ML24145A128

Us Dept. of Transportation, Maritime Administration - Submittal of CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

ML24145A128
Person / Time
Site:	NS Savannah
Issue date:	05/21/2024
From:	Koehler E US Dept of Transportation, Maritime Admin, US Dept of Transportation, Office of Ship Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML24145A128 (1)

Text

U .S. Department Office of Ship O peration s 1200 New Jersey Ave ., SE of Transportation Washington , DC 20590

Maritime Administration

Ref: 10 CF R 50.82, 50.90 and 51.53

May 21, 2024

ATTN: Document Control Desk U .S . Nuclear Regulatory Commissio n Washington, DC 20555

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. SAVANNAH Submittal of CR-137, Suppleme ntal Environmental Assessment and Finding of No Significant Impa ct

Referenc es : (a) Letter from Mr. Erhard W . Koehler (MARAD) t o U .S. Nuclear Regulatory Commission, dated October 3, 2008 , Submittal of Finding of No Significant Impa ct and Environmental Assessment (b) Letter from Mr. Erhard W . Koehler (MARAD) to U .S. Nuclear Regulatory Commission, dated October 23 , 2023 , Submittal and Request for Approval of th e License Termi nation Plan

The Maritime Administration h e reb y subm its CR- 137 , Supplemental Environmental Assessment a nd Finding of No Significa nt Impa ct. T his subm ittal is a suppl ement to Reference (a) and supports NRC rev iew of Reference (b ) .

This submittal contains no new Regulatory Commitments .

If there are any questions or concerns with any issue discussed in thi s s ubmittal, p lease contact me a t:

0  : (202) 366 -263 1, M: ( 410) 776-8268 , and/or e -m ail me at erhard.koe hler@d ot.gov .

Erh ard W. Koehler Senior Tec hnical Advisor , N .S. SAVANNAH Office of Ship Operations

Enclosure Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Submittal of CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact May 21, 2024

Enclosure:

1. Submittal of CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

2 Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Submittal of CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact May 21,2024

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 (rt)

USNRC (Tanya Hood, Andrew Taverna)

USNRC Regional Administrator - NRC Region I .

MD Department of the Environment (Eva Nair)

EWKljmo

3 U .S. Department Office of Ship Operations 1200 New Jersey Ave ., SE of Transportation Was hington, DC 20590

Maritime Administration

Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Submittal of CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact CR-137 SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT

4 CR- 137, Supple~enJal Environm~ntal Assessment and Finding of No Significa,n! Impact

U.S. Department of Transportation Maritime Administration

ENVIRONMENTAL A~ _SES~MENT AND FINDING OF NO SIGNIFICANT IMPACT

CR-137

.,._.*.:, .. ,* ,., . ;- ~By .:

MARAD JZ  ?'f ~ .,: s3U .*'-/ ______ 4)/if,ic'J,./

z~ ,

• N!Ull.e Title Date

This Report Is being

• delivered to MARAD iri accordance with the current contract .

1 of 110 CR- 137, S uppleme ntal En v ironmental Assessment and Findi ng of No Significant Impact

U.S. Department of Transportation Maritime Administration

ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT

CR - 137

Prepared B y MARAD

MARAD Acc epted  :

Nam e Title Dat e

This Repo rt is being delivered to MARA D in acco rda nce with the current con tract .

1 of 1 IO CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

FOREWORD

This document, Contractor Report (CR)-137, is a supplement to CR-106, Environmental Assessment and Finding of No Significant Impact. Even though CR-137 was written by MARAD, it will be classified as a Contractor Report in order to keep it grouped with CR-106. Note that while CR-106 was actually written by Volpe National Transportation Systems Center, a MARAD contractor, it was incorrectly assigned as written by MARAD.

2 of 110 CR- 13 7 , Supplemental Environmental Asses sment and Finding of No Significant Impact

FINAL Environmental Assessment Decommissioning of Nuclear Ship SAVANNAH

April 2019

Prepar ed b y the U.S. DOT Ma ritim e Admini stratio n

3 of 11 0 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Finding of No Significant Impact

U.S. DEPARTMENT OF TRANSPORTATION MARITIME ADMINISTRATION

FINDING OF NO SIGNIFICANT IMPACT (FONSI) FOR THE DECOMMISSIONING OF THE NUCLEAR POWER PLANT ONBOARD THE NUCLEAR SHIP SAV ANNAi-i (NSS)

Pursuant to the Council on Environmental Quality (CEQ) regulations, 40 Code of Federal Regulations (C.F.R.) §§ 1500-1508, implementing procedural provisions of the National Enviromnental Policy Act (NEPA), DOT Order 5610.1 C and Maritime Administrative Order MAO 600-1, the M~ritime Administration (MARAD) gives notice that a Supplemental Environmental Assessment (EA) and Finding of No Significant fmpact (FONS!) have been prepared for the decommissioning of the nuclear power plant onboard the Nuclear Ship SA V ANNAi-i (NSS), which is currently moored in Baltimore, Maryland and that an Environmental Impact Statement (EfS) is not being prepared.

Background:

NSS has been inactive since being defueled in 1971 and is in a state of mothballed protective storage, as a monitored d_eactivated defueled nuclear plant, since 1976. MA~D has no anticipated current or future need for the vessel or onboard reactor. NSS is located at Pier 13, Canton Marine Termina_l in Baltimore, Maryland where it has been since 2008. NSS was listed in the National Register of Historical Places (NRHP) in 1983 and designated a National Historic Landmark in 1991 as one of the most visible and intact examples of the Atoms for Peace program.

Proposed Action: The Proposed Action would be to decommission NSS's nuclear power plant via the Nucleal' Regulatory Commission's (NRC) DECON method. -

The purpose of the Proposed Action is to reduce residual radioactivity to le,*els that allow termination of the NRC lice11se. Low Level Radioactive Waste (LLRW) would be segregated and enclosed while still onboard the vessel, removed from the vessel via crane directly onto* the transportation mode _(rail, highway, barge), and transported to licensed/pennitted facilities for final disposal following Federa_l and/or state: regu~ations. The Proposed Actjon is needed 110w to reduce

• costs associated with maintaining NSS and meet the MARAD mission objective to decommission its nuclear reactor and terminate its NRC license. This project is referred to as Decommissioning License Tennination (DECON-L T). Under the provision of the Consolidated Appropriations Acts for 201 7 and 2018, full funding was appropriated to MA RAD to begin decommissioning, based on implementing the DECON method.

Alternatives Analyzed: The Proposed Action would be implemented at existing commercial facilities located in one of three alternative locations: ( 1) Baltimore, MD, the Preferred Alternative; (2) Hampton Roads, VA; and (3) Philadelphia, PA. The Supplemental EA analyzes three Proposed Action Alternatives and the No-Action Alternative.

The project sites, in Baltimore and the two other alternative locations, are located in developed areas along the waterfront and have restricted access. If MARAD decides to implement the Proposed Action, construction of new facilities and dredging would not be requii-ed because all three locations have existing infrastructure and deep water to accommodate NSS and support decommissioning. - -

Since the vessel is defheled, the nuclear power plant is inoperable rendering NSS incapable of self propulsion. NSS re1.iuires the use *or towing services for transit to and from a facility for

Page I of3

4 of 110 C R - 137, Supplem e ntal En v ironm e ntal As sessment and Findin g of N o Sig nifi cant Impact

Finding of No Significant Impact

d eco mmi ss ion ing. If neces ary. MJ\\ RAD wo uld tow N S to a nd fro m a fac i li ty as part of th e deco mmi ss io ning process in acco rda nce wi th a U.S. Coast Guard issued ce ni ficate . T he towi ng wo uld meet the re qui re m e nts fo r safety , nav iga tion. env iro nm e nt a l. a nd o th e r safeguards . All waste trans po rt at ion and di s posa l ac ti v ities wo uld be co nd uc ted in co mpli a nce with a pplicabl e Federa l a nd s ta te e nv iro nm e nta l laws .

If th e Gove rnm e nt is una bl e to awa rd a co ntrac t, t he No-Acti on Altern a ti ve wo ul d res ult by default.

IO C.F. R. 50.82(a)(3) prov ides the regul atory req uireme nt fo r decommi ssioning within 60 years of th e plan t ceas ing ope rati o n. SS wi ll be regul ated until the license is te nnin atcd . Th e o-Acti on Alt ern a ti ve includes co nt inuous berthing of NSS a t Ba ltimo re and MARAD' s co nt inu ed e nv iro nm enta l li abi lities a nd costs associated wi th continuing to m a inta in th e vesse l in a protecti ve s torage condition. TI,e o-Ac ti on A lte rn ati ve does not meet MA RAD's mi ss ion o bj ecti ves and may res ult in fu ture sig nifica nt unplanned and unbudgeted ex pe nse.

E nvironmental Effect s: The S upple me nta l EA present s a rev iew a nd a na lys is of the potential e n iron me nta l imp ac ts assoc iate d \\l ith th e three Proposed Ac ti o n Alte rn a t i e loca t ions, as we ll as the No-Acti o n A lt e rn ati ve. Impac ts to re leva nt reso urces th a t we re e v a luated include wa ter reso urces , bi o log ica l reso urces, air quality, waste ma nage me nt , and hea lth a nd safety. The e n ironme nt a l co nsequ e nces associate d with impl e me nta tion of th e Pro posed Ac ti o n a nd the No Acti o n Alt e rn a ti ve a re comp a red be low in Ta bl e I .

Tah/e I . Summ a ,y oflmpacl s Resource Bt1ltimort!, M D. I la mpl on Roads. Philadelph ia. PA. o-Ac ti o n rca ltcmatiH! . J\\ltcrnativc Altcrnati, c Alt ernati, *Prclcrrl'd e

Water Minim a l ad ve rse Minim al ad verse Minima l a d ve rse No Re sources imp acts im pac ts imp acts sign ificant imp acts Biological

• o rea on a bl y

• No reasonabl y

• No reaso na bl y No Re sources fo reseeab le ta ke fo reseea bl e ta kes foreseea bl e tak es sig nificant are ex pec ted fo r are ex pected fo r arc ex pected for imp ac ts m a rine m am ma ls. marine m amm a l ma rine mamm a ls.

• ' o e ffec t o n

• No effect o n

• No effec t o n Es e nti a l Fis h Essentia l Fis h Es cnt ia l Fis h I la bi tat. Habita t. Habita t.

ir Qualit) Ins ig nifica nt In significa nt In significa nt No imp acts te mp o rary imp ac ts temporary imp ac ts te mp o ra ry impac ts Was te No sig nificant No signi ficant No s ignifica nt No im pacts fanu gcmi.:nt irnpac ts im pac ts impac ts

1 lcalth a nd No s ig nifica nt No s igni fica nt No significa nt No impac ts Safc t . im pac ts imp ac ts im pacts

1'11c Propo cd Ac tion wo ul d no t adver se ly affect th ese reso urces o ther th an th e vc s c l itse l f. due to li s ti ng on t he a ti o na l Reg is ter of I l istoric Pl aces. Thro ugh cons ulta ti o n with th e R , the a ti ona l Park crvicc. the Advisory Council on I listoric Pre erva ti on, and the Mary land Hi s torica l

Page 2 of3 5 o f 110 C R - 13 7, Supplemental Env ironmental Assessment and Finding of No Significant Impact

Finding of No Significant Impact

T rus t. w hi c h erve s as th e State His to ric Preserva ti o n O ffi cer, a Progra mm at ic Ag reem ent will be impl e me nte d as miti ga ti o n effo rts for D CO -LT. MA RAD is in the p rocess o f fin a li z ing th e de ta il s o f th e PA, w hi c h w ill fo nn a ll y doc um e nt the agreed upo n miti ga ti on m easu res re quired fo r Section 106 comp I iance. Thi s EA de mons trated tha t implem e nta ti on o f a ny o ne o f th e Pro posed Ac t ion A lte rn ati ves wo uld result in no sig ni fi cant im pacts to hum an hea lth o r the e nv iro nm ent.

Preferred Alternative: The Proposed Act io n wo uld co mpl y with a ll Fed e ra l a nd s ta te reg ula ti o ns. gui de lines. a nd agreeme nts. All Pro posed Ac ti o n Alte rn a ti ves a re e nv iro nm e nta ll y equ a l. I loweve r. Ba ltim ore, MD is th e Pre ferred Altern ati ve beca use th e vesse l is aJready the re and m ay not need to wing . T he re wo uld be min or diffe re nces with res pec t lo towing di s tances and was te tra nspo rt ati o n a nd di s posa ls depending on th e a ltern a ti ves . Howeve r, none of the diffe rences wo uld pro du ce sig nificant imp ac ts.

Finding: Based on informati o n ga thered a nd a na lyze d within th e S upplem enta l EA , MARAD finds tha t impl e me nting the Proposed Ac ti o n will not s ignificantl y im pact the qu ality of the natura l or hum a n e n iro nm e nt; the refo re, an EIS is not re quired .

Conclusion and Approval: A ft e r care ful a nd tho rough cons ide ra ti on o f the fa cts contained he re in ,

and in the S upple me nta l EA , the unde rs igned finds th at th e pro po sed fed e ra l ac ti on is con sis tent with e xi stin g natio na l e n v iro nm e nta l po licies a nd o bj ectiv es set fo rth in Secti o n 101 (a) o f NEPA an d th at it wi ll not s ig nificantl y a ffect the qua lity o f th e hum a n en v iro nm e nt of o therwise incl ude a n y conditi o n re qu iring co ns ultation purs uant to Sec ti on 10 2(2)(c) o f NE PA. Therefo re. a FONS I is wa rra nted , a nd prepara ti o n o f an EIS, purs ua nt to EPA is no t required . T hi s FONS! is based o n th e a tt ached upple me nta l EA, which has been inde pend entl y eva lu ate d by MARA D a nd de te rmin ed lo ade quate ly and acc urate ly di sc uss the e nv ironm e nt a l iss ues and imp ac ts o f the proposed projec t. MAR AD ta kes full res ponsibility for the accuracy , scope, and co nte nt o f th e a tt ac hed Suppl e m e nt a l EA.

Rev iewer

1 have co ns id e re d th e infom1a ti on con tained in the Supple mental EA , whi c h is th e basis fo r thi s FO I. Base d o n th e in fo m1 a ti on co nta in ed in th e Supplem e nta l EA, a nd thi s FO S J doc um ent, I ag ree tha t the Pro posed Ac ti o n as d escribed a bove , and in th e S upple m enta l EA , will have no signi fi c~t imp a t o n the en v iro nm e nt.

M Da te

No L Lt,/LL// 1 I

T itle Da te

Page 3 of 3 6 of 110 I

CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

EXECUTIVE

SUMMARY

Purpose and Need This Supplemental Environmental Assessment (EA) contains an evaluation of the potential environmental . impacts resulting from the Department of Transportation Maritime Administration (MARAD)'s decommissioning of the Nuclear Ship SAV ANNAH's (NSS's) nuclear power plant _utilizing the Nuclear Regulatory ~om~ission's (NRC) I;)ECON method.

This Supplemental EA presents an analysis of the potential environmental consequences that may result from implementation of the alternatives for proposed decommissioning actions and all reasonably foreseeable,

• connected actions. The Supplemental

• EA identifies and analyzes potential. effects on the natural and human environment in sufficient detail to determine the significance** of impacts on the affected environment so that a preferred alternative and. location may be selected and the decommissioning ofNSS's nuclear power plant may be implemented.

Upon completion of the decommissioning, the NRC license (NS-1~- Docket 50-238) will be terminated and the vessel will be released to MARAD to pursue vessel disposal opportunities.

T~.is projeqt is referreµ _to"as Decommissio_ning:-Licen~_e Te~inat_ion (DE_CON-1,T):

MA.RAD has prepared this Supplemental EA in accordance* with .The.National Environmental *

. Polfoy Act (NEPA)" of_ 1969;

• the Council on Enviroiiniental Quality (CEQ) regulations implementing NEPA (40 C.F.R. §§ 1501-1508); 42 U.S.C. §§ 432F4370f; and Maritime.

Admh1istrative _Order MAO 600-l.

NSS has been inactive since being defueled in 1971 and has. been. in a. state of mothballed protective storage, as a monitored deactivated defueled nuclear plant;,since 1976 .. NSS is located.

at Pier 13, Canton Marine Terminal in Baltimore, MD where it has been since 2008. Under the provisibn~ofth~ C~ns_~lidated Approp:rj~tio~s A~t; fo~ 2oi'i~a-2018;funqing*~as appropriat~d to MARAD to begin decommissioning, based on implementing DECON-LT. The Proposed

'A:ction is needed now to* reduce costs- associated witli -maintaimnfNs~fano meet the MARAD '

mission objective to decommission its nuclear power. plant and terminate its*NRC license.

• NSS was listed in the National Register of Histoncaf Places-(NRHP) in.1983 and designated a National Historic Landmark (NHL) in 1991 as one of the most visible and intact examples of the Atoms for. Peace program. MARAD initiated the National Historic Preservation Act (NHP A)

Section 106 cm1~u_ltatio_n with the NRC, the National P*ark S~rvjce, *the Advisory Council on

.Historic Preservation,. and the Maryland Historical Trust, which serves as the State Historic Preservation Office (SHPO). The consultation has been handled separately from, but coordinated with, this Supplemental EA.

Description of Proposed Action and Alternatives The purpose of the Proposed Action is to reduce residual radioactivity to levels ,that allow termination of the NRC license. Low Level Radioactive Waste *(LLRW) would be segregated and enclosed while still onboard the vessel, removed from the vessel via crane directly onto the transportation mode (rail, highway, barge), and transported to licensed/permitted facilities for final disposal following Federal and/or state regulations.

DECON-LT is expected to be completed by the end of 2024. The project would be completed in three phases. Phase 1 includes pre-decommissioning planning, engineering, hazardous materials abatement, infrastructure preparation, and license amendment actions (which would be completed at the current berthing site) that takes about two years. Phase 2 includes the removal

7 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

of the systems, structures, and components related to the nuclear power plant and disposal of these items at licensed radioactive waste disposal facilities in the United States, which takes about four years. Phase 3 includes a final status and confirmatory survey conducted by the NRC with license termination, which can take up to one year and may be conducted at an alternate location from the decommissioning site.

Phase 2 of the Proposed Action would be implemented at existing commercial facilities located in one of three alternative locations: (1) Baltimore, MD, the Preferred Alternative; (2) Hampton Roads, VA; and (3) Philadelphia, PA. These alternative locations were identified during an Alternative Location Screening Analysis which eliminated other locations which did not meet a series of screening criteria. The Supplemental EA analyzes the three Proposed Action Alternatives and the No-Action Alternative.

All three Proposed Action Alternatives are located in developed areas along the waterfront and have restricted access. If MARAD decides to implement the Proposed Action, construction of new facilities and dredging would not be required because all three locations have existing infrastructure and deep water to accommodate NSS and support decommissioning of its nuclear .

power plant. -

• Since the vessel is defueled, the nuclear power plant is inoperable rendering NSS incapable of self-propulsion. NSS requires the use of towing services for transit to and from two of the three decommissioning alternative locations. NSS would be towed if necessary, in accordance with a U.S. Coast Guard issued certificate. The towing would meet the requirements for safety, nav~gation, environmental, and other safeguards. All waste transportation and disposal activities would be conducted in compliance with applicable Federal and state environmental laws.

If the Government is unable to award a contract, the* No-Action Alternative would result by default. NSS will be regulated until the license is terminated. The No-Action Alternative includes continuous berthing ofNSS at Baltimore; MD and MARAD's continued environmental liabilities and costs associated with continuing to maintain the vessel in a protective storage condition. The No-Action Alternative does not meet MARAD's mission objectives and may result in future significant unplanned and unbudgeted expense.

Affected Environment and Environmental Consequences The Supplemental EA presents a review and analysis of the potential environmental impacts associated with the three Proposed Action Alternative locations, as well as the No-Action Alternative. Impacts to relevant resources that were evaluated include water resources, biological resources, air quality, waste management, and health and safety. Due to the fact that NSS would be towed and decommissioned at a commercial facility with no construction required and with controlled and limited access, the project would have no impact on land use, geology, soils and seismicity, socioeconomics and environmental justice, transportation, noise, utilities, aesthetics or visual resources. The environmental consequences associated with implementation of the Proposed Action and the No-Action Alternative are compared below in Table 1.

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Table 1. Summary of Impacts Resource Baltimore, MD, Hampton Roads, Philadelphia, PA, No-Action Area Preferred Alternative VA, Alternative Alternative Alternative

Water Minimal adverse Minimal adverse Minimal adverse No Resources impacts impacts impacts significant

- impacts Biological

• No reasonably

• No reasonably ~ No reasonably No Resources foreseeable takes are foreseeable takes foreseeable takes significant expected for marine are expected for are expected for impacts mammals. marine mammals. marine mammals.

• No effect on

• No effect on

• No effect on Essential Fish Essential Fish Essential Fish Habitat.. .. Habitat. - - _Habitat.* .

Air Quality ..

• Insignificant Insignificant * - .

• Insignificant No temporary impacts temporary impacts- -temporary impacts impacts Waste - - No significant No significant No significant No Management _ impacts. .. _impacts .. impacts . impacts Health.and No significant '. No significant *** .. No *significant .. No

• • Safety impacts impacts *impacts impacts .. C , . *- ,.

. <;um_ulative IJl!pacts _ .

• Cumulative impacts can result from individually irtinor but coilectively significant actions taking

,place over a period of-time (40 C.F.R. § 1508.7).* To be considered cumulative-impacts, the*

~ffects must meet the following criteria:. the effect~ .woul4 occur i.11 a co~mon locale or region; the effects would not be localized (i.e., they would contribute to effects of other actions); the effects would impact a particular resource in. a -similar manner; aiid the effects would be

• long term (short-term impacts are temporary and would not typically contribute to significant cumulative impacts). To analyze cumulative impacts, a region mffst be identified for which the

-Proposed Action and other past, proposed, *and reasonably foreseeable actions would be cumulatively recorded or experienced. The cumulative impacts analysis considers impacts arising from the Proposed Action for each Proposed Action Alternative location combined with the impacts of other known past, present, and reasonably foreseeable future actions within each region. Other projects that are ongoing in all three regions are generally larger ill' scope than the Proposed Action, and have their own environmental analysis. These ongoing projects would potentially have a more significant impact on each Proposed Action Alternative location area than the DECON-LT. No significant cumulative effects were identified.

Other Considerations Required by NEPA This EA evaluated other considerations required by NEPA including: compliance with Federal

• acts, executive orders, policies, and plans; coordination with state and regional agencies; compliance with applicable state, local, and regional plans, policies, and controls; and evaluation of energy requirements and conservation potential, irreversible or irretrievable commitment of natural or depletable resources, and the relationship between short-term use of the environment

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CR-137, Supplemental Environmental Assessment and Finding ofNo Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

and the impacts that such use could have on the maintenance and enhancement of long-term productivity of the affected environment. This EA demonstrated that implementation of the Proposed Action would comply with existing Federal, state, regional, and local regulations, policies, and programs and would not result in any significant immitigable impacts other than those that will be stipulated in the Programmatic Agreement.

Conclusion This EA demonstrated that implementation of any one of the Proposed Action Alternatives would result in no significant impacts to human health or the environment. The Proposed Action would not adversely affect these resources other than the vessel itself, due to its NRHP listing.

Through consultation with the NRC; the National Park Service; the Advisory Council on Historic Preservation, and the Maryland Historical Trust, which serves as the SHPO, a Programmatic Agreement will be implemented as mitigation efforts for DECON-LT. MARA.D is in the process of finalizing the details of the PA, which will formally document the agreed upon mitigation measures required for Section 106 compliance.

The ~roposed Action would c_omply with _.;all J;i'e;:qeral a:p:cl state regQlations, guiqeline!l, an~*

- agreements. -All Proposed Action Alternatives are environmentally equal. - However, Baltimore, MD is the- Preferred Alternative because the vessel is already there and may not need towing.

There would be minor differences with respect to towfog distances and waste transportation and dispO!l~ls dep_ending on_ the altem.~tives. However, none of the differe1;19es woulq prod1,1ce

significant impacts. Based on the findings from this EA, a FONS! has been prepared.

