Administrator - NRC Region I MD Department of the Environment (Eva Nair) 3
U.S. Department of Transportation Maritime Administration Office of Ship Operations Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Submittal of Decommissioning Funds Status Report for CY2023 1200 New Jersey Ave., SE Washington, DC 20590 STS - 225, DECOMMISSIONING FUNDS STATUS REPORT FOR CY2023 4
U.S. Department of Transportation Maritime Administration N.S. SAVANNAH DECOMMISSIONING FUNDS STATUS REPORT FOR CY2023 Approved:
STS - 225 Revision 0 Manager, N.S. SAVANNAH Programs Prepared by:
Nuclear Ship Support Services, LLC Date: April 1, 2024
SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 Record of Revisions Revision Summary of Revisions 0
The original version of the Decommissioning Funds Status Report for CY2023 List of Effective Pages Page No.
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 Table of Contents
1.0 INTRODUCTION
2.0 DECOMMISSIONING STATUS, FUNDING AND SERVICES 2.1 Decommissioning Status 2.2
. Decommissioning Funding 2.3 Decommissioning Services 2.4 Other Decommissioning Costs 3.0 STATUS OF DECOMMISSIONING FUNDS 4.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT 4.1 Report required by 10 CFR 50.82(a)(8)(v) 4.2 Report required by 10 CFR 50.82(a)(8)(vi) 4.3 Report required by 10 CFR 50.82(a)(8)(vii) 5.0 REGULATORY COMMITMENTS REGARDIN_G DECOMMISSIONING FUNDING 5.1 Annual Submittal of New Estimate 5.2 Revised Decommissioning Cost Estimate (DCB) 6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING
7.0 REFERENCES
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SA VANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0
1.0 INTRODUCTION
This Decommissioning Funds Status Report (DFSR) is submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH (NSS) and covers the calendar year (CY) 2023 reporting period. This report incorporates the guidance contained in Regulatory Guide (RG) 1.159, Assuring the Availability of Funds 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(f)(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. On October 23, 2023, MARAD submitted its License Termination Plan (LTP), Reference (b ), to NRC for review and approval. The LTP includes a comprehensive update of the site-specific decommissioning costs, with information current as of September 30, 2023. Section 3.0 of this Decommissioning Funds Status Report includes the seven (7) reports required by 10 CFR
- 50. 75(f)(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 (c). Section 4.0 of this Decommissioning Funds Status Rep<;>rt includes the reports required by 10 CFR 50.82(a)(8)(v)-
(vii).
This is the first DFSR to follow MARAD's October 2023 submittal of its LTP. MARAD has two continuing action commitments related to decommissioning costs whose resolution has been linked to the LTP. The proposed resolution for each commitment is discussed in Section 5.0 of this report.
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 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. 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 (Referenced) to allow dismantlement and disposal. As a result of License Amendment 15, the ship's status changed from "Mothballed" to "Dismantlement."
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 Dismantlement is defined in Regulatory Guide (RG) 1.86, Termination of Operating Licenses for Nuclear Reactors, Reference (e). This 1974 RG describes the no"'. 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.
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 for Calendar Year (CY,) 2018, Reference (f). 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 Storage 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 27,000 137 000 140,000 143,000 146 000 149,000 152 000 Notes:
Active Decommissioning began in CY20171, with activities beginning in the 3Q of FY 2017.
2024 3 000 (3 660)
(660) 151,340 Both the FY2017 and FY2018 DECON-LT funds were included in the final omnibus appropriations acts that were passed in the third quarter of each year. Funds were not available beforehand.
Full-year appropriations for FY 2024 were enacted on May 8, 2024. The appropriation includes $3M for annual protective storage funding. The appropriation also permanently rescinds $3.660M of prior year unobligated balances in the Ship Disposal Program appropriations. The final allocation of that rescission between MARAD's Ship Disposal and NSS DECON accounts has not been determined as of the date of
. this report. This report conservatively assumes that the rescission is taken wholly from the approximately
$18.5M in unobligated DECON funds available as of March 8, 2024. The protective storage account unobligated balance of approximately $0.4M will not be applied to the rescission.
