ML21063A240: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot change)
(StriderTol Bot change)
 
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:}}
{{#Wiki_filter:U.S. Department of Transportation Maritime Administration N.S. SAVANNAH ANNUAL REPORT FOR CY2020 STS - 214 Revision 0 Approved: ~      £ ~ ~ L - - - - - . . ! :D::!!a:::te-:,_::February 26, 2021 Manager, N.S . SAVANNAH Programs Prepared by:
TOTE Services, Inc.
 
SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revision 0 RECORD OF REVISIONS Revision                                    Summary of Revisions 0          The original version of the 2020 Annual Report License NS-1 LIST OF EFFECTIVE PAGES Pll!!eNo.      Rev.No.          Pll!!eNo.        Rev. No.        Pll!!e No. Rev.No.
1            0                2                0                  3        0 I
4              0                5                0                  6        0 7            0                  8              0                  9        0 10            0                11              0                12        0 13            0                14              0 Revision 0                                                                                2
 
SAVANNAH Technical    Staff STS-214, Annual Report for CY2020, Revisic::m 0 Table of Contents
 
==1.0      INTRODUCTION==
4 l
2.0      ITEMS REQUIRED BY TECHNICAL SPECIFICATIONS                                              4 2.1      TS 3.4.2.1.a. Status of the Facility                                              4 2.1.1 License Activities                                                                5 2.1.2 Organiz.ation                                                                      5 2.1.3 Review of Other Technical Specification Requirements                              5 2.2      TS 3.4.2.1.b. Radiation Surveys and Monitoring Station Dosimeter Readings          6 2.2.1 Radiation Surveys                                                                  6 2.2.2 Monitoring Station Dosimeter Results                                              7 2.3      TS 3.4.2.1.c. Environmental Sample Analysis Surveys                                7 2.4      TS 3.42.1.d. Quarterly Intrusion Alarm System Checks                              7 2.5      TS 3.4.2.1.f. Principal Decommissioning and Maintenance Activities                7 2.6      TS 3.4.2.1.g. Unauthorized Entry Into Radiologically Controlled Areas (RCAs)      9 2.6.1 Event Discussion                                                                  9 2.6.2 Improvements to Access Control                                                    9 2.7      'fS 3.4.2.1.h. Inspection of Primary, Secondary and Auxiliary Systems Degradation  9 2.8      TS 3.4.2.1.i. Summary of Occupational Exposure                                    9 3.0      OTHER NRC REPORTS                                                                        9 3.1      10 CFR 50.59(d)(2) Report of Changes, Tests or Experiments                        9 3.2      10 CFR 50.54(wX3) Insurance Annual Report                                    ,_    9 3.3      Commitment Management                                                              9 4.0      SIGNIFICANT MARAD ISSUES                                                                10 4.1      Remaining Decommissioning Timeline                                                10 4.2      Public Events, Visitation and Training                                            10 4.3      Historic Stewardship                                                              10 4.4      National Historic Preservation Act Consultation                                  10 4.5      COVID-19 Pandemic National Emergency                                              10 I
 
==5.0      REFERENCES==
11 APPENDIX A.        CY2020 Radiation Survey Results in Radiologically Controlled Areas          12 J
APPENDIX B.        CY2020 Ra~iological Environmental Sampling Results                          14 Revision 0                                                                                        3
 
