ML24157A096
| ML24157A096 | |
| Person / Time | |
|---|---|
| Site: | NS Savannah |
| Issue date: | 05/30/2024 |
| From: | Tanya Hood Reactor Decommissioning Branch |
| To: | Koehler E US Dept of Transportation, Office of Ship Operations |
| References | |
| EPID L-2023-LLA-0151 | |
| Download: ML24157A096 (1) | |
Text
REQUEST FOR ADDITIONAL INFORMATION RELATED TO SUBMITTAL AND REQUEST FOR APPROVAL OF THE LICENSE TERMINATION PLAN UNITED STATES MARITIME ADMINISTRATION NUCLEAR SHIP SAVANNAH DOCKET NO. 50238 EPID L2023LLA0151 By letter dated October 23, 2023 (Agencywide Documents Access and Management System Accession No. ML23298A041), United States Maritime Administration (MARAD, licensee),
submitted a license amendment for the Nuclear Ship Savannah (NS Savannah). The proposed amendment would modify the license to add License Condition 2.C.(4) to include License Termination Plan (LTP) requirements to the U.S. Nuclear Regulatory Commission (NRC) license for NS Savannah.
The NRC staff has reviewed the information submitted and determined that additional information is required to complete its review. To support the NRC staffs technical review of the LTP license amendment request pursuant to the regulations in Title 10 Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.82, Termination of license, please provide the additional information described in the specific requests for additional information (RAIs) listed below.
The NRC developed this set of RAIs using the regulations in 10 CFR 50.82, 10 CFR 51.45, Environmental report, 10 CFR 20.1402, Radiological criteria for unrestricted use, and the related guidance in NUREG1575, Revision 1, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (ML003761476), NUREG1700, Revision 2, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans (ML18116A124), NUREG1757, Volume 2, Revision 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria (ML22194A859), and the related guidance in Regulatory Guide (RG) 1.179, Revision 2, Standard Format and Content of LTPs for Nuclear Power Reactors (ML19128A067), in its review of the application.
RAI 21: Characterization Reports Basis:
The regulations in 10 CFR 50.82(a)(9)(ii) outline the required components of a LTP, which includes a site characterization. Applicable guidance on site characterization can be found in NUREG1700, Revision 2, Section 2.2, and NUREG1757, Volume 2, Revision 2, Section 4.
Guidance on scoping surveys can be found in NUREG1757, Volume 2, Revision 2, Section 4.3, and NUREG1575, Revision 1, Section 2.4 and 5.2.
Issue:
Section 2.4, Initial Classifications, of the LTP states that, during development of the LTP, MARAD completed reviews of the 2018 and 2019 characterization survey results compiled for the decommissioning.
Based on the above statement, and further statements regarding waste classification in Section 2.3.1, Activation Analysis in 2004, Section 2.3.3, RPV [Reactor Pressure Vessel],
Reactor Internals and NST [Neutron Shield Tank] Sampling in 2005, and Section 2.3.7, Sampling NST lead in 2021, of the LTP it is unclear to NRC staff whether these sampling and analysis programs were used to inform site characterization and development of radionuclides of concern (ROCs) or solely used for the purpose of waste classification.
In addition, Section 2.3.2, WPI Characterization in 2005, of the LTP discusses the shipwide radiological survey campaign conducted by WPI, a contractor, in 2005. The LTP states that as this characterization aged, MARAD determined that it effectively devolved into a scoping characterization that, at best, would provide insight into developing a new characterization performed much closer to actual decommissioning. However, Section 2.3.4, Characterization Activities in 2018, and Section 2.3.5, Characterization Activities in 2019, state that the intention of this work was not to repeat previous characterization efforts, but to fill in gaps and expand on characterization data in certain areas. It is unclear to NRC staff to what extent the 2005 WPI characterization informed later characterizations. The NRC staff wants assurance that there was a complete characterization effort identifying contamination in all impacted areas.