The President's FY2025 Budget Request was submitted to the Congress on March 11, 2024. It includes protective storage funding at $3M. The appropriations for FY2025 will be included in the CY2024 report.
- 1 MARAD's first phase of decommissioning formally began on October I, 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 ofFY 2017.
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 2.3 Decommissioning Services There have been no substantive changes to MARAD's decommissioning services contracts from previous reports. The primary DECON service contract was modified to add additional funds either as part of planned incremental funding, or to settle change orders. The two technical support contracts ( engineering and independent oversight services; and supplemental field inspection / independent regulatory analysis and review) were modified to add incremental funding during CY 2023, with those modifications completed before the close of FY 2023. The effect of all of these modifications is included in the decommissioning costs update included in the L TP.
2.4 Other Decommissioning Costs The DECON-LT appropriation supports the collection of fees through an Interagency Agreement between MARAD and NRC. The appropriation also 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(f)(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 assure that funds are available for decommissioning. Much of the reporting is forward-looking in nature.
Information in this section is derived from the content of Chapter 7 of the LTP, Reference (b). That information was current as of September 30, 2023. No contract modifications were issued between September 30 and December 30, 2023. The only changes to financial status in those three months were based on the payment of invoices and salaries.
MARAD is presently engaged in the final phases of its decommissioning process and anticipates terminating its license no earlier than December 2025. The firm fixed price DECON services 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 $119.933 million2as of December 30, 2023.
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)(l)(iv) allowsfundingfor decommissioning activities to be obtained by appropriations when necessary. As previously described, MARAD has received full funding to support its DECON-LT activities and continues to receive annual appropriations to support its baseline activities. These funds are non-expiring. Section 2.2, Table 1 includes the cumulative amount of funds appropriated to MARAD.
3.3 A schedule of the annual amounts remaining to be collected.
2 This estimate is derived from Table 7-1 of the LTP. The unobligated balance of funds (i.e., canyover) of$18.517M is deducted from the appropriation of$131.0M. The result is $112.483M, to which the Table 7-1 projected remaining DECON costs of $7.450M is added.
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 Annual collection of funds is not applicable to the NSS. As a Federal licensee, 10 CFR 50. 75(e)(J)(iv) allowsfundingfor 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 decommissioning funds, and rates of other factors used in funding projections.
Based on the discussions in sections 7. 5 of the LTP, and 5.1 of this repor,t, MARAD believes the intent of JO CFR 50. 75(a) has been met, and consequently that there is no added-value to performingformula-based escalation calculations for the few years remaining before license termination.
There are no rates of earnings 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)(J)(iv) method.
3.6 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 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 JO CFR 50.75(e)(J)(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 of protective storage as a decommissioning baseline, all the appropriated funds spent by MARAD in CY2023 and preceding years have been for decommissioning purposes. MARAD 's budget requests through FY2024 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 CY2023 reporting period, MARAD obligated approximately $6.5 million, of which approximately $3.2M were sourced from the DECON-LT appropriation, and the balance from the annual protective storage appropriation. The cumulative DECON-LT obligations since CY2017 are approximately $112.4 million.
- 2. The remaining balance of any decommissioning funds, and For the DECON-LT line of accounting, after subtracting the total obligated funds through the end ofCY2023 ($112.5 million)from the total appropriatedfunds ($131 million), the remaining balance of decommissioning funds is $18.5 million at the beginning of CY2024.
- 3. The amount provided by other financial assurance methods being relied upon; Revision 0 7
SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 None. MARAD, as a Federal licensee, relies solely on the 10 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; Please refer to Chapter 7, Section 7.3 of the LTP.
(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.
(D) Any material changes to trust agreements or financial assurance contracts.
Not applicable because MARAD, as a Federal licensee, relies solely on the JO CFR 50.75(e)(l)(iv) method.
4.2 Report required by JO CFR 5O.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 of return, 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.
