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Ns Savannah License Amendment for Approval of License Termination Plan Cover Letter
	ML24334A030
Person / Time
Site:	NS Savannah
Issue date:	01/30/2025
From:	Tanya Hood; Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Koehler E; US Dept of Transportation, Maritime Admin
Shared Package
ML24334A022	List: ML24334A030; ML24334A031;
References
	Download: ML24334A030 (1)
	v • d • e

Mr. Erhard W. Koehler Senior Technical Advisor, N.S. Savannah U.S. Department of Transportation Maritime Administration (MAR-640.2) 1200 New Jersey Avenue, SE Washington, DC 20590-0001

SUBJECT:

NUCLEAR SHIP SAVANNAH - ISSUANCE OF AMENDMENT 19 TO FACILITY OPERATING LICENSE TO ADD LICENSE CONDITION TO INCLUDE LICENSE TERMINATION PLAN REQUIREMENTS (EPID L-2023-LLA-0151)

Dear Erhard W. Koehler:

The U.S. Nuclear Regulatory Commission (NRC) is issuing the enclosed Amendment No. 19 to Possession Only License No. NS-1 for the Nuclear Ship Savannah (NS Savannah or NSS). This amendment is in response to your application dated October 23, 2023 (Agencywide Documents Access and Management System Accession No. ML23298A041), as supplemented by letters dated June 27, 2024, October 16, 2024, and December 19, 2024 (ML24183A271, ML24292A030, ML24358A227, and ML24358A242 respectively), in which the United States Maritime Administration (MARAD, licensee), submitted a license amendment request to the NRC to approve NS Savannahs License Termination Plan (LTP) and add License Condition 2.C.(4) to include LTP requirements and establish criteria for determining when changes to the LTP require prior NRC approval.

The NS Savannah LTP provides the details of the licensees plan for characterizing, identifying, and remediating the remaining residual radioactivity at the NS Savannah site (i.e.,the ship) to a level that will allow the site to be released for unrestricted use. The NS Savannah LTP also describes how the licensee will confirm the extent and success of remediation through radiological surveys, provide financial assurance to complete decommissioning, and ensure that the environmental impacts of decommissioning activities are within the scope originally envisioned in the documented environmental evaluations for the site. The licensee anticipates requesting license termination to be effective in December 2025, provided all prerequisite actions are complete at that time.

This licensing action amends Possession Only License No. NS-1 for the NS Savannah to reflect approval of the NS Savannah LTP. Specifically, the amendment adds License Condition 2.C.(4),

which incorporates the approved NS Savannah LTP, and associated addendum, and establishes the criteria for determining when changes to the LTP require prior NRC approval.

The LTP will become a supplement to the licensees other decommissioning documents and will be implemented by the licensee to complete decommissioning activities at the NS Savannah.

Once decommissioning is complete, the licensee will need to submit a separate request to the NRC to terminate the NS Savannah license.

January 30, 2025

E. Koehler 2

A copy of the NRCs related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next monthly Federal Register notice of license amendments issued.

Sincerely, Tanya E. Hood, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No.: 50-238 License No.: NS-1

Enclosures:

1. Amendment No. 19 to NS-1

2. Safety Evaluation cc: Listserv Parrott, Jack signing on behalf of Hood, Tanya on 01/27/25

ML24334A022; Ltr ML24334A030

via email OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/RDB/PM NMSS/REFS/EPMB2/BC NAME THood JParrott RSun DATE 12/3/2024 12/26/2024 1/6/2025 OFFICE NMSS/REFS/ ETRB1 NMSS/REFS/FAB NMSS/DUWP/RDB/BC NAME MRome FMiller SAnderson DATE 1/7/2025 1/7/2025 1/10/2025 OFFICE NMSS/DUWP/RTAB/BC OGC - NLO*

NMSS/DUWP/D*

NAME CMcKenney KGeorgiev JMarshall DATE 1/13/2025 1/27/2025 1/30/2025 UNITED STATES MARITIME ADMINISTRATION DOCKET NO. 50-238 NUCLEAR SHIP SAVANNAH AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 19 License No. NS-1 1.

The Nuclear Regulatory Commission (the Commission or the NRC) has found that:

A.

The application for a license amendment filed by the United States Maritime Administration (MARAD, the licensee), dated October 23, 2023, as supplemented by letters dated June 27, 2024, October 16, 2024, and December 19, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and applicable portions of the Commissions regulations set forth in 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made; B.