SAVANNAH Technical      Staff STS- 214, Annual Report for CY2020, Revision 0
 
==1.0      INTRODUCTION==
 
This Annual Report is submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH (NSS) and covers the Calendar Year (CY) 2020 reporting period. This report is arranged into three sections following the introduction. Section 2.0 provides the discussion of the various reporting items required by the Technical Specifications (TSs). Section 3.0 includes other periodic reports required by the NRC, and issues of regulatory significance. Section 4.0 includes facility issues that MARAD believes may be of interest to the NRC, including the COVID-19 pandemic national emergency.
In accordance with the requirements of TS 3.42.1, the written annual report shall be submitted prior to March 1 of the following calendar year, and shall specifically include the eight (8) reporting items listed in that specification. These items are addressed in Sections 2.1 through 2.8 inclusive. In addition, TS 3.6.3 requires the Safety Review Committee (SRC) to review ten (10) items, one of which is this annual report. Section 2.1.3 includes the status of these ten (10) SRC review items.
2.0      ITEMS REQUIRED BY TECHNICAL SPECIFICATIONS The eight (8) TS 3 .4.2.1 items specifically required to be included in the written annual report are as follows:
a        The status of the facility (see 2.1).
: b.      The results of the radiation surveys and monitoring station dosimeter readings (see 22).
: c.      The results of environmental sample analysis surveys (see 2.3).
: d.      The results of quarterly intrusion alann system checks (see 2.4 ).
: e.      A description of the principal maintenance performed on the vessel (see 2.5).
: f.      Any unauthorized entry into radiation control areas by visitors or employees and corrective action taken to improve access control (see 2.6).
: g.      Any degradation of one of the several boundaries which contain the radioactive materials aboard the NSS (see 2.7).
: h.      Results of occupational exposure indicated by personal dosimetry (see 2.8).
The status of these subject items were reviewed by the Safety Review Committee at its annual meeting on December 17, 2020 and by the Executive Steering Committee members during its concurrence routing prior to submission of this annual report to the NRC.
2.1      TS 3.4.2.1.A. STATUS OF THE FACILITY During CY2020, the ship was berthed at Pier 13, Canton Marine Terminal, 4601 Newgate Avenue, Baltimore, MD after February 14, 2020 when it returned, under tow, from Philadelphia Ship Repair, LLC, (PSR) in Philadelphia, PA. The ship had been located at PSR starting on September 10, 2019 for drydocking.
MARAD holds a Possession-only license for the NSS nuclear utilization facilities that was modified by License Amendment 15 (Reference a) to allow dismantlement and disposal. As a result of License Amendment 15, the status of the facility is "Dismantlement."
Dismantlement is defined in Regulatory Guide (RG) 1.86, "Termination of Operating Licenses for Nuclear Reactors," Reference (b). This 1974 RG describes the now outmoded Dismantling option of decommissioning. MARAD understands RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12, 2016 and that its withdrawal does not impact the Revision 0                                                                                                  4
 
SAVANNAH Technical      Staff STS - 214, Annual Report for CY2020, Revision 0 NSS licensing basis. MARAD uses the words 'active decommissioning' and 'dismantlement' interchangeably.
Dismantlement is characterized by removal of radioactive fluids, radioactive wastes and other _
materials having activities above accepted unrestricted activity levels. Mothballed activities continue to be performed. These include 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.
Decommissioning activities conducted during the reporting period are described in Sections 2.1.1 and 2.5 below.
2.1.1 LICENSE ACTIVITIES No License Amendments were issued in CY 2020.
MARAD submitted License Amendment Request (LAR) 2020-001 (Reference c) on September 4, 2020. The LAR proposes three administrative changes: 1) eliminate a redundant reporting requirement; 2) eliminate a redundant security requirement; and, 3) revise a requirement to monitor the ship's draft marks instead of draft stripes. NRC acceptance review was noticed in the Federal Register (85FR63146) on October 6, 2020.
2.1.2 ORGANIZATION There were no significant organizational changes during 2020. The 2018 bridge contract awarded to TOTE Services on September 28, 2018 [see Annual Report for CY2018 (Referenced)] was extended several times during CY 2020 and remained in effect at the end of 2020. Staffing levels under the contract fluctuated during the year; the principal factors being the completion of work covered by the contract, and the temporary suspension of decommissioning activities because of the COVID-19 pandemic national emergency (See Section 4.5). As in previous years, the organization is staffed by MARAD direct employees, contractors, and consultants.
The acquisition of a successor contract to carry out MARAD's 2nd and 3ni decommissioning phases was ongoing at the end of the reporting period.
2.1.3 REVIEW OF OTIIBR TECHNICAL SPECIFICATION REQUIREMENTS In accordance with the TS 3.6.3, the Safety Review Committee (SRC) is specifically required to review the following items with or without a formal meeting:
: a.      Proposed changes to Technical Specifications The committee reviewed (LAR) 2020-001 prior to its submittal.
: b.      Evaluations required by 10 CFR 50.59 Safety Evaluation Screenings were performed as required and forwarded for committee review for information. No screening determined that a 10 CFR 50.59 Evaluation was required; consequently, none were performed. Additional information regarding 10 CFR 50.59 Evaluations is found in Section 3.1 of this report.
: c.      Proposed changes or modifications to a Radiologically Controlled Area entry alarm system or reactor containment vessel system The Safety Review Committee reviewed all changes to alarm systems and reactor containment vessel system prior to their implementation. These are summarized in Section 2.5 of this report.
Revision 0                                                                                              5
 