Request:
a) Clarify the purpose of the activation analysis in 2004, the RPV, Reactor Internals and NST sampling in 2005, and the NST lead sampling in 2021. Explain if they were used to inform site characterization and development of ROCs or solely used for the purpose of waste classification.
b) Clarify the purpose of the WPI characterization in 2005 and describe to what extent this was used to inform the 2018 and 2019 characterization efforts.
RAI 22: Initial Classifications Basis:
The regulations in 10 CFR 50.82(a)(9)(ii) outline the required components of a LTP, which includes a site characterization. Applicable guidance on site characterization can be found in NUREG1700, Revision 2, Section 2.2, and NUREG1757, Volume 2, Revision 2, Section 4.
Issue:
Table 28, 2018 Areas Surveyed, of the LTP lists the areas and systems surveyed during the 2018 characterization effort. Table 224, Initial Classification of Systems, and Table 225, Initial Classification of Structures or Rooms, list all initial classifications of NS Savannah areas and systems. Several locations listed in Table 28 do not appear to be captured in Table 224 and Table 225 including: Hold Deck, CRDM Pump Room, and NEWS Room bulk inventory.
The NRC staff wants assurance that there was a complete characterization effort identifying contamination in all impacted areas.
Request:
Explain the inconsistencies between the information provided in Table 28 and the information provided in Tables 224 and 225. Clarify if there are any other systems or areas not included in Table 224 and Table 225. If possible, include maps or drawings of the ship showing areas classified as impacted or non-impacted.
RAI 23: Continuing Characterization Basis:
The regulations in 10 CFR 50.82(a)(9)(ii) outline the required components of a LTP, which includes a site characterization. Applicable guidance on site characterization and characterization surveys can be found NUREG1575, NUREG1757, NUREG1700, and RG 1.179 that cover purpose, extent, and methods.
Issue:
Section 2.1.4, Other Considerations Regarding Site Characteristics and Characterization, of the LTP states that measurements and samples were taken in each accessible area. There is no further discussion of what, or if, further characterization remains in inaccessible areas, justification for those inaccessible areas, or plans for continuing characterization.
The NRC staff notes that continuing characterization should include verification of the ROCs, insignificant contributors, radionuclide fractions, and surrogate ratios.
Request:
Clarify if any inaccessible areas remain where characterization still needs to occur. If uncharacterized areas remain, provide plans for future characterization.
RAI 2-4: Volumetric Contamination Basis:
The regulations in 10 CFR 50.82(a)(9)(ii) outline the required components of a LTP, which includes a site characterization. Applicable guidance on site characterization can be found in NUREG1700, Revision 2, Section 2.2, and NUREG1757, Volume 2, Revision 2, Section 4.
Site characterization information is provided to determine the extent and range of radioactive contamination on site, including systems and components.
Issue:
Section 2.3.5 of the LTP states the results of internal system components surveys of systems inside Reactor Compartment/Containment Vessel only established removeable activity levels and not total activity or if radioactivity had penetrated material. The NRC staff is unsure what system components this is referring to and if those components will be removed as part of decommissioning and dismantlement activities.
While there appears to be some sampling of the NST done in 2005 as discussed in LTP Section 2.3.3, the NRC staff wants assurance that there was a complete characterization determining the extent and range of radioactive contamination anticipated to remain on site, including systems and components.
Request:
a) Clarify if the system components referred to in Section 2.3.5 of the LTP will be removed or remain in place after license termination.
b) If these, or any, impacted system components will remain in place, provide an evaluation for neutron activation of these components including activation products such as C-14, Ni-59, Ni-63, and Co-60. Provide data from a statistically significant number of samples to supplement the characterization data provided in the LTP.
c) Provide a discussion of how this additional characterization data affects radionuclides of concern, insignificant contributors, and/or surrogate ratios in your survey plans.
RAI 5-1: Radionuclides of Concern (ROCs)
Basis:
The regulations in 10 CFR 50.82(a)(9) requires a final status survey (FSS) plan. Applicable guidance in NUREG1757, Volume 2, and NUREG-1575, Revision 1, discuss FSS plans and identification of ROCs and insignificant contributors.