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10 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

TABLE OF CONTENTS EXECUTIVE

SUMMARY

............................................................................................................. i ACRONYMS AND ABBREVIATIONS ..................................................................................... vii

1. PURPOSE AND NEED ....................................................................................................... 1-1 1.1 Introduction ................................................................................................................... 1-1 1.2 Project Location ............................................................................................................ 1-1 1.3 Vessel History ............................................................................................................... 1-2 1.4 Purpose of and Need for the Proposed Action .............................................................. 1-2 1.5 Resource Analysis***************'.***************************************************************************************** 1-2

2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES ............................... 2-1 2.1 Proposed Action ............................................................................................................ 2-1 2.2 Alternatives ................................................................................................................... 2-2 2.2.1 Waste Management Activities ........ * ....................................................................... 2-2 2.2.2 Locations for Phase 2 ............................. -.................................................. :.: ........... 2-3 2.3 Baltimore, Maryland, Alternative *.......... : ... :***************************************************************** 2-4 2.4 Hampton Roads, Virginia, Alternative .......................................................................... 2-4 2.5 Philadelphia, Pennsylvania, Alternative ...... : .......... : ...................... : ..... , ......................... 2--4 2.6 No-Action Alternative ................................................................................................... 2-4 2.7 Summary oflmpacts_ ................................ ; .................................................................. ;2-5

3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES.; ........... 3-1 3.1 Water Resources ............................................................................................................ 3-1 3.1.1 Regulatory Setting ............ -.................. * .......... : ....................... : .................. ~ ..... : ....... 3:..1 3.1.2 Affected Environment ..................... : ...................... ; ....... ~ ....................................... 3-1 3.1.3 Environmental Consequences ................................................................................ 3-4 3.2 Biological Resources ..................................................................................................... 3-5 3.2.1 Regulatory Setting .......... : ...................................................................................... 3-5 3.2.2 Affected Environment. ........................................................................................... 3-5 3.2.3 Environmental Consequences .............................................................................. 3-12 3.3 Air Quality ................................................................................................................... 3-15 3.3.1 Regulatory Setting ............................................................................................... 3-15 3.3.2 Affected Environment .......................................................................................... 3-16 3.3.3 Environmental Consequences .............................................................................. 3-17 3.4 Waste Management ..................................................................................................... 3-19 3 .4.1 Regulatory Setting ******* ********************:******************************************************************* 3-19 3 .4.2 Affected Environment .......................................................................................... 3-19 3.4.3 Environmental Consequences .............................................................................. 3-22 3.5 Health and Safety ........................................................................................................ 3-22

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3.5.1 Regulatory Setting ........................................................  : ........... : .......................... 3-22 3.5.2 Affected Environment. ...............................................  ; ......................................... 3-23 3.5.3 Environmental Consequences ............................................................................... 3-23

4. CUMULATIVE IMPACTS .................................................................... , ............................ 4-1 4.1 Baltimore, MD ***********:****.******:******.******:**--:********:*::**:*******::************************************:***:***'. 4-1 4.2 Hampton Roads, VA ..... : ............. : ......... :: ....... ;*:.: .... ; ........ : .......... : .............. : ...... : ........ : .... 4:.. 1 4.3 Philadelphia,_ PA**************:**:**************:**************:************************************************************ 4-2 4.4 Environmental Analysis: ....... ;: .... : .......... :.: ...................... :: ............................................ 4-2 4.4.1

• Water Resources ........... : ....... , ..... ;.::.: .. : ... :* .......... : .....*.. , .. : ... : .............. : ....... :.: ... :.: .... 4-2 4.4.2 Biological Resources*.: .......... : ................................................................................ 4-2 4.4.3 Air Quality**********-*****:***********************.*'.*****;******************:************:*************'..: .............. 4-3 4.4.4 Waste Management ................................................................................................ 4-3

. - - - . . - - . - ~ . - . ' --

4.4;5 Health and Safety.: .... *.;:; .. ;:.:;; .. :;*: ... : .... ; . .-; ... ;.; ......... .-.. ;:; ...... : ............... ; ........ :.-: .. : ... .-... 4.;;3 *-

• *~- J~ ., .. ~ - _____ .. ,. ,,__ ** .,. -- * ,., *** -* - -* .,. __ ** '--* -

. 5. OTHER CONSIPEM1JONS REQVlREP J3Y N:gJ>.A .... , ....... , .............. , ....... ,., ....... , .. _ .. _..,. 5-1 5.1 Possible Conflicts between the Proposed Action and-the Objectives of Federal, State, Regional, and Local LandUse Plans, Policies, and Controls .......................................  : .......... 5-1.

"5.2 Federal *Acts, E~ecutiv*e *orciers, Policies; artd Pla,ns.:; .. ~ .... ; . .'.: . .-.: ... : ...... ::.-.... : ....... : .. ; ..... *5~)

• 53 . _ Stat_e, Local, and R~gfomi:l_~la~~.J;>plictes, ~d Contro~.s: ...... : .......... , .................. ::***:.-; ... : 5.-3 _

5.4 Energy Requirements and Conservation Potential of Alternatives Including the

- Pfopos¢d .Action arid All Mitig*ion*M~a:s:(ife~ Being Coiisidered' ...... ~ .. \\ ......... :, .. :: ... , .......... :,.,5:.;i 5.5 Irreversible ~r Irr~trievable Conim.ittnent ofNatur~l or Depletable R~sour~es .......... :. 5-4

• 5:6 Relationship between.Local Short~Ternt Use"ofthe Huinan Environment an.a" **

_ Maintenance and Enhancement ofLong~Term*Natural Resource Productivity; ...... ; .. ; ... :.: ..... 5-4 --

5:7

• Means to Mitigate and/or*Monitor Adverse Environmental Impacts: .. : .. : ........... : .. :.: ... 5;:-4.

5.8 Any Probable Adverse Environmental Effects that cannot be Avoided and are not Amenable to Mitigation ........ .: ... ;.; ...... ;; .............. ; ............. : .... : ..... :.; .... _ ......... : .. : ............. : ...... .-.... 5-5

6. CQNCLUSION ...................... , .. :., .. _. ........ ; ... _ ........ , ... : ..... : ..... _, .............. ,,_ ........ _. .. :.:.: ................... ?-1

List of Appendices Appendix A - Figures and Tables Appendix B - Regulatory Correspondence Appendix C - Record of Non-Applicability (RONA)

Appendix D - Preparers Appendix E - References

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Supplemental EA for Decommissioning of NS SAVANNAH

ACRONYMS AND ABBREVIATIONS

ACHP Advisory Council on Historic Preservation ACM asbestos-containing material AQCR Air Quality Control Region CAA Clean Air Act CATEX Categorical ;Exclu~ion CEQ Council on Environmental Quality C.F.R.

• Code o_f)2'ederal Regulations Ci. Curie cm 2 square centimeter CMP Co!!stal Managerµent Program co carbon monoxide CO2 carbon dioxide COMAR _ *code prMaryland _R¢gul1;1tions -

CWA Clean .Water Act .

• ~ -

• k' ~ * * -

CWF Compa_ct Wi:tste facility cy cubic yards

-CZMA  :

• C_oast_al Zone Jv.fanagetrient_Act DPE dichlcrrodiphenyl_dichloro.~thylene

-DDT . dichlorodiphenylttic;hloroethane DECON-LT Decommissioning-License Termination

-:DEM -pepru:tmenf of g"nv~i-orjmental Management DEQ Department of Environmental Quality DEP -_ - D*epaririierit ofEiivitbnmerlfal Protection

- ~DHR Departrp.ent of HistQric Resources DO - dissolved oxygen DOE Department of Energy POT Department of Tnm.sport11Jio1J.

EA Environmental Assessment EFH Essential Fish Habitat EIS Environmental Impact Statement ELMR Estuarine Living Marine Resources EO Executive Order EPA United States Environmental Protection Agency ERL Environmental Research Laboratories ESA Endangered Species Act FERC Federal Energy Regulatory Commission FONS! Finding of No Significant Impact FR Federal Register ft feet fl2 square feet FWF Federal Waste Facility GEIS Generic Environmental Impact Statement h hour

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HAPC Habitat Areas of Particular Concern km kilometer kph kilometers per hour LBP lead based paint lbs pounds LLRW Low Level Radioactive Waste LNG Liquefied natural gas m meter m2 square meter MAFMC Mid-Atlantic Fishery Management Council MAIA Mid-Atlantic Integrated Assessment MARAD Maritime Administration MBTA Migratory Bird Treaty Act MD Maryland MDE Maryland Department of the Environment MDNR Maryland Department ofNamral Resources mm millimeter MMPA Marine Mammal Protection Act mph miles per hour MW megawatt NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act

-NESHAP National Emission Standards for Hazardous AirJ>_pllutants NHL National Historic Landmark NHPA National Historic Preservation Act NMFS National Marine Fisheries Service . .

NO2 nitrogen dioxide NOx nitrogen oxides

• NOAA National Oceanic and Atmospheric Administration NPL National Priorities List NRC United States ~uclear Regulatory Commission NRHP National Register of Historic Places NSPS New Source Performance Standards NUREG NRC Regulatory Guidance 03 Ozone OSHA Occupational Safety and Health Administration OTR Ozone Transport Regiop.

PA Pennsylvania PADEP Pennsylvania Department of Environmental Protection PAH Polycyclic Aromatic Hydrocarbons Pb lead PCB polychlorinated biphenyl PEL Probable Effects Level PM10 particulate matter less than 10 microns in diameter PM2.s particulate matter less than 2.5 microns in diameter ppm parts per million

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ppt parts per thousand RCRA Resource Conservation and Recovery Act RONA Record of Non-Applicability RPV Reactor Pressure Vessel SAFSTOR Safe Storage SAV Submerged Aquatic Vegetation SHPO -State Historic Preservation Office SIP St~t~ fuiplem~ntation Plan S02 sulfur dioxide SOx sulfur oxides STS -Savannah Technical Staff T&E Threatened and Endangered TEL Threshold Effects Level TMDL Total maximum daily loads UFC Unified Facilities Code U.S. United States u.s.c. United States Code USGS United States Geological Survey USFWS United States Fish and Wildlife Service VA _Virgini.a __ _

VDH Virginia Department of He~dth VHWMR Virginia Hazardous Waste Management Regulations voe volatile organic compound VSWMR .Virginia Solid W_aste Managem~nt Regulations WAC- - Waste Acceptance Criteria -

WCS Waste_C~mtr<>~ Specialists .

-µg/m3 ip.icrogrnms *per cubic meter* *

µR micro-Roentgens -

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15 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

1. PURPOSE AND NEED 1.1 Introduction This supplemental,Environmental Assessment (Supplemental EA) contains an evaluation of the potential environmental impacts resulting from the Department of Transportation Maritime Administration (MARAD)'s decommissioning of Nuclear Ship SAVANNAH's (NSS's) nuclear power plant utilizing the Nuclear Regulatory Commission's (NRC) DECON method. NSS is currently berthed in the Port of Baltimore, Maryland under a long-term lay-berth contract with Canton Marine Terminal (see Figure 1.1 in Appendix A).

NSS has been moored at this lo*cation since 2008. In March 2008, MARAD completed a Final Environmental Assessment and Finding of No Significant Impact (Report No. STS-106)

(FEA/FONSI), which analyzed the environmental impacts of decommissioning of the NSS's nuclear power plant via the DECON, SAFSTOR, and ENTOMB options described in the NRC Generic Environmental Impact Statement (GEIS) on the decommissioning of nuclear facilities.

The FEA/FONSI does not identify a preferred alternative for decommissioning the NSS and notes that appropriate facilities need to be identified and selected to complete the decommissioning of its nuclear power plant. The FEA/FONSI also recognizes that a supplemental, site-specific environmental review is necessary to complete the* NSS decommissioning of its nuclear power plant process. This Supplemental EA presents an analysis of the potential environmental consequences that may result from implementation of the alternatives for* proposed decommissioning actions and all reasonably foreseeable, connected actions. The Supplemental EA identifies and analyzes potential effects on the natural and human environment in sufficient detail to determine the sigµificance of impacts on the affected environment.

This Supplemental EA has been prepared by MARAD in accordance with The National Environmental Policy Act (NEPA) of 1969; the Council on Enviromhental Quality (CEQ) regulations implementing NEPA (40 C.F.R. §§ 1501-1508); 42 U.S.C. §§ 4321-4370f; and Maritime Administrative Order MAO 600-1.

The action proponent and lead agency for the Proposed Action is MARAD. There are no cooperating agencies for the preparation of this Supplemental EA.

1.2 Project Location

NSS is currently moored at Pier 13, Canton Marine Terminal in Baltimore, MD. Portions of this project may take place at another location or locations. MARAD would tow NSS, if necessary, to a facility to complete decommissioning via a contractor that would be responsible for the segregation of wastes and decommissioning to support license termination. Low Level Radioactive Waste (LLR W) would be enclosed, removed and transported to the final disposal location following Federal and/or state regulations further described in Section 2.1. When the decommissioning is completed, the NRC license (NS-I, Docket 50-238) will be terminated; this project is referred to as Decommissioning-License Termination (DECON-LT).

MARAD Savannah Technical Staff has procedures for waste management for the Proposed Action and potential impacts are discussed in Chapter 3. There is adequate space on NSS for all waste processing and packaging then removal via crane straight to the transportation mode (rail, highway, barge) to a waste disposal facility in the United States. Of the three options 0utlined in Section 2.2.1, this option would minimize the handling of the waste and the potential April 2019 1-1

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environmental effects and be most efficient. Potential decommissioning locations were screened and the sites determined to be the most feasible were evaluated as Proposed Action Alternatives.

Possible locations for proposed decommissioning operations are described in Section 2.2 Alternatives. It is important to note that the alternative locations represent a range of viable locations that could be selected to complete the Proposed Action.

1.3 Vessel History NSS was removed from service in 1970; the reactor was defueled in 1971; and MARAD determined not to refuel and reactivate it in 1973. These actions were retroactively declared a permanent cessation of operations, with an effective date of December 3, 1971. NSS has been in a state of mothballed protective storage since 1976. In 2006, MARAD started exploring the DECON option, as well as SAFSTOR, as a means to terminate its NRC license. The FEA/FONSI was completed in 2008 analyzing the environmental impacts of the available decommissioning options. Ultimately, the decision was made to keep the NSS in protective storage and in 2008 the NSS was drydocked for maintenance and berthed in Baltimore, MD until funding was appropriated for decommissioning. 10 C.F.R. 50.82(a)(3) provides the regulatory requirement for. decommissioning (license termination) within 60 years of the plant ceasing operation. The* license termination deadline is this December 3, 2031. The NSS will be regulated until the license is terminated.

NSS was listed in the National Register of Historical Places (NRHP) in 1983 and designated a National Historic Landmark (NHL) in 1991 as one of the most visible and intact examples of the Atoms for Peace program. MARAD initiated the National Historic* Preservation Act (NHPA)

Section 106 consultation with the NRC, the National Park Service, the Advisory Council on Historic Preservation, and the Maryland Historical Trust, which serves as the State Historic Preservation Office (SHPO). MARAD also invited non-government consulting parties (see Appendix B) to participate in the Section 106 process. The consultation has been handled separately from, but coordinated with, this Supplemental EA.

1.4 Purpose of and Need for the Proposed Action Under the provision of the Consolidated Appropriations Acts for 2017 and 2018, funding was appropriated to MARAD to begin decommissioning, based on implementing the DECON method. The purpose of this Supplemental EA is to analyze specific alternatives and locations for completing the decommissioning work via DECON-LT such that a preferred alternative and location may be selected and the DECON-LT of the NSS may be implemented. Since MARAD has received the required funding, decommissioning needs to occur as soon as possible.

The Proposed Action meets the decommissioning objectives of protecting the environment and human health and doing so with available equipment and resources. The Proposed Action will comply with the applicable regulatory requirements for decommissioning identified in 10 C.F.R.

50.59, 10 C.F.R. 50.82, the NS-1 License (hereinafter "license") and its appended Technical Specifications.

1.5 Resource Analysis This Supplemental EA .documents MARAD's evaluation and assessment of the potential environmental impacts associated with the decommissioning ofNSS's nuclear power plant. The NEPA, CEQ regulations, and MARAD's procedures for implementing the NEPA specify that an EA should only address.those resource areas potentially subject to impacts. In addition, the level of analysis should be commensurate with the anticipated level of environmental impact. The

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proposed Federal action would not be expected to involve major construction activities at the alternative locations, there would only be minor alterations to the NSS itself to aid in decommissioning actions.

Environmental resources potentially affected by the Proposed Action and all reasonably foreseeable actions to be evaluated in this Supplemental EA include:

• Water Resources

• Biological Resources

• Air Quality

• Waste Management

• Health and Safety Because the vessel would be towed to, if needed, and then it's nuclear power plant decommissioned at a commercial facility, actions would take place on coastal land with controlled and limited access, and because no major construction or modifications to facilities are anticipated, the resources that are not evaluated in detail in this Supplemental EA are:

• Cultural Resources - There would be no effects to cultural resources at any industrial facility; Section 106 for the vessel is ongoing in a separate coordinated action.

• Land Use -There would be no change in land use as a result of the Proposed Action.

• Geology, Soils and Seismicity - There would be no effects to these resources.

• Aesthetics and Visual Resources - The vessel does not have aesthetic value that would be negatively affected. The Proposed Action does not have an effect on the existing visual character or quality of the possible decommissioning sites and their surroundings.

• Socioeconomics -* The project would not have a negative effect on the state, local and regional econ9my, housing, or commµnity services.

• Environmental Justice - This addresses environmental and human health conditions in minority and low-income communities; the Proposed Action would occur at an existing facility and would not require construction of new facilities within minority or low income communities. Waste disposal routes are discussed in Chapter 3 and would not have an impact on *environmental justice. Thus, environmental justice concerns are not applicable.

• Transportation - The Proposed Action would not result in increased traffic or number of personnel at the vessel's current location or the decommissioning facilities' locations; waste transportation is part of decommissioning and discussed under waste management.

• Noise - The Proposed Action is considered a routine vessel movement and the decommissioning of its nuclear power plant would not generate any noise above and beyond what is routinely generated at these facilities.

• Utilities - There is no need to provide additional utilities for the Proposed Action.

• Emergency Services - There would be no effect on emergency services resulting from the Proposed Action.

• Wetlands and floodplains - The Proposed Action would not affect wetlands or floodplains.

As part of the NEPA. compliance process, MARAD has notified, or informally consulted with, potentially interested local, state and Federal stakeholders, including the following: U.S. Fish and Wildlife Service (USFWS), and National Oceanic and Atmospheric Administration (NOAA)

National Marine Fi~heries Service (NMFS). A notice of intent letter and co:rrespondence with

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these agencies are included in Appendix B. The Proposed Action will not have an impact on any 1resource of coastal use or natural the coastal zone.

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2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES 2.1 Proposed Action The Proposed Action considered in this Supplemental EA is the decommissioning of NSS's nuclear power plant via DECON-LT activities performed solely on the vessel, through an integrated support contractor at one of three locations: Baltimore, MD; Hampton Roads, VA; or Philadelphia, PA. MARAD would tow NSS, if necessary, to, and potentially back from, a facility in accordance with a U.S. Coast Guard issued Load Line Exemption Certificate.

MARAD will decommission the NSS nuclear power plant and associated components, segregate wastes, and transport wastes for disposal in accordance with applicable permits, licenses, and Federal, state and local laws and regulations. The decommissioning of the NSS nuclear power plant shall comply with NRC requirements in 10 C.F.R 20, Standards for Protection Against Radiation, 10 C.F.R. 50.59, 10 C.F.R. 50.82, the License and Technical Specifications.

If MARAD decides to implement the Proposed Action, no major construction of new facilities would be anticipated. Moreover, no dredging would be required and there is no seasonal towing restriction.

In addition to decommissioning, NSS is scheduled for its ABS routine drydock in 2019, which will include, at a minimum, surveys of the ship's exterior and underwater hull.

DECON-LT is expected to be completed by the end of 2024. The project is described below.

There are three phases to the project work. Phase 1 includes pre-decommissioning planning, engineering, hazardous materials abatement, infrastructure preparation, and license amendment actions (which would be completed at the current berthing site) that takes about two years.

Much of the activities included in the Phase 1 apply to both DECON and SAFSTOR decommissioning *options and are not location specific; therefore, the environmental impacts of those activities were analyzed under the 2008 FEA/FONSI. Phase 2 includes the removal of the systems, structures, and components related to the nuclear power plant and disposal of these items at licensed J;adioactive waste disposal facilities, which takes about' four years. Pha~e 2 activities may take place in one of the three cities analyzed in this EA and could require towing.

Phase 3 includes a final status and confirmatory survey conducted by the NRC with license termination, which can take up to one year and may be conducted at an alternate location from the decommissioning site.

There are some vessel modifications needed in cargo holds 3 and 4 to support the decommissioning of its nuclear power plant. Cargo hold 4 will be used for waste receiving, segregation and packaging and work includes removing tween deck hatch leaves, trunking the hatch square, and establishing two ventilation systems; one for slightly negative pressure ( dirty),

and one for work space outside the hatch trunks ( clean). Cargo hold 3 work involves installing a door into cargo hold 4 at the tank top for additional waste packaging spaces, sealing the D Deck hatch as a ventilation boundary, and using the space on B and C Decks for "blue collar" work space (the clean ventilation system extends here).

Decommissioning Decommissioning procedures may vary slightly among facilities. The following general description is the basis for the analysis in Chapter 3.

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According to the NRC's Consolidated Decommissioning Guidance NUREG-1757, decommissioning means to safely remove a facility or site from service and reduce residual radioactivity to a level that permits termination of the license. This process involves waste removal, transport and disposal.

It is anticipated that three low level radioactive waste categories would be generated during decommissioning activities: solid radioactive waste, liquid radioactive waste, and mixed waste.

The radioactive potential contaminants of concern are primarily in the form of activation and corrosion products. All radioactive materials above guidance limits would be removed. The reactor pressure vessel (RPV) and ancillary components ( e.g. piping, valves, pumps) within the containment vessel would be disconnected and removed piece by piece.- It is anticipated that the RPV would remain intact and removed as one piece. The components would be enclosed in DOT approved containers for appropriate transport to an approved waste disposal site.

The LLRW material removed would be transported to a disposal location via secure methods and routes typically used to ship low-level radioactive waste. The NRC, DOT, and Department of Energy (DOE) regulate the transport and disposal of radioactive waste, and have specific regulations for shipping and planning for potential accidents. Trucks and tractor-trailers, as well as* railways and barges; are typically used to transport low-level radioactive wastes, and are placarded to comply with DOT requirements to indicate that hazardo11s materials are contained within the waste packages. Waste transporters are trained and licensed for the safe handling and transport of these materials. Local. agencies and states have. emergency response plans in place in case'ofaccidenis. * * * ' *

• The r~dioactive waste* removed from NSS wouid be disposed of ~ccording to Federal regulations and applicable state regulations at an approved facility ... The NRC, DOE, EPA and individual

• states govern the operatioP:s of waste-disposal'sites to protect huni~n heal!h aiid the* envitorihient.

Potential licensed* commercial waste sites capable of- receiving NSS waste incfude:

EnergySolutions facility irt Clive,* Utah and Waste Control sp-ecialists-(WCS) in Texas. WCS operates both a Compact Waste Facility (CWF) and a Federal Was_te Facility (FW!').

The NSS decommissioning process is described in MARAD's -2008 Post Shutdown Decommissioning Activities Report (PSDAR), Rev 1. The current condition and configuration*

oftJie NSS nuclear power plant is described in MARAD'-s current (2017, and updated bi~nnially)

Updated Final Safety Analysis Report (UFSAR), Revision IX. Additionally, the proposed decommissioning ofNSS will comply with the applicable requirements of 10 C.F.R 20.1402, 10 C.F.R. 50.59, 10 C.F.R. 50.82, the License and Technical Specificatio~s.

2.2 Alternatives 2.2.1 Waste Management Activities Nuclear power plant decommissioning waste management activities could potentially occur in three ways:

1. Solely on the vessel;

2. Solely in a land-based facility adjacent to the vessel; 3.*Partially on the vessel and partially in a land based facility-as necessary.

However, the NRC license applies to the entire NSS vessel and waste management actions done within the vessel. Option 1 is the only method that is covered by the existing license and it would also minimize the handling of the waste and the potential° environmental effects and be

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most efficient. Option 2 and 3 would require NSS license amendments approved by the NRC and involve multiple waste handling activities in the physical environment outside of the NSS, which would increase the potential for environmental effects. As discussed in Section 1.2 regarding adequate space on the vessel and the reasons mentioned above, Option 1 was chosen for all waste management activities. Options 2 and 3 are not viable for NSS and will not be further discussed in this Supplemental EA.

2.2.2 Locations for Phase 2 Twelve years ago, MARAD began exploring options to decommission NSS's nuclear power plant at existing industrial facilities along the East and Gulf Coast by taking into account facility availability and multiple waste types. Facilities were investigated that would have the ability to host decommissioning of the vessel's nuclear power plant with respect to adequate facility size, crane capacity and other equipment.

The waste management activities discussed above may be implemented at commercial facilities located in one of three alternative locations: (1) Baltimore, MD, the Preferred Alternative; (2)

Hampton Roads, VA; and (3) Philadelphia, PA.

The No-Action Alternative for this Proposed Action is that NSS's nuclear power plant would not be decommissioned and the vessel would remain in Baltimore, MD in protective storage. These alternative locations are shown in the Project Area Map (Figure 2.4 in Appendix A).

Alternative Location Screening Analysis NSS has the following characteristics, which were considered in the screening analysis:

Length Overall: 596 feet (ft) Beam: 78.0 ft Draft: 29.5 ft Screening criteria were developed to identify reasonable alternatives based on the purpose and need of the Proposed Action and to eliminate those that did not meet the criteria. For an alternative to be considered reasonable, it must: -

• Be at an approved commercial industrial facility with sufficient infrastructure and without limitations (including extra permits) for working with radioactive materials and that is within a region that will allow for the disposal of radioactive waste at a licensed/permitted disposal facility. *

• Have waterways leading up to the facility that are currently deep enough to allow NSS to be towed to the site without dredging.

• Have adequate laydown space for a 100 ton landside crane and contiguous land for decommissioning.

• Have adequate space/support for a 1000 ton crane, as either a barge-mounted shear leg derrick or a land-side polar crane.

• Have multiple transportation routes (barge, rail, highway) for waste transport.

• Remote access and no residential area within one mile (preferred).

• Preferably be geographically close to Baltimore, MD to minimize potential environmental impacts from long-distance open-ocean towing.

Alternatives Considered but Eliminated Whales (as discussed in Section 3.2) are rare visitors to the Chesapeake Bay and port, but the area outside of the Bay and farther offshore in open ocean are high use areas, especially during migration. Potential impacts to whales, sea turtles and manatees are much greater for open ocean tows.

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The following alternative locations were considered for NSS but ultimately eliminated from further review:

• Galveston, TX has a requirement for obtaining a Specific Use Permit for decommissioning

• Savannah, GA has poor arrangement, and no space for the largest crane needed and a lack of transportation

• New London, CT has inadequate space for required cranes and no remote access

• Wilmington, NC has inadequate space for cranes and laydown, insufficient transportation, and a lack of suitable infrastructure and industrial facility for this project

• Charleston, SC and Jacksonville, FL would require long-distance open-ocean tows that could potentially impact whales and sea turtles.

2.3 Baltimore, Maryland, Alternative This alternative would decommission NSS at a commercial facility at or adjacent to the port of Baltimore, MD that has existing infrastructure to support decommissioning the nuclear power plant on a vessel of this size and would not require construction of any new facilities.

Baltimore, MD is on the Patapsco River at the northern end of the Chesapeake Bay. There are no navigational concerns regarding bridges with this alternative. The towing to another location in Baltimore, MD for nuclear power plant decommissioning, if necessary, meets the requirements for safety, navigation, environmental, and other safeguards.