SAVANNAH Technical      Staff STS - 214, Annual Report for CY2020, Revision 0
: d.      Evaluations of substantive changes to the results ofradiological swveys There were no substantive changes to the results of radiological surveys.
: e.      Procedures and revisions per TS 3.5 Procedures and their revisions were reviewed prior to approval.
: f.      Evaluations ofreported violations of Technical Specifications There were no NRC reportable violations to Technical Specifications in 2020.
: g.      Evaluations of reportable events per TS 3.4.3.1 There were no NRC reportable events in CY2020.
: h.      Evaluations of deviations allowed by TS 3. 7.1. 7 One new deviation was approved in 2020:
* STS-004 Deviation - Cupola Head Removed for an extended period.
The deviation associated with alann monitoring while the ship is moving to and from Philadelphia, PA was cancelled after the ship returned to Pier 13.
Other deviations in effect at the end of CY 2020:
* STS-004 Deviation - Loss of Alann Coverage of Technical Specification 3.7.1.5 Doors.
* STS-004 Deviation - Severe Weather prevents daily security patrols.
* STS-004 Deviation - B deck door unlocked and unguarded during RC/CV entry.
: 1.      Audits and self-assessments to verify the effectiveness of the Decommissioning Quality Assurance Plan Assessments were performed in the following functional areas in the reporting period:
* QSA-2020-001, Technical Specification 3.7.1.7 Deviations Review
* QSA-2020-002, Commitment Periodic Review
* QSA-2020-003, 2019 Annual Radiation Protection Program Assessment
* QSA-2020-004, 2020 Annual Radiation Protection Program Assessment J.      Annual reports to the NRC During CY2020, the following reports were reviewed prior to their submission to the NRC:
* CY2019 Annual Report (STS-209).
* CY2019 Decommissioning Funds Status Report (STS-210).
* CY2019 Annual Radiological Environmental Monitoring and Radioactive Effluents Release Reports (STS-212).
2.2    TS 3.4.2.1.B. RADIATION SURVEYS AND MONITORING STATION DOSIMETER
    ' READINGS 2.2.1 RADIATION SURVEYS A routine radiological survey program continued to be followed in CY2020. Radiological survey measurements were taken in various RCAs and non-RCAs. All readings in non-RCAs were insignificant as compared to background radiation levels.
The results of the CY2020 Radiation Survey Results in RCAs are listed in Appendix A.
Revision 0                                                                                            6
 