Issue:
Section 6.4, Radionuclides for Evaluation, of the LTP discusses the process for developing a list of ROCs for NS Savannah. The LTP states that 12 composite smear samples from the 2019 characterization report (CR-109) were sent to GEL Laboratories, LLC for analysis. Five of these smear samples were also analyzed for hard to detect ratios. Table 6-2, Initial Suite of Radionuclides, of the LTP contains an initial list of radionuclides of concern and their half-lives.
The LTP does not contain any technical justification for the selection of the initial suite of 8 radionuclides.
Table 6-3, Offsite Laboratory Results of Sample Analyses, of the LTP contains all analytes from the five samples sent to GEL laboratories. This table appears to be inconsistent with Table 6-2, as it contains three additional radionuclides (Ag-108m, Am-241, and Pu-239/240) than the list of initial radionuclides. It is not clear which list is representative of the initial suite of radionuclides nor the technical justification for excluding other radionuclides from the Derived Concentration Guideline Levels (DCGL) calculations.
The basis for selecting or deselecting radionuclides from the initial suite of radionuclides is not clear. NUREG/CR-3474 Long-lived Activation Products in Reactor Materials, (ML20097H412) and NUREG/CR-4289 Residual Radionuclide Contamination Within and Around Commercial Nuclear Power Plants, (ML20154M803) provide guidance on expected residual radionuclide contamination from nuclear reactors. It is not clear to the NRC staff how the licensee has chosen the initial suite of radionuclides (Table 6-2) or the basis for not including other radionuclides that may be present from reactor materials.
Clarification is needed of the licensees approach to selecting and deselecting ROCs which directly affect the demonstration of compliance with 10 CFR 20.1402.
Request:
a) Provide clarity on whether Table 6-2, Table 6-3, or some other list of radionuclides is indicative of the initial suite of radionuclides considered at the NS Savannah.
b) Discuss how MARAD considered data from its 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste, waste stream analysis when developing ROCs.
c) Provide technical justification for the deselection of radionuclides not listed in Tables 6-2 or 6-3.
RAI 5-2: Surrogate Ratios Basis:
The regulations in 10 CFR 50.82(a)(9) requires a FSS plan. Applicable guidance in NUREG1757, Volume 2, and NUREG-1575, Revision 1, discuss FSS plans and identification of ROCs and insignificant contributors.
Issue:
Section 6.13, Radionuclides of Concern and Insignificant Dose Contributors, of the LTP establishes the insignificant contributors along with their relative dose fractions for NS Savannah. Table 6-21, Relative Dose Fractions, of the LTP lists these relative dose fractions, and for the steam generator composite sample, shows that Ni-63 has a relative dose fraction of 8.12%.
Section 5.4.5.2, Surrogate Ratio DCGLs, of the LTP discusses the process to assess the need to use surrogate ratios for FSS and the equation used to calculate surrogate DCGLs. This section notes that no single radionuclide can be screened out if greater than or equal to 5% of the mix and the sum of all screened radionuclides cannot exceed 10%. Radionuclides not screened out require a surrogate DCGL (DCGLSurrogate).
It is unclear to NRC staff whether or not MARAD intends to establish a DCGLSurrogate for Ni-63, which has been dispositioned as an insignificant contributor even though it exceeds 5% of the dose in the mixture based on Table 6-21.
Request:
Clarify the sections from the LTP discussed above and state if MARAD intends to establish a DCGLSurrogate for Ni-63. If this is the case, include data and discussion for establishing an activity ratio between Ni-63 and an easy-to-detect radionuclide.
RAI 5-3: DCGL-elevated measurement comparison (DCGLEMC) and Area Factors Basis:
The regulations in 10 CFR 20.1402 requires radiological license termination criteria not to exceed 25 mrem/year and that the residual radioactivity be reduced to levels that are as low as reasonably achievable (ALARA). NUREG1757, Volume 2, and NUREG-1575, Revision 1, provide guidance on methods for demonstrating compliance with these criteria.