2.4 . Hampton Roads, Virginia, Alternative This alternative would decommission NSS at a commercial facility in Hampton Roads, Virginia that has existing infrastructure to support decommissioning the nuclear power plant on a vessel of this size and would not require construction of any new facilities.

• Hampton Roads incorporates the mouths of the Elizabeth River, Nansemond River, and James River with sev(?ral smaller rivers and empties into the Chesapeake Bay near its mouth leading to the Atlantic Ocean. There would be no navigational. concerns regarding bridges with this alternative. The towing to Hampton Roads meets the requirements for safety, navigation, environmental, and other safeguards.

2.5 Philadelphia, Pennsylvania, Alternative This alternative would decommission NSS at a commercial facility in Philadelphia, Pennsylvania that has existing infrastructure to support decommissioning the nuclear power plant on a vessel of this size and would not require construction of any new facilities.

Philadelphia is located at the intersection of the Delaware and Schuylkill Rivers approximately 80 miles up the Delaware River from the Atlantic Ocean. The river has a depth of 40 feet and two fixed bridges with adequate overhead clearance and no navigational concerns. The towing meets the requirements for safety, navigation, environmental, and other safeguards.

2.6 No-Action Alternative Tpe NEPA requires that MARAD evaluate a No-Action Alternative in addition to the other reasonable alternatives that are being analyzed for potential environmental impacts. Under the No-Action Alternative, NSS's nuclear power plant would not be decommissioned and the vessel

_would remain in Baltimore, MD in protective storage. It would require MARAD to maintain its license with the NRC, as well as continue the regular maintenance of the vessel. The No-Action

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Alternative is not consistent with NRC license termination requirements, and does not meet MARAD mission objectives to decommission their nuclear power plant and terminate their license. Therefore, this* alternative is not considered reasonable.

2. 7 Summary of Impacts .

This Supplemental EA has determined that implementation of the Proposed Action or the No Action Alternative would not result in significant impacts to any resource areas. The environmental consequences associated with implementation of the Proposed Action and the No Action alternative are presented and compared in Table 2-2 of Appendix. A. For a detailed description and analysis, refer to Chapter 3, Affected Environment and Environmental Consequences. - -

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3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 3.1 Water Resources Water resources, including water and sediment quality in the project area, is described in existing conditions and potential environmental consequences. Surface water includes bays and estuaries, lakes and ponds, rivers and creeks, and overland precipitation runoff. Sediment quality describes the chemical and physical composition of sediment in bodies of water. For the purposes of this analysis, water and sediment quality is evaluated with respect to possible disturbances of existing conditions associated with the proposed project activities. This project is entirely in-water and all considered alternatives are at hard shorelines developed with piers and other facilities, thus no groundwater would be impacted.

3.1.1 Regulatory Setting Water resource regulations focus on the protection of beneficial uses of water within the vicinity of the project area. The principal Federal law protecting water quality is the CWA, as amended (33 U.S.C. § 1251 et seq.), which is enforced by the ~U.S. EPA. Under Section 303(d) of the CWA and EPA's Water Quality Planning and Management Regulations (40 C.F.R. Part 130).

States are required to develop total maximum daily loads (TMDLs) for impaired waterbodies unable to meet their designated uses. A TMDL "establishes the amount of a pollutant that a waterbody can assimilate without exceeding its water quality standard for that pollutant."

Section 307(c) of the CZMA requires that any Federal actions that would directly or indirectly affect any land or water use or natural resource of the coastal zone must be consistent to the maximum extent practicable with the state program. The states of Maryland 1 Pennsylvania, and Virginia have prepared Federally-approved Coastal Management Programs (CMPs).

3.1.2 Affected Environment Baltimore; MD, Alternative Water Quality The water quality in the port city of Baltimore is impaired due to contamination by chlordane, polychlorinated biphenyls (PCBs), metals, low oxygen, and bacteria in tidal waters. Siltation in non-tidal waters, a consequence of urban runoff, habitat alteration, and channelization, results in the failure of some areas to meet all designated uses. Fish consumption advisories are in place for waterways in and around Baltimore, MD (MDE, 2011).

Baltimore, MD lie_s in the Patapsco watershed. The Patapsco River is a 39-mile-long river in central Maryland which flows into Chesapeake Bay. The river's tidal portion forms the harbor for the city of Baltimore. Maryland Department of the Environment (MDE) has designated the Patapsco River as Classification II for Tidal Water indicating migratory spawning and nursery use (February 1 through May 31), shallow water submerged aquatic vegetation use (April 1 through October 30), open water fish and shellfish use (January 1 through December 31 ),

seasonal deep water fish and shellfish use (June 1 through July 30), and seasonal deep channel refuge (June 1 through September 30).

The Baltimore Harbor is within the Upper Chesapeake Subregion which is part of the Mid Atlantic Watershed Region of the Chesapeake Bay basin. The Chesapeake Bay basin encompasses 64,000 square miles of land including portions of six states (Maryland, Virginia,

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New York, Pennsylvania, West Virginia, and Delaware) and the District of Columbia.

Approximately 94 percent of Maryland drains to Chesapeake Bay (USGS, 2007).

In 2012, the Baltimore Harbor was listed as an impaired waterbody for aquatic life and wildlife use (MDE, 2012). The watershed area surrounding the decommissioning facility is primarily urban, with a population of nearly 1.5 million people; it has been impacted by point source and non-point source pollution resulting in water quality degradation. The Baltimore Harbor has TMDL for nutrients, chlordane, bacteria, chromium, PCB, zinc and lead.

Sediment Quality Sediments in the waterways near Baltimore, MD are composed primarily of clay particles and have been classified as impaired by the MDE. Specific contaminants for the Baltimore Inner Harbor include PCBs, polycyclic aromatic hydrocarbons (PAHs), chlordane, mercury and nickel; Chlordane and PCB contamination were found in sediment of Baltimore Harbor (MDE, 2012).

Sediment analyses were conducted in 2006 and 2007 by the Federal Energy Regulatory Commission (FERC) for the construction and operation of a liquefied natural gas (LNG) import terminal and natural gas pipeline facilities. Sediment test results were compared to the Threshold Effects Levels (TELs) 1 and_the Probable Effects Levels (PELs)2 as provided by the EPA Marine Sediment Guidelines. Results found P AHs exceeded the PELs at multiple surface locations. The locations with the most elevated concentrations of P AHs were close to shore along the finger docks of the historic shipbuilding docks. The concentrations of metals generally decreased with depth, with fewer exceedances of the PELs in the intermediate and deep samples.

All metals exceeded PEL at the shallow depth and most exceeded at the intermediate depth interval. Only arsenic and mercury exceeded sediment criteria at depth (FERC, 2008).

_Hampton Roads, VA, Alternative Water Quality Hampton Roads, Virginia is located in southeastern Virginia and has a combination of rural, residential, commercial and industrial activities. Hampton Roads is bounded by the James River to the west and south and the Chesapeake Bay to the east. These waterways are commonly used for recreational boating and fishing and commercial fishing activities.

The James River basin is 410 miles long and drains approximately 10,300 square miles of land throughout Virginia before emptying into the Chesapeake Bay, near tidally influenced, brackish waters.

Water quality impairments have been detected throughout the Chesapeake Bay and its tributaries. James River is designated as a Class II water body and has been placed on the Section 303(d) list of impaired water bodies. Water quality designation is EPA Category 5 (waters are impaired or threatened and a TMDL is needed). All segments of the James River failed to meet chlorophyll-a criteria due to the presence of algal blooms. All segments of the James River, except for the lower tidal fresh zone, attained the assessed dissolved oxygen criteria. Benthic communities are impaired due to inadequate conditions for growth of submerged aquatic vegetation.

The prevalent forms of pollution affecting .the James River are sediment, nitrogen and phosphorus. High levels of nitrogen, phosphorus and sediment enter the water from a variety of

1 TEL represents the concentration below which adverse effects are expected to occur only rarely.

2 PEL is the level above which adverse effects are frequently expected.

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sources, including agricultural operations, urban and suburban runoff, wastewater facilities, onsite septic systems, air pollution, and other sources. In December 2010, the EPA established the Chesapeake Bay TMDL, which includes limits on nitrogen, phosphorus and sediment. The James River is the only river in the Chesapeake Bay watershed with a numeric TMDL standard for chlorophyll-a. As a result, in addition to nutrient and sediment reductions necessary to help achieve dissolved oxygen standards in the mainstream of the bay, EPA has called for additional reductions to meet the James River specific chlorophyll-a standard.

Sediment Quality Sediment pollution continues to have widespread impacts throughout the James River system.

These impacts include silting in critical-stream and river habitat, as well as clouding the water and blocking sunlight from underwatei; grasses. The James River is susceptible to high pollution -

levels during years with heavy rainfall.

Areas of the lower James River (e.g. Willoughby Bay, Newport News) have been observed to contain toxic sediments. Further up the James River, extensive contaminant data are lacking, but the river has health advisories due to historical Kepone contamination. The Virginia Department of Environmental Quality (DEQ) _and the Virginia Departinent of Health (VDH) regulate Kepone in* the James- River because it settles in the soils-in the bed of the rivers-and creeks and* is an issue when dredging channels in contaminated-a:r:eas. Additionally,:VI?H _has issued fish cons~ption advisories for the James River, due to potentially harmful levels of PCBs in the fish.

Pbiladelp_hia, PA, Altern;Jtive Port areas in Philadelphia, -Pennsylvania lie between two rivers, the Schuylkill River and the Delaware River: The Schuylkill River watershed encompasses 2,000 square - miles - irt

. southeastern P..ell:lsyJv~nia and_ .is. Dela_wa_re Riv~r'& larg~st. tri:butary.__ The __ Delaware_ Rjver

- watershed -encompasses -about 13;500 square* miles*. in* four- states: New -York~ New Jersey,

e~nnsylv_ani~, @cl :Oelawar_e. Smface_ w~te:r nm.off .drai11s i11to. the Schµyl~ill Riyer nea_r jt~ ..

confluence with the* belaware River as. weir as dh-ectiy *into tlie Delaware River.

• The rivers generally flow south from the Philadelph{~F area and *empty into the Delaware Estuary, which connects to the Atlantic Ocean.

• The shorelines of both the Schuylkill and Delaware rivers are heavily developed with residential, coinmercial, and manufacturing land uses;* Both the Schuylkill and Dehmrare rivers are usedfor municipal and industrial water supplies and_ as discharge points for treated wastewater. The intensity of shoreline development and water use has degraded the water quality of these rivers in the greater Philadelphia area.

The pres_ence of PCBs are of particular concern in the Delawar_e River due to high PCB concentrations found in fish tissue. The segment of the Delaware River between the head of Delaware Bay (River Mile 48.2) and Trenton, New Jersey (River Mile 133.4) has been found to be impaired. In 2003, a PCB TMDL of 44.8 picograms per liter was developed for the portion of the Delaware River adjacent to Philadelphia ports. This is the only TMDL developed for the Delaware River in Pennsylvania.

Sediment Quality Given the heavy industrial history of the project areas and the known contamination ofDelaware River sediments, sediment quality is anticipated to be poor. Studies were conducted on the Delaware River in 1995 and 1997 as part of a proposed channel deepening project. Area sediments are predominantly silty clay and silty sand. Bulk sediment analyses found no frequent

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occurrences or high concentrations of pesticides, PCBs or volatile and semi-volatile organics.

Sediment organic contaminants including polynuclear aromatic hydrocarbons (PAHs) and phthalates (di-n-butyl phthalate) were detected at several locations. Most sample concentrations, however, were well within the acceptable range of guidelines used by the New Jersey Department of Environmental Protection and the Delaware Department of Natural Resources and Environmental Control.

Facilities. in the greater Philadelphia area have been in . operation for over sixty years, thus sediment quality beneath and surrounding the vessel is likely to be degraded. The U.S. Arriiy Corps of Engineers (USACE) conducted a sediment and water quality study in 2009 for the area.

Analysis found bulk sediment concentrations exceeded consensus-based sediment threshold effect concentrations (i.e. concentr~tions ~hove which harmful effects on aquatic life are likely to be observed; MacDonald et *al., 2000). Sediment concentrations of concern include PCBs, DDT, DDE, endrin, and mercury. Additionally, dissolved elutriate PCB concentrations were found to exceed the Delaware River Basin Commission's chronic water quality criterion for the protection of aquatic life and the commission's criterion for human health-and fish ingestion. Despite the occurrence of concerned chemicals, none of the . parameters exceeded the Pennsylvania Department of E_nvironmental _Protection (PADEP) gen~ral permit_ for beneficjal crit.eril;i vaJu.e .

(USACE, 2009).

3.1.3 Environmental Consequences

• Towing impacts apply to all alternatives. Potential impacts from any required towing operations include temporary bottom sediment disturbance and surface water turbidity through the generation of surface wakes and prop_dler wash. However, as the t_owing operations wtli be conducted in compliance with applicabie wake and speed limits, the impact on

• sediment resuspension. will be minimal. Towing can pose a risk *to water quality if significant-levels of

• contamination from ex.foliating paint chips on vessel hulls are released into the environment.

- However; the NSS hull has beentaketi-down to *bare metal twice before painting* and*does not*

have lead paint; NSS was last drydocked in 2008 and is scheduled for the next one in 2019.

There is potential risk for oil spill due to_ collision, grounding, or tank or hull rupture. or* leakage ...

However, such events are rare. Additionally, the vessel is subject to detailed inspections to ensure it is safe for towing. Towing procedures and safety measures would be implemented to minimize pQtential for collision 9r grounding 9[ the vessel during tnmsport.

• Additionally, the Proposed Action does not require dredging or in-water work-.

Baltimore, MD, Alternative The Proposed Action does not involve new construction off the vessel, only the removal, transportation and disposal of LLRW materials. NSS already has an NRC license to perform

• decommissioning activities and will obtain any required additional state and local permits for waste transportation and disposal. Compliance with regulations would avoid significant impacts on water and sediment quality.

This alternative may not require towing, so potential impacts are minimized. Due to the industrial nature of the site, no submerged vegetation or sensitive marine habitat exists in the project area. All activities would be conducted in compliance with applicable Federal and state environmental laws to avoid significant impacts on water and sediment quality. The Proposed Action should have no adverse impacts on water and sediment quality and would not combine with impacts from other past or future projects in such a manner that would create a cumulative impact.

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Hampton Roads, VA, Alternative The Hampton Roads, VA, Alternative requires removal of the vessel from Baltimore, MD through towing which include temporary bottom sediment disturbance and surface water turbidity. All activities would be conducted in compliance with applicable Federal and state environmental laws to avoid significant impacts on water and sediment quality. Other than towing, the Proposed Action should have no adverse impacts on water and sediment quality and no cumulative impacts. .

Philadelphia, PA, Alternative Similar to the Hampton Roads, VA, Alternative, the Philadelphia, PA; Alternative requires removal of the vessel from Baltimore, MD through towing. All activities would be conducted i~

compliance with applicable Federal and state environmental laws to avoid sigpificant impacts on water and sediment quality. Except for temporary bottom sedim~nt disturbance and surface water turbidity, the Proposed Action should have no adverse impacts on water and sediment quality and no cumulative impacts.

No~Acti9n A\\t~rna_tive Under fh'e No~Action Alternative; NSS wouM not be decommissioned and would not be removed *

. froin Baltimore, MD. As a *result, there would *be no significant immediate water resources and quality impacts to Baltimore; MD as *a-result of this action.

3.2 - Biological Resources 3~~-1 . Regulatory Settjiig The Federal Endangered Species Act (ESA) protects Federally-listed threatened and endangered (T ~E) plant_ a~d animal spe~tej. -Tliria_tene4 *and *end~ger~d sp~~ies ~re :<;lefined a,s tho_se plal!t _.

and animal species in danger of extinction throughout all or a significant portion of its range, by

-the USFWS, NMFS~ -ot appropriate state agency. the Marine MammarProtection- Act' (MMP A)  :

protects marine mammals_ from "take'~ (harm ,or harassment). The Federal laws.and tequirem~nt~

protecting many bird-species are the Migratory Bird Treaty Act (MBTA)- and EO 13186 Responsibilities of Federal Agencies to Protect Migratory Birds. Bald and golden eagles are protected under the Ba:ld and Gold_<<:m E.agle Protection Act, which prohibits the "take" of bald or.

golden eagles in the United States ..

• 3.2.2 Affected Environment Biological resources consist of native and nonnative plant and animal species and the habitats in which they occur. Biological resources can be grouped into two primary categories: terrestrial and marine resources. Since this project is almost entirely in water, the discussion will focus *on marine resources as well as migratory birds.

Marine biological resources are transient resources that can range in and out of surrounding habitat area. As a result, this section not only includes species that are within the project action area but also ones that may be affected by the project. For example, a fish may be included if it lives downstream from the area, and birds include resident and migratory species.

Each location section is divided* into* subsections that address: 1) wetlands; 2) benthic communities; 3) fish and Essential Fish Habitat (EFH); and 4) protected species in the area.

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Baltimore, MD, Alternative Wetlands Wetlands in the Chesapeake Bay are designated open water and tidal estuarine emergent wetlands. Very few natural wetlands exist along Baltimore Harbor's urban shorelines, but since 2010 there have been floating wetlands created and in use. There are no wetlands identified at the potential facilities for decommissioning in Baltimore.

~enthic Communities Sampling conducted at the proposed site for FERC for the construction and operation of a liquefied natural gas (LNG) Environmental Impact Statement (EIS) indicated that the benthic corrmmnity cq_nsisted of i3 sp~cies ancJ *was dominated by the polychaete Nereis succinea (47%

of collected individuals) followe4 by the biyalve Tellina agilis, and the polychaete Str~blospio

• benedicti ( combined 15% of collected individuals). Other invertebrates, such as grass .shrimp, would also be expected in such* estuarine habitats, According to surveys completed for, and studies referenced in, the LNG EIS from December 2008., there is. no Submerged Aquatic Vegetation. (SA V) in the project area. SA V refers to v~scular_, r(?oted, ~o~~rjng~ plants* !hilt live anq grow m9_stly underwa~er. There_ is Iio, s~~sit!ve vegetation within this hig~ly_ in~us~rial area.

The Chesapeake Bay supports a major blue crab fishery. Low numbers of bhie crabs were found in_l;>ottom trawl_s in the vicinity _of the proposed l,]'{G tennina_L Du~ to !he industrial nature _of the facilities irt Baltimore, MD, no blue crabs ate expected in the decoimrtissioning location:

• Fish an<f: Esseniiµl Fish Habitat. . .

Baltimore, MD is a highly industrialized-area with an estuarine water characterization supporting fish -species that_ can tolerate a wide range

• of salinities: Water fa this* area-* is an impaired waterbody for aquatic** life and *wildlife use. However, the Chesapeake Bay Program is attempting to reduce nutrient and-sediment loads in the bay. -* -.

• The open waters of the Patapsco . River_ provide a migratory corridor for anadromous. and catadromous 3 fish that move between. .their respective spawning and nursery grounds in the-main stem of the river and tributaries. These fish species include alewife, blueback herring, American shad, white perch, yellow. perch, and American eel (NMFS, 2005). The American eel is the only true* catadromous fish that may occur in the project area~ Bluefish (Pomatomus saltatrix), and summer flounder, are the species for wliich*EFH has been identified by NMFS in the vicinity:

Bluefish are present in the project area only in low numbers and only during a few months of the year. Summer flounder occupy inshore shallow coastal and estuarine waters during spring and

• summer and migrate offshore ip. the fall. They are not likely to be in polluted areas or areas with inadequate circulation in Maryland coastal bays. Therefore, summer flounder do not generally occur in the project area during winter or spring and they may be present in the project area in low numbers during the late summer and early fall when they migrate offshore.

River herring, white perch, and yellow perch are not designated as EFH species but are important forage fish for managed game fish in:the project area. River herring (also called alosine species) include American shad, hickory shad (Alosa *mediocris), alewife (Alosa pseudoharengus), and blueback herring (Alosa aestivalis). The annual migration of river herring in the area occurs from late February through early June. During sampling for the LNG EIS in June and October

3 Catadromous fish spawn in the* ocean but complete most of its life cycle in fresh water.

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2006, no suitable habitat was identified for the American shad and none were captured in trawls.

White perch are ubiquitous in estuaries and freshwater ecosystems and were the most abundant fish found in the area.

Protected Species The state government entity responsible for protection of state listed species in the project area is the Maryland Department of Natural Resources (MDNR). Thirty species that are Federally listed as endangered or threatened are found in Maryland and nine potentially occur within the Project area. These include five mammals (North Atlantic right whale, humpback whale, fin whale, sperm whale, and sei whale), three reptiles (Kemp's ridley sea turtle, green sea turtle, leatherback sea turtle), and one fish species (shortnose sturgeon). See Table 3-1 in Appendix A. No critical habitat for Federally listed threatened and endangered species has been designated in the project area.

Peregrine falcons (designated by Maryland as a Species In Need of Conservation) nest high on towers and bridges and are not expected near the decommissioning location. The Chesapeake Bay watershed supports one of the highest concentrations of bald eagles in the continental U.S.,

with most found within one mile of the bay and its tidal tributaries. The bald eagle would occur over the waterway only as transient individuals during migration or moving within their range across Chesapeake Bay.

Waterbirds use the open water habitat adjacent to the facility. Seabirds and waterfowl within the

_ Chesapeake Bay include gulls, terns, _ducks such as scaup and scoters, double:-crested cormorant, and brown pelican. A midwinter waterfowl survey is conducted annually by MDNR- biologists during the month ofJanuary, when waterfowl are considered to be in their wintering areas arid migration has ended. Species observed in this area include Canada goose; American black duck; mallard; gadwall; American wigeon;- canvasback; redhead; bufflehead; hooded, cqnimon arid red-breasted mergansers (MDNR, 2012). Most of the various bird species are well adapted to human- activity and may be present in an:d around the project area during towing and mooring activities. However, the MDNR has established 0.25-mile_ radius protection zones around nesting sites for the colonial waterbird colonies on Sparrows Point and Fort Carroll Island. Since potential decommissioning locations are located farther than the protection zones, no effect on nesting sites is expected. The MDNR has similarly established restrictions as protection guidelines for nesting peregrine falcon on the Francis Sc;ott Key Memorial-Bridge. No effect on the nesting site is expected.

The NMFS reports that North Atlantic right whales, humpback whales and fin whales are rare visitors to the Chesapeake Bay and port, but the area outside of the Bay is a high use area for these species, especially during migration. Sperm and sei whales are found farther offshore than the other whales and their potential presence would be unlikely in the Bay. Though very unlikely, considering this alternative would potentially involve a very short distance tow and sperm or sei whales may be present within the towing path.

The Kemp's ridley and green sea turtles are known to be present in the Chesapeake Bay from April 1 to November 30, but mainly in the late spring, summer, and early autumn when water temperatures are relatively warm. Leatherback turtles are seasonally present in the Bay. Recent data from sightings and inddental captures in fishing gear indicate that Kemp's ridley *are the sea turtle species most likely to be found in the waters of the bay, while leatherback and green sea turtles are relatively less common. In general, sea turtles are less common in the upper bay; however, data from the MDNR sea turtle tagging program and from the Sea Turtie Stranding

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Salvage Network indicate that sea turtles have been found near the mouth of the Patapsco River.

Typically sea turtles are unlikely to be present in the port.

A small and vulnerable population of shortnose sturgeon is known to be present in the Chesapeake Bay though no shortnose sturgeon were reported during June and October 2006 marine surveys in the Patapsco River (FERC, 2008).

Hampton Roads, VA, Alternative Wetlands Wetlands found within the Hampton Roads, VA area are predominately tidal wetlands that border the river along its lower reaches. They are a combination of estuarine and palustrine emergent wetlands. These sensitive ecosystems vary in plant communities, salinity, and tidal influence, depending on their distance from both the Chesapeake Bay and the James River shoreline. Species richness is very low, with one to a few submerged vascular aquatics present.

These consist primarily of beaked ditch-grass (Ruppia maritima), common eel-grass (Zostera marina), horned pondweed (Zannichellia palustris), and sago pondweed (Potamogeton pectinatus). Riverine marshes are strongly dominated by saltmarsh cordgrass (Spartina alterniflora), often in association with big cordgrass (Spartina cynosuroides) or saltmarsh bulrush (Scirpus robustus) (Fleming et al.,_2010).

Benthic Communities The major natural environmental factor influencing faunal distribution in estuaries is salinity.

The region has the oligohaline (0.5 to 5.0 parts per thousand (ppt)) salinity zone and the mesohaline (5.0 to 18.0 ppt) zone up the James River; and the polyhaline (18.0 to 30.0 ppt) zone near the Hampton Roads region (Diaz; 1989).

Dominant species in the oligohaline zone are likely to include the bivalve Rangia cuneata, the polychaete Scolecolepides viridis, and amphipods in the genus Gammarus. The common rangia (R. cuneata) is a common estuarine clam (Diaz, 1989). Salt-tolerant freshwater species such as the Asiatic clam ( Corbicula jluminea ), tubificid oligochaetes of the genus Limnodrilus, and the chironomid insect larvae Coelotanypus and Cryptochironomus became dominant at th_e upper end of the oligohaline zone and into the tidal freshwaters (Diaz, 1989). Dominant species in the mesohaline zone included the amphipods Leptocheirus plumulosus and Corophium lacustre, the oligochaete Tubificoides heterochaetus, the bivalve Brachidontes recurvus, and the polychaetes Paraprionospio pinnata and Heteromastus filiformis (Diaz, 1989).

NOAA's Estuarine Living Marine Resources (ELMR) program determined the invertebrates Daggerblade grass shrimp (Palaemonetes pugio) and Blue crab (Callinectes sapidus) were both highly abundant throughout the oligohaline and mesohaline zones of the estuary. Daggerblade grass shrimp use the estuary during all life stages, while blue crabs move offshore to brood eggs and release larvae (Stone et al., 1994). American oyster (Crassostrea virginica) and northern quahog (Mercenaria mercenaria) are abundant during all life stages, but are not typically numerical dominants in the estuary. Blue mussel (Mytilus edulis) and sevenspine bay shrimp

( Crangon septemspinosa) are considered common, and softshell clam (Mya arenaria) and brown shrimp (Penaeus aztecus) are found in the estuary but considered rare (Stone et al., 1994).

