ML24352A199
| ML24352A199 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/2024 |
| From: | Tanya Hood Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Koehler E, Osborne J, Jack Parrott US Dept of Transportation (DOT) |
| References | |
| EPID L-2023-LLA-0151 | |
| Download: ML24352A199 (1) | |
Text
From:
Tanya Hood To:
Koehler, Erhard (MARAD)
Cc:
Jack Parrott; John Osborne
Subject:
Nuclear Ship Savannah - Request for Confirmatory Information RE: Submittal and Request for Approval of the License Termination Plan (EPID L--2023-LLA-0151)
Date:
Monday, December 16, 2024 3:42:00 PM
SUBJECT:
NUCLEAR SHIP SAVANNAH - REQUEST FOR CONFIRMATORY INFORMATION RELATED TO REQUESTED LICENSING ACTION RE: SUBMITTAL AND REQUEST FOR APPROVAL OF THE LICENSE TERMINATION PLAN (EPID L-2023-LLA-0151)
Dear Erhard W. Koehler
By letter dated October 23, 2023 (Agencywide Documents Access and Management System Accession No. ML23298A041), as supplemented by letters dated June 27, 2024, and October16, 2024 (ML24183A271 and ML24292A030, respectively), United States Maritime Administration (MARAD, licensee), submitted a license amendment for the Nuclear Ship Savannah (NS Savannah). The proposed amendment would modify the License to add License Condition 2.C.(4) to include License Termination Plan (LTP) requirements to the U.S. Nuclear Regulatory Commission (NRC) license for NS Savannah.
The purpose of this request for confirmation of information (RCI) is to clarify the NRC staffs understanding of the licensees administrative limit of 15 mrem/y on its remediation efforts.
Affirmative responses to the RCIs will allow the NRC staff to have confidence in the understanding of the information provided in support of the NS Savannah LTP. Prompt attention and response to this request would be appreciated in order to maintain the revised schedule for the NS Savannah LTP review.
The NRC evaluated the LTP to verify that the licensee satisfied the requirement that the plans described in the LTP provide reasonable assurance that the licensee will be able to perform adequate surveys to demonstrate compliance with the radiological criteria for unrestricted use, as specified in Title 10 of the U.S. Code of Federal Regulations (10 CFR)
Paragraph 20.1402, Radiological Criteria for Unrestricted Use.
The NS Savannah project is nearing completion and based on the conservative decommissioning activities a predetermined compliance measure for as low as reasonably achievable (ALARA) is not suitable for this vessel. MARAD has chosen to commit to a performance-based compliance method for ALARA similar to that mentioned in Section 6.3.6.2 of NUREG-1757, Consolidated Decommissioning Guidance, Volume 2, Revision
- 2. However, instead of instituting new programs while the project is concluding, it is sensible to confirm that ALARA concepts that have been in place are, and would be, demonstrable for ALARA.
It is the NRC staffs understanding that MARAD has a radiation safety officer, or the equivalent, who routinely evaluated work activities, contamination levels, and worker exposures to ensure ALARA was maintained during the ships remediation. Also, that MARAD is considering other regulatory drivers that will ensure the actual residual radioactivity will be significantly less than 25 millirem per year (mrem/y). For example, MARAD is establishing an administrative limit of 15 mrem/y on its remediation efforts that can be considered an ALARA practice.
MARAD has also previously communicated that it will not have any elevations of residual radioactivity that exceed the 15 mrem/y derived concentration guideline limit (DCGLw) concentrations. Specifically, all sludge and water containing residual radioactivity will be removed from the ship before license termination, and MARAD has consistently ensured processes are in place that are more restrictive than in the plan (e.g., processes or procedures are established for decontamination personnel to attempt to remediate any area causing instruments to have readings in excess of 1,000 cpm). Lastly, removable activity will be reduced to less than 10percent of the total activity present consistent with assumptions associated with developing the DCGLs.
Please confirm the accuracy of the information above and that these actions will ensure that actual residual radioactivity remaining at license termination will coincide with a much lower hypothetical dose to an average member of the critical group than 25 mrem/y and will demonstrate the residual radioactivity in the NS Savannah at license termination is ALARA.
In accordance with 10 CFR Section 2.390, Public inspections, exemptions, requests for withholding, of the NRCs Agency Rules of Practice and Procedure, a copy of this will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC website at: http://www.nrc.gov/reading-rm/adams.html.
If you have any questions, please contact me.
Tanya E. Hood, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards 301-415-1387