ML24351A024

Environmental Assessment for the License Termination Plan for the Nuclear Ship Savannah in Baltimore, Maryland

ML24351A024
Person / Time
Site:	NS Savannah
Issue date:	12/19/2024
From:	NRC/NMSS/DREFS
To:
References
EAXX-429-00-000-1734414149
Download: ML24351A024 (63)

Text

Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards ML24351A024 EAXX-429-00-000-1734414149 Environmental Assessment for the License Termination Plan for the Nuclear Ship Savannah in Baltimore, Maryland Docket Number: 50-238 Issued: December 2024

Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards

i Table of Contents ABBREVIATIONS AND ACRONYMS......................................................................................... v 1

INTRODUCTION.............................................................................................................. 1-1 1.1 Description of the Proposed Action.......................................................................... 1-4 1.2 Purpose of and Need for the Proposed Action......................................................... 1-4 1.3 Scope of the Environmental Analysis....................................................................... 1-4 1.3.1 MARADs Supplement to the Environmental Report.................................... 1-4 1.3.2 NRCs Decommissioning GEIS.................................................................... 1-6 2

PROPOSED ACTION AND ALTERNATIVES................................................................. 2-5 2.1 Proposed Action....................................................................................................... 2-5 2.1.1 NS Savannah............................................................................................... 2-5 2.1.2 Port of Baltimore........................................................................................... 2-7 2.1.3 Decommissioning Activities.......................................................................... 2-7 2.2 Alternatives............................................................................................................... 2-9 2.2.1 No-Action Alternative.................................................................................... 2-9 2.2.2 Alternative Sites............................................................................................ 2-9 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS................................. 3-1 3.1 Land Use.................................................................................................................. 3-1 3.1.1 Land Use including Site Description and Vicinity......................................... 3-1 3.1.2 Land Use Direct and Indirect Impacts.......................................................... 3-2 3.2 Visual and Scenic Resources/Aesthetics................................................................. 3-3 3.2.1 Description of the Visual and Scenic Affected Environment......................... 3-3 3.2.2 Visual and Scenic Resources Direct and Indirect Impacts........................... 3-3 3.3 Climatology, Meteorology, and Air Quality............................................................... 3-3 3.3.1 Climatology and Meteorology....................................................................... 3-3 3.3.2 Air Quality..................................................................................................... 3-4 3.3.3 Air Quality Direct and Indirect Impacts......................................................... 3-5 3.3.4 Greenhouse Gases and Climate Change..................................................... 3-6 3.4 Noise..................................................................................................................... 3-7 3.4.1 Noise Levels................................................................................................. 3-7 3.4.2 Noise Direct and Indirect Impacts................................................................. 3-7

ii 3.5 Geology and Soils.................................................................................................... 3-7 3.5.1 Regional and Site-Specific Geology............................................................. 3-7 3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts....... 3-7 3.6 Water Resources...................................................................................................... 3-8 3.6.1 Surface Water............................................................................................... 3-8 3.6.2 Groundwater............................................................................................... 3-10 3.7 Historic and Cultural Resources............................................................................. 3-10 3.7.1 Historic and Cultural Resources................................................................. 3-10 3.7.2 Historic and Cultural Resources Direct and Indirect Impacts..................... 3-11 3.8 Ecological Resources............................................................................................. 3-12 3.8.1 Terrestrial Resources................................................................................. 3-12 3.8.2 Aquatic Resources..................................................................................... 3-15 3.9 Socioeconomics..................................................................................................... 3-19 3.9.1 Socioeconomic Characteristics of the Site Vicinity..................................... 3-19 3.9.2 Socioeconomic Direct and Indirect Impacts............................................... 3-21 3.10 Public and Occupational Health............................................................................. 3-22 3.10.1 Existing Radiological Conditions................................................................ 3-22 3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts....................................................................................................... 3-23 3.10.3 Non-Radiological Impacts........................................................................... 3-24 3.11 Transportation........................................................................................................ 3-25 3.11.1 Transportation Affected Environment......................................................... 3-25 3.11.2 Transportation Direct and Indirect Impacts................................................. 3-25 3.12 Environmental Justice............................................................................................ 3-26 3.12.1 Minority and Low-income Populations in the Vicinity of NSS..................... 3-26 3.12.2 Impacts....................................................................................................... 3-27 3.13 Waste Management............................................................................................... 3-28 3.13.1 Radioactive Waste...................................................................................... 3-28 3.13.2 Nonradioactive Waste................................................................................ 3-30 3.13.3 Waste Management Direct and Indirect Impacts........................................ 3-30 3.14 Cumulative Effects................................................................................................. 3-30 4

CONSULTATION AND COORDINATION..................................................................... 4-33

iii 4.1 State Review.......................................................................................................... 4-33 4.2 National Historic Preservation Act Section 106 Consultation................................. 4-33 4.3 Endangered Species Act Section 7 Consultation................................................... 4-33 5

CONCLUSIONS AND FINDING OF NO SIGNIFICANT IMPACT................................... 5-1 6

LIST OF PREPARERS.................................................................................................... 6-1 7

REFERENCES................................................................................................................. 7-2

iv List of Figures Figure 1-1 Sideview of NSS...................................................................................................... 1-1 Figure 1-2 MARADs Overall Schedule for License Termination............................................... 1-3 Figure 2-1 NSS Location and Immediate Surrounding............................................................. 2-6 Figure 2-2 NSS at Pier 13, looking northwest........................................................................... 2-6 Figure 3-1 NSS at Pier 13, looking northeast........................................................................... 3-1 Figure 3-2 NSS at Pier 13, looking northwest........................................................................... 3-2 Figure 3-3 Geographic Scope................................................................................................. 3-20 List of Tables Table 2-1 NSS Dimensions........................................................................................................ 2-5 Table 3-1 Federally Listed Terrestrial Species at NSS and in the Vicinity............................... 3-13 Table 3-2 State-Listed Terrestrial Species in Baltimore City................................................... 3-14 Table 3-3 Federally Listed Aquatic Species in the Action Area............................................... 3-16 Table 3-4 State-Listed Aquatic Species in Maryland............................................................... 3-16 Table 3-5 Demographics.......................................................................................................... 3-20

v ABBREVIATIONS AND ACRONYMS

°C degrees Celsius

°F degrees Fahrenheit ALARA as low as is reasonably achievable BMP best management practices CFR Code of Federal Regulations CRD control rod drive DCGL derived concentration guideline levels DOT U.S. Department of Transportation EA Environmental Assessment EPA U.S. Environmental Protection Agency ESA Endangered Species Act of 1973 FONSI Finding of No Significant Impact FR Federal Register ft foot (feet) ft2 square feet FTT Fuel Transfer Tank FWS U.S. Fish and Wildlife Service GCRP U.S. Global Change Research Program GEIS Generic Environmental Impact Statement GHG greenhouse gases GTCC Greater-than-Class-C (waste) ha hectare(s) in inch(es) km kilometer(s)

LLRW low-level radioactive waste LTP License Termination Plan m

meter(s) m2 square meters mi mile(s)

MARAD Maritime Administration MBTA Migratory Bird Treaty Act of 1918 MDNR Maryland Department of Natural Resources MPA Marylands Port Administration MWth megawatt thermal mrem millirem mSv millisievert NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act of 1969 NHPA National Historic Preservation Act of 1966

vi NST Neutron Shield Tank NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NRHP National Register of Historic Places NPS U.S. National Park Service NSS Nuclear Ship Savannah PA Programmatic Agreement PCB Polychlorinated Biphenyls PSDAR Post Shutdown Decommissioning Activities Report PWR pressurized-water reactor RAI Request for Additional Information RCA radiologically contaminated area RPP Radiation Protection Program RPV Reactor Pressure Vessel SER Safety Evaluation Report Sv Sievert TEDE Total Effective Dose Equivalent U.S.

United States USCB U.S. Census Bureau yr year(s)

1-1 1

INTRODUCTION By letter dated October 23, 2023, the United States (U.S.) Department of Transportation (DOT)

Maritime Administration (MARAD), the licensee, submitted an application to the U.S. Nuclear Regulatory Commission (NRC or Commission) requesting a license amendment to approve the License Termination Plan (LTP) for the Nuclear Ship Savannah (NSS), located at Pier 13, Canton Marine Terminal in Baltimore, Maryland (MARAD 2023b).

NSS is the worlds first nuclear-powered merchant ship (see figure 1-1) (MARAD 2023b). It was constructed and operated as a joint project between MARAD and the U.S. Atomic Energy Commission to demonstrate the commitment of the United States to the peaceful use of atomic energy. MARAD owns NSS and holds NRC license No. NS-1, Docket No. 50-238, for the ship.

Figure 1-1 Sideview of NSS (Modified from MARAD 2008a)

NSS operated from 1962 through 1970 with an 80-megawatt thermal (MWth) pressurized-water reactor (PWR). The ship ceased operations in 1970 and was defueled in 1971 (MARAD 2008a).

In 1976, following removal of all high-level radioactive components and material from the nuclear systems and modifications to make the nuclear power plant inoperable, the license was changed to a possession-only license. The ship operated as a museum from 1981 to 1994 at the Patriots Point Naval and Maritime Museum in Mount Pleasant, South Carolina. In 1983, the ship was listed in the National Register of Historic Places (NRHP). In 1991, the ship was designated as a National Historic Landmark of the United States. In 1994, MARAD placed the ship in protective storage at the James River Reserve Fleet, Ft. Eustis, Virginia, and in 2008, the ship was moved to Pier 13, Canton Marine Terminal, in Baltimore, Maryland (MARAD 2023b).

On December 11, 2008, MARAD submitted the Post Shutdown Decommissioning Activities Report (PSDAR), Revision 1 (MARAD 2008b). On March 11, 2009, the NRC staff conducted a public meeting at Pier 13, Canton Marine Terminal, in Baltimore to discuss and accept public questions and comments on the PSDAR (NRC 2009b). On April 23, 2018, the NRC amended license NS-1 to allow dismantlement and disposal of the ship without prior approval of the NRC (i.e., active decommissioning) (NRC 2018).

1-2 Submittal of the LTP is one of the final steps in the NRCs nuclear power reactor decommissioning process, which involves the safe removal of a facility from service and the reduction of residual radioactivity to a level that permits NRC license termination. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82, Termination of license, promulgates the requirements for terminating power reactor licenses. Those requirements specify what must be included in a licensees LTP when submitted to the NRC for review and approval. The LTP describes the process the licensee will use to meet the requirements for terminating the license and releasing the site for unrestricted use.

In accordance with 10 CFR 50.82(a)(9), by letter dated October 23, 2023, MARAD submitted an application to the NRC requesting a license amendment to approve the LTP for NSS. If the NRC staff approve the LTP and amend MARADs license, the NRC staff would add a condition to the license reflecting NRCs approval of the LTP and establishing criteria for determining when changes to the LTP require prior NRC approval. Chapter 10 of the LTP (MARAD 2023b) describes the proposed changes that MARAD would take without NRC approval if the NRC approves the LTP as submitted.

MARADs goal is to terminate the 10 CFR 50 license and release NSS for unrestricted use in accordance with 10 CFR 20, Standards for Protection Against Radiation, after meeting the performance-based criteria for unrestricted use in 10 CFR 20.1402, Radiological criteria for unrestricted use. (MARAD 2023b). This criterion, as specified by 10 CFR 20.1402, is:

A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a [total effective dose equivalent]

TEDE[1] to an average member of the critical group that does not exceed 25 millirem (mrem) (0.25 milliSievert [mSv]) per year (yr), including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA). Determination of the levels which are ALARA must take into account consideration of any detriments, such as deaths from transportation accidents, expected to potentially result from decontamination and waste disposal.

MARAD anticipates decommissioning and terminating the license by December 2031 (i.e., no later than 60 years after permanent cessation of operations). Accordingly, MARAD plans on requesting license termination to be effective in December 2025 (MARAD 2023b). Once decommissioning has been completed, the NRC license has been terminated, and NSS has been released for unrestricted use, MARAD will proceed with disposition of the vessel. Figure 1-2 shows MARADs overall schedule for license termination. Chapter 6 of the LTP (MARAD 2023b) describes the end-state scenarios (disposition options) that MARAD could pursue including preservation, destruction by dismantlement (shipbreaking/scrapping), and artificial reefing.2 1 10 CFR 20.1003 defines TEDE as the sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). Dose equivalent means the product of the absorbed dose in tissue, quality factor, and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and Sv.

2 While disposition of the vessel is not subject to NRCs jurisdiction, the NRC staff considered the environmental impacts in the cumulative effects analysis in this environmental assessment (EA).

1-3 Figure 1-2 MARADs Overall Schedule for License Termination (Source: MARAD 2023b)

If the NRC determines the LTP demonstrates that the remainder of the decommissioning activities will be performed in accordance with NRCs regulations, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment, and after notice to interested persons, the NRC will approve the LTP by license amendment [see 10 CFR 50.82(a)(10)]. The NRC staffs review and approval of the LTP is the regulatory mechanism by which the NRC ensures that final decommissioning activities are appropriately completed. As part of the LTP review process, the NRC staff will determine whether MARADs proposed procedures and activities for completing decommissioning (e.g., adequacy of radiation release criteria and adequacy of the design of the final radiation survey) are sufficient as described in the LTP.

On December 15, 2023, the NRC staff accepted the license amendment request and LTP for detailed review (NRC 2023). On May 8, 2024, the NRC held a hybrid public meeting related to the LTP request at NSS. The NRC staff discussed the overall decommissioning process, the LTP review process, and took questions and comments from the public on the LTP (NRC 2024b).

The NRC staff prepared this environmental assessment (EA) consistent with NRCs regulations at 10 CFR 51, Environmental protection regulations for domestic licensing and related regulatory functions, which implement the National Environmental Policy Act (NEPA) of 1969.

This EA evaluates and documents the potential environmental impacts that would result from the NRCs approval of MARADs license amendment request and the subsequent implementation of the LTP.

Additionally, because the ship is a National Historic Landmark, MARAD developed a balanced approach to achieve both compliance with decommissioning and license termination requirements and preservation goals consistent with the National Historic Preservation Act of 1966 (NHPA). This approach includes an executed programmatic agreement (PA), to which the NRC is a signatory. The purpose of the PA, executed in March 2023, is to facilitate preservation Additionally, to demonstrate compliance with the unrestricted use criteria, MARAD considered several exposure scenarios based on these disposal options.

1-4 of NSS during decommissioning, license termination, and final disposition. Execution of the PA documents compliance with MARAD and NRCs obligations under the NHPA (MARAD 2023a).

The NRC staff is also performing a detailed safety analysis of MARADs license amendment request. The results of the safety analysis will be documented in a separate safety evaluation report (SER). The NRCs decision whether to approve the license amendment request will be based on the results of the NRC staffs review as documented in this EA and the SER.

1.1 Description of the Proposed Action The proposed action is the NRC staffs review and, if appropriate, approval of MARADs LTP for NSS located in Pier 13, Canton Marine Terminal, in Baltimore, Maryland. In accordance with 10 CFR 50.82(a)(9), MARAD chose to submit its LTP before submitting an application to terminate the license. If approved by the NRC, the NSS license will be amended by adding a license condition that documents approval of the LTP and stipulating the changes that MARAD can make to the LTP without prior NRC approval. These proposed changes are described in Chapter 10 of MARADs LTP (MARAD 2023b). After NRCs approval, MARAD would implement the LTP to NSS to complete decommissioning activities. Once decommissioning is complete, MARAD plans to submit a request to the NRC to terminate the license.

1.2 Purpose of and Need for the Proposed Action The purpose of and need for the proposed action is to authorize MARAD to complete decommissioning of NSS to meet the unrestricted use criteria as specified in 10 CFR 20.1402. If the NRC approves the LTP and amends the license, MARAD would proceed to complete decommissioning, followed by a request to terminate the NSS license. Upon NRCs termination of the license, MARAD would proceed to disposition the ship (e.g., preservation, shipbreaking, or artificial reefing) consistent with the process established in the PA executed in accordance with the NHPA (MARAD 2023a).

1.3 Scope of the Environmental Analysis To fulfill its obligations under NEPA, the NRC must evaluate the radiological and non-radiological environmental impacts associated with approval of MARADs LTP. These evaluations involve an assessment of the impacts of remaining decommissioning and license activities documented in the LTP.