Salt-tolerant SAV such* as widgeon grass (Ruppia maritima) is likely to be fourid in Hampton Roads. Wild celery, hydrilla, redhead grass, sago pondweed, and Eurasian watermilfoil, also thrive in low salinity and are found in the middle and upper reaches of . . the estuary (VIMS, 2011).

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The prevalence and health of SA V is largely dependent on salinity and water quality; thus the improving quality in the region has increased the abundance of SA V.

Several invasive invertebrates have been reported from Chesapeake Bay including the zebra mussel (Dreissena polymorpha ), the Asiatic clam ( Corbicula fluminea ), and the Japanese shore crab (Hemigrapsus sanguineus) (Moser, 2002). The zebra mussel has been found within a limited range in the upper reaches of Chesapeake Bay (ELI, 2007). The Asiatic clam has already become established throughout the Bay, and is a community dominant in the oligohaline zone of the James River estuary (Moser, 2002; Diaz, 1989).

Fish and Essential Fish Habitat Due to salinity levels, fewer species of fish are likely to occur near Hampton Roads than in other reaches of the estiJary. Atlantic menhaden (Brevoortia tyrannus), bay anchovy (Anchoa mitchilli), killifishes (Fundulus species), silversides (Menidia species), and hogchoker (Trinectes maculatus) were all identified as numerical dominants in the estuary. White perch (Marone Americana), bluefish (Pomatomus saltatrix), spot (Leiostomus xanthurus), Atlantic croaker (Micropogonias undulatus ), and gobies ( Gobiosoma species) are not typically identified as numerical dominants, but are all considered abundant in the James Rivet Estuary (Stone et al.,

1994). Common species that are frequently encountered but not in high numbers include common cownose*ray (Rhinoptera bonasus), American eel (Anguilla r_ostrata), blueback herring (Alosa aestivalis), alewife (Alosa pseudoharengus), American shad (Alosa sapidissima), channel catfish (Ictalurus punctatus), oyster toadfish (Opsanus tau), northern pipefish (Syngnathus fuscus), striped bass (Marone saxatillis), black sea bass (Centropristis striata), yellow perch (Perea flavescens), pinfish (Lagodon rhomboides), spotted seatrout (Cynoscion nebulosus),

weakfish (Cynoscion-regalis), black drum (Pogonias cromis), red drum (Sciaenops ocella.ws),

tautog (Tautoga onitis), butterfish (Peprilus triacanthus), and summer. flounder (Paralichthys dentatus); Other ecologically or economically important fish that are occasionally-found in the James River Estuary, but ar! cons,ider~d rare include Atlantic stingray (Dasyatis _sabin_a),

Atlantic sturgeon (Acipenser oxyrhynchus), Atlantic herring (Clupea harengus), red hake (Urophycis chuss), northern seatobin (Prionotus carolinus), scup (Stenotomus chrysops),

northern kingfish (Menticirrhus saxatilis), mullets (Mugil species), Atlantic mackerel (Scoinber scombrus), windowpane flounder, and winter flounder (Pleuronectes americanus) (Stone et al.,

.1994).

The Mid-Atlantic Fishery Management Council (MAFMC) is one of eight regional fishery management councils and is responsible for the creation of Fishery Management Plans in Federal waters. off New York, New Jersey, Pennsylvania, Delaware, Maryland, Virginia, and North Carolina. The MAFMC has designated the waters surrounding these eastern coastal states as EFH for 13 species; nine of these species, including bluefish, windowpane flounder, black sea bass, butterfish, summer flounder, red drum, king mackerel, Spanish mackerel (Scomberomorus maculatus), and cobia, are EFH-designated for the James River Estuary. Habitat Areas of Particular Concern (HAPC) for sandbar shark have been designated in the project area.

Threatened and Endangered Species According to the USFWS, there are 54 animal and 15 plants that are listed as Federal T&E species in Virginia.* No Federally listed species occur in Newport News (City) County, Suffolk, Isle of Wight, or Hampton Counties, but four listed animal species occur in the waters of Virginia Beach County (USFWS, 2013); all four are sea turtles. See Table 3-2 in Appendix A.

No critical habitat-for Federally listed T&E species has been designated in the project area.

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Kemp's ridley, leatherback, and green sea turtles are known to be present in Chesapeake Bay seasonally. Data from sightings and incidental captures in fishing gear indicate that Kemp's ridley is the sea turtle species most likely to be found in the waters of the bay, while leatherback and green sea turtles are relatively less common. When not migrating, green turtles prefer sea grass flats which occur in shallow areas of the Chesapeake Bay in late summer and early fall.

Hawksbills generally like the habitat of coral reefs. Only two hawksbill strandings have been reported in Virginia; both of these are considered "strays" from the tropical waters they normally inhabit (VIMS, 2013). Typically sea turtles do not enter riverine environments.

Although bald eagles are no longer listed as a threatened or endangered species, they are still protected under the Protection of Bald & Golden Eagle Act. Bald eagles range from Alaska to the northern border of Mexico, and from the Pacific to the Atlantic coast, and can be found in all the lower 48 states. In the Chesapeake Bay area, breeding activity begins in November and can last through mid-July (VADGIF, 2011). Nests are generally built in one of the largest live trees available with accessible limbs capable of supporting the nest. Bald eagles in the Great Lakes region and adjacent areas in Canada migrate eastward to winter along the Atlantic Coast from Maine and New Brunswick to Chesapeake Bay. Because of its rich food resources, Chesapeake Bay also is host to a large influx of summer migrants from Florida and other Gulf Cqast states from May to September.

Osprey (Pandion haliaetus), a protected migratory bird, undergoes conservation and management from the authorities of the VA Department of Game and Inland Fisheries and the USFWS. There is a guideline for Removal or Relocation of Osprey Nests in Virginia that follows USFWS regulations.

Philadelphia, PA, Alternative Wetlands Both the D~laware and Scl).uylkill Rivers, and their undeveloped shorelines are designated tidal riverine systems by the National Wetlands Inventory. Tidal riverine systems have water that is usually flowing; the gradient is low and water velocity fluctuates under tidal influence, the streambed is mainly mud with occasional patches of sand, and fauna include species that thrive in still water and true planktonic organisms.

Benthic Communities The EPA performed a Mid-Atlantic Integrated Assessment (MAIA) of benthic conditions in the Delaware River estuary to track the condition of benthic communities. According to the results of the MAIA, the benthic conditions in the project area were classified as "severely impacted."

The Delaware Estuary is characterized by an historical lack of SA V, predominantly due to naturally-occurring low water clarity. It is also one of the most nutrient enriched estuaries in the world, although harmful phytoplankton blooms are held in check by other factors, including low water clarity (EPA, 2006). Species that occur in the area would include freshwater mussel species, crabs, and snail species. These species would not be fit for consumption because of the water quality of the Delaware River. Only blue crab (Callinectes sapidus) is known to be harvested by individuals.

The Delaware *and Schuylkill Rivers are an important migratory flyway for numerous bird species. As a result, avian species diversity would be greatest during the spring and fall months.

Bird species utilizing the area as habitat would generally be limited to those species that are tolerant of human activities; these species include sparrow species, dove species, European

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starlings as well as corvid species (crows and jays) and gulls. However, since many sites in the vicinity are currently abandoned, less tolerant species could be found in these areas.

Aquatic birds found in the vicinity that forage primarily on benthic organisms include the bufflehead (Bucephala albeola); while fish eating aquatic birds found in the vicinity include the hooded merganser (Mergus merganser) and cormorants (Phalacrocorax auritus). These species are fall and spring migrants and over wintering birds within the area. Diving ducks, including the ruddy duck (Oxyura jamaicensis), canvasback (Aythya valisineria), and lesser scup (A.

affinis), are also present in the vicinity and feed on aquatic invertebrates (SAIC, 2004).

Fish and Essential Fish Habitat The project area is not classified as EFH by NMFS. Habitat value for the fish species in the project area is considered to be minimal. Eight species of anadromous fish use the Delaware River as a migratory corridor. Within the vicinity of the project area, recreational fishing is limited by pollution and marine traffic. Except for small harvests of American shad (Alosa sapidisima), and blueback herring (Alosa aestivalis), minimal fishing occurs. Most commercial fishing occurs where the Delaware River meets the Delaware Bay.

According to tlie Pennsylvania Fish and Boat Commission, the shortnose and Atlantic sturgeon (Acipenser brevirostrum, Acipenser oxyrhynchus), the eastern mudminnow (Umbra pygmaea) and the threespirie stickleback (Gasterosteus aculeatus) have been recorded in the Philadelphia area. The eastern mudminnow is a candidate for protective status within the state while the remaining species are currently considered threatened or endangered within the state. The mudminnow and the stickleback are unlikely to occur within the -project area due to a lack of suitable habitat. The shortnose sturgeon is also a Federal endangered -species and_ discussed below.

Protected Species According to the USFWS; seve:p.teen Federal T&E species occur in Pennsylvania and the shortnose sturgeon (Acipenser brevirostrum) is the only one found in the vicinity of the project area. Table 3-3 in Appendix A lists the T &E species in the project area. In recent years, the major area of occurrence of the shortnose sturgeon in the Delaware River has been above Philadelphia. Due to high salinity, occurrence of shortnose sturgeon are rare in this area.

Historically, NMFS and P ADEP have limited in-water construction activities in the Delaware River to the eight and_ a half-month period from July 1 through March 14. Activities are prohibited between March 15 and June 30 to protect migrating Atlantic sturgeon and other fish species. Other species of fish, the eastern mudminnow and the threespine stickleback, inhabit wetlands and small streams and ditches and, therefore, are unlikely to occur in the project area.

The Bog turtle (Glyptemys muhlenbergii) is Pennsylvania's smallest native turtle and is known to inhabit wet meadows and bogs where soils are mucky and grasses dominate the wetlands.

Bog turtles have been historically found in Philadelphia, but there are no known Bog turtles present in the area today. Due to the industrial nature and lack of wetlands within the project area, this species is unlikely to be present. No Federally protected amphibian or reptile species are known to occur in the potential project area.

The only Federal T &E bird species known to occur in the Philadelphia area is the Rufa Red Knot. Rufa Red Knots ( Calidris canutus rufa)), a Pennsylvania threatened species, are migratory birds that are known to nest primarily in intertidal, marine habitats, especially near coastal inlets.

No Federally protected bird species are expected in the project area.

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The only state threatened or endangered bird species known to occur in the area is the Peregrine Falcon. Peregrine falcons (Falco peregrinus), a Pennsylvania endangered species, are known to nest on the Girard Point Bridge (I-95) right at the entrance to the Philadelphia Naval Business Center from the Schuylkill River. Peregrine falcons have been federally delisted but are still covered under the MBT A.

Incidental occurrences of Federal threatened and endangered species have been noted in this area. Such instances are considered rare and are not expected to occur during the Proposed Action.

Additionally, there may be protected whales and turtles where Delaware Bay meets the Atlantic Ocean. They are oceanic and potential summer visitors to Delaware coastal waters and not expected to be in the Project Area along the Delaware River and Delaware Bay portion of the tow route.

3.2.3 Environmental Consequences The potential impacts may vary according to the location of the activity, time of year when the activity occurs, and the location of each species during their respective life cycle.

For all alternatives, tug and tow will transit at speeds of 10 knots or less in accordance with the Whale Ship Reduction Rule (50 C.F.R. 224.105, December 9, 2008) for protection of right whales in seasonal management areas. In addition, whenever marine mammals or sea turtles are sighted in an area; the tug's crew will increase vigilance and take prudent actions to avoid collisions or activities that might result in close interaction of the ship and the animals. Actions may include changing speed and/or direction as dictated by-environmental and other conditions (e.g., safety, weather). Towing the vessel may affect, but is not likely to adversely affect, T&E species and designated critical habitat will not be adversely affected or modified by the alternatives discussed below. For any alternative, the Proposed Action would not combine with impacts from other past or future projects in such a manner that would create a cumulative impact.

Baltimore, MD, Alternative Wetlands There would be no significant impacts to wetlands from decommissioning the vessel's nuclear power plant in Baltimore, MD.

Benthic Communities If towing is required, potential direct, adverse impacts to benthic communities may result from effects of propeller wash, although towing in deep water will reduce the potential for impacts.

Turbidity and siltation associated with propeller wash would be local and transient. As discussed in the water quality section, contaminants could be released during ship transport (from accidental spills or ship collision). However, following approved procedures and permits would reduce potential impacts to temporary and minor. The larger, more mobile benthic megainvertebrates, such as shrimp species, would be able to flee the area during towing and, therefore, would not be affected. Considering the industrial nature of the location, the potential impact on benthic communities is considered minor.

No changes to the overall operations at this location are expected due to the decommissioning of this vessel's nuclear power plant. Additionally, the abundance and distribution of benthos are influenced by heavy ship traffic, industrial activities, and dredgihg which result in the relatively

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low occurrence of benthos in the area surrounding the facility. Thus, any impacts to local benthic communities would be comparable to those occurring routinely in this industrial location. Overall, impacts to the benthos from contaminant exposure, physical disturbance, or suspended sediments resulting from decommissioning at the Baltimore, MD facility are not expected to be significant.

There are no known stands of SA V within the project area; therefore, SA V would not be affected. Blue crabs are not expected in the area, and would not be impacted. There are limited species in the project area that can tolerate the poor environmental conditions. Overall, impacts to the benthos from contaminant exposure, physical disturbance, or suspended sediments resulting from decommissioning in Baltimore, MD are not expected to be significant.

Fish and Essential Fish Habitat Potential impacts to fish resources from decommissfoning activities would be similar to those described above for benthic communities; contaminant exposures and re-suspended sediments are potential impacts to fish as well. Minimal to no impact is anticipated for mobile fish species that can readily avoid the temporary disturbance and potentially increased turbidity in the water column that may occur because of towing activities. Overall, impacts to fish resources from contaminant exposure, physical disturbance, or suspended sediments resulting from

_decommissioning are neither likely nor expected to be significant.

Potential impacts to EFH would be as described above for fish resources and benthic communities. The EFH-designated species are present in the project area only in low numbers.

Impacts to fish resources from contaminant exposure, physical disturbance, or suspended sediments resulting from decommissioning at the Baltimore, MD facility are neither likely nor expected to be significant. There would be no effect on EFH.

Protected Species Impacts to whales and turtles are. most often caused by vessel strike. This potential impact would be mlnimized by the low speed of the tugs (four to six knots) along the channel and at the pier. The NMFS' "Vessel Strike Avoidance Measures and Reporting for Mariners" document would be followed to reduce the potential of vessel strikes to marine species. There would be no reasonably foreseeable takes of marine mammals; the towing action may affect but is not likely to adversely affect threatened and endangered species.

Impacts on sea turtles which may be found in the area are likely to be minimal due to the permits and regulations in place to guard against the discharge of contaminants into the aquatic environment. Any contaminants that may enter the water would likely be at low concentrations and the probability that they would be ingested by sea turtles, or their prey species, is almost non-existent. Thus, there would be no effect on protected sea turtles from decommissioning activities.

There is a very low probability that the bald eagle ( delisted but still protected under the Migratory Treaty Act and the Bald and Golden Eagle Protection Act) and peregrine falcon could be harmed by ingestion through fish or chemical contaminants released during decommissioning activities. There would be no reasonably foreseeable takes of migratory birds, including bald eagles, and no effect on the peregrine falcon.

Considering compliance with all Federal and state regulations, guidelines, and agreements, the decommissioning activities at a Baltimore, MD facility are not expected to have significant impacts on biological resources.

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Hampton Roads, VA, Alternative Wetlands Although the hazardous materials involved in ship decommissioning can pose serious threats to aquatic environments and wetlands, Federal and state regulations would substantially reduce the risk of contamination to nearby wetlands. Permits would impose regulations that limit the migration of any potentially hazardous materials into aquatic habitats that would need to travel some distance to reach any wetlands. Thus, there would be no significant impacts to wetlands from decommissioning the vessel's nuclear power plant iri Hampton Roads, VA.

Benthic Communities The impacts associated with benthic communities described above for the Baltimore, MD Alternative would also apply to this alternative. Overall, impacts to the benthos from contaminant exposure, physical disturbance, or suspended sediments resulting from decommissioning at a Hampton Roads location are not expected to be significant.

Fish and Essential Fish Habitat

_ The impacts associated with fish and EFH described above for the Baltimore, MD Alternative would apply to this alternative. Overall, impacts to fish resources are neither likely nor expected to be significant. There would be no effect on EFH.

Protected Species The impacts associated with protected species described above for Baltimore, MD Alternative would also apply to this alternative. There would be no effect on protected sea turtles from decommissioning activities. There would be no reasonably foreseeable takes of marine mammals; the towing ~ction may affect but is not likely to adversely affect threatened and endangered species. There would be no reasonably foreseeable takes of migratory birds including bald eagles. -

Considering compliance with all Federal and state regulations, guidelines, and agreements, the short distance of towing in near-shore waters (no open ocean) to Hampton Roads, VA, and the subsequent decommissioning activities are not expected to pave si~ificant impacts on biological resources.

Philadelphia, PA, Alternative Wetlands This is a highly industrialized area and there would be no significant impacts to wetlands from decommissioning the vessel's nuclear power plant in Philadelphia, PA.

Benthic communities Due to poor sediment and water quality, benthic habitat within the project area has very low biodiversity, and is limited to organisms that are tolerant of poor environmental conditions.

There are no known stands of SA V within the project area that could be affected by the decommissioning. There are limited species in the area that can tolerate the poor conditions.

The impacts associated with benthic communities described above for the Baltimore, MD Alternative would also apply to this alternative. Overall, impacts to the benthos are not expected

.to be significant.

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Fish and Essential Fish Habitat The impacts associated with fish described above for the Hampton Roads, VA, Alternative would also apply to this alternative. Overall, impacts to fish resources are neither likely nor expected to be significant. There is no EFH.

Protected Species Given the industrial nature and the poor sediment and water quality that characterize this location, these species are unlikely to occur. The implementation of seasonal in-water activity windows would minimize impacts to these species. The impacts associated with protected species described above for Baltimore, MD Alternative would also apply to this alternative.

There would be no effect on protected sea turtles from decommissioning activities. There would be no reasonably foreseeable takes of marine mammals; the towing action may affect but is not likely to adversely affect threatened and endangered species. There would be no reasonably foreseeable takes of migratory birds including bald eagles.

Considering compliance with all Federal and state regulations, guidelines, and agreements, the short distance of towing in near-shore waters to Philadelphia, PA, and the subsequent decommissioning activities are not expected to have significant impacts on biological resources.

No-Action Alternative Under the No-Action Alternative, NSS would remain in Baltimore, MD and its nuclear power plant would not be decommissioned. The vessel would continue to age and MARAD would continue to implement preventative maintenance actions including periodic dry:.dockings to avoid/minimize deterioration. However, over time there will be an increased cost to maintain the vessel and reduce environmental impact.

3.3 Air Quality 3.3.1 Regulatory Setting Air quality in a given location is defined by pollutant concentrations in the atmosphere and is 3 generally expressed in units of parts per million (ppm) or micrograms per cubic meter (µg/m).

One aspect of significance is the concentration of a pollutant in compar1son with the national and/or state ambient air quality standard. These standards represent the maximum allowable atmospheric concentrations that may occur and still protect public health and welfare with a reasonable margin of safety. The national standards, established by the U.S. EPA, are termed the National Ambient Air Quality Standards (NAAQS). The NAAQS represent maximum acceptable concentrations that generally may not be exceeded more than once per year, except the annual standards, which may never be exceeded. The six criteria pollutants are ozone (0 3),

carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter (PM), sulfur dioxide (SO2),

and lead (Pb).

The EPA designates all areas in the country as nonattainment, attainment, maintenance, or unclassifiable with respect to the NAAQS for each criteria pollutant:

• Areas that violate ambient air quality standards are designated as nonattainment areas;

• Areas that comply with Federal air quality standards are designated as attainment areas;

• Areas that have improved air quality from non:attainment to attainment and have an EPA approved plan are designated as maintenance areas;

• Areas that lack monitoring data to demonstrate attainment or nonattainment status are designated as unclassified and are considered*to be in attainment for regulatory purposes.

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Varying levels of nonattainment have been established for ozone, CO, and PM to indicate the severity of the air quality problem (i.e., the classifications runs from marginal to extreme for ozone; moderate to serious for CO).

The CAA requires each state to develop, adopt and implement a State Implementation Plan (SIP) to achieve, maintain, and enforce Federal air quality standards throughout the state. SIPs are developed on a pollutant-by-pollutant basis whenever one or more air quality standards are being violated (nonattainment). Under the EPA's General Conformity Rule (40 C.F.R. § 93), Federal agencies must determine whether the action either is exempt from a Conformity Determination or conforms to the applicable SIP. Actions are exempt when the total of all reasonable foreseeable direct and indirect emissions would be: 1) less than the de minimis emission threshold, and 2) less than ten percent of the area's annual emission budget. If these conditions are met, the requirement for a Conformity Determination is not applicable. In addition, the Conformity Determination Rule contains a number of specific Federal activities that are exempted from Conformity Determination because they will either result in no or de minimis increases in emissions (40 C.F.R. § 93(c)(2)).

3.3.2 Affected Environment The air pollutants that are considered in this analysis include volatile organic compound (VOCs) and nitrogen oxides (NOx), which are precursors to ozone formation, as well as particulate matter less than 2.5 microns in diameter (PM2 .5). The following section summarizes the attainment status and local air quality for each alternative.

Current stationary air emission industrial sources in the vicinity of the project areas consist of boilers, above-ground and underground storage tanks, emergency generators, paint spray booths, industrial furnaces, solvent cleaners, abrasive blast stations, plating operations, and fuel dispensing systems. Mobile emission sources include motor vehicles, trains and vessels.

Baltimore, MD, Alternative Baltimore, MD is located within the Metropolitan Baltimore Intrastate Air Quality Control Region (AQCR) 115. With respect to the 2008 8-hour ozone standard, AQCR 115 is classified as moderate non-attainment. For PM2 .5 , AQCR 115 is classified as maintenance.

Maryland is considered part of the Ozone Transport Region (OTR). The OTR encompasses eleven northeast states and the District of Columbia, all of which have at least some areas not meeting the NAAQS for ozone. Because ozone attainment is a region-wide problem involving interstate transport of ozone precursors, projects located in all areas within the OTR must meet more stringent non-attainment new source review requirements. The applicable emissions thresholds triggering major new source review in AQCR 115 are 50 tons per year for either VOCs orNOx.

The Baltimore Nonattainment Area 8-Hour Ozone SIP was submitted to the EPA in December 2012. If power generators are used, permits are not required before installing or modifying emergency generators powered by engines with less than 500 brake horsepower (COMAR 26.11.02.10). The Cross State Air Pollution Rule would require NOx reduction during the Ozone Season for any affected sources, such as boilers and generators.

Hampton Roads, VA, Alternative Hampton Roads, VA is part of the Hampton Rqads Intrastate AQCR 223. Current regional air quality is in attainment and no formal conformity review is required. If power generators are

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used, air permitting under Virginia's section 9 VAC 5 Chapter 80 could be required. The Cross State Air Pollution Rule would require NOx reduction during the Ozone Season for any affected sources, such as boilers and generators.

Philadelphia, PA, Alternative Philadelphia is located within the Philadelphia-Wilmington AQCR 45. Pennsylvania has adopted all of the NAAQS standards as well as several standards of its own including beryllium, fluorides, and hydrogen sulfide. _State standards, established by the PADEP, are termed the Pennsylvania Ambient Air Quality Standards.

The project area is classified as marginal nonattainment for the 2008 8-hour ozone standard, attainment for PM 2.5 standard. In addition, the Commonwealth of Pennsylvania is included in the OTR. If power generators are used, air permitting would not be required under Regulation:

25 Pa Code 127.14(a)(8). The Cross State Air Pollution Rule would require NOx reduction during the Ozone Season for any affected sources, such as boilers and generators.

Pennsylvania has an EPA approved SIP that is comprised of state air pollution control regulations as well as plans detailing methods to be used to achieve or maintain compliance with theNAAQS.

3.3.3 Environmental Consequences Estimated emissions from a proposed Federal action are typically compared with the relevant national and state standards to assess the potential for increases in pollutant concentrations.

Impacts would occur if the action alternatives directly or indirectly produce emissions that would be the primary cause-of, or would significantly contribute to, a violation of state or Federal ambient air quality standards. _Emission thresholds associated with CAA conformity requirements are another means of assessing the significance of air quality impacts. A formal

_ Conformity Determination is required _for Federal actions occurring in nonattainment or maintenance areas when the total direct and indirect stationary and mobile source emissions of nonattainment pollutants or their precursors exceed thresholds or de minimis values (Table 3-7 in Appendix A). Because two of the Proposed Action locations are in regions of moderate or marginal nonattainment or maintenance, a Record of Non-Applicability (RONA) has been prepared and is included as Appendix C of this EA.

Jhe Proposed Action would not combine with impacts from other past or future projects in such a manner that would create a cumulative impact.

Baltimore, MD, Alternative The Proposed Action would not result in significant impact to air quality as the action requires no construction and no dredging. The Baltimore, MD Alternative may not require towing of the vessel. However, any required towing operation would result in a minimal and temporary increase of marine vessel emissions. The potential towing of the ship qualifies as a "routine movement" by the EPA and is exempt from the requirements of the Conformity Determination Rule; according to 40 C.F.R. § 93.153(c), the towing qualifies as an action which would result in no emissions increase or an increase in emission that is clearly de minimis:

"(viii) Routine Movement of mobile assets, such as ships and aircraft, in homeport assignments and stations (when no new support facilities or personnel are required) to perform as operational groups and/or for repair or overhaul."

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Ship decommissioning activities could generate air pollutants that are regulated by the CAA. If a facility emits regulated amounts of air pollutants, it must obtain the appropriate operating permit and comply with all emissions requirements set forth in that permit.