SAVANNAH Technical Staff STS- 214, Annual Report for CY2020, Revision 0 2.2.2 MONITORING STATION DOSIMETER RESULTS Forty-five (45) permanently placed thermo-luminescent dosimeter (TLD) monitoring stations are dispersed throughout the non-RCAs of the NSS and in those areas of the NSS that are routinely occupied. Fixed point radiation surveys are performed during TLD change outs. Results from the TLDs from all monitoring stations indicated that readings were insignificant as compared to the background radiation levels. No fixed-point radiation dose rate exceeded 5 µR/hr (micro-R/hr).
2.3      TS 3.4.2.J.C. ENVIRONMENTAL SAMPLE ANALYSIS SURVEYS Environmental water and sediment samples were taken adjacent to the ship at various times during the calendar year as required by TS. The environmental sample results indicate that any changes in the radiological conditions in the environment surrounding NSS are insignificant as compared to the samples taken shortly before the NSS arrived at Pier 13. Therefore, based on the results of the radiological environmental monitoring program, NSS operations at Pier 13 did not have any adverse effects on the health and safety of the public or on the environment in 2020.
The results of the CY2020 Radiological Environmental Sampling Results are listed in Appendix B.
2.4      TS 3.4.2.J.D. QUARTERLY INTRUSION ALARM SYSTEM CHECKS Routine security surveillances were conducted as required by TS 3.7.2.1. On a quarterly basis, the staff performed SIC-TS-Q-1, RCA Entrances Secured, Lock, Key and Seal Number Verification Inspection.
Other monitored doors were tested.
Redundant security alarms were removed from the fire alarm system.
2.5      TS 3.4.2.J.F. PRINCIPAL DECOMMISSIONING AND MAINTENANCE ACTIVITIES At the beginning of CY 2020, NSS was on drydock at PSR. The drydocking availability included some component removals from RCAs that were performed in CY 2019, and described in Reference (e). Most of the drydock work completed during CY 2020 involved steel repairs to the ship's exterior shell plating; surveys and repairs to double bottom ballast tanks; painting of the ship's underwater hull; and other tasks associated with maintenance of the ship's hull structure and mooring equipment. The drydock maintenance and repairs were performed under survey by the American Bureau of Shipping (ABS) for third party accreditation of the hull and equipment material condition. During the dry docking period, PSR also performed several Phase I decommissioning work activities, including:
* Work to reactivate the Reactor Compartment Hatch and install a new hatch lifting assembly (whose design is based on a similar installation fitted for the 1971 defueling).
* Temporary removal of the Containment Vessel Cupola Shield Ring to provide access to the CV Cupola Head bolts; most bolts were removed to facilitate future removal of the cupola head.
* Modifications to the A Deck Fan Room to receive a new high capacity HEPA exhaust fan for the future decommissioning HVAC system.
* Fabrication and installation of two watertight stair tower enclosures as the exterior termini for the future cargo hold fire stair installation.
* Installation of penetrations and stub piping in the CH 4 Port and Stbd double bottom ballll$t tanks for combined suction and discharge connections, tank level indicators, and cross-over tank venting for the future heel control system.
The ship was refloated on February 8, 2020. On February 11, an inclining experiment was conducted with the ship afloat inside the drydock basin. The inclining experiment was performed to determine the ship's lightship stability characteristics, and to aid in developing ballasting plans for decommissioning.
Revision 0                                                                                                  7
 
