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N.S. Savannah, Submittal of Decommissioning Funds Status Report for 2015
	ML16095A234
Person / Time
Site:	NS Savannah
Issue date:	03/31/2016
From:	Koehler E; US Dept of Transportation, Maritime Admin
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	Download: ML16095A234 (15)
	v • d • e

U.S. Department of Office of Ship Disposal 1200 New Jersey Ave., SE Transportation Washington, DC 20590 Maritime Administration Ref: 10 CFR 50.75(1)(1); 50.82(a)(7) and 50.82(a)(8)(v)-(vii)

March 31, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. SAVANNA.H Submittal of Decommissioning Funds Status Report for Calendar Year (CY) 2015 The Maritime Administration hereby submits Revision 0 of the CY 2015 Decommissioning Funds Status Report for the Nuclear Ship SAVANNAH (see enclosed). The decommissioning cost estimate was updated in its entirety in 2015.

This letter contains no commitments.

If you have any questions or concerns, please feel free to contact me at (202) 366-2631, or by email erhard.koehler@dot.gov.

~'/77_'

~ ~ £/________

Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal Enclosures

Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for CY 2015, Revision 0 March 31, 2016 Enclosures

1. Decommissioning Funds Status Report for CY 2015, STS-197 2

Docket No. 50-238; License NS-1; N.S. SAVANNAH Submittal of Decommissioning Funds Status Report for CY 2015, Revision 0 March 31, 2016 cc:

Electronic copy NSSESC NSS SRC MAR 610, 612, 615 Hardcopy, cover letter only MAR-600, 640, 640.2 Hardcopy w/ all enclosures MAR-100, 640.2 (rf)

USNRC (Ted Smith, Mark C. Roberts)

USNRC Regional Administrator - NRC Region I MD Department of the Environment (Roland G. Fletcher; George S. Abum, Jr.)

NC Department of Environment & Natural Resources (Beverly 0. Hall)

SC Department of Health & Environmental Control (Susan E. Jenkins; Aaron Gantt)

VA Department of Emergency Management (Michael M. Cline)

VA Department of Health (Leslie P. Foldesi)

EWK/jmo 3

1200 New Jersey Ave., SE U.S. Department of Washington, DC 20590 Transportation Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Submittal of Decommissioning Funds Status Report for CY 2015 DECOMMISSIONING FUNDS STATUS REPORT FOR CY 2015, STS -197 4

U.S. Department of Transportation Maritime Administration N.S. SAVANNAH DECOMMISSIONING FUNDS STATUS REPORT FOR CY2015 STS - 197 Revision 0 Approved: Date: March 31, 2016 Manager, N.S. SAVANNAHPrograms Prepared by:

TOTE Services, Inc.

SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 Record of Revisions Revision Summary of Revisions 0 The original version of the Decommissioning Funds Status Report for CY 2015 Revision 0 2

SAVANNAH Technical Staff STS -197, Decommissioning Funds Status Report For CY 2015, Revision 0 List of Effective Pages Page No. Rev.No. Page No. Rev. No. Page No. Rev.No.

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 Table of Contents

1.0 INTRODUCTION

5 1.1 Decommissioning Status 5 1.2 Decommissioning Funding Sources 6 2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT 6 3.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT 7 3.1 , Report required by 10 CFR 50.82(a)(8)(v) 7 3.2 Report required by 10 CFR 50.82(a)(8)(vi) 8 3.3 Report required by 10 CFR 50.82(a)(8)(vii) 8 4.0 CY 2015 FUNDING 9 4.1 FY 2015 9 4.2 FY 2016 9 4.3 FY 2017 9 5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING 9 5 .1 Annual Request for Funds 9 5.2 Annual Submittal of New Estimate 10 5 .3 Revised Decommissioning Cost Estimate (DCE) 10 5.4 Content ofMARAD Budget Requests 10 6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING 10

7.0 REFERENCES

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0

1.0 INTRODUCTION

This Decommissioning Funds Status Report is submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH(NSS) and covers the calendar year (CY) 2015 reporting period.