1.3.1 MARADs Supplement to the Environmental Report In accordance with 10 CFR 50.82(a)(9), the LTP must include a supplement to the environmental report, pursuant to § 51.53, describing any new information or significant environmental change associated with the licensee's proposed termination activities; [see 10 CFR 50.82(a)(9)(ii)(G)]. In Chapter 8 of the LTP, Supplement to the Environmental Report, MARAD concludes that there is no new information or significant environmental changes based on previous environmental analyses conducted in support of decommissioning decision-making (MARAD 2023b). These analyses include MARADs 2008 EA and Finding of No Significant Impact (FONSI) (MARAD 2008a) and 2019 Supplemental EA and FONSI (MARAD 2019), which in MARADs view, in combination with Chapter 8 of the LTP, constitute the environmental report for post operating license stage required per 10 CFR 51.53(d).

1-5 MARAD, as a Federal agency subject to NEPA, published an EA and FONSI in 2008 in support of its decision to decommission NSS. The 2008 EA evaluated the environmental impacts from the decommissioning methods SAFSTOR3 and DECON,4 and the no-action alternative5 (MARAD 2008a). In developing the EA, MARAD relied on the NRCs NUREG-0586, Supplement 1, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (Decommissioning GEIS) (NRC 2002). To evaluate the environmental impacts of the decommissioning, MARAD considered an east coast port city (e.g., Hampton Roads, Virginia; Baltimore, Maryland; and Charleston, Sout Carolina) with existing industrial facilities, including transportation infrastructure to waste disposal facilities (MARAD 2008a). The EA considered impacts on air quality, water quality, navigation, hazardous materials, public health and safety, socioeconomics and environmental justice, coastal resources, wildlife and vegetation, and historic resources. The EAs preferred method for decommissioning NSS was the DECON approach. Based on the EA, MARAD published a FONSI in the Federal Register (FR) on May 14, 2008 (73 FR 27888).

On December 11, 2008, MARAD submitted the PSDAR, Revision 1 to the NRC (MARAD 2008b). Consistent with 10 CFR 50.82(a)(4)(i), MARAD discussed the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements. MARADs conclusion in the PSDAR is based on its 2008 EA and FONSI.

In 2019, MARAD supplemented the 2008 EA to: (1) account for the time that had passed since the issuance of the initial EA in 2008, (2) further evaluate the impacts from the DECON method, and (3) evaluate alternative locations to carry out the DECON activities (MARAD 2019). The 2019 Supplemental EA evaluated the impacts from the DECON activities on the following five environmental resource areas at three ports (Baltimore, Maryland; Philadelphia, Pennsylvania; and Hampton Roads, Virgina): (1) water resources, (2) biological resources, (3) air quality, (4) waste management, and (5) health and safety. MARAD also evaluated the no-action alternative.6 MARAD selected these three locations because all have the infrastructure necessary to support decommissioning of the ship and, thus, would not require construction of new facilities or dredging7 (MARAD 2023b). MARAD did not identify significant impacts on human health or the environment from the decommissioning using the DECON method at any of the locations, except for impacts to the ship itself because of its National Historic Landmark 3 The Glossary of the Decommissioning GEIS defines SAFSTOR as [a] method of decommissioning in which the nuclear facility is placed and maintained in a safe stable condition for a number of years until it is subsequently decontaminated and dismantled to levels that permit license termination. During SAFSTOR, a facility is left intact, but the fuel has been removed from the reactor vessel and radioactive liquids have been drained from systems and components and then processed. Radioactive decay occurs during SAFSTOR period, thus, reducing the quantity of contaminated and radioactive material that must be disposed of during decontamination and dismantlement (NRC 2002).

4 The Glossary of the Decommissioning GEIS defines DECON as [an] option for decommissioning in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits termination of the license shortly after cessation of operations (NRC 2002).

5 The no-action alternative discussed in MARADs 2008 EA involves returning the vessel to the reserve fleet without any decommissioning actions, which MARAD did not consider feasible (MARAD 2008a).

6 In its 2019 supplemental EA, MARAD determined that the no-action alternative does not meet MARAD's mission objectives and may result in future significant unplanned and unbudgeted expense (MARAD 2019).

7 Dredging is the removal of sediments and debris from the bottom of lakes, rivers, harbors, and other water bodies.

1-6 status. MARADs preferred alternative is to carry out the DECON work at the Baltimore, Maryland, port because the ship is already docked there, minimizing potential environmental impacts from towing the vessel to an alternative location (84 FR 10576).

Additionally, on June 27 and October 16, 2024, MARAD submitted responses (MARAD 2024b and MARAD 2024c, respectively) to the NRCs requests for additional information (RAIs) (NRC 2024a and NRC 2024c) in support of the safety and environmental reviews for the LTP.

To limit redundancy, to the extent possible, the NRC staff uses the technique of incorporation by reference throughout this EA. Specifically, the NRC staff incorporates by reference, where appropriate, evaluations in MARADs 2008 EA and FONSI and 2019 Supplemental EA and FONSI. Further, to address adverse effects on NSS from decommissioning, license termination, and disposition of NSS, consistent with Section 110(f) of the NHPA, MARAD executed a PA (MARAD 2023a) in March 2023. The PA documents MARADs compliance with its obligations under the NHPA. Because the NRC is a signatory to the PA, NRCs obligations under the NHPA for the review and approval, if appropriate, of MARADs LTP are also satisfied. The 2023 PA is, thus, also incorporated by reference in this EA.

1.3.2 NRCs Decommissioning GEIS The NRC previously evaluated the potential environmental impacts of nuclear reactor decommissioning in the Decommissioning GEIS (NRC 2002). The Decommissioning GElS is considered generic in that it evaluates environmental impacts from decommissioning activities common to nuclear power reactor facilities, including PWRs, boiling-water reactors, and multiple reactor stations. The generic analysis was based, in part, on experience with reactors that had already undergone or were undergoing decommissioning.

The scope of the Decommissioning GEIS includes decommissioning activities from the time that a licensee certifies it has permanently ceased power operations until the license is terminated.

In the Decommissioning GEIS, the NRC staff concluded that the environmental impacts of decommissioning, including license termination activities, can be determined generically for all nuclear power plants and will have SMALL impacts8 in all but six environmental resource areas.

The NRC staff concluded that two of these six resource areas (i.e., threatened and endangered species and environmental justice) must always be evaluated on a site-specific basis in site-specific EAs, such as this EA for the NSS LTP. Depending on the site-specific circumstances, the following four additional resource areas are conditionally site-specific: (1) off-site land use, (2) historic and cultural resources, (3) terrestrial ecology beyond the operational area, and (4) aquatic ecology beyond the operational area (NRC 2002).

While NSS is not a nuclear power plant in the traditional sense, the ship was powered by an 80 MWth PWR. MARAD also used the Decommissioning GEIS, where appropriate, during the preparation of its 2008 EA (MARAD 2008a). The NRC staff agrees that the Decommissioning GEIS is partially applicable to the decommissioning of NSS. Where the NRC staff used the Decommissioning GEIS to bound the potential environmental impacts of the proposed action, 8 NRC staff uses a standard of significance in the Decommissioning GEIS, described as either SMALL, MODERATE, or LARGE. SMALL impacts are defined as environmental impacts that are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource (NRC 2002).

1-7 the NRC clearly points to the Decommissioning GEIS and discusses the basis for its applicability.

Additionally, in the Decommissioning GEIS, the NRC staff determined that a decommissioning cost assessment is not a NEPA requirement, but still included a decommissioning cost evaluation (without environmental significance levels) because accurate decommissioning cost estimates are necessary for safe and timely plant decommissioning. Licensees must submit decommissioning funding plans annually. Upon receipt of a decommissioning funding plan, the NRC reviews the estimates to determine if the licensee has demonstrated compliance with 10 CFR 50.82(a)(8)(v)-(vii), thus, providing assurance that the licensee is maintaining the sufficient funds for decommissioning. In Chapter 7 of the LTP, Update of the Site-Specific Decommissioning Costs, MARAD summarizes the site-specific decommissioning costs as of September 30, 2023 (MARAD 2023b). And, on April 1, 2024, MARAD submitted its decommissioning funds status report for calendar year 2023 (MARAD 2024d).

2-5 2

PROPOSED ACTION AND ALTERNATIVES 2.1 Proposed Action This section discusses the history of NSS, describes the ship, and details the decommissioning activities to be performed in accordance with the LTP.

2.1.1 NS Savannah The reactor used in NSS was an 80 MWth PWR. MARAD is the owner and licensee of the ship.

The NSS licensed site boundary is defined by the ships hull (MARAD 2023b). The ships dimensions are included in table 2-1 below.

The ship ceased operations in 1970 and was defueled in 1971 (MARAD 2023b). In 1972, the spent fuel elements were shipped to the U.S. Department of Energys Savannah River Site in Aiken, South Carolina. All high-level radioactive materials were also removed (i.e., fuel core, fuel assemblies, radioactive fluids, most of the coolant and coolant pumps, and resins) (MARAD 2008a). In 1976, the license was changed to a possession-only license.

Table 2-1 NSS Dimensions Meters (m) (Feet [ft])

Length Overall 181.5 (595.5)

Length Between Perpendiculars 166.1 (545)

Beam, Maximum 23.8 (78)

Height, baseline to weather deck (A-deck) 15.2 (50)

Height, baseline to top of house 25.9 (85)

Draft, design 8.8 (29)

Draft, light ship (approximate) 5.6 (18.3)

Source: MARAD 2023b The ship operated as a museum from 1981 to 1994 at the Patriots Point Naval and Maritime Museum in Mount Pleasant, South Carolina. In 1983, the ship was listed in the NRHP and in 1991, it was designated as a National Historic Landmark.

In 1994, MARAD placed NSS in protective storage at the James River Reserve Fleet in Ft.

Eustis, Virginia, and in 2008, moved it to the Port of Baltimore (MARAD 2023b). The ship has been berthed at that location since 2008. Table 2-1 of MARADs LTP, incorporated by reference in this EA, lists in chronological order significant events for the ship (MARAD 2023b).

NSS is located at Pier 13, Canton Marine Terminal, in Baltimore, Maryland. Figures 2-1 and 2-2 show the location of NSS and features in its immediate vicinity and an aerial view of ship, respectively. The terminal is within the Port of Baltimore, which sits on the Patapsco River, which flows into the Chesapeake Bay. The Patapsco River also forms Baltimores Inner Harbor.

2-6 The boundary consists of the exterior surface of the ships hull, the superstructure, and other fixed items such as masts, spars, booms, rigging, and boats. (MARAD 2023b). Everything outside of the ship itself is considered off-site area (e.g., the Patapsco River, Pier 13). The site (i.e., the ship) contains no soils or groundwater (MARAD 2023b).

Figure 2-1 NSS Location and Immediate Surrounding (from Google Maps)

Figure 2-2 NSS at Pier 13, looking northwest (modified MARAD 2023b)

MARAD has held public events onboard NSS, at the Canton Marine Terminal. For example, as discussed in its Annual Report for CY2023 submitted to the NRC, MARAD hosted a public open house on NSS in conjunction with the National Maritime Day on May 21, 2023. That function was attended by approximately 450 persons. Also, the NSS Association manages guided tours of NSS. Approximately 100 persons attended these tours from August to December 2023 (MARAD 2024a).

2-7 2.1.2 Port of Baltimore The Port of Baltimore, an industrial facility, is one of the major ports of the United States. The port is one of the nations busiest, with approximately 11.7 million tons (10.6 million metric tons) of general cargo handled by the ports public terminals in fiscal year 2023. The Port of Baltimore is ranked ninth in total dollar value and tonnage of international cargo (MD 2024a). It has over 50 ocean carriers with approximately 1,800 annual visits.

There are numerous commercial and industrial facilities within 1.6 kilometers (km) (1 mile [mi])

of NSS. The Port of Baltimore generates approximately $3.3 billion in total personal income and supports 15,330 direct jobs and 139,180 indirect jobs. The Port also generates more than $395 million in taxes and $2.6 billion in business income. The top export commodities by weight in 2022 were coal, liquefied natural gas, wastepaper, ferrous scrap, and automobiles/light trucks.

The top imports were automobiles/light trucks, salt, paper/paperboard, gypsum, and plywood/veneer/particle board (MD 2024a).

While there are no residences within 1.6 km (1 mi), there are two communities within 3.2 km (2 mi) of NSS with residences, medical facilities, schools, and parks. No off-site wells are used by nearby communities, and potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b).

2.1.3 Decommissioning Activities Pursuant to 10 CFR 50.82(a)(4)(i), MARAD submitted the PSDAR, Revision 1 on December 11, 2008 (MARAD 2008b).9 MARAD selected the DECON method for decommissioning NSS. On April 23, 2018, the NRC amended license NS-1 allowing dismantlement and disposal of the ship without prior approval of the NRC (i.e., active decommissioning) (NRC 2018).

MARADs decommissioning approach consists of the following three phases (MARAD 2019).

Phase I: pre-decommissioning planning, engineering, hazardous materials abatement, and infrastructure preparation Phase II: removal of the systems, structures, and components Phase III: final status and confirmatory survey to be conducted by NRC Because of the NSSs National Historic Landmark status, MARAD designed a decommissioning approach that balances both meeting the radiological criteria for unrestricted use in 10 CFR 20 and historic preservation goals. The ship itself would not be dismantled, and decommissioning activities would be conducted, to the greatest extent practicable, within the ships license site boundary (MARAD 2023a). Accordingly, MARAD established the following principles to guide decommissioning (MARAD 2023a).

When possible, decommissioning activities are undertaken in a manner that fosters future preservation.

9 MARAD submitted Revision 0 of the Post Shutdown Decommissioning Activities Report on December 11, 2006, but it was withdrawn on January 27, 2007 (MARAD 2023b).

2-8 Dismantlement activities will use existing ship accesses to the maximum extent practicable to minimize impacts to adjacent structure.

When an option is presented or evaluated, the path that promotes preservation is taken.

Opportunities to improve the ship concurrent with decommissioning are exercised.

MARAD also chose to handle the waste solely on the vessel to minimize impacts to adjacent facilities and the environment and avoid changes to the license boundary. In general, MARAD separates and packages waste onboard for subsequent transport of the waste via rail, highway, or barge for disposal at a permitted facility (MARAD 2019).

Chapter 3 of the LTP (MARAD 2023b) describes activities that MARAD has completed as well as the remaining decommissioning activities. In summary, MARAD has dismantled the reactor auxiliary systems and components in the radiologically contaminated areas (RCAs) outside the reactor compartment and the low-level radioactive waste (LLRW) generated was disposed of in 2022 (MARAD 2023b). MARAD then focused on the reactor compartment systems. In 2022, MARAD completed the removal of major components including the control rod drive (CRD) tower, port and starboard steam generator tubes and tube sheets, the reactor pressure vessel (RPV) head, RPV internal components, and the RPV itself (MARAD 2023b). Between 2022 and 2023, MARAD disposed of reactor auxiliary system components, contaminated liquids, and mixed waste. For the pressurizer, a large opening was cut into one side to remove the internals.

Laser ablation was used to reduce contamination followed by grinding the inner stainless-steel cladding. In 2023, MARAD removed the lower section of the pressurizer (containing heater penetrations) and shipped it as LLRW (MARAD 2023b). The goal is to retain the remaining portions of the pressurizer. MARAD also plans to retain the containment vessel and the secondary shield, while primary ship structures such as decks, bulkheads, and the contaminated liquid storage tanks (integral to the ships double bottom hull structure) will be decontaminated and remediated to meet the criteria for unrestricted use (MARAD 2023b).

The approach for removal of the RPV, implemented in November 2022, consisted of opening two access points in the neutron shield tank (NST) to remove the RPV and inner wall of the NST/fuel transfer tank (FTT), while retaining the tank structure (including the exterior lead shielding surrounding the NST) (MARAD 2023b). This approach, supported by activation analyses and surveys, eliminated the alternative to remove the lead shielding by hand (MARAD 2023b). Based on prior activation analyses and surveys, MARAD had concluded that all nuclides are within the Waste Classification Class A limit both individually per isotope and when combined using the sum of the fractions for Class A Waste (MARAD 2023b). Additional information about these analyses and results can be found in Section 2.3.3 and table 2-7 of the LTP (MARAD 2023b). The RPV head and internals were transported from Baltimore, Maryland to the EnergySolutions LLC facility in Clive, Utah and disposed of as LLRW (MARAD 2023c and MARAD 2024b).