Fugitive dust may be generated from tailpipe emissions caused by equipment and vehicles, but appropriate fugitive dust control measures would be taken. No open burning of ship materials would occur at the project area. Exhaust emissions from the transport of workers and machinery

. to/from the site and from decoD?missioning equipment would be considered de minimis.

OSHA has established exposure limits for various air contaminants that are considered toxic.

Complianc~ with OSHA requirements will minimize any impacts on worker safety.

No significant impacts to air quality can be attributed to handling, loading, and transportation of_

hazardous and radioactive mate.r;ials (see the STS-005-001 Radiation Protection Plan and waste_

management Section 3.4). Waste managem~nt activities would have no impact on non radiological ambient air quality and would not be expected to cause either radiological or non radiological air quality impacts to exceed state* or Federal standards, or to significantly affect air quality in any other respect at Baltimore, MD. Details of the air _quality impacts are provide_d in t~e GEIS 011 the deconuiJ.i~sio$g *of n11clear_ fa~ilities. _

The decommissioning of.NSS does not require construction or dredging activities, thus related

- air emissions would be minimal. - Moreover, emission of fuel/petroleum/combustible gases from ship decomtnissioning _activmes would_ be_ compl.iant with, all_ Federal an~_ state permit requirements: The decoimilissionihg;" of NS S would not represent a new or significantly different line of work for the shipyard, with different effects ori the environment, but rather a continuation of a long term, ongoing program, with minimal

• surrounding effect.* Relevant -air emissions would be lo_caljzed and of ~hort. duration. _ Th~re(m:e, implementation of the_ Baltimore,_ MD,

-Alternative :would not have a significant impacfon air quality.

-- - - -- Hampton Roads,- VA, Alternative The environmental air impacts of decommissioning at this location are comparable to those

• described in Baltimore, MD and are not repeated here;'

The Proposed Action would not result in significant impact to air quality as the action requires

- n:o "construction and no dredging. - Decommissioning activities are not expected to change the designation o_f the area with respect to NAAQS. _ Additionally, project activities that comply w_ith applicable rules and regulations would not significantly affect air quality.

Philadelphia, PA, Alternative Similar- to Baltimore, MD* and Hampton. Roads, VA, the Proposed Action would not result in significant impact to air quality as the action requires no construction and no dredging. In general, decommissioning activities could result in temporary minor, localized impacts to air quality, but are not expected to change the designation of the area with respect to NAAQS.

No-Action Alternative The No-Action Alternative would leave NSS at the Baltimore, MD facility. Under the No Action Alternative, the vessel would continue to be maintained in a protective storage condition (SAFSTOR). Therefore, no significant impacts to air quality would occur.

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3.4 Waste Management 3.4.1 Regulatory Setting Federal laws and requirements relating to waste management include: Resource Conservation and Recovery Act (RCRA) of 1976 (PL 94-5800), as amended by PL 100-582; USEPA, Subchapter I-Solid Wastes (40 C.F.R. § 240-280); Toxic Substances Control Act (PL 94-496);

USEPA, Subchapter R-Toxic Substances Control Act (40 C.F.R. § 702-799); and Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition (EO 13101). The proposed decommissioning would be completed in compliance with 10 C.F.R. Part 20.1402, "Radiological Criteria for Unrestricted Use." Hazardous Wastes are regulated under 42 USC 6901 (RCRA), and the DOT Hazardous Materials Program Procedures, 49 C.F.R. Part 107.

The License and Technical Specifications include additional waste management requirements.

These are implemented through Savannah Technical Staff (STS) procedures that cover waste management and will be applied during DECON-LT: STS 005-010 Free Release of Materials; STS-005-013 Radioactive Material Shipping and Handling; STS-005-020 Offsite Dose Calculation Manual; STS-005-022 Radioactive Waste Process Control Program; STS-005:-023 Low Level Radioactive Waste Management Plan; all;d STS-005-024 Mixed Waste Manage~ent Plan. All of these procedures are daught_ers to the STS-005-001 Radiation Protection Plan in their Health Physics ManuaL- STS-005-020 Offsite Dose Calculation Manual; STS-005-022 Radioactive Waste Process Control Program are required by the License Technical Specifications. Any changes to these procedures are required by the Technical Specification to be reported to the NRC annually:

The NRC GEIS (NUREG 1496) analyzed waste management and determined there would be no significant impacts from decommissioning activities.

3.4.2 Affected Environment The main hazardous material of concern is the generation of LLRW present on NSS. LLRW will be classified and compliant based on a selected disposal faci,lity's acceptance criteria and any applicable Federal and state regulatory requirements. Radioactive wastes that are sent to a commercial radioactive waste disposal facility (all but the DOE location) regulated by an agreement state or Federal government will be classified as required in 10 C.F.R. Part 61.55, Waste Classification, into the following four categories:

Class A- Low levels of radiation and heat; no shielding required to protect workers or Public; rule of thumb states that it should decay to acceptable levels within 100 years.

Class B- Has higher concentrations of radioactivity than Class A and requires greater isolation and packaging ( and shielding for operations) than Class A waste.

Class C- Requires isolation from the biosphere for 500 years; must be buried at least 5m below the surface and must have an engineered barrier ( container and grouting).

Greater Than Class C- This LLR W does not qualify for near-surface burial; includes commercial transuranic alpha emitting wastes that have half-lives greater than 5 years and activity concentration gre~ter than 100 nCi/g.

The NSS nuclear power plant was contracted by the former Atomic Energy Commission (AEC) as part of the original MARAD-AEC joint project to construct and operate NSS. Consequently, it is reasonable to predict that the DOE will find that there is a nexus, and that NSS waste may be

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eligible for disposal at a federal facility (WCS FWF). Radioactive waste being sent to a DOE facility is not broken into the waste categories as described above. The DOE manages waste consistent with DOE Order 435.1. LLRW is acceptable at DOE sites provided they have a "clear and unambiguous nexus" to a DOE-funded project, DOE-performed operation, DOE-owned material/waste, or project whose waste disposition is directed by statute. The FWF at WCS is currently operated under a State of Texas License and follows the classifications similar to those identified in 10 CFR 61.55.

Specifically, the following disposal sites will be evaluated based on availability, waste type eligibility, acceptance conditions and criteria, location with respect to decommissioning location, and costs of disposal:

• FWF at WCS, LLC (Andrews, Texas)

• CWF at WCS, LLC (Andrews, Texas)

• EnergySolutions, Inc. (Clive, Utah)

. A key consideration in the selection of the disposal site(s) is where the decommissioning ofNSS will take place and the associated costs for transportation and disposal fees for each option.

Because of compact agreements, only waste generated in certain states may be eligible for disposal at a specific disposal site. Each site selected has its own Waste Acceptance Criteria (WAC) that the decommissioning contractor will comply with and use to ensure proper certification for each waste shipment.

LLRW or hazardous waste (e.g., RCRA) will be properly packaged, removed and transported to the final disposal location. Additional details regarding how waste will be removed from NSS segregated and packaged according to waste type,. and shipped to a licensed disposal *site will be contained in the STS Procedures and the PS.DAR.

The Energy Solutions facility in Clive, Utah holds a State of Utah Radioactive Material License UT 2300249. Waste Control Specialists in Texas holds a LLRW Disposal License R04100 and a By-Product Material Disposal Facility License R05807. Waste Control Specialists operates a Compact Waste Facility i:is well as a Federal Waste Facility for the DOE.

In addition, other possible hazardous materials that may be removed include PCBs (mainly in electrical cables, gaskets, grout/caulking, and other electrical components), ACM (insulation materials and joiner work), LBP, mercury in electrical switches and other components, fuels, oils, lubricants, and some ozone depleting substances in refrigerants. The removal of hazardous materials from NSS is required to be in accordance with Federal, state, and local regulations.

The majority of materials would be recycled for beneficial reuse to the maximum extent practicable to reduce the use of local landfills or other disposal sites.

Baltimore, MD, Alternative This industrial location routinely works on vessels with various types of waste. The decommissioning requires that MARAD has all required permits and licenses to operate, adheres to safety procedures and waste management requirements, and follows all required regulations.

The EPA CERCLIS database contains information on hazardous waste sites, potentially hazardous waste sites, and remedial activities across the nation, including sites proposed fot the National Priorities List (NPL) or actually listed on the NPL (i.e. Superfund sites). The database currently lists 29 CERCLIS sites in Baltimore County, with 18 listed in the City of Baltimore, of which all but three are not NPL sites; those three are Colgate Pay Dump (part of an NPL site),

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Picorp - Operable Unit (part of NPL site) and RM Winstead Co (part of NPL site). No RCRA facilities are anticipated to be impacted by this project.

In addition to the Federal waste management regulations listed in Section 3.4.1, some of the applicable state laws and regulations that should be followed are: Code of Maryland Regulations (COMAR) 26.15 et. Seq., Disposal of Controlled Hazardous Substances - Radioactive Hazardous Substances; COMAR 26.16 et. Seq., Lead; COMAR 26.02 et. Seq., Occupational, Industrial, and Residential Hazards; COMAR 26.04 et. Seq., Regulation of Water Supply, Sewage Disposal, and Solid Waste; COMAR 26.10 et. Seq., Oil Pollution and Taruc Management; COMAR 26.13 et. Seq., Disposal of Controlled Hazardous Substances; and COMAR 26.14 et. Seq., Hazardous Substance Response Plan.

Hampton Roads, VA Alternative This industrial location routinely works on vessels with various types of waste similar to the Baltimore, MD location discussed above.

Local areas listed in the CERCLIS database include Fort Eustis, which is an NPL site; Patrick Henry Airport in Newport News City; and Goodwin Jun1cyard in Isle of Wight County. Neither Patrick Henry Airport nor Goodwin Jun1cyard is an NPL site. Numerous sites are listed in the RCRA online database that generate, store, transport or dispose of hazardous wastes, including stores and various companies- such as dry cleaning, sign manufacturing, natural gas distribution, as well as ship facilities in Newport News. None of these sites are anticipated to be impacted during this project.

Wastes that are generated during qecommissioning must be characterized, tested (as necessary) and disposed of in accordance with applicable Federal, state, and local laws and regulations.

While it is not anticipated that any impacts to soil will occur_ as a result of the Proposed Action,

• any soil that is suspected of contamination must be managed in the same manner described for wastes above. In addition to the Federal-waste management regulations listed in Section 3.4.1, some of the applicable state laws and regulations that should be followed are: Virginia Waste Management Act, Code of Virginia Section 10.l-_1400 et seq.; Virginia Hazardous Waste Management Regulations (VHWMR) (9VAC 20-60); Virginia Solid Waste Management Regulations (VSWMR) (9V AC 20-81 ); Virginia Regulations for the Transportation of Hazardous Materials (9V AC 20-110).

Philadelphia, PA, Alternative This industrial location routinely works on vessels with various types of waste similar to the Baltimore, MD location discussed above. The EPA CERCLIS database lists 49 CERCLIS sites in Philadelphia County, of which all but one are not NPL sites; the one is Fran1clin Smelting (part of NPL site). The RCRA database lists numerous facilities that generate, store, transport or dispose of hazardous wastes in Philadelphia. None of these sites are anticipated to be impacted by this project.

In addition to the Federal waste management regulations listed in Section 3.4.1, Pennsylvania has well developed environmental regulations that governs waste management activities within the state, administered by the Department of Environmental Protection (DEP). In addition to the Federal waste management regulations applicable state laws and regulations that include: Solid and Municipal Waste Management (Article Vill. 25 PA Code, Chapters 271- 285)), Recycling and Residuals Management (Article IX. 25 PA Code, Chapters 286-299)), and Hazardous Waste Management and Transportation (Article VII. 25 PA Code, Chapters 260-270).

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3.4.3 Environmental Consequences The STS procedures discussed in Section 3.4.1, together with the NRC license Technical Specifications governing radiological releases provide the controls necessary to prevent the spread of contamination, and therefore no significant release of airborne or liquid contamination is anticipated during decommissioning activities. The decommissioning requires environmental monitoring to ensure controls are adequate to protect human health and the environment. Waste material generated during decontamination activities would be managed to minimize disposal volumes arid take aclvantage of- opportunities to segregate wastes/debris for any non contaminated disposal or recycling. Worker radiation exposures would be limited in accordance with 29 CFR 1915 and 1917,' as well as the STS Procedures discussed* in Section 3.4.1.

Characterization of waste for radiological and non-radiological hazardous constituents will assure waste is acceptable for off-site disposal. All wastes generated would be disposed of according to Federal regulations at one of the approved regulated/permitted facilities discussed previously in Section 3.4.2.

In considering the Proposed Action Alternatives, the effects at the facilities would be the same regardless of which alternative is chosen. The-Proposed Action would not combine with impacts from other past or future projects in'such a manner that would create a cumulative impact.

Baltimore, MD, Alternative Considering compliance with all Fed.era! and state regulations, gu_idelines, and agreements, the decottfinissioniilg activities are not expected to have significant -impacts due to waste management Hampton Roads~ VA, Alternative

- - * , s - -

Considering c9mpliance with all Federal and state regulaticms, guidelines, and agreements; the towing of the vessel to the Hampton Roads, VA decommissioning facility, and the subsequent decommissioning- activities- are *not *expected -to have significant impacts due to- waste management.

Philadelphia, PA, Aiternative Consi_dering compliance with all federal and state regulations, guidelines, and agreements, the towing of the vessel to the Philadelphia, PA decommissioning facility~ and the subseqtierit decommissioning activities are not expected to have significant impacts due to waste management.

No-Action Alternative Under the No-Action Alternative, NSS's nuclear power plant would not be decominisioned arid there would be no significant impacts as a result of this action.

3.5 Health and Safety 3'.5.1 Regulatory Setting Federal regulations for protecting health and safety include OSHA (29 C.F.R.), and 10 C.F.R. 20, "Standards for Protection Against Radiation," The proposed decommissioning would be completed in compliance with 10 C.F.R. Part 20.1402, "Radiological Criteria for Unrestricted Use," as implemented in STS procedures. Additionally, STS safety and h~alth programs adhere to OSHA regulations, and will be implemented during decommissioning activities.

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3.5.2 Affected Environment MARAD is responsible for ensuring that NSS remains in compliance with the NRC license that incorporates by reference NRC regulations to ensure adequate protection for worker and public health and safety and protection of the environment. For individual ports, the US Coast Guard and the Port Authority, or similar office, usually maintain health and safety plans as well as emergency response plans for the port area. They are often responsible for inspecting commercial vessels. for compliance with Federal laws and regulations, responding to oil spills and hazardous material releases into the marine environment, enforcing safety and security zones, investigating marine casualties such as collisions, groundings, and fires, issuing licenses and Mariner's documents to merchant seamen; and monitoring the transfer of bulk liquid products at marine facilities. Vessel movements in port areas, such as vessels under tow or under control of the Port Pilots must comply with these regulations. MARAD is responsible for ensuring that the towing of NSS is in compliance with all US Coast Guard and Port Authority requirements.

The Proposed Action involves only the removal, transportation and disposal of regulated materials. Transportation corridors are disturbed areas, no construction is planned, and transportation will be conducted in accordance with regulations* such as NRC, DOT, and applicable state requirements; minimal impacts to health and safety via transportation are anticipated. Waste disposal locations are regulated and licensed to ensure no impacts to health and safety.

Each of the alternatives has similar affected environments with regards to health and safety. All of the locations considered are governed by the same Federal and very similar state regulations to ensure minimal to no impacts to health and safety. - -

3.5.3 Environmental Consequences The decommissioning also requires environmental monitoring to ensure controls are adequate to protect human health and the environment. The NRC !icense Technical Specifications require radiol9gical _re_lease an~ control program~_ including: a) a Process Control P!ograin; b) mfOffsite Dose Calculation Manual; c) a Radiological Effluent Control Program (gaseous and liquid); and d) a Radiological Environmental Monitoring Program. These license programs are embedded within the STS procedures *described in Section: 3.4.1, and will be implemented during decommissioning. No significant release of airborne or liquid contamination is anticipated during decommissioning activities. Waste material would be managed to minimize disposal volumes and to maintain proper containment of hazardous materials. Worker radiation exposures would be limited in accordance with 10 C.F.R. Part 20. Additionally, actions would comply with a site-specific Radiation Protection Program in order to minimize all radiation exposures to both workers and the public.

The decommissioning work would be completed by trained workers who will ensure that all waste is contained to prevent release to the off-site environment. According to NRC, the exposure to occupational workers for this kind of activity is considered minor (NRC 1988).

Public exposure to radiation would be significantly less than that of workers and meet requirements identified in the decommissioning permit. The radiation dose to. the public from the transportation of radioactive wastes is estimated to be minor, if at all, and considerably below the average background levels of radiation; thus impacts are expected to be negligible.

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Inhalation is considered the dominant exposure pathway for public radiation exposure from naturally occurring radioactive materials. According to NRC's GEIS on decommissioning, the inhalation radiation dose to the public from airborne radionuclide releases during decommissioning of nuclear facilities in general is estimated to be negligible (NRC 1988).

These minor adverse exposures to the public would be offset by the beneficial impacts of permanently removing the waste from the vessel and properly disposing of it and other waste materials.

The NRC GEIS has analyzed decommissioning activities and determined that there would not be significant impacts to health and safety. In considering the proposed alternative locations, the effects would be the same regardless of which alternative is chosen; though varying populations may be exposed.

Considering compliance with all Federal and state regulations, guidelines, and agreements, the removal of the vessel from Baltimore, MD, towing to facilities, and the decommissioning activities are not expected to have significant impacts on health and safety. The Proposed Action would not combine with impacts from other past or future projects in such a manner that would create a cumulative impact.

No-Action Alternative Under the No-Action Alternative, NSS would not be decommissioned. MARAD would continue to monitor and maintain the vessel. NSS would continue to age, posing an increasing threat to the environment over the long-term. The increased threat will likely increase costs for MARAD to ensure protection of human health and the environment.

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4. CUMULATIVE IMPACTS I

Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 C.F.R. § 1508.7). To be considered cumulative impacts, the effects *must meet the following criteria: the effects would occur in a common locale or region; the effects would not be localized (i.e., they would contribute to effects of other actions); the effects would imp~ct a particular resourc~ in a similar manner; and the effects would be lo:µg term (short-term impacts are temporary and would not typically contribute to significant cumulative impacts).

Federal regulations implementing NEPA (42 U.S.C. 4321 et seq.), DOT Order 5610.lC and Maritime Administrative Order MAO 600-1, require that the cumulative impacts of a Proposed Action be assessed. The CEQ regulations implementing the procedural provisions of the NEPA define cumulative impacts as: "The impact on the environment- which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future action!; r~gardless 9f what_ agency (Federal or non-Federal) or person undertakes such other actions;" (40 C.F.R. § 1508.7)

To analyze cumulative impacts, a cumulative impacts region must be identified for which the Proposed Action and *other: past,. proposed, and reaSoriably foreseeable actions would be

• cumulatively recorded or experienced. Consequently, the area of potential effects where cumulativ~ imp~cts may occur consists of three-locations that include Baltimore, MD, as*well as the two. additional potential decommissioning locations. Therefore,_ this. analysis considers

, impacts arising, from* the Proposed Action combine~ -~ith the impacts. of other known past; present, ~4 reasonal?Jy foreseealJl~ futµre ~ctio_ns w~thin_ tp.e !egions des_ctib~d below.

4.1 Baltimore; MD There . have*-been*-*dozens of* vessels, including Navy, MARAD: and *commercial *vessels;*

dismantled to_ certain_ degrees in Bijltimore, M:O, at_ facHities that were c_apable J:>f dismantling Jn\\.lltjple ves~els"*at_a Jim.e, *rraoepointAtlan.tic, which wi;i.~_ Sp~ows Point Terrn.ip.al until 2016 and was a former steel mill, is a 3,250-acre multimodal industrial site and current EPA remediation site that plans to deepen their berths and channel 10 to 15 feet. Port Covington, a inostly indllstrial 235-acre area in South B_altimore with three _n1_iies of waterfront, Is currently one of the largest urban redevelopment projects in America. These projects would potentially have a more significant impact on the project area than the DECON-LT. The Proposed Action and reasonably foreseeable projects would not likely be occurring at the same time in the same area. Therefore, their cumulative effect would not be significant.

4.2 Hampton Roads, VA _

Hampton Roads, VA facilities routinely conduct ship construction, repairs and upgrades, as well as scheduled and emergent maintenance work. New nuclear-powered aircraft carriers are currently under construction. There have been numerous government and commercial vessels constructed and deactivated in this location. USACE recently approved the Wider, Deeper, Safer project to dredge and deepen the channels to 55 feet and widen them for two-way traffic ofultra large container vessels; the project is expected to complete in 2024. These ongoing activities and projects would potentially have a more significant impact on the project area than the DECON LT. The Proposed Action and reasonably foreseeable projects would not likely be occurring at the same time in .the same area. Therefore, their cumulative effect would not be significant.

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4.3 Philadelphia, PA The Port of Philadelphia is currently deepening the Delaware River channel from 40 feet to 45 feet mean low water and is expected to be completed at the end of 2018; the Port is also obtaining five super post-Panamax cranes, of which two have already arrived, as part of the Port Development Plan. This project and the resulting increase in marine traffic would potentially have a more significant impact on the project area than the DECON-LT. The Proposed Action

.- and reaso-nably foreseeable projects would not likely be occurring at the same time in the *same area. Therefore, their cumulative effect would not be significant. *

• 4.4 Environmental Analysis The Proposed Action generally would have a lesser impact to* the project aiea than existing or completed nearby construction and dismantling projects: Other projects in the same locations are generally larger in scope than the Proposed Action, and have their own environmental analysis.

Past and ongoing dredging projects would not to have a significant effect on the environment, individually or cumulatively. Below, cumulative impacts are discussed within each impact area.

pue to the fact that the NSS would be towed and its nuctear power plant decommissioned at a

.commercial facility. with no construction required and the vessel access.would .be controlled and limited, the project .. would haye no impact on land use,. geology,- soils and- seismicity,.

socioeconomics and environmental justice, transportation; noise,. utilities, aesthetics and visual resources. Therefore, it would have no cumulative impacts on these resources when considered with other-projects'. * * * * -

• 4.4.1 Water Resources - .. . .

The Proposed Action would cause temporary impacts to water quality as a result of increased

. iiiioidity:*:froin iefwiiig. However;_*. when*. considered with dr~dging* proj~cts:* a~d other in-w~ter work, the Proposed Action would not significantly impact sediment or water quality~ Towing proceclures would-*be* implemented. to avoid sediment disturbaiice ... Therefore,* the Proposed_.

Action wouJd nothave a cumulative impact when considere_d with thes~ proje9t!;,.

Otliet projects in the region could produce minor discharges. that would flow inter surface drainages and eventually to the marine environment. However, these projects would also be required to comply with applicable Federal, state, and. local_ regulations, as well as general and construction stormwater permits. These mandated requirements would reduce potential impacts on water quality to less than significant levels. Therefore, the cumulative impact on water resources would reflect several actions with individual effects that are not significant. The Proposed_ Action and reasonably foreseeable projects would not likely be occurring at the same time, in the same area. Therefore, the Proposed Action would not have any cumulative* impact when considered with these projects.

4.4.2 Biological Resoul'.'ces The Proposed Action would not significantly affect marine biological resources.

• Due to the limited scope and local area of the impacts associated with the other identified projects there would be no significant cumulative impacts on biological resources. The Proposed Action and other projects would have the potential to temporarily affect marine species and their habitat, including sea turtles and marine mammals, but there would be no significant impact on these species because they are highly mobile and able to a:void the disturbance area. Moreover, these projects-would not likely be occurring at the same time in the same area. No in-water work is

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planned in the project area. No cumulative effects due to towing are anticipated. No cumulative impacts to biological resources are anticipated.

4.4.3 Air Quality Impacts resulting from project emission sources, in combination with impacts from any past and reasonably foreseeable future projects, would not have any cumulative impacts. Temporary and minimum impact to air quality would occur during decommissioning activities. However, the Proposed Action and reasonably foreseeable projects would not likeiy be* occurring at the same time in the same area, so potential impacts would be moderated over time_ and space.

Additionally, ambient air quality is expected to return to the original condition upon the

.completion of each project. As a result, the Proposed Action would not have cumulative impacts to air quality when considered with other activities in the project area.

4.4.4 Waste Management Other projects, specifically shipyard dismantling actions, could produce hazardous waste.

However, these projects would also be. required. to comply with applicable Federal, state, and lc;,c.~I, regulation,s. .A4<;litionally, tJ;ie .d~CQ11)11lis~ioning"*perinit will identify limits for release "of materials ~d radioactive waste disposal site~ are_ sulJject to strict siting, maintenance, and

µionitoring criteria. _Thi;_se mandated requirements_ would reduce po_tentiaJ i_mpac(s to le~s than significant levels. Therefore, the cumulative impact would reflect several actions with individual ef(~cts that are* not significant.:. As a result, thtf Proposed Actiori would not have any ctin;mlative impact ~~eri_ con&idered with thes~ projects .

.-

• 4A:5 *aealth and Safety

• 0th.et proj~cts *tn the region h~ve- the potential fo produce mi!f<>r-impact~ t6 _health and safety.

However, these projects would also be required to comply with applicable Federal, state, and local regulations;---These mandated requirements would *reduce-potential "impacts on health and safety _to less than. significant levels. Therefore, the cumulative impact would reflect several actions with individual effects that are not significant. As a result, the Proposed Action would not have an_y cumulative impact when considered with these projects.