This report incorporates the guidance contained in Regulatory Guide (RG) 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Rev 1, Reference (a). The report is arranged in four sections following this introduction.

In accordance with the requirements of 10 CFR 50.75(f)(l), each power reactor that has already closed is required to report annually the status of its decommissioning funds to the Nuclear Regulatory Commission (NRC) on a CY basis. Section 2.0 of this Decommissioning Funds Status Report includes the seven (7) reports required by 10 CFR 50.75(f)(l).

In accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii), each power reactor that has already submitted its site-specific Decommissioning Cost Estimate (DCE) is required to provide a financial assurance status report annually to the NRC on a CY basis. MARAD submitted a summary of its DCE with its Post Shutdown Decommissioning Activities Report (PSDAR), Rev 1, Reference (b). Section 3.0 of this Decommissioning Funds Status Report includes the reports required by 10 CFR 50.82(a)(8)(v)-

(vii).

Section 4.0 of this report provides specific information regarding the funds made available to and expended by MARAD during the reporting period.

Finally, Section 5.0 of this report provides information on regulatory commitments made by MARAD that are germane to decommissioning funding.

Because the Federal fiscal year (FY) does not align with the CY, each annual decommissioning funds status report will include information from at least the two FYs that directly provide funds for expenditure during the reporting period. Prior to the submission of the report on (or about) March 31, the President will submit a budget request to the Congress for the upcoming FY. Given that NSS activities are funded on an annual basis, the President's budget request is an early, although not definitive, indicator of future NSS decommissioning funding. Since future funding can impact the decommissioning schedule described in the PSDAR, MARAD includes this public information for context, and in partial satisfaction of the 10 CFR 50.82(a)(7) requirement to notify the NRC of expected changes to content in the PSDAR.

1.1 DECOMMISSIONING STATUS The NSS is presently in protective storage. This phase of decommissioning activities is characterized by active surveillance, monitoring and maintenance of the nuclear facilities housed onboard the ship, and custody and maintenance of the ship as the primary physical boundary and protective barrier of the licensed site. Collectively, these are referred to as MARAD's licensed activities, and are reported annually to the NRC.

As described in the PSDAR, and elsewhere, the license termination deadline for the NSS is December 3, 2031. 1 Final decommissioning of the NSS nuclear facilities will be performed by the DECON2 method.

1 December 3, 1971 is the de facto date of permanent cessation ofoperations. On that day, MARAD completed the reactor defueling by tensioning the reactor vessel head with six studs.

2 DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are removed or decontaminated to a level that permits termination of the license after cessation of operations, as defined by Regulatory Guide 1.184, Rev. 1, Decommissioning of Nuclear Power Reactors.

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 3

In the interim, a project to bring the NSS into conformance with contemporary NRC SAFSTOR criteria (known as "SAFSTOR Preparations") has been described and committed to in the PSDAR.

This report addresses the funding status for all three of these decommissioning phases - licensed activities, SAFSTOR Preparations, and DECON.

1.2 DECOMMISSIONING FUNDING

SOURCES MARAD is a modal agency of the United States Department of Transportation (DOT). It is a Federal licensee as defined by the NRC. As such, funds for decommissioning and termination of the NSS license will be provided by Federal appropriations. The budget process by which such appropriations are requested is deliberative and privileged, and is subject to Executive Branch priorities and direction.

Furthermore, the congressional review and authorization I appropriation actions taken on such requests are fully within the purview of the Legislative Branch. MARAD by itself cannot guarantee that decommissioning funds will be requested by the President or authorized and appropriated by the Congress in any given fiscal year.

2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT This section provides a discussion of the seven items required by 10 CPR 50.75(f)(l), and incorporates the guidance contained in RGl.159. The reporting requirements and corresponding MARAD information are provided below.

2.1 The amount of decommissioning funds estimated to be required.

a) Current licensed activities require approximately $3. 0 million annually. MARAD plans to dry-dock the NSS for regular maintenance once during the protective storage period, in 2018, at an estimated cost of$ 6. 8 million. 4 b) The revised SAFSTOR project cost estimate is $12.2 million.

c) The revised site-specific DECON-License Termination cost estimate is $109.0 million.