MARAD shipped and disposed of solid waste at the EnergySolutions LLC radioactive waste disposal facility in Clive, Utah, and disposed of liquid waste at the EnergySolutions LLC waste disposal facility in Erwin, Tennessee (MARAD 2024b).

According to MARAD, all planned dismantlement activities were completed at the time of the LTP submittal (MARAD 2023b). MARAD has continued to decontaminate, transport, and dispose of the LLRW remaining on the ship. Decontamination continued in all RCAs (including LLRW storerooms, the material handling area in Cargo Hold 4, and controlled areas in Cargo

2-9 Hold 3). The reactor compartment hatch will be closed; and the decommissioning heating and ventilation and air conditioning system will be decontaminated and retained for continued operation (MARAD 2023b). Pending confirmation that the unrestricted use criteria have been met, MARAD will maintain the current RCA boundaries for personnel entry/exit, monitoring stations, dosimetry, and material handling (MARAD 2023b).

After decontamination, the final status survey will be performed to verify that residual radioactivity has been reduced to meet the radiological criteria for unrestricted use in 10 CFR 20.1402. Table 8-1 in MARADs response to NRC staffs RAIs summarizes the end states of the systems at license termination, including those that remain to be surveyed (MARAD 2024c).

The NRC will not terminate the NSS license until MARAD demonstrates in its final radiation survey that the site meets the 10 CFR 20.1402 criteria, and that the facility has been decommissioned in accordance with the approved LTP.

2.2 Alternatives 2.2.1 No-Action Alternative As an alternative to the proposed action, the NRC staff considered the no-action alternative.

Under the no-action alternative, the NRC would not approve the LTP or the license amendment request because regulatory requirements have not been met. Consequently decommissioning, to an extent, and other onsite maintenance activities would continue. MARAD would not be able to request license termination and the ship would not be released for unrestricted use. MARAD would not be able to pursue disposition of the vessel in its planned timeline.

10 CFR 50.82(a)(10) states that the Commission shall approve an LTP, by license amendment, if the LTP demonstrates that the remainder of the decommissioning activities will be performed in accordance with the NRCs regulations, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment. If the NRC was unable to approve the LTP because the regulatory requirements were not met, then MARAD would have to take the necessary actions to ensure the regulations are met. MARAD would need to take additional action to prepare an LTP that meets the requirements in 10 CFR 50.82(a)(10) and submit the updated LTP to the NRC for approval prior to applying for license termination. Under this scenario, until MARAD resubmits an updated LTP, berthing of NSS at the Port in Baltimore would likely continue, including maintenance activities. Environmental impacts would neither significantly increase nor decrease as a result of the additional time required for the LTP resubmission, except for the costs associated with continuing to maintain the ship in a protective storage condition (MARAD 2019).

2.2.2 Alternative Sites MARAD evaluated the environmental impacts of decommissioning NSS using the DECON method at three different ports: Baltimore, Maryland (proposed action); Philadelphia; Pennsylvania, and Hampton Roads, Virginia.

In screening potential sites, MARAD considered: an existing industrial facility with sufficient infrastructure; adequate waterway access to avoid dredging; laydown space for a 100-ton (91-metric ton) landside crane and adjacent space for parking and truck access; adequate infrastructure for a 1,000-ton (910-metric ton) crane (barge-mounted or land-/pier-side polar crane); multiple transportation options for waste transport (i.e., road, rail, and barge); remote

2-10 access and location away from residential area; and location geographically close to Baltimore to minimize costs and environmental impacts from open-ocean towing (MARAD 2023b).

The three alternative sites are in developed (industrial) areas along a deep-water waterfront with restricted access. Decommissioning work at any of these locations, thus, would not require construction of new facilities or dredging (MARAD 2019). Decommissioning activities would be similar regardless of the location; therefore, most of the environmental impacts anticipated at the Philadelphia or Hamptons Roads locations would not be significantly different from the environmental impacts discussed in Chapter 3 of this EA for the Port of Baltimore. Further, MARAD did not identify significant impacts on human health or the environment from decommissioning of NSS using the DECON method at any of the locations except for impacts to the ship itself because of its National Historic Landmark status. As the ship is currently docked at the Port of Baltimore, selecting any other location would require MARAD to tow the ship, which could result in additional potential environmental impacts. Also, for any location, a site-specific analysis of the impacts to threatened and endangered species would be conducted in accordance with the Endangered Species Act of 1973 (ESA). Similarly, a site-specific review in accordance with the NHPA would need to be conducted to determine effects to historic and cultural resources. However, regarding compliance with the NHPA, a PA to address adverse effects would be anticipated and would not be significantly different than the PA that MARAD executed for the decommissioning of NSS at the Port of Baltimore. Waste generated from decommissioning is also anticipated to be similar regardless of the location. And, although transportation routes for disposing the waste would differ depending on where NSS is located, the impacts are not expected to differ significantly because any transportation of waste would be conducted in accordance with applicable Federal and State requirements.

3-1 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS This section describes the current environmental conditions where NSS is located to provide a framework, or baseline, for the evaluation of the potential environmental impacts. It also describes the environmental impacts on those resources that may be affected by the proposed action.

As discussed in Section 1.4.2 of this EA, some of the analyses in the Decommissioning GEIS are applicable to the NRCs review and approval of MARADs LTP. The NRC staff used the Decommissioning GEIS, where appropriate, to establish the bounds of impacts applicable to the decommissioning activities of NSS. Where the NRC staff used the Decommissioning GEIS to bound the potential environmental impacts of the proposed action, the NRC clearly points to the Decommissioning GEIS and discusses the basis for using the GEIS because not all the GEISs generic findings are applicable to the proposed action.

3.1 Land Use 3.1.1 Land Use including Site Description and Vicinity NSS is located at Pier 13, Canton Marine Terminal, in Baltimore, Maryland. The site is the ship itself. The boundary consists of the exterior surface of the ships hull, the superstructure, and other fixed items such as masts, spars, booms, rigging, boats, etc. (MARAD 2023b). Everything outside of the ship itself is considered off-site area (e.g., the Patapsco River, Pier 13, etc.).

Figures 3-1 and 3-2 provide an aerial view of NSS and features in its immediate vicinity.

Figure 3-1 NSS at Pier 13, looking northeast (modified MARAD 2023b)

3-2 Figure 3-2 NSS at Pier 13, looking northwest (Modified from MARAD 2023b)

The Port of Baltimore, an industrial facility, is one of the major ports of the United States and sits on the Patapsco River, which flows into the Chesapeake Bay. The port consists of public and private terminals. Several cranes are used to unload container ships and additional cranes are anticipated to be added in the future. The port is one of the busiest in the United States, with approximately 11.7 million tons (10.6 million metric tons) of general cargo handled by the ports public terminals in fiscal year 2023. The port is ranked ninth in total dollar value and tonnage of international cargo handled. The port also has a passenger terminal that is used by several cruise lines (MD, 2024a).

As discussed in the LTP, the terrain in the vicinity of the ship is relatively low and flat. There are numerous industrial and commercial facilities within 1.6 km (1 mi) of NSS. The bulk unloading facility of the National Gypsum Companys wallboard plant is located immediately east of Pier 13 and further is the Maryland Port Administration's Seagirt Marine Terminal. To the west is Pier 12 (remains of the PRR bulk ore pier) and Pier 11 (active general cargo and coal export facilities of the Canton Marine Terminal) and the CNX Marine Terminal. Other commercial facilities and rail tracks lie to the north of Pier 13. Other companies located on Pier 13 include Moran Towing, with three ship-assist tugs, and Project Liberty Ship, which includes the historic SS John W.

Brown. MARAD had previously layberthed10 two general cargo ships at Pier 13 in the Canton Industrial District of the Port of Baltimore (MARAD 2023b).

3.1.2 Land Use Direct and Indirect Impacts As discussed in Section 3.1.1 of this EA, the ship itself is considered the site and it is a National Historic Landmark. Because decommissioning activities can impact the ship, MARAD executed a PA (MARAD 2023a), in accordance with the NHPA, to address adverse effects from decommissioning on the ship and, to the maximum extent possible, minimize harm to this landmark. Accordingly, MARAD is employing an approach that balances compliance with NRCs regulatory requirements for unrestricted use and historic preservations goals. The NRC is a signatory to the PA. Additional information about the PA can be found in Section 3.7 of this EA.

Because MARAD will carry out the decommissioning activities discussed in the LTP consistent with the PA, the NRC staff finds that adverse effects on NSS as a historic landmark would be addressed.

10 A layberth is a general berth for use by vessels for a short time while awaiting a loading or discharging berth to become available.

3-3 Additionally, in selecting a location to carry out the decommissioning activities, MARAD considered industrial locations with sufficient infrastructure to avoid construction of new facilities; adequate waterway access to avoid dredging; laydown space for a landside crane and adjacent space for parking and truck access; adequate infrastructure for a 1,000-ton (907 metric ton) crane (barge-mounted or land-/pier-side polar crane); multiple options for waste transport (i.e., road, rail, barge); and a location away from residential areas (MARAD 2023b). The Port of Baltimore met the criteria and, thus, decommissioning activities described in the LTP do not involve major construction or changes to land use adjacent to Pier 13. Dredging is not required.

Transportation of waste would be completed in accordance with applicable Federal and State requirements and would not be significantly different from transportation of cargo currently carried out at the Port of Baltimore. In its 2019 Supplemental EA and FONSI, MARAD also concluded that there would be no change in land use as a result of the decommissioning of NSS (MARAD 2019). Therefore, consistent with MARADs finding, incorporated here by reference, and because no new facilities or dredging will be necessary, the NRC staff concludes that off-site land use impacts would be minimal and not significant.

3.2 Visual and Scenic Resources/Aesthetics 3.2.1 Description of the Visual and Scenic Affected Environment As described in Section 3.1.1 of this EA, NSS is currently berthed in Pier 13 in Canton Marine Terminal at the Port of Baltimore.

3.2.2 Visual and Scenic Resources Direct and Indirect Impacts As discussed in the Decommissioning GEIS (NRC 2002), temporary impacts from dust and noise would result from decommissioning activities of nuclear power plant sites; however, licensees are expected to use best management practices (BMPs) to control dust and noise.

The NRC staff does not expect impacts from dust and noise beyond those discussed in the Decommissioning GEIS during decommissioning of NSS.

Additionally, the ship and proposed license termination activities would not upset or change the industrial setting and general activities currently conducted at the Port of Baltimore (e.g., cargo handling). In its 2019 Supplemental EA and FONSI, incorporated here by reference, MARAD also concluded that the proposed decommissioning activities would not have an effect on the existing visual character or quality of the possible decommissioning sites and their surroundings (MARAD 2019).

Finally, because of NSS status as a National Historic Landmark, MARAD will carry out the decommissioning activities discussed in the LTP consistent with the PA (MARAD 2023a) to address adverse effects to the ship. Therefore, the NRC staff does not anticipate significant impacts to aesthetics or visual resources from the proposed license termination activities at NSS.

3.3 Climatology, Meteorology, and Air Quality 3.3.1 Climatology and Meteorology Maryland has a temperate climate, experiencing all four seasons. The mean temperature for Baltimore has been 12.6 degrees Celsius (°C) (54.6 degrees Fahrenheit [°F]), according to the

3-4 State Climatologist Office. The highest recorded annual average temperature was 15.1°C (59.2°F) in 1931, and the lowest was in 1904, at 11.4°C (52.6°F). Baltimore's recorded precipitation has averaged 106.5 centimeters (cm) (41.94 inches [in.]) a year, with the highest amount falling in 2003 with 159.1 cm (62.66 in.). The lowest precipitation recorded was in 1930 with 54.7 cm (21.55 in.) (MD 2024b). The city is adjacent to the Chesapeake Bay and the Atlantic Ocean to the east and the Appalachian Mountains to the west. The coldest and warmest months are January and July, respectively. The highest average wind speeds are experienced during winter and spring. While Baltimore Harbor can freeze during severe winters, icebreakers and larger power-driven vessels are used to maintain the dredged channels so port activities can continue (MARAD 2023b).

3.3.2 Air Quality The Clean Air Act requires EPA to set National Ambient Air Quality Standards (NAAQS) for six commonly found air pollutants known as criteria air pollutants (i.e., carbon monoxide, lead, nitrogen dioxide, ozone, particle pollution, and sulfur dioxide). The U.S. Environmental Protection Agency (EPA) has classified the Baltimore Area as moderate for the 8-hour ozone (2008), serious for the 8-hour ozone (2015), and nonattainment for sulfur dioxide (2010) (EPA 2024a).

Decommissioning of NSS does not require construction of new facilities or dredging. MARAD also determined that decommissioning of the ship would not require an air quality permit, primarily because the ship operates on electrical power supplied from shore and does not use electricity supplied by fossil fuel-driven generators (MARAD 2024b). Additionally, most of the decommissioning tools and equipment were not a source of air emissions. The equipment MARAD used for dismantling the interior structure of the NST, release of the RPV from its welded supports, removal of the steam generator risers and downcomers, and removal of a section of the pressurizer shell generated air emissions. Accordingly, MARAD employed engineered controls to filter the emissions primarily for the control of airborne radioactivity, but also to address carbon monoxide build-up and to capture particulate matter. Further, MARAD considered emissions from transient operations involving truck transportation and crane operations in both the 2008 EA and 2019 Supplemental EA and found these emissions de minimis (MARAD 2024b).

Air pollutants from equipment and vehicles (e.g., worker vehicle traffic and truck traffic) are generated during typical decommissioning activities. According to MARAD, at the time of LTP submittal, all planned dismantlement activities have been completed (MARAD 2023b). MARAD has continued to decontaminate, transport, and dispose of the LLRW remaining on the ship.

The remaining LLRW material will be placed in approved containers to be transported to a permitted disposal facility. MARAD uses trucks and tractor-trailers, railways, and barges typically used to transport waste (MARAD 2008a). In general, transportation occurs over routes typical for transporting these wastes including major highways (MARAD 2008). As of June 2024, MARAD had transported LLRW to the Clive, Utah disposal facility in 25 truck shipments, and estimated two more truck shipments to transport the remaining LLRW from decommissioning (MARAD 2024b). Waste shipments generate emissions; however, these are anticipated to be small.

On an annual basis, MARAD sends NRC the results of the radiological environmental monitoring program and any radioactive effluent releases (liquid, gaseous, and solid) that occurred during the year. MARADs Offsite Dose Calculation Manual describes the methodology and parameters used in the calculation of off-site doses resulting from radioactive gaseous and

3-5 liquid effluents; the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints; and the conduct of the radiological environmental monitoring program (MARAD 2023d).

3.3.3 Air Quality Direct and Indirect Impacts Section 4.3.4 of the Decommissioning GEIS lists several activities that could impact air quality during decommissioning. Decommissioning activities include vehicle traffic, demolition of structures, dismantlement and decontamination of systems, and movement of materials onsite and shipment off-site occurring until decommissioning is complete. The Decommissioning GEIS concluded that impacts on air quality from decommissioning are SMALL.

As discussed in its 2008 EA, MARAD determined that transportation of waste from decommissioning would generate a minor amount of emissions. Because shipments would be managed in accordance with Federal and State regulations, MARAD determined that impacts would be minimal (MARAD 2008a). MARAD does not expect new permanent or mobile sources of emissions. MARAD also concluded that impacts to air quality would be temporary and minor and would not change the designation of the area with respect to NAAQS. In its 2019 Supplemental EA, MARAD further concluded that the emissions associated with the decommissioning of NSS would not contribute to an exceedance of an ambient air quality standard (MARAD 2019). These conclusions documented in MARADs 2008 EA and 2019 Supplemental EA are incorporated here by reference.