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5. OTHER CONSIDERATIONS REQUIRED BY NEPA 5.1 Possible Conflicts between the Proposed Action and the Objectives of Federal, State, Regional, and Local Land Use Plans, Policies, and Controls Implementation of the Proposed Action would comply with existing Federal, state, regional, and local regulation, policies and programs .. The Federal acts, EOs, po!icies, and plans that apply

- include the following: NEPA; CAA and-Federal General Conformity Rule; CW A; CZMA; ESA; MBTA and EO .13186; MMPA; NHPA; and EO 12372, Coordination with state and regional agencies .. Applicable state, local, and regional plans, policies, and controls include: state Coastal Zone Management Programs; state ESAs; and the relevant AQCR rules and regulations. . -

5.2 Federal Acts, Executive Orders, Policies, and Plans

• National Environmental Policy Act This EA has been prepared in accordance with the NEPA of 1969, 42 U.S.C. §§ 4321-4370d, as implemented by the CEQ regulations, 40 C.F.R. §§1500-1508, DOT Order 5610.lC and Maritime Administrative Otder*MA0'600_-L EO 11991 of 24.May 1977 directed the CEQ to

--issue regulations for procedural -provisions of the -NEPA; *these are binding for all federal agencies.

The NEPA, and tiie implementing regulations promulgated by the CEQ, require that

_ enviro:pmental information i~- mad_e available to*_ deGi~ion makers and citizens _ befor~, making

• decisions and taking *major Federal actibnS,, and that the NEPA process should identify and

.,aS,sess: effects. - - - *- - * - - - -

• ieasQnable alternatives to Proposed ActipnS, to avoid or-rp.in,imiz.e adverse eiivirontJ1(;:ntal

- Clean Water Act -

__ The 1'.edera!CWA was e1.1acted as_anmn.e11dment_to thC;?_Federal Wetter Po1lt1tion Gontrol Act of 1972~\\vhfoh *outlined-tlie basic structure for regulating discharges *of polhitants to waters cit' the

- U.S: The-CW A includes programs addressing both point source--and nonpoint source pollution, and empowers the states to set state-'specific water quality standards and to* issue permits containing effluent limitations for point source discharges. Maryland, Virginia, and Pennsylvania are the delegated permit authorities in the project area. The states administer point source. discharges of pollutants through. an -EPA-approved Program. Indirect industrial discharges of effluent to publicly owned -treatment works are subject to pretreatment standards promulgated by the EPA and the state.

Clean Air Act and General Conformity Rule The CAA of 1955 and subsequent amendments specify regulations for control of the nation's air quality. Federal and state ambient air standards (NAAQS) have been established for each criteria pollutant: SO , CO, PM . , NO, lead, and 0. National emissions standards

2 10 and PM2 5 2 3 were set for individual sources of hazardous air pollutants as well as regulation of mobile sources of air emissions and a permit program for stationary sources. The results of the air quality analysis determined that the emissions associated with the Proposed Action would not contribµte to_ an exceedance of an ambient air quality standard.

Achieving CAA standards is the responsibility of the states. Each state must develop SIPs that outline to the EPA how it will achieve and maintain the standards. SIPs implement CAA programs such as the Title V operating permit, new source performance standards (NSPS), new source review, and national emission standards for hazardous air pollutants (NESHAPs) at the

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state and local level. States may require pollution control and prev~ntion standards .that are more stringent than those mandated by the EPA, but may not allow measures that are less stringent.

Federal agencies must comply with the requirements of Federal, state, interstate, and local air pollution regulations.

The CAA requires Federal actions to conform to the goals of the applicable SIP before proceeding with the action. MARAD has determined that this Proposed Action would conform

- to- the SIPs. A RONA is included as Appendix C of this EA. - -

Coastal Zone Management Act The CZMA of 1972 requires that Federal actions that affect any land or water use or natural resource of the coastal zone must be consistent to the maximum extent practicable with the state program. State CZMA programs include point and ncin-point source pollution control, flood control, sediment control, grading control, and stormwater runoff control. Maryland, Virginia, and Pennsylvania have prepared Federally-approved CMPs, which are known as the Virginia Coastal Zone Management Program, Maryland Chesapeake and Coastal Program, and

- Pennsylvania Coastal Resources management Program respectively. Pursuant to Section 307( c) of. the CZMA, the decommissionjng of NSS's- nuclear power plant would not affect the coastai

~one. MAAAD- has determined that_ the Proposeq Action-would be consistent to the maximum

• extent practicable with the enforceable policies of the three state programs .and permits and practic_es already est~~lished.

• Endangered Species Act

• The ESA *of 1973 and subsequent amendments provide for the protection of threatened and endangered -species of fish; wildlife, and plants and their -habitats:

• The act requires Federal age~cies to ensure Jh~t n_o age_ncy acti9_n -i,s likely to j,eopardize the -_c_ontinued existence of enoangered or threatened specie~. The ESA prohibits-Federal-agencies from taking any action that woul~ adversely affect any endang,ered :or threatened _species, or _critical habitat. The ESA

• prohibits all persons subject to U.S. jurisdiction, including Federal agencies, from "taking"

- endangered species. The taking prohibition includes any- harm or harassment, and applies within *

• the u:s:* and on fhe high seas. MARAD-has-concluded that the Proposed Action inay affect but is not likely to adversely affect sea turtles and would have no effect on other threatened or endangered species.

Migratory Bird Treaty Act Marine birds are protected under the MBTA and Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, which direct Federal agencies to avoid or minimize adverse effects on migratory birds, to protect their habitats, and to consider effects on migratory birds in NEPA documents. MARAD has determined that the Proposed Action would have no reasonably foreseeable takes and would have no effect on migratory birds.

Marine Mammal Protection Act The 1972 MMPA established a Federal responsibility to conserve marine mammals with management vested in the Department of the Interior for sea otter, walrus, polar bear, dugong, and manatee. The Department of Commerce is responsible for cetaceans and pinnipeds, other than the walrus. With certain specified exceptions, the Act establishes a moratorium on the taking and importation of marine mammals as well as products taken from them, and establishes*

procedures for waiving the moratorium and transferring management responsibility to the states.

The law authorized the establishment of a Marine Mammal Commission with specific advisory

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and research duties. The analysis provided in this EA concludes the Proposed Action would have no reasonably foreseeable takes of marine mammals (i.e., cause harm or harassment of any marine mammals) and may affect but is not likely to adversely affect marine mammals. The Proposed Action would comply with the MMP A.

• National Historic Preservation Act The NHP A was passed in 1966 to provide for the protection, enhancement, and preservation of those properties that possess significant architectura( archaeological, historical, or cultural characteristics. 36 C.F.R. Part 800 further defined the obligations of Federal agencies concerning this act.

Section 106 of the NHPA requires Fedenil agencies to take into account the effects of their undertakings on historic properties qualifying for inclusion in or eligible for listing in the* NRHP and afford the Council a reasonable opportunity to comment on such undertakings. An

. undertaking is defined as a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out on behalf of a Federal agency; those carried out with Federal financial assistance; and those requiring a Federal permit, license, or approval. The governor of.each state .or.territory appoints, a SHPO who.is respqnsible for administering cultural .res_ources programs within_ a given jurisdiction, and

. MARAD

• initiates consultation. procedures* with tlie respective SHPO. in accordance with the NHPA.

The NSS w_as designated a NHL in i99L SectJ.off 110 of the NHPA_r~qufresthat Federal owners

• of NHLs must, to the maximum extent possible, undertake such planning and actions as are*

necessary to* minimize harm to the landmark:*

• MARAb has consistentiy "applied the minimize h~- standard to all of its _(vessel)-_ decommissioning.phmning efforts. The Proposed A9tio11 would not adversely affect ariycultural resources besides the vessel itself:

Executiv"t~' Order 123 72 EO 12372, Intergovernmel1tal Review_ of Federal Programs, w.as issued in 1982 in order to foster an intergovernmental partnership and. a. strengthened federalism by relying. on state. and local processes for the state and local government coordination and review of proposed Federal firnmcial assistance and direct Federal deyelopment.

MARAD pursues close and harmonious planning relations with local and regional agencies and pianning commissions of adjacent cities, counties, and states for cooperation and resolution of mutual land use and environment related problems. In preparing this EA, relevant data from state, regional, and local agencies were reviewed in order to determine regional and local conditions associated* with the Proposed Action. With respect to the Proposed Action, no mutual land use or environmental issues require resolution.

5.3 State, Local, and Regional Plans, Policies, and Controls State Coastal Zone Management Program MARAD has determip.ed that there is no effect on the coastal zone. The project is consistent with the Maryland and other state CMPs.

State Endangered Species Acts Although state ESAs do not apply to Federal actions, some state-listed species are addressed in this document. MARAD has concluded that there would be no effect from the Proposed Action on species covered under the st~te ESAs.

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Air Quality Management District Rules and Regulations The Proposed Action air emissions would comply with all applicable AQCR rules and regulations.

5.4 Energy Requirements and Conservation Potential of Alternatives Including the Proposed Action and All Mitigation Measures Being Considered The Proposed Action would not result in any additional energy requirements above the current

-routine operations of the industrial facilities-. Therefore, -no -mitigation and/or monitoring measures will be implemented.

5.5 Irreversible or Irretrievable Commitment of Natural or Depletable Resources The NEPA requites an analysis of significant, irreversible effects resulting from implementation of a Proposed Action. Resources that are irreversibly or irretrievably committed to a project are those that are typically used on a long-term or permanent basis; however, those used on a short-_

term basis that cannot be recovered ( e.g., non-renewable resources such as metal, wood, fuel, _

paper, and other natural or cultural resources) are also irretrievable. Human labor is also conside_red an irretrievable*-resowc¢. All_ suc4 fesQur¢es are i:,;-r~trievable in that they are _used fQt  :

one project ~d thu~ b_ecome ,1¥1avail_able for_othe! purposes. __ An impact that falls under the c_aJegory of the irreversible or irretrievabJ~ C01ll,Illitm~nt o( r~sowct?~ is the destruction of n~tural resources that could limit the range of . . - -- ** potential uses of that resource.

- 1:mplerrientatioh of the-Proposed J\\ction would i*estih in an-irreversible co:rrimitinent of fuel for decommissioning, human labor,_ and other resources.- - These commitments of resources are neither unusual nor fuiexpected, given the nature of the action.

The Proposed ~ction would not result in the qest.n)ction_of envifoninerttal resources stich th~t the.

range of potential uses of the environment would be limited, rior affect the biodiversity of the

'- - region.

• 5.6 Relationship between Local Short-Term Use of the Human Environment and Maintenance and Enhancement ofLong.;.TermNatural Resource Productivity The NEPA requires consideration of the relationship between short-term use of the environment and the impacts th~t such use- could- have on_ the riiaintenance and enhancement of long-term productivity of the affected environment. Impacts that narrow the range of beneficial uses of the environment are of particular concern. Such impacts include the possibility that choosing one option could reduce future flexibility to pursue o_ther options, or that choosing a certain use could eliminate the possibility of other uses at the site.

Implementation of the Proposed Action would not result in any such environmental impacts because it would not pose long-term risks to health, safety, or the general welfare of the communities surrounding the project area that would significantly narrow the range of future beneficial uses. In addition, biological productivity would not be affected as implementation of the Proposed Action would not result in cumulative impacts to any biological resources.

5.7 Means to Mitigate and/or Monitor Adverse Environmental Impacts The Proposed Action would result in only one potentially significant environmental impact: the decommissioning of the vessel's nuclear power plant. Therefore, the only mitigation and/or monitoring measures that will be implemented are those that will be stipulated in the

April 2019 5-A

55 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

.Supplemental EA for Decommissioning of NS SAVANNAH

Programmatic Agreement between MARAD, the NRC, the National Park Service, the Advisory Council on Historic Preservation, and the Maryland Historical Trust, which serves as the SHPO.

5.8 Any Probable Adverse Environmental Effects that cannot be A voided and are not Amenable to Mitigation This EA has determined that the Proposed Action would not result in any significant immitigable impacts; therefore, there are no probable adverse environmental effects that cannot be avoided or are not amenable to mitigation. * -

• April 2019 5-5

56 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

6. CONCLUSION Overall, no significant environmental impacts are expected to occur as a result of the Proposed Action. NSS is listed in the National Register of Historic Places. Through consultation with the NRC, the National Park Service, the Advisory Council on Historic Preservation, and the Maryland Historical Trust, which serves as the SHPO, a Programmatic Agreement will be implemented as mitigation efforts for DECQN-.LT, MARAD is in the process of finalizing the details of the PA, which will formally document" the agreed upon mitigation measures required

• for Section 106 compliance.

The Proposed Action would comply witli all Federal and state regulations, guidelines, and agreements. All .Proposed Action Alternatives are enviromnentally equal. However, Baltimore, MD is the Preferred Alternative because the vessel is already there and may not need towing.

There would be minor differences with respect to towing distances and waste transportation and disposals depending on the alternatives; however, none of the differences would produce significant impacts. Based on the findings from this EA, a FONSI shall be prepared.

r

April 2019 6-1

57 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

APPENDICES

A-1

58ofl10 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

- .APPENDIX A

- FIGURES AND TABLES

A-2

59 of 110 CR- 137 , Suppleme ntal Env ironmenta l Assessme nt and Find ing ofNo Significant Impac t APPENDIX A Figu res and Table s

Howvl\\OA.,. j- *- *-

1-'o,i McHenry runnel I jl !

I NorthwUI HltbO(

• X N.S . Savannah

600 yds P I I I p s C o

Figure 1.1 - NS SAVANNAH at Baltimore, MD

60 of 11 0 C R - 13 7, Supp le m ent al Env ironme nta l Assessm ent and F ind ing ofNo Sig nificant Im pact APPENDIX A Figu res and Tables

Philadelphia, PA

• • -

• Alternative Location

Baltimore, MD

• Current Location

n Roads, VA tive Location

so 100 150 miles I

Figu re 2.2 - Project Area Map with Alternatives

61 of l JO CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact APPENDIX.A Figures and Tabl es 1

Table 2-1. Summary of Impacts

Resource Baltimore, MD, Hampton Roads, Philadelphia, PA, No-Action Area Alternative VA, Alternative Alternative Alternative Cultural No adverse effects No adverse effects - No adverse. effects -* No adverse Resources on Other cultural on other cultural on other cultural effects resources. resources. resources.

Water Minimal adverse Minimal adverse Minimal adverse No significant Resources impacts impacts impacts impacts Biological

• No reasonably

• No reasonably

• No reasonably No significant Resources foreseeable takes are foreseeable takes are foreseeable takes impacts

. expected for marine - expected for marine are expected for mammals. mammals.* -* marine mammals.

.. Essential * - No effect on '* ** No effect on

• No effect oh Fish Essential Fish* Essential Fish

.. - - - , Habitat .. . Habitat. ---- Habitat . ** -

.* lnsiiinificant -- --- l\\fo Air Quality - -insignificant - -- - lnsfgnificant impads --

temporary impacts temporary impacts temporary impacts . '

WpsJe N9 significant --  !"Jo s.ignifjcan~ f\\Jp signi_fican~ N~ impact~

_ Management - impacts .impacts: - _. impacts

-- N,5" significanc -.. ,*.- NO-significant ***-* Nc5 significant --- .. :No impacts

• Health and ..

Safoty impacts irr1pacts impacts -

- .. - - - -- . - --- - -. -* -* ---* -- -- - -- ,. ~ - .

62 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact APPENDIX A Figures and Tables

Table 3-1. Threatened and Endangered Species List for Baltimore, MD

Common Name Scientific Name Status Listing

MAMMALS

North Atlantic: right whale Euba/aena g/acialis E Federal, Maryland

Humpback whale Megaptera E Federal, Maryland

novaeangliae

Fin whale Balaenoptera E Federal, Maryland .

physa/us

Sperm whale Physeter E Federal*, Maryland

macrocepha/us

• Seiwhale' _ Ba/aenop{era bo;ealis E _ :Feaeralll<, Maryland

Kemp's ridley sea turtle Lepidochelys kempii E ** Federal,* Maryland

-Gr~en .~eaJ~itle - T

.Leatberback sea . .tur:tle * * . - *

• Dermoche/ys cor:icea .. * ,E .. : -  : Federal, Maryland -

FISH --- ... -- . - - .. - . . .

Shortnose sturgeon Acipenser E Federal, Maryland

. - brevirostrum **-

BIRDS* ...

Peregrine falcon Falco peregrinus N Maryland

Bald eagle Haliaeetus w Maryland (for breeding

leucocepha/us species)

E = Endangered, T = Threatened, N = Species in need of conservation, W= Watch List

• Found in deep ocean water

63 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact APPENDIX A Figures and Tables

Table 3-2. Threatened and Endangered Species List for Hampton Roads, VA

Common Name Scientific Name Status listing

REPTILES.

Hawksbill sea turtle Eretmochelys E Federal, Virginia

- . " imbricata -

Kemp's ridley sea turtle Lepidochelys kempii E Federal, Virginia

Green sea turtle Chelonia: mydas -r - Federal, Virginia

Leatherback sea turtle Dermoche/ys coricea E Federal, Virginia

E = Endangered, T = Threatened

• Table 3-3. Threatened and Endangered Species List for Pennsylvania location

• - Common Name

• Scientific Name

FISH.

Shortnose sturgeon Acipenser brevirostrum E Federal, Pen-nsylvania . -

Atlantic sturgeon Acipenser oxyrhynchus T Proposed listed .-. . .. . .. . - . Federal, f>e,nr:isylyania_

.. Umbra pygmaea* - .. E --- -Pennsylvania . - ..

Eastern mudminnow Threespirie stickleback - -* Gastero$te'us aculeatus C Pennsylvania - "

REPTILES

Red-bellied turtle Pseudemys rubriventris T Pennsylvania

AMPHIBIANS

New Jersey chorus frog Pseudacris feriarum kalmi E . Pennsylvania

Coastal Plain leopard frog Rana utricularia E Pennsylvania BIRDS -

Peregrine falcon Falco peregrinus E Pennsylvania

.E = Endangered, T = Threatened, C = Candidate

64 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact APPENDIX A Figures and Tables

Table 3-2. Biological Resource Impact Summary

Environmental Feature ' ' Baltimote MD ' * : H~mptci~.Road~, VA ,>*f>hiladelphia, PA;  ;

• ,,/ ;.Aite;n~;i~~ *' ' . '*. .' Alternative " ' ' Alteth~tive ,;: *

• * *:, * *,,1*- ,.~  : - <>,  :~c ~ ' * ' O' n* ** ,; )'., *  ;,- * * ,'I ~  :- "> * *~ *,

., . ~  ;, '  ; ' .. *- .. ,

Wetlands No impact No impact No impact

Benthic Communities Temporary impacts Temporary impacts Temporary impacts

Temporary impacts to Temporary impacts to Temporary impacts to Fish and Essential Fish Habitat unprotected fish; no unprotected fish; no unprotected fish; rio effect on EFH effect on EFH effect on EFH

May affect but not likely May affect but not May affect but not to adversely affect and likely to adversely likely to adversely Protected Species no reasonably affect and no affect and no foreseeable takes reasonably fore~eeable reasonably takes foreseeable takes

Table 3-3. Ap~licable Criteria Pollutant de minimis Levels (Tons/Year) for Alternative Locations (40 C.F.R. § 93.153)

Location voe* NOx PM2.5

Baltimore, MD 50 100 100

Hampton Roads, VA -- - .. --

Philadelphia, . . ... PA - 50 100 100

65 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

APPENDIXB REGULATORY COMMUNICATION

B-1

66 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Stakeholders Sent Regulatory Notification Letters

Virginia:

Jeffrey D. Stern, Ph.D., State Coordinator Virginia Dept of Emergency Management

- 10501 Trade Court Richmond, VA 23236-3713 PH (804)897-6501 FX (804)897-6506 Attn: J eff.Stern@vdem.virginia:gov

-Steve A. Harrison, Director Division of Radiological Health Department of Health-James Madison Bldg.

1Q9 Gover:rtor Street, Rm 736

-Richmond, VA 23219 PH (804)864-8151 FX (804)864--8155 attn: steve.harrison@vdh.virginia~gov -

- :stephanie Nash U.S. Fish and Wildlife Service 5275 Leesburg Pike,

-- {703)  :}5*8~1896 --Falls Church, VA 22041

- _ Attn: S.tephanie_Nash@fws_.gov

Christy J ohnsori-Hughes

• "tis: Fish aria Wildlife Service Ecological Services 5275 Leesburg Pike Fall_s Church, VA 22041-3803 703-358-1922 Attn: Christy JohnsonHughes@fws.gov

John Fisher Department of Environmental Quality Office of Environmetnal Impact Review 629 East Main Street, 6th Floor Richmond, VA 2329 Attn: John.Fisher@deq.virginia.gov

Virginia Marine Resources Commission Main Office 2600 Washington Ave., 3rd Floor Newport News, VA 23607 Michele.Guilford@mrc.virginia.gov

1 67 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Ms. Ellie Irons, Program Manager Office of Environmental Impact Review P.O. Box 1105 Richmond, VA 23218 F:llie.lrons(Wdeq.virginia.gov

Pennsylvania: -

David Allard, CHP, Director PA Dept. of Environmental Protection Bureau of Radiation Protection Rachel Carson State Office Building P.O. Box 8469

- _Harrjsb1,1rg, PA 171,05~8469 ..

. PH_(z17)787-2480 FX (717)783-8965

. _dj~Uard@pa:gov

ijarbara Okorn (NEPA Reviewer

• NEPA Specialty Topic: Transportation-Virginia and West Virginia, Endangered

_ Species Act, L!3-nd_ Managern~_nt) _ ..

• - l)nitec:l States Environm~ntal Protection*Agency -

R~gion 3 ___ _

Water Protection Divison (3WPo*or 1650 Arch Street

-Philadelphia; PA 19103--2029 Attn: Okorn.barbar@epa.gov

Rebecca Soudo-Glyn (NEPA Reviewer NEPA Specialty Topic: Transportation-Pennsylvania)

United States Environmental Protection Agency Region 3 Water P'rotection Divison (3WPOO) 1650 Arch Street Philadelphia, PA 19103-2029 Attn: Rebecca Soudo-Glyn Glyn.rebecca@epa.gov

Kevin Magerr (NEPA Reviewer NEPA Specialty Topic: Energy, Maryland Transportation)

United States Environmental Protection Agency Region 3

• Water Protection Divison (3WPOO) 16 5 0 Arch Street 2

68 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Philadelphia, PA 19103-2029 Attn: Magerr.kevin@epa.gov

Maryland:

Russell Strickland Emergency Response Director Maryland Dept of the Environment 1800 Washington Blvd, Suite 7111

- Baltimore, MD 21230-1720 Attn: russell.strickland@maryland.gQv

Eva Nair Environmental Program Manager III Radiological Health Program

_ Air"a,nd Ra,diatiori Manage*menfAdin.

Maryalnd Dept of the Environment .

16-00 Washington Blvd.

Baltimore, MD 212.30-1720 Attn: eva,.naii@maryl;;inq.gov _

Trevor Clark - -

U.S. Fish & Wildlife Service a* Chesapeake Bay Field Office 177 Admiral Cochrane Drive Ami~ipolis; MD 2 i401  : * '.

• Attn: trevor _clark@fws.gov

Environmental Protection and Sustainability

- Envi_ronmental Impact Revie~

Jefferson Building

• .. 105 West Chesapeake Ave.

Suite 400 Towson, MD 21204 Email: eps@baltimorecountymd.gov

Endangered Species Coordinator NMFS Northeast Regional Office Protected Resources ivision One Blackburn Drive Gloucester, MA 01930-2298 J ennifer.Anderson@noaa.gov

Joe Abe, Coastal Policies and Project Review Chesapeake & Coastal Service Maryland Department of Natural Resources 3

69 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Tawes State Office Building E-2 580 Taylor Avenue Annapolis, Maryland 21401 Phone: 410-260-8740 Attn: jabe@dnr.state.md.us

Maryland State Clearinghouse Maryland Office of Planning, Suite 1101 301 West Preston Street Baltimore, MD 21201-2365 mdp.clearinghouse@maryland.gov

J Rodney Little - Director & SHPO Department of Planning Maryland Historical Trust - Crownsville Office 100 Community Place Crownsville, MD 21032-2023 Phone 410-514-7601 RLtiitle@mdp.state.md.us

South Carolina:

Susan Jenkins

• Assistant Director South Carolina Department of Health and Environmental Control Bureau of Land and Waste Management Division of Waste Management 2600 Bull Street, Columbia, SC 29201 Attn: Jenkinse@dhec.sc.gov

Aaron A. Gantt, Chief Dept of Health & Environmental Control Bureau of Radiological Health 2600 Bull Street Columbia, SC 29201 PH (803)545-4420 FX (803)545-4412 ganttaa@dhec.sc.gov

Shelly Wilson Federal Facilities Liaison South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 4

70 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Phone: 803-896-8955 Attn: wilsonmd@dhec.sc.gov

Greg Mixon South Carolina Department of Natural Resources Marine Resources Division PO Box*12559

• Charleston, SC 29422 MixonG@dnr.sc.gov

John Cox Coastal Zone Consistency Coordinator South Carolina Department of Health and Environmental Control Division of Ocean & Coastal Resource Management 1362 McMillan Ave;

• s:uiti 400 .

Charl~ston, SC 29405 joh.n.COX@dhec.sc.gov -, -

j oe Cockrell Ecological Services (or Field Supervisor)

US. Fish and Wildlife Service

• 176*Crog~an Spur Roag.; Suite zop-Charleston, SC 29407 Joe_c.ockreli@fws.gov -

South Carolina Department of Archives and History 8301 Parklane Road Columbia, SC 29223 W Eric Emerson, Ph.D. - SHPO Phone 803-896-6187 Attn: eemerson@scdah.state.sc.us

Chris Militscher United States Environmental Protection Agency Region 4 Water Protection Divison Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-8960 Attn: Militscher.chris@epa.gov .

5 71 ofl 10 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Florida:

Cynthia Becker, M.P.H., Chief Bureau of Radiation Control Florida Department of Health 4052 Bald Cypress Way, SE, Bin C21 Tallahassee, FL 32399-1741 cindy.becker@flhealth.gov

Susan Smith Florida Fish and Wildlife Conservation Commission

• Farris Bryant Building 620 S. Meridian St.