SAVANNAH Technical        Staff STS - 214, Annual Report for CY2020, Revision 0 Ballast conditions were later developed that account for the removal of the fixed weight of the nuclear power plant major components, systems and structures associated with DECON-LT, while maintaining a positive stability range for the ship. NSS departed the PSR facility on the morning of February 13, 2020, and was towed directly to Pier 13 via the Delaware River, Chesapeake and Delaware Canal, Elk River, Upper Chesapeake Bay and the Patapsco River into Baltimore Harbor. NSS arrived at Pier 13 at approximately 10pm February 13, and was secured to the pier with shore power restored early in the morning of February 14.
In the immediate weeks following the return to Pier 13, work to complete the Phase I decommissioning infrastructure and ship outfitting progressed rapidly. However, by mid-March, the effects of the COVID-19 pandemic were becoming visible. Shutdowns in Pennsylvania preceded those in Maryland, and affected several subcontractors providing service to NSS. As noted in Section 4.5, MARAD itself suspended work activities on March 31. None of the projects were physically complete by March 31, and remained suspended until the NSS Return to Work plan was approved in late June (see Section 4.5).
After work resumed, the balance of the infrastructure and outfitting could be completed. The work performed in CY 2020 after the ship's return from PSR included the following:
* Repairs and reconditioning of the CH 4 Main Deck hatch covers and installation of new electric winches and controls for operation of the hatch.
* Completion of the Reactor Hatch lifting assembly including rigging, testing, and fitting of a locking mechanism for the hatch when it is in the raised position.
* Removal of the CV cupola head and shield ring to facilitate access to the CV for component and waste material removals during future dismantlement activities (cupola head and shield ring are stored under cover on Pier 13).
* Completion of Fire Haz.ards Analysis action items including the replacement of the forward emergency egress ladder system; aft emergency egress ladder system; paint locker fire suppression system; expansion of the fire and smoke detection and general alarm systems, with expanded annunciation throughout the working areas of the cargo holds and on the weather decks.
* Completed the Heel Control System in Cargo Hold 4. The system cross connects the port and starboard double bottom tanks to allow ballast water transfers between the tanks to minimize the ship's list (heel) during major lifting operations, such as the future Reactor Pressure Vessel removal.
* Completed construction of three stair towers in Cargo Holds 2 (aft) and 4 (forward and aft stairs) for personnel access and egress to the working areas of Cargo Holds 3 and 4; two of the stairs are enclosed with termini on the main deck for fire safety/ egress.
* Installed and tested a decommissioning Heating, Ventilation and Air Conditioning (HVAC) system encompassing Cargo Holds 3 and 4, and the Reactor Compartment (RC). The RC and lower levels of Cargo Holds 3 and 4 are serviced by the high capacity HEPA exhaust fan to keep those working areas at a slight negative pressure during dismantlement and waste material handling activities. Several structural boundaries were erected to segregate the negative pressure zones from normal HVAC supply.
* Completed safety barrier improvements within the CV, and replaced the interim ladder access to the RC Lower Level with a permanent installation.
* Implemented the Cold and Dark Panel survey for the RC to sever electrical cables and remove redundant panels, as needed, to establish Cold and Dark conditions inside the RC.
Lighting and alarm systems inside the RC were isolated from original sources of power and the old sources were verified deenergized.
Revision 0                                                                                                8
 
SAVANNAH Technical      Staff STS - 214, Annual Report for CY2020, Revision 0 2.6      TS 3.4.2.1.G. UNAUTHORIZED ENTRY INTO RADIOLOGICALLY CONTROLLED AREAS (RCAS)
No unauthorized entries were made into any RCAs in CY2020.
2.6.1 EVENT DISCUSSION None 2.6.2 IMPROVEMENTS TO ACCESS CONTROL None
: 2. 7    TS 3.4.2.1.H. INSPECTION OF PRIMARY, SECONDARY AND AUXILIARY SYSTEMS DEGRADATION The annual inspection required by TS 3.7 3.4 was completed on December 22, 2020. It is documented in SIC-TS-A-2 RO Structures, Systems and Components Annual Inspection 2020. There was no notable degradation of the primary, secondary or auxiliary systems since the last inspection in 2019. The report noted many improvements in areas throughout the ship that corrected long standing issues.
2.8      TS 3.4.2.1.L
 
==SUMMARY==
OF OCCUPATIONAL EXPOSURE Because the NSS has been permanently shutdown for more than 45 years, no individual is expected to receive in one year from sources external to the body, a dose in excess of 10 percent of the limits specified in 10 CFR 20.1201. In 2020, the number of individuals monitored with Tills during their entries into RCAs was 95. No individual received more than 10 mRem from occupational sources during the monitoring period.
3.0      OTHER NRC REPORTS 3.1      10 CFR 50.59(D)(2) REPORT OF CHANGES, TESTS OR EXPERIMENTS The regulations require each power reactor licensee to submit, at intervals not to exceed 24 months, a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each.                                                                                  ,
No Changes, Tests or Experiments were proposed in CY2020 that would require a 10 CFR 50.59 evaluation, and, consequently, no evaluations were completed.
Screenings are forward~d to Safety Review Committee members for information.
3.2      10 CFR 50.54(W)(3) INSURANCE ANNUAL REPORT The regulations require each power reactor licensee to obtain insurance available at reasonable costs and on reasonable terms from private sources or to demonstrate to the satisfaction of the NRC that it possesses an equivalent amount of protection covering the licensee's obligation. MARAD adheres to the Federal rules of self-insurance as a matter of established policy.              '
3.3      COMMITMENT MANAGEMENT No Regulatory Commitments were made or revised in CY2020.
Revision 0                                                                                                9
 