Issue:
Section 5.4.5.3, Elevated Measurement Comparison and Area Factors, of the LTP states that a review of the scanning minimum detection concentration (MDC) for the instruments to be used for the FSS show that they are a small fraction of the DCGLs. Therefore, no area factors have been calculated and the DCGL-elevated measurement comparison DCGLemc will not be used. In addition, Table 5-2, Investigation Levels, of the LTP shows that investigation levels for Class 1 and Class 2 areas are greater than operational DCGLW [DCGL-wide], while investigation levels for Class 3 areas are greater than 0.25 x operational DCGLW.
The NRC staff notes that, because no DCGLemc or area factors are being proposed, any measurements above DCGLw must be remediated.
Request:
Confirm plans are to remediate materials with measurements above the DCGLW until residual radioactivity is less than the DCGLw or provide instructions on how any elevated measurements will be addressed in demonstrating compliance with 10 CFR 20.1402.
RAI 5-4: Advanced Technologies Basis:
The regulations in 10 CFR 50.82(a)(9) requires a FSS plan. Applicable guidance in NUREG1757, Volume 2, and NUREG-1575, Revision 1, discuss FSS plans and survey methods.
Issue:
Sections 5.1, Introduction, and 5.7.1.3 Advanced Technologies, of the LTP state that MARAD does not expect to use advanced technologies for survey methods. Section 5.5, Final Status Survey Design Elements, of the LTP states that other advanced survey methods will be used for the FSS for the NS Savannah rooms and Class 1 and Class 2 Areas. Thus, there are conflicting statements in the LTP regarding the use of advanced technology survey methods.
Request:
Clarify whether advanced technologies, not found in NRCs guidance, will be used for surveys and, if so, describe what technologies are anticipated, how it will be utilized, and what will be the sensitivity of the technology for the ROCs.
RAI 6-1: Dose Models for Various Exposure Scenarios Basis:
The regulations in 10 CFR 20.1402 requires radiological license termination criteria not to exceed 25 mrem/year. Applicable guidance in NUREG1700, Revision 2, discusses characterization information to develop input for use in the dose modeling.
Issue:
Section 6, Compliance with the Radiological Criteria for License Termination, of the LTP notes multiple models were used to derive DCGL values for ROCs from different exposure scenarios.
These DCGL values that will be used in the demonstration of compliance with 10 CFR 20.1402.
NUREG1757, Volume 2, Revision 2, Section 5.3.2, indicates that licensees should provide input and output files or printouts for any computer programs that were used in the demonstration of compliance with that regulatory requirement.
Section 6.8, Tools Used for Calculations and Analyses, of the LTP mentions utilizing ModelRisk4.0 to model the surface contamination values for the remediation worker and component removal worker scenarios. In addition, Section 6.9.2, Remediation Worker on Ship, of the LTP mentions utilizing MicroShield dose point model for the exposure source for the remediation worker and component removal worker scenarios. MicroShield was also used to evaluate the external exposure for the scrapyard worker scenario. Since these are all conservative exposure scenarios for some radionuclides, validating these models is important to NRC Staff.
Request:
Please provide and discuss the:
a) ModelRisk4.0 model input and output files for the remediation and component removal worker scenarios b) MicroShield model for the external exposure scenario for the scrapyard worker.
RAI 6-2: Sensitivity Analyses and Parameter Selection Basis:
The regulations in 10 CFR 20.1402 requires radiological license termination criteria not to exceed 25 mrem/year. Applicable guidance in NUREG1700, Revision 2, discusses characterization information to develop input for use in the dose modeling.