2.2 The amount accumulated to the end of the calendar year preceding the date of the report.

Accumulation offunds is not applicable to the NSS. As a Federal licensee, 10 CFR 50. 75(e)(l)(iv) allows funding for decommissioning activities to be obtained by appropriations when necessary.

2.3 A schedule of the annual amounts remaining to be collected.

Annual collection offunds is not applicable to the NSS. As a Federal licensee, 10 CFR 50. 75(e)(l)(iv) allows funding for decommissioning activities to be obtained by appropriations when necessary.

2.4 The assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

The site specific decommissioning cost estimate was revised in its entirety in December 2015.

Therefore, there was no escalation ofprevious decommissioning cost estimate or funding projections.

There are no rates of earnings on decommissioning funds.

3 SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state 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, as defined by Regulatory Guide 1.184, Rev. 1 ,

Decommissioning of Nuclear Power Reactors.

4 The drydocking cost estimate is escalated to a 2018 basis from the $4.1 million contract cost for drydocking the NSS in CY 2008.

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 2.5 Any contracts upon which the licensee is relying pursuant to paragraph (e)(l)(v) of this section.

Not applicable because MARAD, as a Federal licensee, is funded per the JO CFR 50. 75(e)(J)(iv) method 2.6 Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

There have been no modifications to MARAD 's financial assurance methodology, which is limited to the use of Federal appropriations. Please refer to the response in Section 4. J below for more information.

2.7 Any material changes to trust agreements.

Not applicable because MARAD, as a Federal licensee, is funded per the JO CFR 50. 75(e)(J)(iv) method Consequently, no trust agreements exist.

3.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT This section provides a discussion of the 10 items required by 10 CFR 50.82(a)(8)(v)-(vii). Effective December 17, 2012, Section 50.82 imposed new reporting requirements on licensees who previously submitted to the NRC site-specific DCE. The reporting requirements and corresponding MARAD information are provided below.

3.1 REPORT REQUIRED BY 10 CFR 50.82(A)(8)(V)

(A)

1. The amount spent on decommissioning, both cumulative and over the previous calendar year, Within the context ofprotective storage as a phase ofdecommissioning activities, all of the funds spent by MARAD in CY 20J 5 and preceding years (FY 2005 - present) have been spent for decommissioning purposes. As a practical matter, no funds have been spent on major actions described in either the SAFSTOR Implementation Plan or the DECON Cost Estimate.

2. The remaining balance of any decommissioning funds, and Not applicable because MA.RAD, as a Federal licensee, is funded per the JO CFR 50. 75(e)(J)(iv) method. Although funds appropriated to MARAD's Ship Disposal account are "available until expended, " any year-to-year carryover is applied to immediate requirements. No balance is maintained.

3. The amount provided by other financial assurance methods being relied upon; None. MARAD, as a Federal licensee, relies solely on the JO CFR 50. 75(e)(l)(iv) method.

(B) An estimate of the costs to complete decommissioning, reflecting any difference between actual and estimated costs for work performed during the year, and the decommissioning criteria upon which the estimate is based; MARAD's CY 20J5 site specific estimate to complete decommissioning is $J09 million. It was revised in its entirety in 20J 5.

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 (C) Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report; and There have been no modifications to MARAD 's financial assurance methodology, which is limited to the use ofFederal appropriations. Please refer to the response in Section 4.1 below for more information.

(D) Any material changes to trust agreements or financial assurance contracts.

Not applicable because MARAD, as a Federal licensee, relies solely on the JO CFR 50. 75(e)(J)(iv) method.

3.2 REPORT REQUIRED BY 10 CFR 50.82(A)(8)(VI)

If the sum of the balance of any remaining decommissioning funds, plus earnings on such funds calculated at not greater than a two percent real rate of return, together with the amount provided by other financial assurance methods being relied upon, does not cover the estimated cost to complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion.