• Tallahassee, FL 32399-1600 * (850) 488-4676 Susan_Smith@FWS.gov

Noah Silverman Section 7 Coordinator NMFS Southeast Regional Office 263 13th-Ave. South St. Petersburg, FL 33701 noah.silverman@noaa.gov

• General:

Mr. Edward Wandelt Director, Office of Environmental Management Coast Guard (CG-47)

Department of Homeland Security 2100 Second Street, SW, STOP 7901 Washington, DC 20593-7901 Attn: edward.f.wandelt@uscg.mil

FEMA Region III-DC, DE, MD, PA, VA, WV Catharine McManus Regional Environmental Officer DHS/FEMA Region III 615 Chestnut Street th One Independence Mall, 6 Philadelphia, PA 19106-4404 Phone: 215-931-5510 Fax: 215-931-5501 Email: kate.mcmanus@dhs.gov

FEMA Region IV - Florida and South Carolina

6 72 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Dr. William R. Straw Regional Environmental Officer DHS/FEMA Region IV - Hollins Building 3003 Chamblee Tucker Road Atlanta, GA 30341 Email: william.straw@dhs.gov

Alliance for Nuclear Accountability Ms. Katherine Fuchs Program Director Alliance for Nuclear Accountability 322 Fourth Street, NE Washington, DC 20002 Phone: 202-544-0217 (ext. 2503)

Fax: 202-544-6143 Email: kfuchs@ananuclear.org

Citizens for Alternatives to Radioactive Dumping (CARD) www.~ardnm.org Ms. Janet Gree_nwald Citizens for Alternatives to Radioactive_Dumping 202 Harvard Street, SE Albuquerque, NM 87106 Phone: 505-266-2063 Fax: 505-266-:2663 _or 505-2_62-1864*

Email: contactus@cardnm.org

Citizens for Environmental Justice.

Dr. Mildred McClain Executive Director* -

Harambee House, Inc.

Project: Citizens for Environmental Justice 1115 Habersham Street Savannah, GA 31401 Email: cfej@bellsouth.net - 1

Citizens for Nuclear Technology Awareness www.c-n-t-a.com Citizens for Nuclear Technology Awareness is interested primarily in nuclear issues education.

Mr. Clinton Wolfe Executive Director 1204 Whiskey Road, Suite B Aiken, SC 29803 Email: cnta@bellsouth.net

Nuclear Energy Institute www.nei.org Ms. Lisa Steward Senior Director and Assistant Corporate Secretary Member Relations Nuclear Energy Institute 1776 I Street NW, Suite 400

7 73 of 110 CR-137 , Supplemental Environmental Asses sment and Finding of No Significant Impact

Washington, DC 20006 - 3708 Email: lis@nei.org

Baltimore Port Alliance Pilot/Maritime Center Second Floor 3720 Dillon Street Baltimore, MD 21224 Attn  : info@baltimoreportalliance .org

Sector Charleston 196 Tradd Street Charleston, South Carolina 29401

Sector Jacksonville Sarah Geofrion 10426 Alta Drive Jacksonville, Florida 32226

Sector Hampton Roads Peter Zohorsky 4000 Coast Guard Blvd.

Portsmouth, VA 23703

Sector Balitmore Stephen Thompson US Coast Guard Building 70 2401 Hawkins Point Road Baltimore, BD 21226-1791

Sector Delaware Bay LDCR Jennifer Doherty 1 Washington Ave .

Philadelphila, PA 19147

Sierra Club 7338 Baltimore Ave .

1. 102 College Park MD 20740 losh.tulkin@sierraclub.org

The Propeller Club of Baltimore Brian Greenbaum 3301 Edwards Lane Middle River, MD 21220 8

74ofll0 CR- 137, Supplemental Environmental Asses smen t and Finding ofNo Significant Impact

Baltimore Port Alliance Pilot/Maritime Center, Second Floor 3720 Cillon Street Batimore, MD 21224 info@baltimoreportalliance.org

Citizens for Alternatives to Radioactive Dumping (CARD)

Janelt Greenwald 202 Harvard Street, SE Albuquerque, NM 87106 contactus@cardnm.org

Betsy Thompkins American Nuclear Society 555 North Kensington Ave La Grange Park , Illinois 60526 Btompkins@ans .org

Health Physics Society 1313 Dolley Madison Boulevard Suite 402 McLean, Virginia hps@burkinc.com

9 75of110 CR-137 , Supplemental Environmental Assessment and Finding ofNo Significant Impact

CGS- BMT JV , LLC CGS 440 1 Fo rd Avenue , Suite 1000 Alexand ria , V A 22302 , Uni ted States BMT T el: +1 703 920 7070 JOI N T VEN 1 URL Fax  : + 1 703 920 7177

June 26, 2018

Russell Strickland Emergency Response Director Maryland Dept of the Environment 1800 Washington Blvd, Suite 7111 Baltimore, MD 21230-1720 Attn: russell.strickland@maryland.gov

Dear Russell Strickland:

I am writing to you on behalf of the Maritime Administration (MARAD) who is preparing a Supplemental Environmental Assessment (EA) for a proposed project to fully decommission the Nuclear Ship SAVANNAH (NSS). This action will result in the termination of their nuclear license by the US Nuclear Regulatory Commission (NRC) under 10 CFR Part 50 as a power generation reactor .

MARAD owns and maintains the NSS, the world's first nuclear powered merchant ship.

NSS was deactivated in 1970, defueled in 1971, and has been in a state of mothballed protective storage since 1976. All high lev el radioactive materials were removed, any areas of remaining radioactivity were sea led and contained and the vessel has since been in protective storage. MARAD prepared a Final Environmental Assessment and Finding of No Significant Impact (Report No. STS-106) (FEA/FONSI) in 2008 that discussed decommissioning options; however, full decommissioning was not completed, and the decision was made to keep NSS in protective storage while awaiting funding for full decommissioning. The vessel was moved to berthing in Baltimore where it remains.

The project is being completed now because funded has been received .

The proposed action is to decommission NSS at an existing commercial industrial facility via NRC's DECON method. MARAD is responsib le for towing the vessel, if necessary, to a suitable port lo cation . DECON actions for all low- lev el radioactive waste (LLW) processing and packaging will be done aboard the vessel, then removed via crane.

Waste will then be transported to a licensed nuclear (Class A) waste disposal location via secure methods and routes typically used to ship LLW. This proposed action is a continuation of the work discussed in the DECON portion of the 2008 FEA/FONSI.

Viable port cities to be analyzed in this Supplemental EA include Baltimore, MD; Hampton Roads, VA; Philade lphi a, PA; Charleston, SC; and Jacksonville, FL at existing industrial facilities . It is important to note that the DECON actions are limited to within

76 of 110 CR-137 , Supplemental Environmental Assessment and Finding ofNo Significant Impact

the vessel, other than the transportation of packaged waste to disposal facilities; no actions will occur in the water. After all low-level waste is removed , the vessel will still float and final disposition of NSS can be determined in the future ( options may include establishing a museum , reefing, and dismantling).

If the vessel is moved from its current location, marine species that may be encountered (and will be evaluated in this Supplemental EA) are West Indian Manatee, whales (North Atlantic right, humpback, fin, sperm, blue, and sei), reptiles (hawksbill sea turtle, Kemp's ridley sea turtle, green sea turtle, leatherback sea turtle, loggerhead), and also fish species (short nose and Atlantic Sturgeon).

Three of these port cities were analyzed in the 2008 NSS FEA/FONSI and the 2014 STURGIS FEA/FONSI and similar results are expected: although threatened and endangered species have been identified as having the potential to occur in the project area (which encompasses all potential locations and towing paths), they are not likely to be adversely affected by the proposed action.

The National Historic Preservation Act Section 106 consultation is ongoing and is being handled separately from, but coordinated with , this Supplemental EA.

The Supplemental EA will be prepared shortly and we will send a copy to your office when drafted . Please advise Ms . Jill Enright at jenright@dandp.com of any environmental concerns that you feel should be addressed . If you have any questions or concerns please address them to Ms . Kristine Gilson at Kristine .gilson@dot.gov .:.

Sincerely ,

CGS- BMT JV

Jill Enright, P.E.

NEPA Coordinator

77 of I JO CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

MNRYLAND DEPARTl\\'[ENT.OF

Larry Hogan, Governor Robert S. McCord, Secretary Boyd Rutherford, Lt. Governor

June 28, 2018

Ms. Jill Enright, P.E.

NEPA Coordinator CGS BMT Joint Venture, LLG 4401 Ford Avenue, Suite 1000 Alexandria, VA 22302 STATE CLEARINGHOUSE REVIEW-PROCESS State Application ldentifie,r: l\\1])~0180627-0498. . _

Project

Description:

Scoping for the Supplemental Environmental Assessment (EA): Full Decommissioning of the Nuclear Ship SAVANNAH (NSS), Baltimore, MD Project Location: Baltimore City Clearinghouse Contach Myra Barnes _

Dear.Ms. Enright:

Thank you for submitting your project for intergovernmental review. Participation in"the Maryland Intergovernmental Review*

and Coordination (MIRC) *process helps ensiifo project consistency with 'plaris, programs; and objectives of State agencies *and local goyerru_nents.

Notice of your application is being provided to Staie and local public officials through the 1i,te;govei-nme11ia1 Mo11it~r. which

• is a_database*ofprojects received by the State Clearinghouse for Intergovernmental Assistance;-:-This information may be -

• viewed at htn,://ap_ps.planning.matyland,gov/emircpublic/. The.projectlias been assigned a unique State Application Identifier that should be used on all documents and correspondence.

A "Project Status Form" has been enclosed and should be completed and returned after you receive notice that your project was approved or not approved. .

Al:l MIRC requirements haye been inet in accordan_ce with Code of Maryland Regulatio_ns (COMAR 34.0_2.01.04-.06) a1ui !his concludes the review process for the above referenced project.

• If you need assistance or have questions, contact the State

• Clearinghouse staff noted above at 410~ 767-4490_ or through e-mail at,myra.barnes@maryland.gov. Thank you for your cooperation with the MIRC'process.

• Sincerely,

~&.~

Myra Barnes, Lead Clearinghouse Coordinator

MB:MB Enclosure(s) cc: Kristine Gilson - DOT 18-0498 _NM.NEW.docx

Maryland Department of Planning

• 301 West Preston Street, Suite 1101

• Baltimore

• Maryland

• 21201

Tel: 410.767.4500

• Toll Free: 1.877.767.6272 7§ oHtd1sers: Maryland Relay

• Planning.Maryland.gov CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

MARYLAND DEPARTMENT OF 1.~. -----------'----

,~ Larry Hogan, Governor Robert S. McCord, Secretary PLANNING Boyd Rutherford, Lt. Governor

PROJECT

• STATUS FORM

Please complete this form and return it to the State Clearinghouse upon receipt of notification that the project has been approve~ or not approved by -the al?proving authority. * *

• TO: Maryland State ClearinghoJ)s_e DATE: ________ _

Maryland Department of Planning (Please fill in the date form completed) 301 West Preston Street Room 1104 Baltimore, MD 21201-2305

FR0!\\1: ___________ _ PHONE:**  ;. -* (Area Code 8i P-h..,.._ o,..._ n-e,,..._n-um....,.._ b'er)

(Name of person completing this form.j

RE: State Application Identifier: MD20l80627-0498 Project

Description:

Scoping for the Supplemental Environmental Assessment (EA): . Full Dec<>mmissioning of the Nuclear Ship SAVANNAH (NSS), _Baltimore, MD

This project/plan was: [J Apprrived * -

• Approved- with Modifi(:ation

N;1me of Approving Authority: D~te Approved:

The funding (if.applicable) has beeri approved-for the period* of:

_____________ , 201 to ----------~ 201 __ as follows:

Federal$: Local-$: . State $: Other $:

Further comment or explanation is attached

Maryland Department of Planning

• 301 West Preston Street, Suite 1101

• Baltimore -

• Maryland

• 21201

.-- __ T_e-,1: 410.767.4500

• Toll Free: 1.877.767.627279*0 r11tiusers: Maryland Relay

• Planning.Maryland.gov MDPCH-1F J CR- 137, Supplemental Environmental Assessment and Finding ofNo Significant Impact

Jill Enright

From: Myra Barnes - MDP- <myra.ba rnes @mary land .gov >

Sent Thursday , June 28, 2018 1:03 PM To: Jill Enright Cc: Kristine.gilson@dot.gov

Subject:

Scoping for the Supplemental Environmental Assessment (EA): Full Decommissioning of the Nuclear Ship SAVANNAH (NSS), Baltimore, MD (MD20180627-0498)

Attachments: 18-0498_Monitor .NEW .doc.pdf

Follow Up Flag  : Follow up Flag Status  : Flagged

Hello Ms . Enright,

Enclosed is the State Clearinghouse Review Process Acknowledgment letter , including an attachment for the Scoping for the Supplemental Environmental Assessment (EA): Full Decommissioning of the Nuclear Ship SAVANNAH (NSS ), Baltimore, MD (MD20180627 -0498). Thank you .

M , 11\\Y L /\\NO O E PAI\\TM CNT o r

"\\MIi.JR PLANNING Myra A. Barnes

.L~ Lead Clearinghouse Coordinator CHANGING Maryland Department of Planning Maryland (410) 767-forllN &il" 4488 I (877) 767-6272

Please take our customer service survey .

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1 80 of 110 7/31fl018 Intergovernmental Monitor CR-137 , Supplemen tal Env ironmenta l A s sessmen t and Finding ofNo Sign i fican t Impa c t

M A R I.A!'l:0 O F.PAR T .MF. T OF Intergovemmental Monitor A Publication of Maryland Department of Planning's State Clcaringbousc Division ~ I ~

Announcing Proposals Received for Intergovernmental Review PLAN I G

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AVAILABLE RECORDS SEARCH & VIEW SEARCH RESULlS VIEW SELECTED RECORD DETAIL erl t tbi:i d~ts:1ll~d [~12Qrt.

IDNUMBER MDl0180627-0498

PROCESS INFORMATION Review 0 Days Reviewer 612812018 Opened  : 6/28/2018 aosed  : 6/28/2018 Period: Comments Due:

Processing Method  : Information Only Clearinghouse

Contact:

MyraBames

REVIEW CONSISTENCY N /A . Thia wu proceued for information pmp01e1 ooly.

DETERMINATION

COMMENTS REQUESTED FROM No asencies were formally~ to IUbmit commeota on 1hia project.

LOCATION Baltimore City

DESCRIPTION Viim: Docummn<t).

Scoping for the Supplemental Envirnnmmtal ~neament (EA)  : Full Decommi uioning of 1he Nuclear Ship SAVANNAH (NSS), Baltimore, MD

A.PPUCA.NT cl CONTACT COS BMT Joint Vcoturc, LLC Till Enright NEPA Coordinator 4401 Ford Avenue, Suite 1000

AleundriaVA22302 Pboae: 703-920-7070

~

F.rmall: jemigbt@dandp .com

CO-A.PPUCA.NT & CONTACT None or not entered/provided.

(if any providetl)

CATEGORY CODE 2A - DEIS/EER/FONSI/EIS/EA/NEPA DOCUMENTS (EXCEPT FOR CDBG & WATER & SEWER) ...

llttRiLLRllllllKJIIID'Jau.ml .,

State~~~

Today's Date: 7/31/.201 8 . 301 West Preltoo S1reet - Suite 1101 Bahimore, MD 2 1201 . Phone: 410-767""'490 Fu:: 410-767~

http://appe .plannlng .maryland .gov/em lrcpublk:/ 8 1 of I I 0 1/1 CR - 13 7, Supplem ental Environm ental Asses sment and Findin g of No Signifi can t Imp act

Jill Enright

From  : Jill Enright Sent Wedne sday , June 27, 2018 9:51 AM To  : ' Eva Nair - MDE- '; Susan Fry e

Subject:

RE : EA Regulatory Notific ation Letter

The wa ste handlin g and pro c essing will a ll occur w ithin the ship. It w ill b e packa ged on the ship a n d then b e mov ed to the pier straight to the tran sportation m etho d (truc k, ra il, etc.) to be sen t to the d ispo sa l facility .

Jill Enr ight, P .E.

Senior Program Engineer BMT Designe rs & Pla nn ers In c

Mob  : +1 315 313 5768

From: Eva Na ir - MDE- <eva . na ir@maryland .gov >

Sent  : Wednesday , June 27 , 2018 9 :09 AM To  : Susan Fry e <SFry e@cgs .us .com >

Cc: Jill Enright <jenright@dandp .com >

Subject  : Re  : EA Regulatory Notification Letter

Good m ornin g Susan,

Tha nk y ou fo r sending us th e letter and keeping us informe d. If th e wo rk will be c onducted in Maryland , wi ll the reacto r ve ssel be packaged for s hipment w it hin the s hip or w ill it have to be move d to t he pier?

T hanks,

Eva

Ev a S. N air Program Manager , Radiological Health Progr am Maryland D ep artm ent of the Env ironm ent (410) 537-3 179

On Tue, Jun 26, 201 8 at 8 :33 PM, Susan Frye < SFrye@ c gs.us.com > w ro te  :

Eva Na ir

I a m writing to you on behalf of th e Ma ritim e Admini s tration (MARAD) who is p repa ring a Supp leme nta l Environment a l Asse s s ment (EA) for a propo sed proj e ct to full y d ecomm issi on the Nuclear Ship SAVANNAH (N SS) . Ple ase s ee attac hed le tter.

Tha nk y ou

Clic k h ere to co rn plete a three qu estio n c u sto m e r ex pe rie n ce surv ey .

1 82 of 110

• I ...........

CR - 137, Suppl e m ental Env ironm ental Assess m ent and Findin g ofN o Signifi cant Imp ac t

Jill Enright

From  : Trevo r Clark <trevor _ clark@fws.go v >

Sent Wed n esday , June 27, 2018 3:08 PM To  : SFrye@cgs .us .com Cc: Jill Enright

Subject:

Re : [EXTERNAL] EA Regulatory Notification Letter

Hi Susan,

Please go to the following website to determine if federally endangered and / or threatened species within the Maryland, Delaware and Washington D. C. region have the potential to be impacted by you r proposed project:

< http: //www . fws.gov/chesapeakebay/EndSppWeb/ProjectReview/Index.html >

Please contact me if you have any questions . Thanks

On T u e , Jun 26 , 2018 at 8:3 9 PM Susan Fry e < SFrye@cgs.us.com > wro te  :

Dear Trevor Clark,

I am writing to you on beha lf of the Maritime Administration (MARAD) who is preparin g a Supplemental Environmental Assessment (EA) for a proposed project to fully dec ommi ssion the Nuclear Ship SAVANNAH (NSS). Please see attached letter.

I Th a nkyou

Trevo r C lark Fish and Wildlife Bio logist U .S. Fi sh and Wildlife Service C hesap eak e B ay Eco logic al S ervic es Fie ld O ffi ce E ndangered and Threaten ed Sp ecies Bran ch 177 Admiral Coc hran e Driv e Ann apo li s, M ary land 2 1401 T elephon e: (41 0) 573-45 27 Fax: (410) 269 -0 832 E m ail : trevor clark@fws.gov

1 83 of I IO CR-13 7 , Supplemental Environmental Assessment and Finding of No Significant Impact

Jill Enright

From  : barbara .gregory@dcr .virginia.gov on behalf of nhreview, rr

<nhrev iew@dcr.virginia.gov>

Sent Friday, July 6, 2018 8:51 AM To  : Jill Enright Subject  : Supplemental Environmental Assessment (EA) for Nuclear Ship SAVANNAH Decommissioning  ; Hampt on Roads , Virginia

Ms . Enright,

A request for a review of the above mentioned project was forwarded to us by the Virginia Dept. of Environmental Quality. If you would like for us to provide comments on this project, a completed Information Services Order Form is required. You can complete the form on - line and it will automatically be sent to us after you hit the "su bm it" button at the bottom of the page. You will also receive a confirmation emai l. The form can be found at the following link:

http://www.dcr .virginia.gov/natura l- heritage/nhserviceform/

Please feel free to contact me if you have any que stions .

Thank you,

Barbara Gregory Se nior Project Review Assistant OCR - Division of Natural Heritage 600 East Main Street, 24th Floor Richmond, VA 23219 804- 225 -2821

1 84 of I 10 CR- 137, Supplemental Env ironmen tal Assessment and Findi ng ofNo Significant Impact

Jill Enright

From  : Susan Frye <SFrye@cgs.us .co m >

Sent Saturday , July 7, 20 18 1:41 PM To: Jill Enright Cc: Kevin Howard Subject  : Fwd  : EA Regulato ry Notificatio n Letter

FYI

- Susan Frye

Begin forwarded me ssage :

From: <nhreview@dcr. virginia. gov >

Date: July 7 , 2018 at 1:40 :32 PM EDT To: < Sfrye@cgs .us.com >

Subject:

EA Regulatory Notification Letter Reply-To: < nhreview@dcr.virginia.gov >

Thank you for submitting your request. Upon review of this project , OCR-Natural Heritage will provide comment s via email within 30 calendar days . Project referenc e ID is 18070713403270.

Appli catio n  : http: //www.dcr.virginia.gov /natural-heritage /nhserviceform/?id=2018-07-07-13 32-703377-oj3

1 85 of 110 CR-I 37 , Supplemental Environmental Assessment and Finding of No Significant Impact

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COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Street addr ess : 629 East Main Street, Richm ond, Vi rgin ia 232 19 Matthew J. Strickler Mailing address  : P .O. Box 1105, Richmond , Virginia 23218 David K. Pay lor Secretary of Natural Resources www.deq .v irg inia.gov Director June 27, 2018 (804) 698-4000 1-800-592-5482

Jill Enright CGS-BMT JV, LLC 4401 Ford Avenue, Suite 1000 Alexandria , Virginia 22302 Via email: jenright@dandp_com

RE: Scoping Request - Supplemental Environmental Assessment (EA) for Nuclear Ship SA VANNAH Decommissioning; Hampton Road s, Virginia

Dear Ms. Enrig ht:

This letter is in response to the scoping request for the above-referenced project.

As yo u ma y know, the Department of Environmen tal Quality, through its Office of Environmental Impact Review (DEQ-OEIR), is responsible for coordinating Virginia 's review of federal environmental document s prepared pursuant to the National Environmental Policy Act (NEPA) and responding to appropriate federal officials on behalf of the Commonwealth. Similarly , DEQ-OEIR coordinates Virginia 's review of federal consistency documents prepared pursuant to the Coastal Zone Management Act which applies to all federal activities which are reasonably likely to affect any land or water use or natural resources of Virginia's designated coastal resou rces mana geme nt area must be consistent with the enforceable policies Virginia Coastal Zone Management (CZM) Program.

DOCUMENT SUBMISSIONS

In order to ensure an effective coordinated review of the NEPA document and federal consistency documentation , notification of the NEPA document and federal consistency documentation should be sent directly to OEIR. We request that you submit one electronic to eir@deg.virginia.gov (25 MB maximum) or make the documents available for download at a website , file transfer protocol (ftp) site or the VITA LFT file share system (Requires an "invitation" for access. An invitation req uest should be sent to e ir@deg.virgi ni a.gov .) . We request that the review of these two documents be done concurrently , if possible.

The NEPA document and the federal consistency documentation (if app licab le) s hould include U. S. Geological Survey topographic maps as part of their information . We strong ly encourage you to issue shape files with the NEPA document. In add ition, project details shou ld be adequately described for the benefit of the reviewers.

86 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

ENVffiONMENTAL REVIEW UNDER THE NATIONAL ENVffiONMENTAL POLICY ACT:

PROJECT SCOPING AND AGENCY INVOLVEMENT

As you may'know, NEPA (PL 91-190, 1969) and its implementing regulations (Title 40, Code of Federal Regulations, Parts 1500-1508) requires adraft and final Environmental Impact Statement (EIS) for federal activities or undertakings that are federally licensed or federally funded which will or may give rise to significant impacts upon the human environment. An Eis carries more stringent public participation requirements than_an Environmental Assessment (EA) and provides more time and detail for comments and public decision-making. The possibility that an EIS may be required for the proposed project should not be overlook~d- in your planninK for_ this project. }\\ccordingly, we refer to "NEPA document" in the remainder of this letter.

While this Office does not participate in scoping efforts beyond the advice given herein; other agencies are free to provide scoping comments concerning the preparation of the NEPA document.

Accordingly, we are providing notice of your scoping request to several state agencies and those localities and Planning District Commissions, including but not limited to:

Department of Environmental Quality: -

o DEQ Regional Office*

o Air Division*

o Office of Wetlands and Stream Protection*

o -Office*ofLocal Government Programs*

o Division of Land Protection and Revitalization -

o

• Office of Stormwater Management~- -

Department of Conservation and Recreation

_ Department of Health* -- - .. ** _ _

• Department of Agriculture and Consumer Services

• Department of Gatfie and Inland Fisherfos*

Virginia :rvlar_ine Resourc_es ~ommi~sion* _

Department of Historic Resources

• Department of Mines, Minerais; and Energy Department of Forestry Department of Transportation

Note: The agencies noted with a star(*) administer one oi more of the enforceable policies of the Virginia CZM Program.

FEDERAL CONSISTENCY UNDER THE COASTAL ZONE MANAGEMENT ACT

Pursuant to the federal Coastal Zone Management Act of 1972, as amended, and its implementing regulations in Title 15, Code of Federal Regulations, Part 930, federal activities, including permits, licenses, and federally funded projects, located in.Virginia's Coastal Management Zone or those that can have reasonably foreseeable effects on yirginia's coastal uses or coastal resources must be conducted in a manner which is consistent, to the maximum extent practicable, with the Virginia CZM Program.