Issue:
Section 6.9.4 Scrap Steel Scenarios in NUREG-1640, of the LTP notes that the source of external exposure for a scrap yard worker is a 3,500 ton pile of steel scrap. The LTP states that this model is reasonable and appropriate but does not further justify the selection of this mass for the model nor the risk significance of this parameter. It is unclear to the NRC staff if a qualitative or quantitative explanation of sensitivity analysis has been performed during parameter selection. Without an understanding of if sensitivity analyses have been performed
and/or which parameters were included in the sensitivity analysis with stochastic distributions and which distributions were correlated, the NRC staff is concerned that the DGCL values may be overestimated, allowing doses to exceed the dose limits. The NRC staff is seeking justification of selecting deterministic and probabilistic parameters, including the mass of the hemisphere used for external exposure modeling for the NUREG-1640 Scrapyard Worker scenario.
Request:
a) Clarify the extent sensitivity analysis was performed, if at all, to represent physical parameters with stochastic distributions for the various exposure scenarios selected (i.e.,
Scrap Yard/Foundry Worker, Leachate, and Component Removal Worker) b) Clarify the risk significance and technical justification for the mass of the hemisphere used for external exposure modeling for the NUREG-1640 Scrapyard Worker scenario.
RAI 8-1: Supplement to the Environmental Report Basis:
The regulations in 10 CFR 50.82(a)(9)(ii)(G), requires a supplement to the environmental report describing any new information or significant environmental change associated with the licensee's proposed termination activities.
Issue:
In Chapter 8, Supplement to the Environmental Report, of the LTP, the licensee concludes that there is no new information or significant environmental changes based on previous environmental analyses conducted by MARAD in support of decommissioning decision-making.
MARAD submitted the 2008 Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) to the NRC on October 3, 2008 (ML082810182). The 2019 Supplemental EA and FONSI is mentioned in the LTP, however, the document has not been submitted on the docket.
Request:
Submit the latest Supplemental EA and FONSI to the NRC.
RAI 8-2: Waste Management Basis:
The regulations in 10 CFR 51.45(b) outline the required components of the environmental report and discuss, in part, the impact of the proposed action on the environment. The information is necessary to analyze the impacts from waste management activities.
Issue:
Chapter 3, Identification of Remaining Site Dismantlement Activities, of the LTP summarizes the activities that MARAD has completed as well as the remaining decommissioning activities.
MARAD has identified the EnergySolutions facility in Clive, Utah, the EnergySolutions facility in
Erwin, Tennessee, and the Waste Control Specialists facility in Texas as potential sites for waste disposal. While MARADs annual reports submitted to the NRC list the systems and components that MARAD has disposed of and the amount of waste disposed, it is unclear where the waste was disposed of.
Request:
a) Confirm the disposal facilities where MARAD disposed of the solid and liquid waste for the systems and components identified above.
b) Clarify whether the decommissioning activities described in the LTP will generate or not generate low level waste Class B and Class C, and Greater-Than-Class C (GTCC) waste. If Class B and Class C low level waste, and GTCC waste will be generated, provide the amount and identify where the waste would be disposed of.
RAI 8-3: Air Quality Basis:
The regulations in 10 CFR 51.45(d) requires the environmental report to list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action and shall describe the status of compliance with these requirements.
Issue:
The NRC staff needs a description of the sources of air emissions during the decommissioning activities described in the LTP.
Request:
Describe the sources of air emissions and confirm whether MARAD is required to obtain an air quality permit from the State of Maryland to address these air emission sources. If MARAD has an air quality operating permit, provide a copy to NRC.
RAI 8-4: Water Resources Basis:
The regulations in Section 307(c) of the Coastal Zone Management Act (CZMA) requires that all Federal actions that may have reasonably foreseeable effects on the uses or resources of a states coastal zone be consistent with the enforceable policies of the states coastal management plans. Specifically, the CZMA requires that applicants certify to the licensing agency that the proposed activity would be consistent with the states coastal management plan.
Issue:
In its environmental assessments, MARAD concludes that the proposed action would not have an impact on any coastal use or natural resources of the coastal zone. MARAD also appended correspondence between potentially interested local, state, and Federal agencies including the U.S. Fish and Wildlife, the U.S. National Oceanic and Atmospheric Administration, the U.S.