Not applicable to MARAD.

3.3 REPORT REQUIRED BY 10 CFR 50.82(A)(8)(VII)

After submitting its site-specific DCE required by paragraph (a)(4)(i) of this section, the licensee must annually submit to the NRC, by March 31, a report on the status of its funding for managing irradiated fuel.

The final disposition and status of the Atomic Energy Commission's nuclear fuel utilized by the NSS is described in the September-21, 1973, Operations Report and also in Section 1.3.1 of the Final Safety Analysis Report as follows:

Thirty six spent Juel elements (Core I and la) were shipped from Galveston, TX to the US Atomic Energy Commission (AEC) - Savannah River Plant, Aiken, SC in nine shipments from October 4 through December 21, 1972 via a lowboy trailer using the Piqua/Elk River Shipping cask.

The 10 CFR 50.82(a)(8)(vii) report must include the following information, current through the end of the previous calendar year:

(A) The amount of funds accumulated to cover the cost of managing the irradiated fuel; MARAD is storing no irradiated nuclear fuel and, therefore, has no accumulated funds to cover such costs.

(B) The projected cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy; and MARAD is storing no irradiated nuclear fuel and, therefore, has no need to project such costs.

(C) If the funds accumulated do not cover the projected cost, a plan to obtain additional funds to cover the cost.

MARAD is storing no irradiated nuclear Juel and, therefore, has no need to obtain additional funds to cover such cost.

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SAVANNAH Technical Staff STS - 197, Decommissioning Funds Status Report For CY 2015, Revision 0 4.0 CY 2015 FUNDING The NSS was maintained in mothballed protective storage throughout CY 2015. Approximately $2.70 million in appropriated, carryover and other prior-year funds were available to MARAD to maintain the NSS during the period. Funds were sourced from within MARAD's Ship Disposal appropriations for FY 2015 (January 1 - September 30, 2015) and 2016 (October 1-December31, 2015).

4.1 FY2015 Funding for FY 2015 was initially provided by a Continuing Resolution (CR) that was effective to December 11, 2014. The Consolidated and Further Continuillg Appropriations Act of2015 provided a lump sum of $4.00 million for activities funded by the Ship Disposal account. A nominal breakdown of the lump sum provides $2.00 million for NSS operations, with the balance of program activities funded by prior year carryover.

Based on the revised decommissioning schedule submitted in Reference ( c), the funding for FY 2015 did not result in a change to the content of the PSDAR, and consequently no 10 CFR 50.82(a)(7) notification was submitted.

4.2 FY2016 Funding for FY 2016 was initially provided by a Continuing Resolution (CR) that was effective to December 11, 2015. The Consolidated Appropriations Act 2016 provided a lump sum of $5 .00 million for activities funded by the MARAD Ship Disposal account. A nominal breakdown of the lump sum provides $2.00 million for NSS operations, with the balance of program activities funded by prior year carryover.

Based on the revised decommissioning schedule submitted in Reference (c), the projected funding for FY 2016 did not result in a change to the content of the PSDAR during the reporting period, and consequently no 10 CFR 50.82(a)(7) notification was required.

4.3 FY2017 Although this falls outside the reporting period, MARAD includes this information for context. The President's FY 2017 Budget Request for the Maritime Administration was submitted to the Congress on February 9, 2016. The request for NSS activities includes $3 .00 million for the baseline protective storage condition, and $8.00 million to initiate DECON. In the budget request narrative, DECON is described as a multi-year, incrementally-funded effort, with nominal performance over a seven (7) year timeframe.

Based on the revised decommissioning schedule submitted in Reference ( c), MARAD anticipates that the projected funding for FY 2017, if authorized and appropriated by the Congress, will result in major changes to the content of the PSDAR, which is presently focused on implementing a SAFSTOR upgrade program and continued maintenance of the NSS in protective storage. At the present time, a 10 CFR 50.82(a)(7) notification is premature based on the FY 2017 budget request alone.