4.3 Report required by JO CFR 5O.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 of the Updated Final Safety Analysis Report as follows:
Thirty six spent fuel elements (Core I and la) 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 of funds 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 Revision 0 MARAD is storing no irradiated nuclear fuel and, therefore, has no need to project such costs.
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 (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 of New Estimate This commitment was established in MARAD's CY 2010 DFSR, Reference (g). It was slightly revised in 2011, and reads 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.
This commitment remains in effect. MARAD has noticed that an error crept into the reporting of this commitment beginning with the CY 2021 DFSR, Reference (h), where the prior-year status of the commitment was conflated with the text of the commitment. There was no explicit written commitment change, and thus the text of the commitment remains as shown above.
The CY 2021 report also described in detail the nature of the fixed price decommissioning service contract, and §tated that the cost estimate was frozen at that time pending submittal of the L'TP.
Section 7.1 of the LTP addresses this question as follows:.
The fixed price nature of the TSIM contract is such that any estimate of remaining costs on any given date is simply the value of future obligations or future invoices as of that date.
Consequently, MARAD believes that new estimates are not required to meet the underlying intent of the regulation...
Pending the NRC's review and approval of the LTP, MARAD believes this commitment is complete and may be closed upon approval of the LTP; provided, that in approving the LTP, this argument is not rejected.
5.2 Revised Decommissioning Cost Estimate (DCB)
This commitment was established in MARAD's CY 2010 DFSR, Reference (g), and read as follows:
The site specific Decommissioning Cost Estimate will be revised at least every five (5) years.
The DCE was revised in 2015.
This commitment was revised in the CY 2019 DFSR, Reference (i) to read as follows:
The site specific DCE will be revised in the License Termination Plan.
At that time, MARAD anticipated that the L TP would be submitted in CY 2021. The COVID-19 Pandemic National Emergency was then about one month old, and the ramifications did not become clear until later. The LTP was not submitted until October 23, 2023. However, the submittal of the L TP does provide the comprehensive update of the site-specific decommissioning costs required by 10 CFR 50.82(a)(9)(ii)(F).
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SAVANNAH Technical Staff STS - 225, Decommissioning Funds Status Report For CY2023, Revision 0 Pending the NRC's review and approval of the LTP, MARAD believes this commitment is complete and may be closed upon approval of the LTP.
6.0 TIME REMAININGTO 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 wen within the allowed 60-year license t~rmina~ion period.3
7.0 REFERENCES
- a. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision 1, October 2003
- b. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated October 23, 2023, License Amendment Request No. LAR 2023-01, Submittal and Request for Approval of the License Termination Plan
- c. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC);
dated December 11, 2008, Submittal of Post Shutdown DeconilJlission{ng A(!tzvities Report, -
Revision 1
- d. Letter from Mr. John B. Hickman (NRC) to Mr. Erhard W. Koehler (MARAD), dated April 23, 2018, lvuclear Ship SAVAM{AH - Issuance Of 4mendment 15 to revisethe License to al{ow.
Dismantlement and Disposal
- e. Regulatory_Guide 1'.86, Termination of Operating Licenses for Nu_clear Reactors, June, 1974
- f.
Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated !'ebruary 27,-2019, Annual Report/or CY2018, Revision O
- g. Letter from Mr. Erhard W. Koehler _(MARA!)) to. U.S: Nuclear Regulatory Commis~ion, dated March 31, 2011, Submittal of Decommissioning Funds Status Report/or Calendar Year (CY,)
2010
- h. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated March 29, 2022, Submittal of Decommissioning Funds Status Report for Calendar Year (CY,)
2021
- 1.
Letter from Mr. Erhard W. Koehler (MAR.AD) to U.S. Nuclear Regulatory Commission, dated April 24, 2020, Submittal of Decommissioning Funds Status Report for Calendar Year (CY,) 2019 3 December 3, 1971 is the de facto date <if permanent cessation of operations date based on completing the reactor defueling that date by tensioning the reactor vessel head with six studs Revision Q