According to the Decommissioning GEIS, licensees are expected to use BMPs to control dust and noise (NRC 2002), therefore, any anticipated particulate matter or fugitive dust resulting from decommissioning activities would be minimized using BMPs. MARADs use of torch and plasma cutting operations during dismantlement and removal of components employed engineered controls to filter emissions (airborne radioactivity and carbon monoxide) and capture particulate matter and sparks (MARAD 2024b). Also, decommissioning activities would be carried out in accordance with all applicable Federal and State regulations related to air quality.

Therefore, emissions during license termination activities are not anticipated to exceed de minimis levels for criteria pollutants.

During decommissioning, workforce is anticipated to temporarily increase. However, this increase in workforce would not contribute significantly to emissions from workforce traffic compared to the workforce currently employed at the Port of Baltimore, which supports 15,330 direct jobs (MD 2024a). Also, heavy machinery and equipment used at the Port of Baltimore also contribute to emissions. Any emissions from the proposed license termination activities are anticipated to be significantly less than those resulting from baseline activities carried out at the Port of Baltimore. Additionally, the workforce is expected to decline after completion of the decommissioning activities and license termination. Therefore, impacts to air quality from MARADs proposed LTP activities would not be noticeable or destabilizing.

Additionally, in its Annual Radiological Environmental Monitoring and Radioactive Effluent Release Report submitted to the NRC for calendar years 2019, 2020, 2021, 2022, and 2023, MARAD reported no radioactive gaseous effluents (MARAD 2023d). NSS has two gaseous continuous release points. A decommissioning heating, ventilation and air conditioning system serves the RCAs in the ship. Effluents are filtered by a high efficiency particulate air filter, monitored by a particulate air monitor, and then vented overboard. In 2022, while troubleshooting an air monitor alarm, effluents vented overboard were monitored by a continuous air sampler for both gross alpha and gross beta. No samples indicated activity above background (MARAD 2023d). Additionally, in September 2022, an engineering control exhaust

3-6 trunk was installed on the reactor hatch for localized smoke removal. MARAD monitored the effluent for gross alpha and gross beta and reported that activity was not above background levels (MARAD 2023d).

Based on the above evaluation, the NRC staff finds that impacts to air quality from the proposed license termination activities at NSS would be minor, temporary and within the bounds of the Decommissioning GEIS. Therefore, impacts to air quality would not be significant.

3.3.4 Greenhouse Gases and Climate Change In CLI-09-21 (NRC 2009a), the Commission provided guidance to the NRC staff on addressing greenhouse gas (GHG) issues in environmental reviews. That guidance directed the NRC staff to include consideration of carbon dioxide and other GHG emissions in its environmental reviews for major licensing actions under the National Environmental Policy Act. This Commission decision was issued after the Decommissioning GEIS was finalized in 2002, and as such, these topics were not addressed in the Decommissioning GEIS.

Decommissioning activities include vehicle traffic, dismantlement and decontamination of systems, and movement of materials onsite and shipment off-site occurring over a period from 2021 until decommissioning is complete. Equipment, worker vehicles, and truck shipments associated with decommissioning activities emit criteria pollutants and GHGs. The NRC developed a generic GHG footprint for the life cycle of a reference 1,000-MWe light-water reactor with an 80 percent capacity factor, for a net electric output of 800 MW(e) (NRC 2014).

The life cycle footprint includes decommissioning. The generic GHG footprint can be scaled for the number of units and electrical capacity. NSS is much smaller in size (80 MWth), and accordingly has a smaller GHG footprint.

In 2023 the U.S. Global Change Research Program (GCRP) published its most recent report regarding the state of climate change in the United States (GCRP 2023). Th report observes that the planet is on average about 2°F (1.1°C) warmer than it was in the late 1800s due to the increases in the atmospheric concentrations of GHGs. NSS is located within the Northeast geographic area defined in the GCRP report. The GCRP characterizes the Northeast as experiencing extreme weather, most notably an increase in rainfall intensity, which has caused flooding across the region, and heatwaves, both anticipated to continue. Oceans and coastal ecosystems are also being affected by increases in temperature, acidification, storm frequency and intensity, and sea levels, which in turn can affect fishing, tourism, and coastal communities (GCRP 2023).

According to U.S. National Oceanic and Atmospheric Administration (NOAA), air temperatures in most locations in the Chesapeake Bay watershed have increased over the last century. The average water temperature has also increased by 1°C (1.8 °F) over the last 30 years. An additional 0.4 to 1.6 m (1.3 to 5.2 ft) in sea level rise is anticipated over the next century (NOAA 2024a). Stronger and more frequent storms, an increase in heavy precipitation events, and an increase in bay water temperatures, all of which are expected to continue over the next century, can alter ecosystems and communities of the Chesapeake Bay watershed. The GCRP report also observes that projected increases in precipitation in the Susquehanna River basin, which contributes about half of all freshwater discharges into the Chesapeake Bay, are drivers for flood risk, poor water quality, and changes to habitats in the bay (GCRP 2023).

Finally, under 40 CFR 98, facilities must report emissions annually to the EPA if they emit 25,000 metric tons (27,558 tons) or more per year of CO2e. Decommissioning of NSS is not

3-7 anticipated to exceed this threshold. Given that GHG emissions during decommissioning would be localized and temporary and well below the EPA-GHG-reporting threshold, the NRC staff concludes that impacts from the proposed license termination activities at NSS on GHG would be minimal.

3.4 Noise 3.4.1 Noise Levels NSS is moored at Pier 13 of the Canton Marine Terminal within the Port of Baltimore. While there are numerous industrial and commercial facilities within a 1.6 km (1 mi) radius of the ship, there are no residences. Likewise, there are no schools, hospitals, prisons, motels, or hotels in the immediate vicinity of the ship. The nearest communities, Canton and Dundalk, Maryland, are located approximately within 3.2 km (2 mi) of the ship (MARAD 2023b). Therefore, given the location, noise receptors would include those working at and visiting the Port of Baltimore.

3.4.2 Noise Direct and Indirect Impacts Noise will be generated primarily from dismantlement and decontamination activities and heavy equipment (e.g., crane). Rail and truck shipments also would generate noise. Construction of new facilities and dredging would not be required as part of NSS decommissioning (MARAD 2023b). Most other activities (e.g., site radiological surveys and scans) would not generate noise. Because of the distance of the ship to the nearest community, and because the ship is moored in an area with numerous industrial and commercial facilities, noise impacts to sensitive receptors would not be anticipated. Further, according to the Decommissioning GEIS, licensees are expected to use BMPs to control dust and noise (NRC 2002).

Because MARADs proposed activities would be conducted in an area where noise from industrial activities like unloading cargo and ship traffic is already experienced, impacts from the proposed license termination activities and shipment of waste are not anticipated to be significantly different. The proposed license termination activities at NSS would be intermittent and temporary and would not contribute adversely to the acoustic environment in the region (MARAD 2008a). Therefore, the NRC staff anticipates that noise impacts would not be significant.

3.5 Geology and Soils 3.5.1 Regional and Site-Specific Geology As described herein to include in Section 3.1.1 of this EA, NSS is moored at Pier 13 of the Canton Marine Terminal within the Port of Baltimore.

3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts The Decommissioning GEIS did not include geology as a resource area because current power plant locations encompass a number of geologic settings, and any new power plant would have its site-specific geologic conditions evaluated as part of the licensing application. Therefore, this resource area was not evaluated in the Decommissioning GEIS (NRC 2002).

Decommissioning activities at NSS would not require dredging and MARAD does not anticipate construction of new facilities (MARAD 2023b). Also, MARAD chose to handle waste solely on

3-8 the vessel to minimize impacts to adjacent facilities and the environment. Because no soils are involved in this action and decommissioning has and will continue be carried out in accordance with NRC regulatory requirements, contamination of soils is not anticipated. Further, in response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c).

On an annual basis, MARAD submits to the NRC the results of the radiological environmental monitoring and radioactive effluent releases (liquid, gaseous, and solid). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d).

While NSS is not expected to disturb the sediments, MARAD samples water and sediment in locations adjacent to the ship at various times during the year. The environmental sample results for calendar years 2019, 2020, 2021, 2022, and 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding the ship compared to samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d). The NRC staff anticipates that radiological conditions would be similar and not change in the future. Therefore, the NRC staff finds that impacts to geology and soils from the proposed license termination activities at NSS would not be significant.

3.6 Water Resources 3.6.1 Surface Water 3.6.1.1 Surface Water Use and Quality The Patapsco River is approximately 62.8 km (39 mi) long. The rivers tidal basin forms Baltimore Harbor. The river and its shoreline provide habitat for different species (see Section 3.8 of this EA for additional information). It is also used for fishing, canoeing and kayaking, and hiking. Because part of the Patapsco River is urbanized and industrialized, stormwater runoff, sewage, and other forms of pollution have impacted water quality (AR 2024).

Baltimore Harbor is within the Upper Chesapeake Subregion, which is part of the Mid-Atlantic Watershed region of the Chesapeake Bay basin. It is considered a historic seaport, and it also serves as a tourist attraction. The Chesapeake Bay is the nations largest estuary. It extends from Havre de Grace, Maryland, south to Virginia Beach, Virginia. The three biggest tributaries are the Susquehanna River in Pennsylvania, the Potomac River in Maryland, and the James River in Virginia (MDSG 2024). The Patapsco River is one of the many tributaries that flow into the Chesapeake Bay. The bays watershed consists of the bay itself; all the tributaries, creeks, and streams; and the land surrounding them (MD 2024c).

Habitats found in the Chesapeake Bay include underwater grasses, wetlands, oyster reefs, rivers, and shorelines. The bay and the watershed provide habitat for more than 3,600 species of plants and animals (NOAA 2024a). The Chesapeake Bay is also a major economic driver in the region. According to NOAA, more than 18 million people live in the Chesapeake Bay watershed, and its coastal communities support commerce and recreation (fishing, beaches, waterfront attractions, living areas, tourism) as well as jobs. The bay is navigable and is home to two of the nations major ports: Baltimore, Maryland, and Hampton Roads, Virginia (MD 2024c).

As described in Section 2.1.2 of this EA, the Port of Baltimore is one of the major ports of the United States. As a result, the water quality around the port is degraded, which has impacted aquatic life and wildlife use. Marylands Port Administration has, however, a Water Quality Master Plan to guide activities to prevent or reduce water pollution (MPA 2024).

3-9 3.6.1.2 Surface Water Direct and Indirect Impacts Decommissioning of NSS using the DECON methodology does not involve major construction activities or dredging. The ship contains no soils or groundwater; however, it sits on the Baltimore Harbor. Also, no off-site wells are used by nearby communities, and potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b).

According to MARAD, at the time of the LTP submittal, all planned dismantlement activities had been completed (MARAD 2023b). MARAD has continued to decontaminate, transport, and dispose of the LLRW remaining on the ship. While MARAD chose to handle the waste solely on the vessel to minimize impacts to adjacent facilities and the environment, MARAD does not plan to dispose decommissioning waste onsite (MARAD 2019). MARAD has not and will not discharge waste from the ship into the water. During Phase I and II of the ships decommissioning process, MARAD generated wastewater that was collected in drums. MARAD either packaged these drums into intermodals and shipped them to the Clive, Utah disposal facility or transferred the contents of the drums to the contaminated liquid collection system, which was removed in 2023. This liquid was shipped to the Erwin, Tennessee EnergySolutions LLC facility (MARAD 2024b). MARAD plans to manage any remaining wastewater via steel or plastic containers, in compliance with Federal and State regulations (MARAD 2024b). Further, there is the potential for oil spill due to collision, grounding, or tank or hull rupture leakage, however, as documented in MARADs 2019 Supplemental EA, incorporated here by reference, these events are rare (MARAD 2019). Additionally, no lead paint is used on the hull (MARAD 2019).

On an annual basis, MARAD submits to the NRC the results of the radiological environmental monitoring and the radioactive effluent releases (liquid, gaseous, and solid). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d). While the decommissioning of NSS is not expected to disturb any sediments, MARAD samples water and sediment in locations adjacent to the ship at various times during the year.

The environmental sample results for calendar years 2019, 2020, 2021, 2022, 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding NSS compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d).

The NRC staff anticipates that radiological conditions would be similar and not change in the future.

Compliance with all Federal, State, and local permits pertaining to water quality throughout decommissioning activities ensures that surface water impacts are either minimal or evaluated in an appropriate environmental review. Between 2019 and 2020, MARAD consulted with the Maryland Department of the Environment regarding liquid discharges from the ship. During current ship operations, anticipated discharges would consist of stormwater and condensate from the heating, ventilation and air conditioning system (MARAD 2024b). Based on MARADs consultation with the State of Maryland, a permit was not required and, thus, MARAD did not obtain a National Pollutant Discharge Elimination System (NPDES) permit (MARAD 2024b).

Further, in response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c).

In its 2019 Supplemental EA, MARAD determined that the decommissioning of NSS would not have an impact on any coastal use or natural resource of the coastal zone. In accordance with the Coastal Zone Management Act and 15 CFR 930, Subpart C, MARAD provided a consistency determination to the State of Maryland for review. To minimize impacts to adjacent

3-10 facilities and the environment, MARAD has and continues to handle the waste solely on the vessel, does not plan to dispose decommissioning waste onsite, has not and will not discharge waste from the ship into the water, and based on water and sediment samples, has not identified any significant changes in the radiological conditions in the environment surrounding NSS.

Therefore, the NRC staff does not anticipate that impacts to surface water use and quality from the proposed license termination activities at NSS would be significant.

3.6.2 Groundwater 3.6.2.1 Groundwater Use and Quality NSS is moored at Pier 13 in the Canton Marine Terminal within the Port of Baltimore. There are no off-site wells used by nearby communities, and potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b). The ship contains no soils or groundwater.

3.6.2.2 Groundwater Direct and Indirect Impacts Decommissioning of NSS does not involve major construction activities or dredging. MARAD has not and will not discharge waste into the water. In general, MARAD separates and packages waste onboard for subsequent transport via rail, highway, or barge to a permitted disposal facility (MARAD 2019). While MARAD chose to handle the waste solely on the vessel to minimize impacts to adjacent facilities and the environment, MARAD does not plan to dispose of decommissioning waste onsite.

On an annual basis, MARAD also submits to NRC the results of the radiological environmental monitoring and radioactive effluent releases (liquid, gaseous, and solid). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d).

While NSS is not expected to disturb the sediments, MARAD samples water and sediment in locations adjacent to the ship at various times during the year. The environmental sample results for calendar years 2019, 2020, 2021, 2022, and 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding NSS compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d). The NRC staff anticipates that radiological conditions would be similar and not change in the future. Therefore, the NRC staff concludes that the proposed license termination activities at NSS would not impact groundwater use and quality.

3.7 Historic and Cultural Resources 3.7.1 Historic and Cultural Resources The NHPA requires Federal agencies to consider the effects of their undertakings on historic properties. The remaining decommissioning and license termination activities at NSS as described by MARAD in its LTP constitute an undertaking that could potentially have effects on historic properties. As defined in 36 CFR 800, historic properties are any prehistoric or historic district, site, building, structure, or object included in, or eligible for, inclusion in the NRHP.

NSS was listed on the NRHP in 1983 with significance under the themes of transportation, engineering, politics/government, and commerce. The ship was designated as a National

3-11 Historic Landmark in 1991 for exhibiting exceptional value in illustrating the nuclear, maritime, transportation, and political heritages of the United States (MARAD 2023a). The ship operated as a museum from 1981 to 1994 at the Patriots Point Naval and Maritime Museum in Mount Pleasant, South Carolina (MARAD 2023b). Most recently, while moored at the Canton Marine Terminal in Baltimore, Maryland, MARAD has used the ship as a venue for public events and visits. As discussed in MARADs Annual Report for CY2023, MARAD hosted a public open house in conjunction with the National Maritime Day on Sunday, May 21, 2023, which was attended by approximately 450 persons. Also, the N/S Savannah Association manages guided tours. Approximately 100 persons attended these tours from August to December 2023 (MARAD 2024a).

Additionally, the U.S. National Park Service (NPS) Historic American Engineering Record conducted recordation and documentation of NSS from 2007 through 2018, and MARAD conducted oral history and research, which developed into a Historic Site Assessment (MARAD 2023a). Chapter 2 of the LTP discusses the Historical Site Assessment and characterization activities conducted to determine the nature and extent of radioactive contamination prior to remediation.