National Marine Fisheries Service, and the State of Maryland, related to other permits, licenses, approvals, or consultations. However, it is unclear from the documentation, including the response from Marylands Clearinghouse, whether MARAD and the State of Maryland reached a conclusion regarding consistency with the states coastal management plan, or the requirement has been waived.
Request:
Confirm and provide documentation in support of the CZMA consistency determination.
RAI 8-5: Water Resources Basis:
The regulations in 10 CFR 51.45(d) requires the environmental report to list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action and shall describe the status of compliance with these requirements.
Issue:
In its 2008 EA, MARAD acknowledges that the only wastewater that could be generated from the decommissioning activities would be if water is used as a cleaning medium, but anticipates wastewater to be minimal. In its LTP, MARAD lists techniques, such as washing and wiping and pressure washing, to reduce surface contamination. However, MARAD does not explain how wastewater would be managed during the conduct of the decommissioning activities described in the LTP.
Request:
Explain how MARAD plans to manage wastewater during the conduct of the decommissioning activities described in the LTP, and whether MARAD has National Pollutant Discharge Elimination System permits, or other relevant wastewater management permits, for the NS Savannah. If so, provide a copy of the permit(s).
RAI 8-6: Ecological Resources Basis:
The regulations in Section 7 of the Endangered Species Act requires Federal agencies to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service regarding actions that may affect listed species or designated critical habitats.
Issue:
In Table 3-2, Biological Resource Impact Summary, of the 2019 Supplemental EA and FONSI, MARAD concludes that the impact to protected species for each of the three alternatives (Baltimore, MD; Hamptons Roads, VA; and Philadelphia, PA) is: may affect but not likely to adversely affect and no reasonably foreseeable takes.
Request:
a) Submit MARADs 2019 Supplemental EA and FONSI to the NRC.
b) Clarify what Federally listed or proposed species this conclusion applies to.
c) Provide documentation of the National Marine Fisheries Service and/or U.S. Fish and Wildlife Service concurrence with this finding, which MARAD would have sought in accordance with 50 CFR 402.13(c).
d) Explain whether the proposed action requires any vessel traffic to or from the NS Savannah. If so, describe the frequency of such vessel traffic, the potential impacts of vessel traffic on federally listed sea turtles and sturgeon, and any best management practices that would be implemented to reduce or avoid impacts.
RAI 8-7: Socioeconomics Basis:
The regulations in 10 CFR 51.45(b) outline the required components of the environmental report and discuss, in part, the impact of the proposed action on the environment. The information required is necessary to analyze the socioeconomic impacts, transportation impacts, and impacts to air quality.
Issue:
In its LTP, MARAD concludes that the decommissioning of the NS Savannah would not have a negative effect on the state, local and regional economy, housing, or community services.
However, no information is provided about the number of workers (including contractors) supporting the decommissioning activities.
Request:
Provide an estimate of the number workers (including contractors) that are directly and indirectly supporting the decommissioning activities at the NS Savannah. Also, provide an estimate of the number of workers that would remain after MARAD completes decommissioning and the NRC terminates the license.
RAI 8-8: Transportation Basis:
The regulations in 10 CFR 51.45(b) outline the required components of the environmental report and discuss, in part, the impact of the proposed action on the environment. The information required is necessary to analyze the transportation impacts and impacts to air quality.
Issue:
In its LTP, MARAD concludes that the decommissioning of the NS Savannah would not result in increased traffic or number of personnel at the vessels current location or the decommissioning
facilities locations. However, no information is provided about the number of shipments via truck, rail, or barge over the course of decommissioning.
Request:
a) Provide an estimate of the number of waste shipments via rail, truck, or barge over the course of decommissioning.
b) Discuss the potential impacts of waste shipments via rail, truck, or barge in light of the identified waste disposal sites in the LTP (e.g., EnergySolutions facility in Utah and Tennessee).