The facility will be maintained in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amended license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, Possession Only License No. NS-1 is amended to add License Condition 2.C.(4) to read as follows:

2.C.(4) License Termination Plan (LTP)

MARAD shall implement and maintain in effect all provisions of the License Termination Plan (LTP), dated October 23, 2023, as supplemented by letters dated June 27, 2024, October 16, 2024, and December 19, 2024, as approved in License Amendment No. 19, subject to and as amended by the following stipulations. MARAD may make changes to the LTP without prior NRC approval provided the proposed changes do not meet any of the following criteria:

(a) Requires Commission approval pursuant to 10 CFR 50.59.

(b) Result in the potential for significant environmental impacts that have not previously been reviewed.

(c) Detract or negate the reasonable assurance that adequate funds will be available for decommissioning.

(d) Decrease a survey unit area classification (i.e., impacted to not impacted; Class 1 to Class 2; Class 2 to Class 3; or Class 1 to Class 3) without providing NRC a minimum 14 calendar day notification before implementing the change in classification.

(e) Increase the derived concentration guideline levels and related minimum detectable concentrations (MDCs) for both scan and fixed measurement methods. If MDCs are increased (relative to what was approved) the licensee should request NRC approval.

(f) Increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs.

(g) Change the statistical test applied to a test other than the Sign test. Note that the Wilcoxon Rank Sum test will not be used at the NSS.

(h) Increase the approved Type I decision error. Only Scenario A will be used in the FSS of the NSS. Therefore, changing the Type II error when using Scenario B is not applicable and does not require NRC approval.

(i) Change the approach used to demonstrate compliance with the dose criteria (e.g., change from demonstrating compliance using derived concentration levels to demonstrating compliance using a dose assessment that is based on final concentration data).

(j) Change parameter values or pathway dose conversion used to calculate the dose such that the resultant dose is lower than in the approved LTP and if a dose assessment is being used to demonstrate compliance with the dose criteria.

3.

This amended license is effective as of the date of issuance and authorizes a possession only license of the NS Savannah until the Commission notifies the licensee in writing that the license is terminated.

FOR THE NUCLEAR REGULATORY COMMISSION Jane E. Marshall, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

Attachment:

1. Changes to the Facility Operating License No. NS-1 Date of Issuance: January 30, 2025 Signed by Marshall, Jane on 01/30/25

ATTACHMENT TO LICENSE AMENDMENT NO. 19 FACILITY OPERATING LICENSE NS-1 NUCLEAR SHIP SAVANNAH DOCKET NO. 50-238 Amendment No. 19 License No. NS-1 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Facility Operating License No. NS-1 Remove Insert UNITED STATES MARITIME ADMINISTRATION DOCKET NO. 50-238 NUCLEAR SHIP SAVANNAH AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 19 License No. NS-1 4.

The Nuclear Regulatory Commission (the Commission or the NRC) has found that:

A.

The application for a license amendment filed by the United States Maritime Administration (MARAD, the licensee), dated October 23, 2023, as supplemented by letters dated June 27, 2024, October 16, 2024, and December 19, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and applicable portions of the Commissions regulations set forth in 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made; B.

The facility will be maintained in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amended license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The licensee is technically and financially qualified to engage in the activities authorized by this amended license in accordance with the rules and regulations of the Commission; E.

The licensee has complied with the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements, of the Commissions regulations; F.

The issuance of this amended license will not be inimical to the common defense and security or to the health and safety of the public; NS-1 Amendment No. 19 NS - 1 Amendment 19 G.

The possession and storage of the byproduct material as authorized by this amended license will be in accordance with the Commissions regulations in 10 CFR Part 30, including Section 30.33; H.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, Facility License No. NS-1 is hereby amended in its entirety to read as follows:

A.

This amended license applies to the facility owned by the U.S. Maritime Administration consisting of a pressurized water nuclear reactor (hereinafter the reactor) and the associated components and equipment, which are located aboard the NS Savannah, and are described in the application for license dated April 30, 1965, and amendments thereto.

B.

Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the U.S. Maritime Administration:

(1) Pursuant to Section 104b, of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, but not operate, the reactor as a utilization facility in accordance with the procedures and limitations set forth in this license; and (2) Pursuant to the Act and 10 CFR Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, to possess, but not to separate, such byproduct material as may have been produced by operation of the facility.

C.

This amended license shall be deemed to contain and is subject to the conditions specified in 10 CFR Chapter I, Part 20, Section 30.34 of Part 30 and Sections 50.54 and 50.59 of Part 50, and to all applicable provisions of the Act, and to the rules, regulations and orders of the Commission now or hereafter in effect and is subject to the following additional conditions:

(1) The licensee shall not reactivate the reactor without prior approval of the Commission; (2) Deleted per Amendment 15; (3) Technical Specification The Technical Specifications contained in Appendix A, as revised through Amendment No. 14, are hereby incorporated in the license. The licensee shall possess the facility in accordance with the Technical Specifications; NS - 1 Amendment 19 (4) License Termination Plan (LTP)