3.7.2 Historic and Cultural Resources Direct and Indirect Impacts MARADs decommissioning, license termination, and final disposition involves dismantlement and remediation activities, including removal of some systems, structures, and components of the ships nuclear power plant. Accordingly, MARAD determined these activities would affect one of the NHLs [National Historic Landmarks] significant and character-defining features (i.e.,

the nuclear power plant itself) and would, thus, have an adverse effect per 36 CFR Part 800, Protection of Historic Properties.

MARAD has developed a balanced approach to achieve compliance with decommissioning and license termination requirements as well as preservation goals. This approach includes an executed PA (MARAD 2023a) to minimize harm to landmarks, to the maximum extent possible, consistent with Section 110(f) of the NHPA. The purpose of the PA, executed in March 2023, is to facilitate preservation of NSS during decommissioning (including license termination and final disposition). MARAD is the lead Federal agency for the decommissioning of NSS and defined the area of potential effects as the entire vessel. The NRC staff agreed that the undertaking herein would have an adverse effect on NSS as a historic landmark. Further, to address the adverse effects, the NRC signed MARADs PA as a signatory, documenting compliance with the NHPA. The PA was also signed by the Advisory Council on Historic Preservation, the Maryland State Historic Preservation Officer, and NPS (as a concurring party). Other concurring parties include the Smithsonian Institution, on behalf of the National Museum of American History, the Steamship Historical Society of America, the N/S Savannah Association, the National Museum of Nuclear Science and History, and the Health Physics Society.

As discussed in the PA, MARAD is guiding its decommissioning activities using the following principles (MARAD 2023a):

Decommissioning activities are conducted in a manner that fosters future preservation; The ship itself would not be dismantled and decommissioning activities would be conducted, to the greatest extent practicable, within the ships licensed envelope to minimize impacts to adjacent structure;

3-12 If there are options under consideration, those that promote preservation would be implemented; and Opportunities to improve the ship concurrent with decommissioning are exercised.

Regarding disposition of the ship, MARAD will prepare a disposition alternatives study, which will consider the following alternatives to be reviewed by the Peer Review Group:11 (1) preservation under continued Federal ownership; preservation under bare Federal ownership with predominant private control and responsibility; and preservation by a non-Federal entity (donation); (2) shipbreaking; and (3) artificial reefing (MARAD 2023a).

The final disposition plan will include at least one preservation alternative and mitigation measures consistent with the adverse effect of each potential alternative, among other elements (MARAD 2023a). While the NRC staff acknowledge the adverse effects on the ship as a historic property, MARAD executed a PA addressing the adverse effects, which the NRC signed, thus, complying with the NHPA.

3.8 Ecological Resources 3.8.1 Terrestrial Resources NSS is moored at the Port of Baltimore, which sits on the Patapsco River tidal basin. Because decommissioning of the ship will occur mostly in the water, MARAD focused its analyses on aquatic resources and migratory birds (MARAD 2019).

As described in Section 3.6.1.1 of this EA, the Baltimore Harbor is within the Upper Chesapeake Subregion. The Chesapeake Bay is the nations largest estuary. Habitats found in the bay include underwater grasses, wetlands, oyster reefs, rivers, and shorelines. Wetlands, forests, shorelines, and tidal grasses provide habitat and protection for various species, and forests also filter water (MDSG 2024). In its 2019 Supplemental EA, incorporated here by reference, MARAD concluded that there could be a few wetlands along Baltimore Harbor, however, none exist where the ship is moored (MARAD 2019).

Because of the industrial and commercial activities that have been carried at the Port of Baltimore, the water quality around the port is degraded, thus, affecting use of the water by aquatic and wildlife. Marylands Port Administration (MPA) has, however, a Water Quality Master Plan to guide activities to prevent or reduce water pollution (MPA 2024). The Port Administration has also taken steps to improve wildlife habitat in the Chesapeake Bay region.

For example, some of the material from dredging has been used to restore wetlands and eroded areas, and abandoned industrial debris has been removed from river shorelines (MPA 2024).

3.8.1.1 Federally and State-Listed Species The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) jointly administer the ESA. The FWS manages the protection of and recovery efforts for listed 11 MARAD established a Peer Review Group to guide the implementation of the PA via consultation.

Participants include the Federal and State agencies and non-governmental organizations.

3-13 terrestrial and freshwater species, and the NMFS manages the protection of and recovery effort for listed marine and anadromous species.

The implementing regulations for Section 7(a)(2) of the ESA define action area as all areas affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action. Using the FWS Information for Planning and Consultation database, the NRC staff generated a species list for an action area comprising NSS and immediately adjacent lands. The species list includes three terrestrial species designated under the ESA as potentially occurring in the action area (see table 3-1). The search did not include any critical habitats nor any FWS refuges in the area where NSS is located.

Table 3-1 Federally Listed Terrestrial Species at NSS and in the Vicinity Species Description Federal Status Northern long-eared bat (Myotis septentrionalis)

Flying mammal; winters in caves and mines; spends the rest of the year in forested habitats where it roosts; the diet consists mostly of insects; this species should only be considered if the project includes wind turbine operations, which NSS does not have (FWS 2024).

Endangered Tricolored bat (Perimyotis subflavus)

Flying mammal; winters in caves and mines; disperses to forested habitats to roost in trees during summer and fall; diet consists mostly of insects (FWS 2024).

Proposed Endangered Monarch butterfly (Perimyotis subflavus)

Insect; habitat needs milkweed and flowering plants; feed on nectar of flowers during breeding and migration; can only lay eggs on milkweed plants (FWS 2024).

Candidate In addition to Federally listed species, the Maryland Department of Natural Resources (MDNR) designates and manages species that it deems to be rare, threatened, and endangered at the State level. Table 3-2 lists such species that occur in Baltimore City, Maryland (MDNR 2024a).

3.8.1.2 Migratory Birds The FWS administers the Migratory Bird Treaty Act of 1918 (MBTA), which prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA protects a total of 1,093 migratory bird species (85 FR 21282). FWS identifies 37 species of migratory birds in the area. Some of the shore and water bird species include the long-tailed duck, common loon, red-throated loon, ring-billed gull, and red-breasted merganser. MARAD also reported that the Canda goose, American black duck, mallard, gadwall, American Wigeon, canvasback, redhead, bufflehead, common, and red-breasted mergansers have been observed in the area (MARAD 2019).

3-14 Table 3-2 State-Listed Terrestrial Species in Baltimore City Species Description American peregrine falcon (Falco peregrinus anatum)

Bird of prey; breeding habitat consists of open lands with cliffs, but also found in tall structures (e.g.,

skyscrapers and bridges); diet consists of medium size birds (MDNR 2024b). MARAD does not expect nests near NSS (MARAD 2019).

Common gallinule (Gallinula galeata)

Bird; often found in marshes, canals, lakes, ponds; typically breeds in marsh environments.

Bald eagle (Haliaeetus leucocephalus)

Large raptor (bird of prey); breeds and winters in forested areas adjacent to large bodies of water (FWS 2024). While bald eagles are found within the Chesapeake Bay watershed, these are only anticipated near NSS during migration or while moving through the bay (MARAD 2019).

Loggerhead shrike (Lanius ludovicianus)

Predatory songbird; found in semi-open habitats such as pastures, fields, cropland; mostly feeds on insects, small mammals, and birds (MBP 2024).

Hooded merganser (Lophodytes cucullatus)

Duck; found in the Chesapeake Bay watershed in spring and fall in wooded lakes, ponds, rivers; diet consists of frogs, insects, juvenile fish, and mud crabs (MDNR 2024b).

3.8.1.3 Bald Eagles The bald eagle also is protected under the Bald and Golden Eagle Protection Act of 1940. While bald eagles are found in high concentrations within the Chesapeake Bay watershed, these eagles are only anticipated to be found near NSS during migration or while moving through the bay (MARAD 2019). The NRC staff expects that MARAD would obtain any permits required under applicable acts and that impacts to bald eagles would be evaluated as part of that permitting process.

3.8.1.4 Terrestrial Resources Direct and Indirect Impacts The Decommissioning GEIS concludes generically that the potential impacts on terrestrial ecology from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of impacts on terrestrial ecology from activities conducted outside of the operational area (NRC 2002). NSS is not a nuclear power plant in the traditional sense; thus, impacts to terrestrial species are evaluated in a site-specific manner in this EA.

MARAD decided to manage waste solely on the vessel, avoiding the use of adjacent lands.

Waste would not be disposed onsite but shipped to licensed/permitted disposal facilities.

Construction of new facilities to support decommissioning are not needed, and no dredging would be conducted. Further, in response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c). On an annual basis, MARAD submits to the NRC the results of the radiological

3-15 environmental monitoring and the radioactive effluent releases (liquid, gaseous, and solid). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d). While NSS is not expected to disturb the sediments, MARAD samples water and sediment in locations adjacent to the ship at various times during the year. The environmental sample results for calendar years 2019, 2020, 2021, 2022, and 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding NSS compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d).

The NRC staff anticipates that radiological conditions would be similar and not change in the future.

While waterbirds may reside in the area where NSS is located, MARAD did not identify areas containing wetlands where the ship is located (MARAD 2019). Birds and other wildlife could be affected by noise generated by license termination activities. However, because of commercial and industrial activities carried out at the Port of Baltimore, it is reasonable to expect that wildlife using habitats near the port has generally acclimated to the noise and human activity typical of industrial sites. Additionally, the Maryland Department of Natural Resources recommends 0.4-km (0.25-mile) radius protection zones around nesting sites for colonial waterbird colonies at Sparrows Point and Fort Carroll Island. NSS is far from these protection zones, and the NRC staff did not identify any other activities of the proposed action that would affect birds. No license termination activities would affect any terrestrial habitats, as all activities would occur within NSS, which is moored at the Port of Baltimore. While waste shipments have continued during decommissioning of the ship, when compared to shipments to and from the Port of Baltimore, the impacts from MARADs waste shipments would not be noticeable or destabilizing to the wildlife. Therefore, the NRC staff determined that the impacts on terrestrial ecology of the proposed license termination activities would be SMALL and not significant.

With respect to Federally listed species, none of the species identified in table 3-1 are expected to occur in the action area because the action area does not provide suitable habitat for either of the bat species or the monarch butterfly. Therefore, the NRC staff concludes that the proposed action would have no effect on any Federally listed, proposed, or candidate species under the FWSs jurisdiction. No critical habitats occur within the action area. Federal agencies are not required to consult with the FWS if they determine that an action will have no effect on Federally listed species or critical habitats. Thus, the ESA does not require consultation on the proposed license termination activities at NSS. The NRC staff considers its obligations under ESA Section 7 to be fulfilled for the proposed action.

3.8.2 Aquatic Resources 3.8.2.1 Aquatic Habitats As discussed in Section 3.6.1.1 of this EA, the Patapsco Rivers tidal basin forms Baltimore Harbor. Baltimore Harbor is within the Upper Chesapeake Subregion, which is part of the Mid-Atlantic Watershed region of the Chesapeake Bay basin (MARAD 2019). The Chesapeake Bay is the nations largest estuary. The Patapsco River is one of its tributaries (MD 2024c).

Habitats found in the Chesapeake Bay include underwater grasses, wetlands, oyster reefs, rivers, and shorelines. Wetlands, forests, and shorelines provide habitats for diverse plant and animal species. Wetlands and tidal grasses provide habitat and protection for various species, while forests also filter water (MDSG 2024). There are very few wetlands along the urban shoreline of Baltimore Harbor, and MARAD did not identify wetlands where NSS is located (MARAD 2019).

3-16 Fish, shellfish, and other aquatic organisms are affected by water quality, temperature, and other conditions. As discussed in Section 3.8.1 of this EA, water quality around the port is degraded, thus, affecting use by aquatic life and wildlife. MPA has, however, a Water Quality Master Plan to guide activities to prevent or reduce water pollution and has taken steps to improve wildlife habitat in the Chesapeake Bay region (MPA 2024).

3.8.2.2 Federally and State-Listed Species Based on information on NOAAs public website, the NRC staff put together table 3-3, which lists Federal threatened and endangered species that potentially occur within the action area (NOAA 2024b). As previously discussed, the action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action.

Table 3-4 lists rare, threatened, and endangered species identified by the MDNR that could occur at or adjacent to where NSS is located (MDNR 2024c). A number of species are classified as in Need of Conservation including mud sunfish, swamp darter, striped shiner, striped bass, hickory shad, American shad, yellow perch, American oyster, Spanish mackerel, multiple orders of sharks (carcharhiniformes, hexanchiformes, lamniformes, rectolobiformes, squaliformes squatiniformes, spiny dogfish), conchs, scup, bluefin tuna, monkfish, swordfish, billfish, walleye, bay scallop, snapper group complex, Atlantic menhaden, jonah crab, and cobia.

Table 3-3 Federally Listed Aquatic Species in the Action Area Species Description Federal Status Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus)

Fish; lives in rivers and coastal waters; hatches in freshwater.

Endangered Shortnose sturgeon (Acipenser brevirostrum)

Amphidromous fish; lives in rivers and coastal waters from Canada to Florida; hatches in the freshwater of rivers and spend most of the time in estuaries of rivers; typically feeds on invertebrates (insects, crustaceans, worms, and mollusks).

Endangered Table 3-4 State-Listed Aquatic Species in Maryland Species Description State Status Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus)

See description in table 3-3.

Endangered Shortnose sturgeon (Acipenser brevirostrum)

See description in table 3-3.

Endangered Stripeback darter (Percina notogramma)

Fish; lives in freshwater habitats; found in the Chesapeake Bay tributaries.

Endangered

3-17 Species Description State Status American brook lamprey (Lampetra appendix)

Fish; found in freshwater streams and rivers within the Chesapeake Bay.

Threatened Comely shiner (Notropis amoenus)

Fish; typically found in streams and other bodies of water two or more feet deep.

Threatened The Federally listed Atlantic and shortnose sturgeon are occasionally present in the Chesapeake Bay (MARAD 2019). Some fish species like the alewife, blueback herring, American shad, white perch, yellow perch, and the American eel (MARAD 2019) have been observed in the open waters of the Patapsco River. MARAD also reported 13 benthic species including polychaete Nereis succinea, bivalve Tellina agilis, and polychaete Streblospio benedicti. While blue crab fishery is carried out in the Chesapeake Bay, MARAD does not anticipate any in the area where the ship is moored because of the industrial and commercial activities conducted at the Port of Baltimore (MARAD 2019).

The Magnuson-Stevens Fishery Conservation and Management Act, as amended, requires Federal agencies to consult with the NMFS on actions that may adversely affect essential fish habitat. According to MARAD, NMFS has identified essential fish habitat for the bluefish (Pomatomus saltatrix) and summer flounder, which may be present in the area where NSS is moored (MARAD 2019). The NRC staff also searched NOAAs Essential Fish Habitat Mapper.

In addition to the bluefish and summer flounder, essential fish habitat for the Atlantic butterfish, black sea bass, and scup can be found within the Mid-Atlantic region (NOAA 2024c). However, because the Port of Baltimore is a highly industrialized area, these habitats are not anticipated where the ship is moored.

3.8.2.3 Aquatic Resources Direct and Indirect Impacts The Decommissioning GEIS concludes generically that the potential impacts to aquatic ecology from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of impacts to aquatic ecology from activities conducted outside of the operational area (NRC 2002). The SMALL conclusion in the Decommissioning GEIS assumes that applicable BMPs are implemented and that necessary permits are obtained. NSS is not a nuclear power plant in the traditional sense; thus, impacts to aquatic species are evaluated in a site-specific manner in this EA.

As discussed in MARADs 2019 Supplemental EA, incorporated here by reference, bluefish can be present in the vicinity of the ship but only in low numbers and during a few months of the year. Summer flounder would generally be found in low numbers during the late summer and early fall when they migrate offshore (MARAD 2019). Sea turtles are unlikely to be present in the port. While shortnose sturgeon are known to be present in the Chesapeake Bay, they are also unlikely to be present within the vicinity of the ship (MARAD 2019). No Federally listed critical habitat has been designated within the project area. MARAD further did not identify wetlands where the ship is moored (MARAD 2019). For biological resources, MARAD

3-18 concluded in its 2019 Supplemental EA that [n]o reasonably foreseeable takes12 are expected for marine mammals and no effect on Essential Fish Habitat, which the NRC staff incorporates here by reference (MARAD 2019).