Additional information on the Virginia's review for federal consistency documents can be found online at http://www.deq.virginia.gov/Programs/EnvironmentalimpactReview/FederalConsistencyReviews,aspx

87 of 110 CR-137 , Supplemental Environmental Assessment and Finding ofNo Significant Impact

DAT A BASE ASSISTANCE

Below is a list of database s that may assist yo u in the preparation of a NEPA document:

• DEQ Online Database  : Virginia Environmental Geographic Information Sys tems

Information on Permitted Solid Waste Management Facilities , Impaired Waters, Petroleum Release s, Registered Petroleum Facilities, Permitted Discharge (Virginia Pollution Discharge Elimina tion System Permit s) Facilities , Resource Conservation and Recovery Act (RCRA) Sites, Water Monitoring Stations , Nationa l Wetland s Inv entory  :

o www .deg.virgin ia.gov /ConnectWithDEONEGIS.aspx

• DEQ Virginia Coasta l Geospatial and Educational Mapping System (GEMS)

Virginia ' s coastal resource data and map s; coastal laws and policie s; facts on coastal resource values; and direct links to collab orating agencie s re sponsi bl e for current data  :

o http: l/128.172.160.131 /gems2/

• MARCO Mid-Atlantic Ocean Data Portal

The Mid -Atlantic Ocean Data Portal is a publicly available onlin e toolkit and reso urce center that con solidate s availab le data and enab les users to visualize and analyze ocean resources and human use information such as fishing grounds , recreational are as, shipping lane s , habita t areas, and energy sites , among others .

http: //portal.midatlanticocean.org/visua l ize /#x =-

73.24&y=38.93&z=7&logo=true&controls=true&basemap=0cean&tab = data&Iegends=false&la yers=true

• OHR Data Sharing System .

Survey record s in the DHR invent ory:

o www.dhr.virginia.gov /archives /data sharing sys.htm

• D CR N atural Heritage Search

Produce s li st s ofre so urce s that occur in specifi c counties , watersheds or physiographic re g ions:

o www .dcr .virginia .gov/natural heritage /dbsearchtool .shtml

• DGIF Fish and Wildlife Informati o n Service

Information about Virginia's Wildlife reso urces  :

o http://vafwi s.org/fwis/

• Env ironm enta l Protection Agency (EPA ) Comprehe nsive Env ironmental Respo nse ,

Comp e nsation , and Liability Information System (CERCLIS) Database  : Superfund Inform atio n Sy stem s

3

88of110 CR-137 , Supplemental Environmental Asses sment and Finding of No Significant Impact

Information on hazardou s waste sites , potentiall y hazardou s waste si tes and remedial activities across the nat io n, including s ite s that are on the National Prioritie s List (NPL) or being considered for the NPL  :

o www .epa.gov /superfund /sites/cursites /index.htm

• EPA RCRAinfo Search

Information on hazardous waste facilities:

o www .epa.gov /enviro /facts /rcra info/search .html

• EPA Envirofacts Database

EPA Environmental Information , including EPA-Regulated Facilities and Toxics Rele ase Inventory Reports  :

o www.epa .gov/enviro /index.html

• EPA NEPAssist Database

Facilitates the e nvironmental review proce ss and project planning  :

http  ://nepaassisttoo l .epa .gov /nepaassist/entry.aspx

If you have questions about the environmental review proces s and/or the federal consisten cy review process , please feel free to contact me (telephone (804) 698-4204 or e-mail bettina .ray field @ deq .v irginia .gov) .

I hope this information is helpful to you.

Sincerely ,

Bettina Rayfield , Program Manager Environmental Impact Review and Long-Range Prioriti es

4

89 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

Jill Enright

From: Warren, Arlene <arlene.warren@vdh.virginia.gov>

Sent: Wednesday, July 18, 2018 4:56 PM To: Jill Enright; r:r Environmental Impact Review

Subject:

Re: NEW SCOPING REQUEST Nuclear Ship SAVANNAH Decommissioning

Project Name: NEW SCOPING REQUEST Nuclear Ship SAVAN"'AH Decommissioning Project#: N/A UPC#: N/A L(?~ation: Hampton Roa_ds, Vl_rglnla

VDH - Office of Drinking Water has reviewed the above project. Below are our comments as they relate to proximity to public drinking water sources (groundwater wells, springs and surface water intakes). Potential impacts to public water distribution systems or sanitary sewage collection systems must be verified by the local utility.

There are no p,u_blic gr~undwater ~ells withjn a _1-mile r_a_dius of the project site.

There are no surface water intakes located within a 5:-mile radius of the project site.

The project is not within - . - . . . . . the water:shed of any public surface water intakes.

. There are no .apparent impacts to public drh:ikjng water sourc(;!S cjue to:this project.

• Comments from VDH - Radiological Health, Mr. Steven Harrison, Director were The Virginia Department of _Heaith's.Office. of 1fadiol_ogical Health-(CiRH) tias reviewed the subject docume11~

• __

regarding decommissioning of the Nuclear Ship Savannah. ORH has no scoping comments to offer regarding this Supplemental Environmental Assessment; Based ori our *review, it is oi.ir understanding

• that all decontamination activit_ies will be c~ndu~ed under the jurisdiction of the U_.S. f;Juclear __

Regulatory.Commission (NRC). This is because the NRC has jurisdiction for all .civilian nuclear.power reactors, and the Nuclear Ship Savannah's reactor falls under that definition. The NRC informed us earlier today tha~ they will share inforrnati~n ~ith st_ate agencies that have an interest in this _ .

proj~ct; They also plan to allow state agen_cies access, when appropriate, to observe decommissioning activities on board the vessel. It is important to note that contractors with a need to possess radioactive materials (e.g., contaminated equipment, parts, or other items) away from the vessel, in the event that need arises, will be required to obtain a Virginia Radioactive License from our Office."

The Virginia Department of Health -- Office of Drinking Water appreciates the opportunity to provide comments. If you have any questions, please let me know.

Best Regards,

Arlene Fields Warren

GIS Program Support Technician 1

9Q*of 110 CR- 13 7 , Supplemental Environmental Assessment and Finding of No Significant Imp act Office of Drinking Water

Virginia Department of Health

109 Governor Street

Richmond, VA 23219

(804) 864-7781

On Wed, Jun 27 , 2018 at 2:55 PM, Fulcher , Valerie <valerie .fulcher@deg.virginia.gov > wrote :

I Good afternoon-attached is a request for scoping comments on the following:

Supplemental Environmental Assessment (EA) for Nuclear Ship SAVANNAH Decommissioning; Hampton Roads, Virginia

If you choose to make comments, please send them directly to the project sponsor (f enright@dandp .co m )

and copy the DEQ Office of Environmental Impact Review: eir@deg.virginia.gov . We will coordinate a review when the environmental document is completed.

DEQ-OEIR's scoping response Is also attached .

If you have any questions regarding this request, please email our office at eir@deq.virginia.gov.

Valerie

Valerie A. Fulcher , CAP, OM, Environmental Program Specialist

Departm ent of Environmental Quality

E nvironmental Enhancement - Office of Environmental Impact Revie w

1111 East Main Street (new street address effective 11/1.7/17)

Richmond , VA 23219

804/698-4330

804/698-4319 (Fax)

email  : Val erie.Fulcher@ deg .vir ginia.g ov

http://www.deg.virgin ia.gov/Programs /EnvironmentalimpactReview.aspi:

2 9 J of 110 CR-137 , Supplemental Environmenta l Assessment and Finding ofNo Significant Impact Rochelle Altholz Matthew J . S trickle r Deputy Direclor of Secretary of Natural Resources Administration and Finance

C ly de E. Cri s tman Russe ll W . Bax ter Direcror Deputy Direclor of Dam Safety & Floodplain Management and Soil & Water COMMONWEALTH of VIRGINIA Conservation

Tho m as L. S m ith DEPARTMENT O F CO NSERVATION AND RECREATION Deputy Director of Operations

August 4, 2018

Susan Frye Chesapeake Geoscience s, Inc .

596 Knollwood Road Sevema Park, MD 2 I 146

Re: Nuclear Ship Savannah Decommissioning Supplemental EA

Dear Ms. Frye  :

The Deparbnent of Conservation and Recreation's Division of Natural Heritage's (OCR) mission is conserving Virginia's biodiversity through inventory , protection , and stewardship. Natural heritage resources are defined a s the habitat ofra re , threatened, or endangered plant and animal , unique or exemplary natural communitie s, and significant geo logic formation s.

As indicated in the information provided for the s upplemental Environment A ssess ment (EA) for the Nuclear Ship Savannah Decommi ssi oning if the ve sse l is moved from its current location in Baltimore , MD to Hampton Roads, VA to be decommis s ioned there is potential for the following" marine s pecies to be enc ountered  : West Indian Manatee , whales (North Atlantic right , humpback , fin , sperm , blue, and sei), reptile s (hawksbill sea turtle ,

Kemp's rid le y sea turtle , green sea turtle , leatherback sea turtle , loggerhead), and also fish specie s (shortnose and Atlantic Sturgeon)". OCR supports the evaluation of potential impacts to these species during the supp lemental EA and recommends coordina tion with the United States Fish and Wildlife Service , the Nati onal Marine Fisheries Service and the Virginia Department of Game and Inland Fisheries to ensure compliance with prot ected species legislation .

Under a Memorandum of Agreement establi s hed between the Virginia Department of Agriculture and Consumer Services (VDACS) and the OCR, OCR represent s VDACS in comments regarding potential impact s on state li sted threatened and endangered plant and insect species. The current activity will not affect any documented state- listed plants or insec ts.

Please note there are State Natural Area Preserves under DCR's juri sdiction in the project vicinity . For more informa ti on on the locatio n of the OCR Natural A rea P rese rves , please visit htt p ://www .dcr .virgi ni a.gov /natura l heritage/natu ra l-area-prese r ves/.

New and updated information is continua ll y added to Biotics. Please re-submit a completed order form and project map for an update on this natural herita ge information if the scope of the project changes and/or six months has passed before it is utili zed.

A fee of $90.00 has been assessed for the servic e of providin g this information . Please find attached an invoice for that amount. Please return o ne copy of th e invoice a long with your remittance made payable to the Treasurer of Virginia, OCR - Division of Natural Herit age, 600 East Main Street, 24 th Floor, Richmond , VA 23219. . .

600 Eas t Mai n Street, 24th F loo r I Ri chm o nd, Vi rginia 232 19 I 804 -786-6 124

Stau Parks* Soil and Water Conservation* Outdoor Recreation Planning Natural Heritage

• Dam Safety and '11f'81Pllfi.!J Management* Land Conservation CR-137, Supplemental Environmental Assessment and Finding ofNo Significant Impact

Payment is due within thirty days of the invoice date. Please note the change of address for remittance of payment as of July 1, 2013. Late payment may result in the s uspension of project review service for future projects .

The Virginia Department of Game and Inland Fisheries (VDGIF) maintain s a database of wildlife locations ,

including threatened and endangered species, trout streams , and anadromous fish waters that may contain information not documented in this letter. Their database may be accessed from http: //vafwi s .org/fwis/ or contact Ernie Aschenbach at 804-367-2733 or Ernie .A schenbach @dgif .virginia .gov .

Should you have any questions or concerns , please contact me at 804-3 71-2708 . Thank you for the opportunity to comment on this project.

Sincere ly ,

I?~ I f1,,,,-:-

S. Rene Hype s Natural Heritage Project Review Coordinator

Cc: Amy Ewing, VDGIF Troy Andersen, USFWS David O'Brien, NOAA Christine Vaccaro , NOAA

93 of 110 CR- 137, Supp lemental Enviro nment al Assessment and Finding ofNo Significant Impact Baltimore NOA submittals

Russell Strickland Emergency Response Director Maryland Dept of the Environment 1800 Washington Blvd, Suite 7111 Baltimore , MD 21230-1720 Attn: russell,strickland@maryland.gov

Eva Nair Environmental Program Manager III Radiological Health Program Air and Radiation Management Adm .

Maryland Dept of the Environment 1800 Washington Blvd.

Baltimore, MD 21230-1720 Attn: eva.nair@maryland.gov

Trevor Clark U.S. Fish & Wildlife Service Chesapeake Bay Field Office 177 Admiral Cochrane Drive Annapolis, MD 21401 Attn: treyor clark@fws.gov

Environmental Protection and Sustainability Environmental Impact Review Jefferson Building 105 West Chesapeake Ave .

Suite 400 Towson, MD 21204 Email: eps@baltimorecountymd.gov

Endangered Species Coordinator NMFS Northeast Regional Office Protected Resources Division One Blackburn Drive Gloucester, MA 01930-2298 I ennifer.Anderson@noaa .gov

Joe Abe, Coastal Policies and Project Review Chesapeake & Coastal Service Maryland Department of Natural Resources 4 Tawes State Office Building E-2 580 Taylo r Avenue Annapolis , Maryland 21401 Phone: 41 0 -260 -8740 Attn: joseph.abe@maryland .gov

94 of 110 CR- 137, Supp l emental E n vironmen ta l Assessment and Findi ng of No Significant Impact Baltimore NOA submittal s

Maryland State Clearinghouse Maryland Office of Planning, Suite 1101 301 West Preston Street Baltimore , MD 21201 -2365 mdp,clearin~ouse@maryland.gov J Rodney Little - Director & SHPO Department of Planning Maryland Historical Trust - Crownsville Office 100 Community Place Crownsville, MD 21032 -2023 Phone 410-514-7601 RLtiitle@mdp.state.md.us Baltimore Port Alliance Pilot/Maritime Center Second Floor 3720 Dillon Street Baltimore , MD 21224 Attn  : info@baltimoreportalliance.org US Coast Guard Sector Maryland -Capitol Region D05-SMB-SECBALT-PSC@uscg.mil or Stephen.g,thompson@uscg.mil

The Propelle r Club of Baltimore Brian Greenbaum 3301 Edwards Lane Middle River , MD 21220 treasurer@propellerclubofbaltimore .com

95 of 110 CR-137 , Supplemental Environmental Assessment and Finding of No Significant Impact

From: Nancy I.ow!

To: "mdp.deannghpuse@marvland.gov" C.c: "krjstjne.gHson@dot.gov": "lalla,Hnares@dot.gov"; "Jill Ennght" subject: Draft Supplemental Environmental Assessment (EA) for dec:ommlsslonln the Nuclear Ship SAVANNAH (NSS)

[Maryland Department~ Plamlng Cleartnghouse Slate Appllc:atlon Identltler: MD20180627-0498]

Date: Thursday, March 21, 2019 2:53:00 PM Attachments: NS SAVANNAH Draft EA Revised 240CT2018 wjth appendjres.pdf

Maryland State Clearinghouse Maryland Office of Planning , Suite 110 I 301 West Preston Street Baltimore , MD 21201-2365 md p.clearinghouse@maryland.gov

To Whom It May Concern  :

In follow-up to our June 20 I 8 correspondence , I am writing to you on behalf of the Maritime Administration (MARAD) who has prepared a Draft Supplemental Environmental Assessment (EA) for a proposed project to fully decommission the Nuclear Ship SAVANNAH (NSS). This action will result in the termination of their nuclear license by the US Nuclear Regulatory Commission (NRC) under IO CFR Part 50 as a power generation reactor .

The attached Draft Supplemental EA is available for your review. If you have any questions or concerns please address them by April 21 , 20 I 9 to Ms . Kristine Gilson , REM , CHMM ,

MARAD Office of Environment , kristioe,gilson@dot.gov, 202-366-1939 .

Regards ,

Nanc y Love

Nancy D . Love , PG Environmental Scientist CGS - BMT JV, LLC

96 of 110 CR- 137 , Su pp lemental Environmental Asse ssment and Finding of N o Sig nificant Impact

From  : sytyja.mossermaryland,ooy To  : kristioe,oHson@dot.goy; Nancy Love Cc: sylvia,roosser@maryland,goy subject: Acknowledgment r:A Oeartnghouse Project: M020190322-0143 Data: Tuesday , March 26, 2019 2: 13:48 PM

Hello Ms. Kristine GIison & Ms. Nancy Love, The following link includes the State aearinghouse Review Process Acknowledgment letter for your project, Draft Supplemental Environmental Assessment (EA): Proposed Project to Fully Decommission the Nuclear Ship SAVANNAH (NSS) at Pier 13, Canton Marine Terminal In Baltimore City, MD; the Decommission will Result in Termination of the NSS' Nuclear License (Prior: MD20180627-0498).

Click this link to view the acknowledgment letter, http://apps.plannlng.maryland.gov/EMIRC_Flles/MD20190322-0143.zlp .

This is a 2 MB file.

Thank you .

Sylvia Mosser, Planner sylvla.mosser@maryland.gov 410-767-4487 Myra Barnes, Lead Clearinghouse Coordinator myra.bames@maryland.gov Please take our customer service survey,

97 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

APPENDIXC RECORD OF NON-APPLICABILITY (RONA)

C-1

98of110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact

APPENDIXC RECORD OF NON-APPLICABILITY (RONA) FOR CLEAN AIR ACT CONFORMITY MARITIME ADMINISTRATION NUCLEAR SHIP SAVANNAH DECOMMISSIONING Introduction The U.S. Environmental Protection Agency (EPA) published Determining Conformity of General Federal Actions to State or Federal Implementation Plans; Final Rule, 1n the 30 November 1993,

• Federal Register ( 40 C.F .It Parts 51 and 93). This publi.cation provides implementing guidance to docinnentClean Air Act (CAA) Conformity Determin*ation requirements.

• Federal regulations prohibit any Department, Agency, or instrumentality of the Federal Government to engage, support, provide financial assistance, license to permit, or approve any activity that does not conform to an applicable implementation plan. It is the responsibility of the Federal agency to determine whether a Federal action conforms to the applicable implementation plan before the action is taken (40 C._F.R. Part 51.8_50(a)).

F id.eral . actions may he exempt from a formai Conformity_ Determination if:. (1) the actions fit within one of the exemption categories or (2) their emissions do not exceed designated de minimis.

fevels for criteri~ ppll:utants (40 C.F:R. § 93.'153(c)),-Tbe exemption categ<;>ries apply to actions*

that would result in no emission increase or an increase in emission that is clearly de minimis.

Pn)pQsed Action .

• Action Proponent: U.S .. Department of Transportation Maritime* .Administration (MARAD).

Nuclear-Ship Savannah (NSS) is wholly owned by MARAD. The Nuclear Regulatory Commission

_ -fa the a1Jthority that grants the lic~ris_e_to MA.RAD. 1\\'.iARAD 1sresp9nsiblefor man~geinent of the vessel.

Location: The vessel is currently located at Pier 1-3~ Canton Marine Terminal in. Baltimore, MD.

Proposed Action Name: Decommissioning ofNSS

Proposed Action and Emission Summary:

The purpose of the Proposed Action is to decommission NSS. Four alternatives, including the no action alternative; are under consideration. The Proposed Action Alternatives would not require construction of new facilities because existing facilities have the capability of berthing a vessel of this size. As an inactive

• vessel, NSS would be towed from its current location to the decommissioning facility; no dredging is required. Each alternative is briefly discussed below.

Baltimore, MD, Alternative. This alternative would decommission NSS at a facility in Baltimore, MD in accordance with applicable Federal, state and local laws and regulations.

Hampton Roads, VA, Alternative. This, alternative would decommission NSS at a facility in Hampton Roads, VA. The vessel would be towed from its current location to a facility in Hampton Roads, VA, for decommissioned in accordance with applicabie Federal, state and local laws and regulations.

Philadelphia, PA Alternative. This alternative would decommission NSS at a facility in Philadelphia, PA. The vessel would be towed from its current location to a facility in Philadelphia, PA for decommissioning in accordance with applieable Federal, state and \\ocal laws and regulations.

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No-Action Alternative. The No-Action Alternative includes continued berthing of NSS at Baltimore, MD. Under the No-Action Alternative, existing conditions would remain unchanged and no emissions would be generated to trigger a Conformity Determination.

Pursuant to the National Ambient Air Quality Standards (NAAQS), Table 1 summarizes the attainment status for each alternative. Table 2 presents the de minimis levels for the applicable criteria pollutants.

Table 1. Attainment Status for Alternative Locations Location Attainment Status for Criteria Pollutants 1 B_al!imore, MD, Alternative Moderate non-attainment for the eight-hour ozone standard and maintenance for the PM2.s standard.

Hampton Roads, VA, Alternative Attainment for all criteria pollutants.

Philadelphia, PA Alternative Marginal non-attainment for the eight-hour _

ozone standard and attainment for the PMi.s

• • - .. .Standard: - . ..

Tabie 2. Applicable Criteria Poliutant de minimis Levels (Tons/Year) for Alternative Locations (40 C.F.R. ~ 93.153) .. ... - -

Location .voe NOx PM2.s*

Baltimore, MD, Alternative **--. 50 . .. ,. *

• 100 100

.. 100 100 Philadelphia; PA* Alternative .. .. 50

• The Proposed Action is *subject to the General Conformity* Rule because the project area is within

- -nonatta_inme'1t areas and the Proposed Action* will _cause air pollutant emissions. However, -the Proposed Action does not require construction, and the air pollutant emissions from towing are

• temporary and tlearly de minimis. According to 40 C.F.R. § 9t153(c), the Proposed Action qualifies for the foilowing exemption category: * - * - * * * - * * *

"(vii) Routine Movement of mobile assets, su~h as ships and aircraft, in homeport assignments and stations (when no new support facilities *or personnel are required) to perform as operational groups and/or for repair or overhaul."

The Baltimore, MD and Philadelphia, PA facilities are within nonattainment areas. Calculations o(the emissions from the tugs result in significantly less than one ton per year for each of VOC, NOx, and PM2.s. The towing to Baltimore, MD or Philadelphia, PA is less than the de minimis emission threshold.

In general, vessel decommissioning activities could result in temporary minor, _localized impacts to air quality, but are not expected to change designation of the area with respect to NAAQS.

Additionally, decommissioning activities that comply with applicable rules and regulations would not significantly affect air quality. The Baltimore, MD and Philadelphia, PA facilities have all required permits. The decommissioning of NSS would not represent a new or significantly different line of work for the facility, with different effects on the environment, but rather a continuation of a long term, ongoing program, with minimal surrounding effect.

1 The six criteria pollutants are ozone (03), CO,.NO2, PM, SO2, and lead {Pb).

100 of 110 CR-137, Supplemental Environmental Assess ment and Finding ofNo Significant Impact

In su mm ary , the Ba lti more , MD and Phi lade lphia, PA loca ti o ns are in nonattainm e nt areas, bu t MARAD is exempt from prepari ng a Con for mit y Determination because the action falls within o ne of the exemptio n categories a nd em issio ns from the towing act io n are considered de minimis.

o s ig nifica nt imp ac ts to air qua lity can be attributed to decomm issio ning activities. Deta il s of the a ir qua lity impact s a re pro v ided in th e SS Suppleme nta l Enviro nm en tal Assessment and uc lea r Reg ulatory Co mmi ss io n (N RC) Generic Env ironmenta l Impact State ment (GE IS) o n the decom mi ss io ning of nuc lear fac ilities. The Hampton Roads, VA locat io n is in attainment; th erefore , the CAA Ge nera l Con fonnity Rule does not app ly to these locations.

Affected Air Ba s in s: Ba ltimo re , MD and Philade lphia , PA Date RONA prepared: 8 August 2018 Proposed Action Exemption T he Pro posed Ac ti o n is loca ted within no natta inm e nt areas; th erefore, th e Pro posed Ac ti o n is not exe mpt fro m th e General Conformity Rule. However , per 40 C.F. R. § 93 . I 53(c) the Proposed Action qualifies as a *'ro utine move me nt" and fits within o ne of the EPA ' s exempti o n ca tegor ies .

Add itio nally , th e towin g to Baltimore, MD and Ph il ade lphia, PA is less th an th e de minimis emi ss io n thres ho ld . Vessel decommi ssioning acti v ities could res ult in tempo rary min or, localized impacts to a ir quality, but are not expected to change des ignation of th e area with respect to AAQS. Hampton Roads, VA is in attainment. T he refo re . the Pro posed Acti o n is exempt fro m a formal Confo rmit y Determi nation.

Attainment Area S tatu s and E mi ss io n Eva luati o n Co nclu s ion Baltimo re , MO is in a m oderate no nattai nm ent area for the 8-ho ur ozo ne standa rd and maintenance fo r PM 2 s standard ; VO Cs a nd Ox are precursors to the formati o n of ozo ne . Moreover, Philade lphia , PA is in a marg inal nona tta inm ent area fo r th e 8- hour ozone standard .

MARAD co nc ludes that the conformity requ iremen ts do not apply to the Pro posed Ac ti o n. Al Ba lt imore, MD , the po te ntial removal of th e vesse l is considered a " ro utine move ment" whic h wou ld res ult in a temp o rary increase o f marine vesse l e mi ss io ns tha t a re c le ar ly de minimis.

Mo reo er, th e vesse l em iss io ns e m it1 ed during tow to Pro posed Action loca ti ons fa ll we ll below the de minimis thres ho lds. Vessel decom mi ssion ing ac tivitie s th at comp ly with app li cab le rul es a nd reg ulatio n wou ld not s ig nificantl y affect air quality. 40 C.F. R. § 93 . I 53(c) s up po rts th e conc lu s io n th at th e de minim is thresho lds fo r a pplicable criteria po llutants wo uld not be exceeded as a res ult of imple menta tio n of th e Pro posed Action. Therefore, MA RAD conc ludes th at further fo rm a l Co n fo rmity Determinati o n procedures are not required, res ulting in this RONA .

RO NA Appro\\lal To th e best of m y kn ow ledge. th e informati o n presented in th is Record of Non-Appli cab il ity is correc t a nd accurate and I conc ur w ith the finding th at the Proposed Ac t io n docs no t req uire a fo rm a l Confo rmit y Deter min atio n.

MA~- - Date

IO I of 1 10 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

APPENDIXD PREPARERS

D-1

102 of 110 CR-137, Supplemental Environmental Assessment and Finding ofNo Significant Impact APPENDIXD

PREPARERS

This EA has been prepared by MARAD and CGS-BMT JV, LLC.

Members of the professional staff who contributed to the preparation of this document are listed below:

David Kindig, CGS-BMT N, LLC Senior Program Manager

Jill Enright, CGS-BMT JV, LLC Senior Technical Project Manager/NEPA Program Manager

Lauren Weissenborn, CGS-BMT JV, LLC Environmental Scientist

Susan Frey, CGS-BMT JV, LLC Environmental Scientist

103 of 110 CR-137, Supplemental Environmental Assessment and Finding of No Significant Impact Supplemental EA for Decommissioning of NS SAVANNAH

APPENDIXE REFERENCES

E-1

104 of 110 CR- 137, Supplemental Environmental Asse ssment and Finding of No Significant Impact APPENDIX E

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