5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING There are four (4) recurring commitments regarding decommissioning funding that are reported on in each annual Decommissioning Funds Status Report. The resolution of any one-time commitments will be described as required. The recurring commitments are described in the following sections.

5.1 ANNUAL REQUEST FOR FUNDS In Reference (d), MARAD made the following regulatory commitment:

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SAVANNAH Technical Staff STS -197, Decommissioning Funds Status Report For CY 2015, Revision 0 Annually, MARAD will request funds specifically for decommissioning. The NR C will be informed of these decommissioning funding requests annually by March 31. [Continuing action}

Each year in its Decommissioning Funds Status Report, MARAD includes a statement regarding the budget requests prepared during the reporting period.

Two budget requests are normally in process during any reporting period. The first is the President's Request that is submitted to the Congress during the first quarter of the reporting period for the FY beginning on October 1st of the reporting period. The second is the deliberative and privileged internal process that begins in April, continues throughout the reporting period, and culminates in the President's Request to Congress in the following year. Although the submission of the outyear (or second) budget request falls outside of the reporting period, it does normally occur prior to the reporting deadline of March 31. As noted in Section 1.0, this outyear request is a reasonable predictor of future decommissioning funding and activity, and publicly available information about the request is included in this report for context.

Although the FY 2016 budget request and enacted appropriations did not include a specific request for decommissioning funds, the successful inclusion of such funding in the FY 2017 budget request supersedes any consideration of 2016. MARAD is pleased to report that this commitment is fully satisfied for the CY 2015 and 2016 reporting periods, and expresses its appreciation to its partners in the Office of the Secretary of Transportation (OST) and Office of Management and Budget (OMB) for their thoughtful consideration and action on the matter ofNSS decommissioning. MARAD, OST and OMB remain cognizant of the responsibilities and future funding requirements for DECON, and these obligations will continue to be examined and balanced during future annual budget development cycles.

5.2 ANNUAL SUBMITTAL OF NEW ESTIMATE In Reference (c), MARAD made a regulatory commitment that was subsequently revised as follows:

Submit a new estimate annually by either revising the site specific estimate based on circumstances that affect its underlying assumptions, or by using cost escalation factors no smaller than those in the most recent revision to NUREG 1307.

The site specific DCE was revised in its entirety in 2015.

5.3 REVISED DECOMMISSIONING COST ESTIMATE (DCE)

In Reference (c), MARAD made the following regulatory commitment:

The site specific DCE will be revised at least every five (5) years.

The site specific DCE was revised in its entirety in 2015.

5.4 CONTENT OF MARAD BUDGET REQUESTS In Reference (e), MARAD made the following regulatory commitment:

Because the privity of the Federal budgeting process precludes public notification of the content of agency budget requests prior to their submittal to the Congress, MARAD has determined that future JO CFR 50.82(a)(7) notifications will be submitted under a 10 CFR 2.390 request for withholding.

Based on the revised Decommissioning Activities Schedule submitted to the NRC in Reference (e),

MARAD determined that no 10 CFR 50.82(a)(7) notification (change to the content of the PSDAR, particularly the decommissioning schedule) was required during CY 2015.

6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING As of December 3, 2015, 44 years of protective storage had elapsed; nearly 75% of the allowed 60-year protective storage - DECON - license termination period.

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7.0 REFERENCES

a. Regulatory Guide 1.159, Assuring the Availability ofFunds for Decommissioning Nuclear Reactors, Revision 1, October 2003

b. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),

dated December 11, 2008, Submittal ofPost Shutdown Decommissioning Activities Report, Revision 1

c. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated March 31, 2011, Submittal of Decommissioning Funds Status Report for CY 2010 and updated Governmental Statement ofIntent for Decommissioning Financial Assurance

d. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated March 9, 2011, Response to Receipt of Decommissioning Funds Status Update for CY 2009

e. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated June 04, 2010, Submittal of Decommissioning Funds Status Update for CY 2009 and Governmental Statement ofIntent for Decommissioning Financial Assurance Revision 0 11