Notwithstanding, the proposed license termination activities at NSS do not involve major construction activities or dredging. Decontamination activities occur within the structure of the ship, which should not impact the water quality of the port (MARAD 2008b). Waste is also handled onsite to avoid impacting adjacent lands and water quality. Compliance with all Federal, State, and local permits pertaining to water quality throughout decommissioning activities ensures that surface water impacts are either minimal or evaluated in an appropriate environmental review. Between 2019 and 2020, MARAD consulted with the Maryland Department of the Environment regarding liquid discharges from the ship. During current ship operations, anticipated discharges would consist of stormwater and condensate from the heating, ventilation and air conditioning system (MARAD 2024b). Based on MARADs consultation with the State of Maryland, a permit was not required and, thus, MARAD did not obtain a NPDES permit (MARAD 2024b). MARAD does sample water and sediment in locations adjacent to the ship at various times during the year. The environmental sample results for calendar years 2019, 2020, 2021, 2022, and 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding the ship compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d). The NRC staff anticipates that radiological conditions would continue to be similar and not change in the future. There is the potential for oil spill due to collision, grounding, or tank or hull rupture leakage, however, as documented in MARADs 2019 Supplemental EA, incorporated here by reference, these events are rare (MARAD 2019). Also, no lead paint is used on the hull (MARAD 2019). In response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c).

According to MARAD, at the time of the LTP submittal, all planned dismantlement activities have been completed (MARAD 2023b). MARAD has continued to decontaminate, transport, and dispose of the LLRW remaining on the ship. While MARAD chose to handle the waste solely on the vessel to minimize impacts to adjacent facilities and the environment, MARAD does not plan to dispose decommissioning waste onsite (MARAD 2019). During Phase I and II of the ships decommissioning process, MARAD generated wastewater that was collected in drums. MARAD either packaged these drums into intermodals and shipped them to the Clive, Utah disposal facility or transferred the contents of the drums into the contaminated liquid collection system, which was removed in 2023 and shipped to the Erwin, Tennessee EnergySolutions LLC facility (MARAD 2024b). MARAD plans to manage any remaining wastewater via steel or plastic containers (MARAD 2024b). As of June 2024, MARAD has transported LLRW to the Clive, Utah disposal facility in 25 truck shipments, and estimated two more truck shipments to transport the remaining LLRW from decommissioning (MARAD 2024b). Waste shipments generate emissions; however, these are anticipated to be small. Further, while ship maintenance and repairs can result in minor emissions, these are not anticipated to exceed de minimis levels for criteria pollutants. MARAD confirmed that Maryland does not require an air quality permit for such operations (MARAD 2024b).

12 A take as defined under the Marine Mammal Protection Act means "to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or kill any marine mammal." See 16 U.S.C. 1362.

3-19 Therefore, license termination activities are not anticipated to affect water quality, water temperature, sediments, or aquatic vegetation. Accordingly, the NRC staff finds no adverse effects on essential fish habitat.

While MARAD does not anticipate transportation of the remaining waste via barge or ship, such transportation could pose a strike hazard for fish and aquatic organisms that inhabit the upper portion of the water column (MARAD 2019). To mitigate this potential impact, MARAD would reduce speeds along channels and near piers. MARAD would follow the NMFS Vessel Strike Avoidance Measures and Reporting for Mariners (NMFS 2008). NMFS anticipates that adhering to this guidance will reduce the risk associated with vessel strikes or disturbance of Federally protected species such that they will not occur. MARAD has also used barge cranes for several heavy lifts, which are mostly completed except for reinstalling the containment vessel cupola head and shield ring, and removing and stowing the reactor compartment hatch mechanism, which MARAD anticipates in 2026 (after license termination) (MARAD 2024b).

MARAD considers these activities as routine vessel movements within the port and harbor (MARAD 2024b).

In summary, water quality, water temperature, sediments, and aquatic vegetation are not anticipated to be impacted by liquid discharges, air emissions, or waste management activities during license termination activities at NSS. Transportation of waste via barge or ship is not anticipated, and the use of a barge crane is anticipated after license termination. Therefore, the NRC staff finds that impacts to aquatic ecology would be SMALL and not significant. Further, the NRC staff finds that impacts to State-listed species would be small. Similarly, the NRC staff determined that the proposed license termination activities would have no effect on the Federally listed Atlantic and shortnose sturgeons. Federal agencies are not required to consult with the NMFS if they determine that an action will not affect listed species or critical habitats.

Thus, the ESA does not require consultation for the proposed license termination activities at the ship. For the reasons explained above, the NRC staff considers its obligations under ESA Section 7 to be fulfilled for the proposed action.

3.9 Socioeconomics 3.9.1 Socioeconomic Characteristics of the Site Vicinity This section describes current socioeconomic factors that have the potential to be directly or indirectly affected by the proposed LTP, which is located at the Port of Baltimore. The geographic scope for the socioeconomics analysis is considered the port itself and the communities that surround it within the City of Baltimore (shown in figure 3-3).

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 is a major economic driver in the region. According to NOAA, more than 18 million people live in the Chesapeake Bay watershed and its coastal communities support commerce and recreation (fishing, beaches, waterfront attractions, living areas, and tourism) as well as jobs. The bay is navigable and is home to two of the nations major ports: Baltimore, Maryland, and Hampton Roads, Virginia (MD 2024c). Baltimores Inner Harbor is considered a historic seaport, and it also serves as a tourist attraction.

3-20 Figure 3-3 Geographic Scope (from Google Maps)

As discussed in Section 2.1.2 of this EA, the Port of Baltimore is one of the busiest ports of the United States. The port generates approximately $3.3 billion in total personal income and supports 15,330 direct jobs and 139,180 indirect jobs. The port also generates more than $395 million in taxes and $2.6 billion in business income. In 2023, the port handled 1.3 million tons (1.8 million metric tons) of imported roll-on/roll-off cargo, heavy machinery; and 847,158 automobiles and light trucks (the most of any U.S. port). In 2023, the port ranked first in the nation in handling automobiles, light trucks, heavy machinery, and ranked second for exporting coal. In 2023, cruises departing from the port carried more than 444,000 passengers. The cruise industry also generates over $63 million to Maryland's economy and supports over 400 jobs (MD 2024a).

According to the U.S. Census Bureaus (USCBs) 2022 American Community Survey 5-year estimates, the population in Baltimore City is approximately 584,548, in Baltimore County is approximately 850,737, and in the State of Maryland is approximately 6,161,707 (USCB 2022).

Table 3-5 presents the demographics. While there are no residences within 1.6 km (1 mi), there are two communities (Canton and Dundalk) within 3.2 km (2 mi) of NSS with residences, medical facilities, schools, and parks (MD 2024a). No off-site wells are used by nearby communities, and potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b).

Table 3-5 Demographics City of Baltimoreb Baltimore Countyb State of Marylandb 6.2 km (4 mi) Radiusb Total Population 584,548 846,161 6,164,660 203,096 Percent (%)

Whitea 27 51.8 47.1 49 Black or African Americana 60.7 30 29.2 31

3-21 City of Baltimoreb Baltimore Countyb State of Marylandb 6.2 km (4 mi) Radiusb American Indian or Alaska Nativea 0.2 0.1 0.1 0

Asiana 2.5 5.9 6.5 3

Native Hawaiian and other Pacific Islander 0.0 0.0 0.0 0

Persons reporting two or more races 3.2 4.9 4.7 0

Persons reporting some other race 0.5 0.6 0.8 3

Persons of Hispanic or Latino origin 5.9 6.6 11.4 12 (a) Not Hispanic/Latino (b) USCB 2022 (c) EPA 2024b The population employed (i.e., civilian labor force 16 years and over) in the City of Baltimore is approximately 271,546 with an unemployment rate of 6.7 percent, higher than Baltimore County and the State of Marylands rate of 5.2 percent and 5.1 percent, respectively (USCB 2022).

Income and poverty information based on USCBs 2022 American Community Survey 5-year estimates shows that the median income in 2019 inflation-adjusted dollars for the City of Baltimore is $50,379 and for Baltimore County is $88,157. The percentage of the population considered to have incomes below poverty level in the City of Baltimore is 19.6 percent, compared to 10.2 and 9.3 percent in Baltimore County and State of Maryland, respectively.

USCB housing data show that the City of Baltimore had an estimated 293,555 housing units, while Baltimore County and the State of Maryland had an estimated 425,347 and 3,116,242 units, respectively (USCB 2022).

3.9.2 Socioeconomic Direct and Indirect Impacts Potential socioeconomic impacts during decommissioning and license termination activities can include increased demand for short-term housing, public services, and increased traffic due to temporary fluctuations in the size of the workforce.

During Phase I of the NSS decommissioning (industrial activities), employment averaged about 50 persons, and during Phase II dismantlement activities, average employee daily attendance was about 80 persons (full-time staff and contractors). An overall decline is expected at the completion of the license termination activities (MARAD 2024b). Employment throughout decommissioning of the ship and a reduction in workforce upon license termination compared to the contributions to the local and regional economy from the activities carried out at the Port of Baltimore in terms of taxes, workforce, demand for housing and infrastructure is not significant.

Also, as discussed in Section 3.6 of this EA, license termination activities at NSS are not anticipated to impact water resources including the Port of Baltimore, Inner Harbor, and the Chesapeake Bay watershed, which are major economic drivers for the area. Therefore, the NRC staff does not anticipate any significant socioeconomic impacts from the decommissioning activities described in MARADs LTP.

3-22 3.10 Public and Occupational Health The goal of decommissioning is to reduce radiological contamination at the site to meet the NRC requirements for unrestricted use. Potential human health hazards associated with decommissioning NSS range from potential exposure to varying levels of radioactivity during dismantlement and decontamination. All facilities that the NRC licenses must adhere to the radiation protection standards in 10 CFR 20 to protect workers and the public against potential health risks from exposure to radioactive material used, generated, and released from the licensed facility.

3.10.1 Existing Radiological Conditions NSS ceased operations in 1970 and was defueled in 1971 (MARAD 2023b). In 1976, the license was changed to a possession-only license. The decommissioning and license termination activities MARAD has carried out and those remaining are described in Section 2.1.3 of this EA. At the time of the LTP submittal, MARAD had completed all planned dismantlement activities (MARAD 2023b). MARAD has continued to decontaminate, transport, and dispose of the LLRW remaining on the ship.

MARAD has not and will not discharge waste from the ship into the water. In general, MARAD separates and packages waste onboard before subsequent transport via rail, highway, or barge for disposal at a licensed/permitted facility (MARAD 2019). While MARAD chose to handle the waste solely on the vessel to minimize impacts to adjacent facilities and the environment (MARAD 2019), MARAD does not plan to dispose waste onsite.

MARAD has taken appropriate measures to make sure that decommissioning is conducted in accordance with MARADs radiation protection program and NRC regulations. For example, the approach selected for removal of the RPV eliminated hand-removal of the lead shielding to improve occupational safety. Additionally, as documented in MARADs annual reports submitted to NRC, in 2022, approximately 223 individuals were monitored and the project dose for calendar year 2022 was approximately 19.6 mSv (1,960 mrem) (MARAD 2023c). In 2023, approximately 54 individuals were monitored and the project dose was approximately 21.7 mSv (2,172 mrem) as of December 31, 2023 (MARAD 2024a). These doses are below NRC regulatory limits.

On an annual basis, MARAD submits to NRC the results of the radiological environmental monitoring and the radioactive effluent releases (liquid, gaseous, and solid). Results from 68 permanently placed thermo-luminescent dosimeter monitoring stations dispersed throughout the non-RCAs and in those areas of the ship that are routinely occupied for calendar years 2022 and 2023 indicated that readings were insignificant as compared to the background radiation levels (MARAD 2023c and MARAD 2024a). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d).

MARAD also samples water and sediment in locations adjacent to the ship at various times. The environmental sample results for calendar years 2019, 2020, 2021, 2022, and 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding NSS compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d).

The NRC staff anticipates that radiological conditions would be similar and not change in the future.

3-23 3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts In the Decommissioning GEIS, the NRC estimated occupational cumulative doses for PWRs using the DECON option to be 560 to 1,000 person-rem (5.6 to 10 person-Sv). The Decommissioning GEIS made the generic determination that the radiological impacts of decommissioning, including license termination activities, are SMALL because the expected doses will remain within regulatory limits (NRC 2002). Additionally, in the Decommissioning GEIS, the NRC determined that the levels of radionuclide emissions were lower for facilities undergoing decommissioning compared to operating facilities. Collective doses to public members were lower than 1 person-rem (0.01 person-Sv) per year within 80 km (50 mi) of the facilities. The maximally exposed individual was estimated to receive a dose of less than 1 mrem/yr (0.01 mSv/yr), which is well within the regulatory limits of 10 CFR 20 (NRC 2002).

MARAD plans to decommission the ship to meet the radiological unrestricted use criteria in 10 CFR 20 [0.25 mSv/yr (25 mrem/yr)] and achieve residual radioactivity levels ALARA.

MARAD has been conducting remediation throughout the decommissioning process based on the results of radiological surveys. According to MARAD, the principal media to be remediated are structural surfaces, and characterization surveys and historical survey data indicate that minimal contamination has been identified to date (MARAD 2023b). MARADs radiation protection program ensures the protection of the public from radiological hazards and ensures occupational, effluent, and environmental dose from exposure to radioactive materials is and remains ALARA (MARAD 2023b).

By washing and wiping large surface areas, MARAD can reduce low levels of loose surface contamination. For small items, overhead spaces, and small hand tools, MARAD implements wiping with detergent-soaked or oil-impregnated media. Other techniques for intermediate levels of surface contamination that MARAD may use are described in Chapter 4 of the LTP and include pressure washing, needle guns, high pressure water blasting, laser ablation, chemical strippers, sponge and abrasive blasting, grinding, and ultrasonic cleaning (MARAD 2023b). The effectiveness of the techniques MARAD employs for remediation will be confirmed by implementing the final status survey plan described in Chapter 5 of the LTP (MARAD 2023b).

MARAD is proposing derived concentration guidance levels (DCGLs) as acceptable levels of residual radioactivity of components that will be retained at NSS (components located within the containment vessel, including the secondary sides of both steam generator assemblies; the upper section of the pressurizer shell; and the outer wall of the NST/FTT) to comply with the unrestricted use criteria. While MARAD plans to retain some structures and components containing residual radioactivity (as discussed in Section 2.1.3 of this EA), any material that exceeds the unrestricted use criteria would be removed. MARAD has developed site-specific DCGLs to evaluate potential dose from residual radioactivity on surfaces at the site (MARAD 2023b). In its response to the NRC staffs RAIs, MARAD clarified that the DCGLs provided in Chapter 6 of the LTP apply equally to structures and components because the dose model MARAD used to develop the DCGLs applies a conservative value to the time spent working with material containing residual radioactivity. MARAD also considered the combination of all exposure pathways and selected the lowest DCGL (highest dose) from each of the pathways and radionuclides of concern. (MARAD 2024c). As part of the NRC decision on whether to approve the LTP, the NRC will evaluate the adequacy of the DCGLs proposed in Chapter 6 of the LTP to provide protection for members of the public. Because of the short operating history, long decay time, and unique design of the ship, routine surveys indicate very low levels of contamination in the containment vessel and reactor compartment (MARAD 2023b). Further,

3-24 MARAD plans to perform periodic surveillance and surveys to verify that no new residual radioactivity has been reintroduced to a survey unit/area once final status survey activities are completed (MARAD 2024c).

After license termination, MARAD will proceed with disposition of NSS. As stated in the PA, MARAD is considering: (1) preservation for public use, (2) shipbreaking (through physical destruction and recycling), and (3) sinking the vessel in shallow water to form an artificial reef (MARAD 2023a). MARAD estimated doses to workers and the public from surface contamination. In Chapter 6 of the LTP, MARAD describes exposure scenarios considered based on the three disposal options. MARAD calculated the potential doses to those individuals identified as significant (full time employees or workers who would handle potentially contaminated components): remediation worker on ship, component removal worker on ship, and scrap steel scenarios. While MARAD considers immediate shipbreaking a bounding scenario for artificial reefing, MARAD did evaluate the potential exposure to recreational divers and consumption of fish in the reefing scenario if the components are not removed. For the preservation scenario, MARAD considered an office worker/tour guide as a significant individual. MARAD determined that the worst-case scenario from a dose perspective would be immediate shipbreaking, while the dose to workers and the public in the preservation end-state would still be minimal (MARAD 2023b).

Additionally, in accordance with the NRCs safety evaluation report supporting NS-1 license amendment number 13 (MARAD 2007), there are no credible accidents that could cause the dose to the public to approach the established dose limit because of the reduced inventory of radioactive material in the ship, and the low activation estimates and general area dose rates (MARAD 2007).

MARADs occupational exposure as of September 30, 2023, is approximately 2.168 person-rem (0.02168 person-Sv) and the estimated exposure from the remaining activities is approximately 2.178 person-rem (0.02178 person-Sv). For comparison, in April 2022, MARAD estimated total radiation exposure to complete license termination activities was approximately 2.258 person-rem (0.02258 person-Sv). MARAD does not anticipate releasing any radioactive material to unrestricted areas during completion of the remaining decommissioning activities (MARAD 2023b). And, in calendar year 2022 and 2023, there were no significant changes in the radiological conditions in the environment surrounding NSS compared to the samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d).

Based on the above discussion, the NRC staff does not expect significant impacts to public or workers health and safety from radiological hazards. Anticipated impacts are also within the bounds of the Decommissioning GEIS. Additionally, because MARAD will transport and dispose of radioactive waste in accordance with Federal and State requirements, the NRC staff does not anticipate significant impacts to the publics health and safety from the transportation of radioactive waste.

3.10.3 Non-Radiological Impacts Normal workplace hazards associated with the decommissioning activities described in MARADs LTP can include accidents from falling objects, fires, operation of equipment, use of tools, and lighting equipment. MARAD would implement operating procedures and safety measures (e.g., first aid kits, nearby medical facilities, adequate ventilation, dust control, and noise control) in accordance with Occupational Safety Health Administration regulations to limit workplace hazards. Other possible hazardous materials may include PCBs (from, for example,

3-25 electrical cables, gaskets, and other miscellaneous electrical components), asbestos (from insulation materials and wallboard), and lead paint (MARAD 2008a). Removal of these hazardous material would be completed in accordance with Federal, State, and local regulations. The NRC staff finds that non-radiological impacts would be minor and not significant.

3.11 Transportation 3.11.1 Transportation Affected Environment The proposed action involves transportation of waste. Radioactive waste is and will be transported from NSS by truck, rail, or barge, or a combination thereof. As discussed in Section 2.1.3 of this EA, MARAD has dismantled the reactor auxiliary systems and components in the RCAs outside the reactor compartment, and removed major components including the CRD tower, port and starboard steam generator tubes and tube sheets, the RPV head, two RPV internal components, and the RPV itself (MARAD 2023b). MARAD has disposed of the LLRW generated during these activities. MARAD also disposed of the reactor auxiliary system components, contaminated liquids and mixed waste between 2022 and 2023, and disposed of the lower section of the pressurizer as LLRW in 2023 (MARAD 2023b). MARAD disposed of liquid waste associated with the decommissioning of the ship at the EnergySolutions facility in Erwin, Tennessee, while solid waste was disposed of at the EnergySolutions LLC facility in Clive, Utah (MARAD 2024b). The RPV head and internals and the RPV were transported from Baltimore, Maryland to the EnergySolutions LLC facility in Clive, Utah and disposed of as LLRW (MARAD 2023c and MARAD 2024b).

As of June 2024, MARAD has transported LLRW to the Clive, Utah disposal facility in 25 truck shipments, and estimated two more truck shipments to transport the remaining LLRW from decommissioning (MARAD 2024b). Because of the size of the ship and PWR compared to a nuclear non-mobile large nuclear power plant, waste shipments via truck are not anticipated to be significant in number. Also, because of the availability of a rail line, waste shipments transported via rail to the disposal facilities such as in Clive, Utah would be a small fraction of the normal rail transport volume and would not contribute additional traffic on those railways.

MARAD will comply with all applicable NRC and DOT regulations, including the Federal Railroad Administration requirements, and will use approved packaging and shipping containers for waste shipments (MARAD 2008a).

3.11.2 Transportation Direct and Indirect Impacts The Decommissioning GEIS addressed impacts to transporting equipment and materials off-site. Materials discussed in the Decommissioning GEIS include LLRW, hazardous and nonhazardous wastes, and mixed waste. Radiological impacts include exposures to the public and workers along the transportation route. The Decommissioning GEIS states that transportation impacts include increases in traffic density, wear and tear on roadways and railways, and transportation accidents. The Decommissioning GEIS estimates that shipment of LLRW by rail rather than by truck would reduce radiological impacts significantly (NRC 2002).

Impacts are considered destabilizing if increased traffic causes a decrease in the level of service or measurable deterioration of affected roads can be tied directly to the activities at the site (NRC 2002). The Decommissioning GEIS concluded that the impact to transportation from decommissioning is SMALL.

3-26 During decommissioning, workforce increased. However, the workforce would not contribute significantly compared to the workforce currently employed at the Port of Baltimore. The port supports 15,330 direct jobs (MD 2024a). Thus, the traffic impacts on the larger capacity roads surrounding the Port of Baltimore would not be noticeable or destabilizing. Additionally, the workforce is expected to decline after completion of the decommissioning activities and license termination.

While waste shipments have continued during the decommissioning of the ship, when compared to shipments to and from the Port of Baltimore, the impacts from MARADs waste shipments would not be noticeable or destabilizing. Additionally, because MARAD will transport and dispose of radioactive waste in accordance with Federal and State requirements, the NRC staff does not anticipate significant impacts to public health and safety from the transportation of radioactive waste. Because of the size of the ship compared to a nuclear non-mobile large nuclear power plant, waste shipments are not anticipated to significantly contribute to transportation networks (highway, railway, maritime) or traffic. Further, in response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c).

Accordingly, the NRC staff does not expect impacts associated with transportation to be destabilizing or beyond those discussed in the Decommissioning GEIS, which concluded that the impact level is SMALL. Therefore, transportation impacts would not be significant.

3.12 Environmental Justice The following environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from activities associated with the proposed action.

Such effects may include human health, biological, cultural, economic, or social impacts.

Minority and low-income populations are subsets of the general public residing in the vicinity of the NSS site.

3.12.1 Minority and Low-income Populations in the Vicinity of NSS Based on current NRC staff guidance (NRC 2003), if the proposed facility is located outside the city limits or in a rural area, a radius of approximately 6.2 km (4 mi) can be used in identifying minority and low-income populations to be included in the environmental justice analysis. The geographic scope should also be commensurate with the potential impact area, and should include a sample of the surrounding population, e.g., at least several census block groups. The goal is to evaluate the communities, neighborhoods, or areas that may be disproportionately impacted. Because MARAD will not be carrying out major construction activities or dredging, no off-site wells are used by nearby communities, potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b), and the ship contains no soils or groundwater, the NRC staff selected a radius of 6.2 km (4 mi) from NSS for the environmental justice analysis.

Based on EPAs EJScreen: Environmental Justice Screening and Mapping Tool, the total population within a 6.2 km (4 mi) radius is approximately 203,096 (EPA 2024b). The largest minority population is Black or African American. There is a 6 percent unemployment rate and approximately 37 percent of the population within a 6.2 km (4 mi) radius of NSS identified as low-income. Table 3-5 presents the demographics for comparison.

3-27 3.12.2 Impacts As discussed in the Decommissioning GEIS (NRC 2002), potential impacts to minority and low-income populations would consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts) and radiological effects. For environmental justice, the Decommissioning GEIS concluded that a site-specific analysis was necessary.

As discussed in Section 3.9.1 of this EA, there are two communities within 3.2 km (2 mi) of the ship with residences, medical facilities, schools, and parks. However, no off-site wells are used by nearby communities, and potable water for residential and commercial use is supplied by municipal systems fed by reservoirs in northwest Baltimore City and further beyond in Baltimore County (MARAD 2023b).

Compliance with all Federal, State, and local permits pertaining to water quality throughout decommissioning and license termination activities ensures that surface water impacts are either minimal or evaluated in an appropriate environmental review. Because MARAD does not anticipate construction of new facilities or dredging, impacts to water resources would not be noticeable.

During license termination activities, the size of the workforce is anticipated to temporarily increase. However, the workforce at NSS would not contribute significantly compared to the workforce currently employed at the Port of Baltimore. Therefore, any increase in demand for rental housing during license termination activities could be accommodated with a minimal impact on housing accessibility.

Decommissioning of NSS would generate air emissions and would be carried out in accordance with all applicable Federal and State regulations related to air quality. Any emissions from license termination activities, however, would be significantly less than those currently generated by industrial and commercial activities carried out at the Port of Baltimore and, thus, would not be noticeable or destabilizing. Any anticipated particulate matter or fugitive dust resulting from license termination activities would be minimized using BMPs. Further, MARAD considered emissions from transient operations involving truck transportation and crane operations in both the 2008 EA and 2019 Supplemental EA and found these emissions de minimis (MARAD 2024b). Emissions during license termination activities are not anticipated to exceed de minimis levels for criteria pollutants. Noise primarily results from demolition activities, worker vehicles, and transportation of waste via trucks and rail, however, any increase in noise levels caused by transportation of waste and license termination activities would be minimal considering the size of NSS compared to the size of nuclear power plants discussed in the Decommissioning GEIS. Transportation activities to and from the ship would occur along existing roads and rail corridors and are not anticipated to be significantly different from current transportation activities at the Port of Baltimore. And, when compared to shipments to and from the port, the impacts from MARADs waste shipments would not be noticeable or destabilizing.

Radiation doses during license termination activities are expected to remain below regulatory limits. On an annual basis, MARAD submits to the NRC the results of the radiological environmental monitoring and radioactive effluent releases (liquid, gaseous, and solid). No liquid or gaseous effluents were released in calendar years 2019, 2020, 2021, 2022, and 2023 (MARAD 2023d). While NSS is not expected to disturb sediments, MARAD samples water and sediment in locations adjacent to the ship at various times during the year. The environmental sample results for calendar years 2019, 2020, 2021, 2022, 2023 did not indicate any significant changes in the radiological conditions in the environment surrounding the ship compared to the

3-28 samples taken shortly before the ship arrived at Pier 13 (MARAD 2023d). MARAD does not anticipate releasing any radioactive material to unrestricted areas during completion of the remaining decommissioning activities (MARAD 2023b).

The NRC staff also determined that the proposed license termination activities would have no effect on Federally listed terrestrial and aquatic species or critical habitats. There are very few wetlands along Baltimore Harbors urban shorelines. Notwithstanding, MARAD did not identify wetlands where NSS is located (MARAD 2019). The license termination activities are not anticipated to disrupt any commercial or recreational fishing activities or fishing for subsistence.

Based on this information and the analysis of human health and environmental impacts presented in this EA, the NRC staff has determined that the proposed license termination activities would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations residing in the vicinity of NSS.

3.13 Waste Management Decommissioning generates both radioactive and nonradioactive wastes. Decommissioning activities are subject to Federal and State (Maryland) regulations, permits, licenses, notifications, and approvals, including those for hazardous waste generation and disposition, handling and removal of asbestos, handling and removal of lead paint, and removal of underground storage tanks. Chapter 2 of the MARADs LTP lists major events involving unplanned liquid releases, facility contamination, and release of radioactive material. Chapter 2 of the LTP also describes studies, analyses, and other efforts to characterize the site to determine the extent of radiological and non-radiological contamination (MARAD 2023b).

3.13.1 Radioactive Waste The NRC has adopted a waste classification system for LLRW based on its potential hazards, and has specified disposal and waste form requirements for each of the general classes of waste: Classes A, B, and C. The classifications are based on the key radionuclides present in the waste and their half-lives. In general, requirements for waste form, stability, and disposal methods become more stringent when going from Class A to Class C waste. Waste classified as greater-than-class-C (GTCC) exceeds the concentration limits in 10 CFR 61.55 and is generally unsuitable for near-surface disposal as LLRW, even though it is legally defined as LLRW. The NRC's regulations in 10 CFR 61.55(a)(2)(iv) require that this type of waste be disposed of in a geologic repository unless approved for an alternative disposal method on a case-specific basis by the NRC (NRC 2002).

In its 2019 Supplemental EA, MARAD considered handling and packaging waste (1) solely on the vessel, (2) solely on land adjacent to the vessel, or (3) a combination of on land and the vessel. To minimize impacts to adjacent facilities and the environment, MARAD chose to handle the waste solely on the vessel. In response, MARAD modified Cargo Hold areas 3 and 4 for waste management activities (MARAD 2019). In general, MARAD separates and packages waste onboard for subsequent transport via rail, highway, or barge to a permitted waste disposal facility (MARAD 2019). MARAD shipped and disposed of solid waste at the EnergySolutions LLC radioactive waste disposal facility in Clive, Utah, and disposed of liquid waste at the EnergySolutions LLC facility in Erwin, Tennessee (MARAD 2024b). As of June 2024, MARAD has transported LLRW to the Clive, Utah disposal facility in 25 truck shipments, and estimated two more truck shipments to transport the remaining LLRW from

3-29 decommissioning (MARAD 2024b). See table 3-6 for information about the volume of waste disposed and anticipated.

Table 3-6 Waste Disposed Waste Volume(a)

Type Dry Active Waste/Metal 611.6 m3 (21,600 ft3)

Radioactive (solid)

Lead 9,616 kg (21,200 lbs) 2.5 m3 (90 ft3)

Recycle (solid)

Mixed (solid)

Water/Chromate/Lead 12.3 m3 (434.5 ft3) 6,67.7 L (1,735 gallons) of water Mixed Reactor Internals 8.83 m3 (312 ft3)

Radioactive (solid)

Reactor Head 4.76 m3 (168 ft3)

Radioactive (solid)

RPV 68.64 m3 (2,424 ft3)

Radioactive (solid)

CRD Tower (metal) 45.31 m3 (1,600 ft3)

Radioactive (solid)

Personal Protective Equipment/Lead fines 7.9 m3 (280 ft3)

Radioactive (solid)

CRD Oil Drum 265 L (70 gallons)

Radioactive (liquid)

Water 68,606 L (18,124 gallons)

Radioactive (liquid)

(a) As of December 30, 2023 Source: MARAD 2024a During Phase I and II of the ships decommissioning process, MARAD generated wastewater that was collected in drums. MARAD either packaged these drums into intermodals and shipped them to the Clive, Utah disposal facility or transferred the contents of the drums into the contaminated liquid collection system, which was removed in 2023. This liquid was shipped to the EnergySolutions LLC facility in Erwin, Tennessee (MARAD 2024b). MARAD plans to manage any remaining wastewater via steel or plastic containers (MARAD 2024b). Further, in response to the NRC staffs RAIs, MARAD confirmed that no reactor plant-related water or sediment will remain on the ship at license termination (MARAD 2024c).

As discussed in Section 2.1.3 of this EA, MARAD has completed all planned dismantlement activities. Decontamination continued in all RCAs (including LLRW storerooms, the material handling area in Cargo Hold 4, and controlled areas in Cargo Hold 3). The reactor compartment hatch will be closed, and the decommissioning heating, ventilation, and air conditioning system will be decontaminated and retained for continued operation. Pending confirmation that the unrestricted use criteria have been met, MARAD will maintain the current RCA boundaries for personnel entry/exit, monitoring stations, dosimetry, and material handling (MARAD 2023b).

MARAD does not anticipate generating any GTCC waste or Class B and C LLRW as part of the LTP implementation (MARAD 2024b).

3-30 3.13.2 Nonradioactive Waste During decontamination and decommissioning, other possible hazardous materials including polychlorinated biphenyls (PCBs) (from, for example, electrical cables, gaskets, and other miscellaneous electrical components), asbestos (from insulation materials and wallboard), lead paint, fuels, oils, lubricants can be generated. Removal and disposal of these hazardous material would be completed in accordance with Federal, State, and local regulations (MARAD 2008a and 2019). MARAD anticipates recycling materials to the maximum extent practicable to reduce the need to use local landfills or other disposal sites (MARAD 2019).

3.13.3 Waste Management Direct and Indirect Impacts Disposal of high-level radioactive waste is beyond the scope of the Decommissioning GEIS (NRC 2002). Regarding LLRW, the Decommissioning GEIS (Section 4.3.18) did consider the volume of land required for LLRW disposal (NRC 2002). The Decommissioning GEIS estimated the volume of land required for radioactive waste disposal as an irretrievable and irreversible impact. In the Decommissioning GEIS (table 4-7), it was estimated that for DECON (see footnote Error! Bookmark not defined. of Section 2.1), 8,000 to 10,000 m3 (282,500 to 353,000 ft3) of land would be needed for disposal of LLRW for a PWR significantly larger in size than NSS.

Because the size of the NSS and the PWR is smaller than the nuclear reactors considered in the Decommissioning GEIS, the amount of waste generated would not challenge capacity at permitted waste disposal facilities. The NRC staff concludes that although remaining decommissioning activities, site remediation, and final site radiological surveys will generate LLRW waste (see table 3-7), the amount generated would not have a noticeable effect on the overall disposal capacity. Radioactive waste will be transported by truck, rail, or barge. MARAD will conduct license termination activities in accordance with its radiation protection program, Offsite Dose Calculation Manual, and administrative procedures to manage the classification, processing, packaging, and removal of radioactive waste.

The Decommissioning GEIS did not consider the impacts of nonradioactive waste generation, handling, and disposal. Based on the information provided in the LTP application, the NRC has evaluated the impacts of the generation, handling, and disposal of nonradioactive waste for NSS. Nonradioactive waste would be either disposed of at a local landfill or recycled. Any material that MARAD was not able to recycle during decommissioning would be considered an irretrievable commitment of Federal resources. Any hazardous waste would be disposed of appropriately as required by Federal, State, and local regulations. Further, based on the availability of landfills, the NRC staff does not expect a noticeable impact on local landfill capacity from license termination activities.

Management and disposal of LLRW, hazardous waste, and nonhazardous waste would require a small short-term increase in energy usage and consume space at treatment, storage, or disposal facilities. Regardless of the location of those facilities, the use of land to meet waste disposal needs would reduce the long-term productivity of the land. However, as previously discussed, the contribution of the license termination activities at NSS would be minimal.

3.14 Cumulative Effects The Council on Environmental Quality regulations that implement NEPA define cumulative effects as effects on the environment that result from the incremental effects of the action when

3-31 added to the effects of other past, present, and reasonably foreseeable actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time. (40 CFR 1508.1). The NRC staff evaluated whether cumulative environmental effects could result from the incremental effects of the proposed action when added to the effects of other past, present, or reasonably foreseeable actions in the area.

NSS is moored at the Port of Baltimore, which is located on the Patapsco River. The rivers tidal basin forms Baltimore Harbor. The river is the habitat for several aquatic species. It is also used for fishing, canoeing and kayaking, and hiking. Because part of the Patapsco River is urbanized and industrialized, stormwater runoff, sewage, and other forms of pollution have impacted water quality (AR 2024). The Port of Baltimore is one of the major and busiest ports of the United States. Approximately 11.7 million tons (10.6 million metric tons) of general cargo was handled by the ports public terminals in fiscal year 2023. As a result, the water quality around the port is degraded, which has impacted aquatic life and wildlife use. Marylands Port Administration has, however, a Water Quality Master Plan to guide activities to prevent or reduce water pollution (MPA 2024). Additionally, MARAD does not anticipate construction of new facilities or dredging, and water use would be minimal. Compliance with all Federal, State, and local permits pertaining to water quality throughout decommissioning activities ensures that surface water impacts are either minimal or evaluated in an appropriate environmental review. Between 2019 and 2020, MARAD consulted with the Maryland Department of the Environment regarding discharges from the ship. During current ship operations, anticipated discharges would be stormwater and condensate from the heating, ventilation and air conditioning system (MARAD 2024b). Based on MARADs consultation, Maryland concluded that a permit was not required and, thus, MARAD did not obtain a NPDES permit (MARAD 2024b). No significant impacts to wetlands and floodplains are anticipated. Because water quality within the Port of Baltimore is already impacted by the port activities, impacts from the proposed license termination activities at NSS are not anticipated to significantly contribute to cumulative impacts. Further, the NRC staff determined that the proposed action would not have a significant effect on terrestrial or aquatic ecology.

A reduction in the NSS workforce compared to the contributions to the local and regional economy from the activities carried out at the Port of Baltimore in terms of taxes, workforce, and demand for housing and infrastructure, is not significant. Further, the license termination activities at NSS are not anticipated to affect water resources including the Chesapeake Bay watershed, which is a major economic driver for the area.

Because the size of the ship and its PWR is smaller compared to a nuclear non-mobile large nuclear power plant, waste shipments via truck are not anticipated to be significant in number.

Also, because of the availability of a rail line, a substantial portion of the radioactive waste shipments will likely use rail as the transport method to the disposal facilities such as the EnergySolutions LLC facility in Clive, Utah. Rail shipments from NSS would be a small fraction of the normal rail transport volume and would not contribute additional traffic on those railways.

As of June 2024, MARAD has transported LLRW to the Clive, Utah disposal facility in 25 truck shipments, and estimated two more truck shipments to transport the remaining LLRW from decommissioning (MARAD 2024b). MARAD will comply with all applicable NRC and DOT regulations and will use approved packaging and shipping containers for waste shipments (MARAD 2008a). Also, any noise generated by MARADs license termination activities, including waste shipments, would not be significantly different than industrial activities carried out at the port like unloading cargo and ship traffic.

3-32 After the NRC terminates the NSS license, MARAD will proceed with disposition of the vessel.

As discussed in the PA, MARAD will prepare a disposition alternatives study, which will consider the following alternatives: (1) preservation under continued Federal ownership, (2) preservation under private control and responsibility with bare Federal ownership, (3) preservation by a non-Federal entity (donation), (4) destruction by domestic dismantlement (scrapping/shipbreaking),

and (5) artificial reefing. The final disposition plan will include at least one preservation alternative and mitigation measures consistent with the adverse effect of each potential alternative, among other components (MARAD 2023a). Chapter 6 of the LTP, provides a description of these scenarios (as potential end-state), which MARAD considered in determining doses to workers and the public to demonstrate compliance with the license termination criteria (unrestricted use).

As described in the LTP, shipbreaking is a complex and hazardous activity. Shipbreaking would result in complete dismantlement of NSS. Workers are exposed to radiological, non-radiological (e.g., lead, asbestos, PCBs, etc.), and workplace/industry hazards. The United States Occupational Safety and Health Administration established standards at 29 CFR 1915, Occupational Safety and Health Standards for Shipyard Employment, to protect workers health and safety from these hazards. While MARAD considers artificial reefing to be less likely, it was evaluated as a potential end-state scenario. NOAA is responsible for developing and maintaining the long-term National Artificial Reef Plan in accordance with the National Fishing Enhancement Act of 1984. Per the Act, artificials reefs would enhance fishery resources; facilitate access and use for recreational and commercial fishing; and minimize environmental risks and risks to personal health; among other benefits. NOAA amended the plan in 2007 to add sport diving in addition to fishing. Subsequently, NOAA added the use of reefs as mitigative strategies against the loss or degradation of marine habitats and aquatic resources. The U.S.

Army Corps of Engineers has authority for permits to construct and place artificial reefs under Section 404 of the Clean Water Act (33 U.S.C. §1344), and Section 103 of the Marine Protection, Research and Sanctuaries Act (33 U.S.C. §1413). Shipbreaking immediately following license termination is considered a bounding scenario for artificial reefing because some of the structures and components would likely need to be removed in preparing the ship for artificial reefing.

In sum, MARAD concluded that the worst-case scenario from a dose perspective would be immediate shipbreaking, while the dose to workers and the public in the preservation scenario would be minimal (MARAD 2023b). In terms of radiological hazards, preservation allows for continued radiological decay over time. Because preservation would not be indefinite and shipbreaking would occur at some point in the future, the dose to workers from deferred shipbreaking would be less than immediate shipbreaking.

The NRC staff has assessed the potential incremental impacts of the proposed action to the current and reasonably foreseeable activities discussed above and, for the reasons discussed in this section of the EA, the NRC staff determined that there would be no significant cumulative effects because there would only be minimal incremental effects from the proposed action and minor overlapping effects with other activities. Therefore, impacts from the license termination activities at NSS are not anticipated to significantly contribute to cumulative impacts.

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CONSULTATION AND COORDINATION 4.1 State Review On August 22, 2024, the NRC staff submitted the draft EA to the State of Maryland for their review and comment. On September 30, 2024, the State of Maryland provided comments regarding: (i) NAAQS designation (attainment/nonattainment status) for the State of Maryland, (ii) air emissions from NAAQS-criteria pollutants, (iii) and coastal effects in accordance with the Coastal Zone Management Act. The NRC staff addressed all comments from the State of Maryland in this final EA.

4.2 National Historic Preservation Act Section 106 Consultation NSS was listed on the NRHP in 1983 with significance under the themes of transportation, engineering, politics/government, and commerce. The ship was designated as a National Historic Landmark in 1991 for exhibiting exceptional value in illustrating the nuclear, maritime, transportation, and political heritages of the United States (MARAD 2023a). Because MARADs decommissioning, license termination, and final disposition involve dismantlement and remediation activities, including removal of some systems, structures, and components of the ships nuclear power plant, MARAD determined that these activities would have an adverse effect per 36 CFR 800, Protection of Historic Properties.

In March 2023, MARAD executed a PA (MARAD 2023a) to minimize harm to landmarks, to the maximum extent possible, consistent with under Section 110(f) of the NHPA. The purpose of the PA is to facilitate preservation of NSS during decommissioning (including license termination and final disposition). MARAD is the lead Federal agency for the decommissioning of the ship and defined the area of potential effects as the entire vessel. The NRC staff agreed that the undertaking herein would have an adverse effect on NSS as a historic property and, accordingly, signed MARADs PA as a signatory to resolve these effects. The PA was also signed by the Advisory Council on Historic Preservation, the Maryland State Historic Preservation Office, and NPS (as a concurring party). Other concurring parties include the Smithsonian Institution, on behalf of the National Museum of American History, the Steamship Historical Society of America, the N/S Savannah Association, the National Museum of Nuclear Science and History, and the Health Physics Society. Implementation of the PA, including consultation with the Peer Review Group, is ongoing. The NRC also attends the Peer Review Group meetings led by MARAD.

4.3 Endangered Species Act Section 7 Consultation Federal agencies may fulfill their obligations to consult with the FWS under ESA Section 7 in conjunction with the interagency cooperation procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the Federal agency should include the results of the ESA Section 7 consultation in the NEPA document [50 CFR 402.06(b)]. The NRC considers this EA to fulfill its obligations under ESA Section 7.

The NRC staff considered whether any Federally listed or proposed species or designated or proposed critical habitats may be present in the action area (as defined at 50 CFR 402.02) for the proposed action. As discussed in Section 3.8 of this EA, the NRC staff determined that the proposed license termination activities for NSS would have no effect on Federally listed aquatic and terrestrial species or critical habitats. Federal agencies are not required to consult with the FWS if they determine that an action will not affect listed species or critical habitats. Thus, the

4-34 ESA does not require consultation on the proposed license termination activities at NSS. The NRC staff considers its obligations under ESA Section 7 to be fulfilled for the proposed action.

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CONCLUSIONS AND FINDING OF NO SIGNIFICANT IMPACT The NRC has prepared this EA as part of its review of MARADs license amendment request for approval of the LTP for NSS, in Baltimore, Maryland (i.e., the proposed action). The purpose of and need for the proposed action is to authorize MARAD to complete decommissioning of NSS to meet the unrestricted use criteria as specified in 10 CFR 20.142. If approved by the NRC, the NSS license will be amended, by adding a license condition that documents approval of the LTP and stipulating the changes that MARAD can make to the LTP without prior NRC approval.

These proposed changes are described in Chapter 10 of MARADs LTP (MARAD 2023b). After the NRCs approval, MARAD would implement the LTP to complete decommissioning activities of NSS. Once decommissioning is complete, MARAD plans to submit a request to the NRC to terminate the license. Upon NRCs termination of the license, MARAD would proceed to disposition the ship (e.g., preservation, shipbreaking, or artificial reefing) consistent with the process established in the executed PA and in accordance with the NHPA (MARAD 2023a).

To fulfill its obligations under NEPA, the NRC evaluated the radiological and non-radiological environmental impacts associated with approval of MARADs license amendment request for the LTP. The NRC staff assessed impacts on several environmental resources including off-site land use, visual and scenic, noise, air quality, water quality, socioeconomics, public and occupational health and safety, terrestrial and aquatic ecology, transportation, waste management, GHG emissions and climate change, historic and cultural resources, and environmental justice. The NRC staff also evaluated cumulative effects.

As discussed in Section 1.3 of this EA, the NRC staff reviewed MARADs LTP (MARAD 2023b);

environmental report for post operating license stage, which consists of Chapter 8 of the LTP; MARADs 2008 EA and FONSI (MARAD 2008a) and 2019 Supplemental EA and FONSI (MARAD 2019); and MARADs responses (MARAD 2024b) to NRCs environmental RAIs. To limit redundancy, the NRC staff considered and incorporated by reference in this EA, where appropriate, these EAs prepared by MARAD. Additionally, the NRC staff relied on the NRCs Decommissioning GEIS, as appropriate. In the Decommissioning GEIS, the NRC previously evaluated the potential environmental impacts of nuclear reactor decommissioning from the time that a licensee certifies it has permanently ceased power operations until the license is terminated. While NSS is not a nuclear power plant in the traditional sense, the ship was powered by an 80 MWth PWR. Therefore, some of the analyses and conclusions in the Decommissioning GEIS are applicable to the decommissioning of the ship.

Based on the discussions in Chapter 3 of this EA, the NRC staff does not anticipate impacts to public or workers health and safety from radiological and non-radiological hazards, air quality, and transportation beyond those discussed in the Decommissioning GEIS, which concluded that the impact level for these issues was SMALL. Additionally, the NRC staff finds that impacts to off-site land use, geology and soils, water quality (surface and groundwater), visual resources, noise, socioeconomics, and waste management would be SMALL and not be significant. As discussed in Section 3.8 of this EA, the NRC staff determined that impacts to terrestrial and aquatic ecology from the proposed license termination activities would be SMALL and not significant.

While MARAD found that decommissioning, license termination, and final disposition of NSS would have an adverse effect on the ship itself considering its status as a National Historic Landmark, MARAD executed a PA in accordance with the NHPA to address adverse effects, to which the NRC is a signatory.

5-2 The NRC staff also concluded that the proposed license termination activities would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations.

Based on the findings discussed in this EA, as summarized above, the NRC staff concludes that approval of MARADs requested license amendment for the LTP for NSS will not have a significant effect on the quality of the human environment. Therefore, the NRC staff has determined that in accordance with 10 CFR 51.31, Determinations based on environmental assessment, preparation of an environmental impact statement is not warranted for the proposed action. Further, in accordance with 10 CFR 51.32, Finding of no significant impact, the NRC staff has determined that a FONSI is appropriate. Consistent with 10 CFR 51.32(a)(4),

this FONSI incorporates this EA.

Documents related to this environmental review are listed in Section 7 of this EA and are available to interested persons through NRCs Agencywide Documents Access and Management System (ADAMS) using the ADAMS number or as noted in Section 7 of this EA.

This finding will also be published in the FR.

6-1 6

LIST OF PREPARERS This EA was prepared by the Environmental Center of Expertise in the Division of Rulemaking, Environmental, and Financial Support in the Office of Nuclear Material Safety and Safeguards.

Contributors to the EA are listed below.

Contributor Years of Experience, Education Diana Diaz-Toro BS Chemical Engineering MBA Business Administration 22 years of professional experience Jean Trefethen BA Biology & Chemistry Duke NEPA Certificate 15 years of professional experience Briana Arlene

• BS Conservation Biology

• Masters Certification, National Environmental Policy Act

• 18 years of professional experience in ecological impact analysis, Endangered Species Act Section 7 consultations, and Essential Fish Habitat consultations

7-2 7

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