SAVANNAH Technical              Staff STS-214, Annual Report for CY2020, Revision 0 4.0        SIGNIFICANT MARAD ISSUES 4.1      REMAINING DECOMMISSIONING TIMELINE The license termination deadline for the NSS is December 3, 2031 1, based on the Permanent Cessation of Operations milestone date of December 3, 1971. Decommissioning is scheduled to be complete well within the allowed 60-year license termination period.
4.2      PUBLIC EVENTS, VISITATION AND TRAINING As a result of the COVID 19 Pandemic, MARAD suspended its traditional program of public access and training support for local, state and federal agencies during CY2020.
4.3      HISTORIC STEWARDSHIP The NSS was designated as a National Historic Landmark (NHL) in 1991, and is the only directly-owned, managed and maintained NHL property in the Department of Transportation inventory. Under the provisions of the National Historic Preservation Act (NHPA) of 1966, as amended, the highest standard of care for historic objects falls upon federal owners of NHLs. MARAD maintains a continuous focus on its historic stewardship responsibilities when conducting activities on the NSS site. All work on the ship, whether radiological or not, is sensitive to maintaining the historic fabric and appearance of the ship.
MARAD's Federal Preservation Officer (FPO) provides expert advice and guidance to licensee staff in these matters, particularly with respect to the implementation of the Secretary of the Interior's Standards for the Treatment of Historic Properties and Historic Vessel Preservation Projects.
4.4      NATIONAL HISTORIC PRESERVATION ACT CONSULTATION As discussed in previous annual reports, MARAD initiated consultation under Section 106 of the NHPA in April 2018 to address the potential adverse effects and harm to the NSS as a NHL arising from decommissioning and license termination activities. NRC is one of four federal agencies and state organizations that are parties to the consultation. The other entities include the Advisory Council on Historic Preservation (ACHP~, the National Park Service (NPS) and the Maryland Historic Trust (MIIT), ,
acting as the State Historic Preservation Officer. Consulting efforts were affected by the pandemic, and completion of a Programmatic Agreement (PA) to cover the aspects of the undertaking were still incomplete at the end of the CY2020 reporting period.
4.5        COVID-19 PANDEMIC NATIONAL EMERGENCY As reported to the NRC in an email dated March 30, 2020, MARAD temporarily suspended its decommissioning Phase I projects at the onset of the COVID-19 emergency. Operations essentially reverted to the pre-decommissioning baseline, with onboard staff limited to essential personnel and all visitations restricted. Modified access controls were established to include pre-boarding medical screening of all personnel; the watchstanding function was relocated to the pier to facilitate this.
MARAD confirms its TSIM contractor maintained core staff, and performed all necessary surveillances and inspections during the suspension period. The Savannah Emergency Radiological Assistance Team (SERAT) capability was also maintained as required to meet Technical Specification (TS) requirements.
MARAD implemented a phased return-to-work (RTW) program beginning on June 22, 2020. Under RTW-2, the shipboard complement was increased to thirty (30) persons, with density controls established to limit personnel concentrations within working spaces. Decommissioning work activities were resumed in July to complete the Phase I work scope. Two Monday-Friday production shifts and regular Saturday shifts were required from August through the end of November to make up for both the lost time (months 1
December 3, 1971 IS the de facto date of permanent cessation of operat.lons date based on completmg the reactor defueling that date by tensmning the reactor vessel head with six studs Revision 0
 
SAVANNAH Technical Staff STS- 214, Annual Report for CY2020, Revision 0 of April-June) and RTW ship density limitations. The RTW-2 shipboard complement was further increased to forty-five (45) persons in early December, at which time the multiple shifts were discontinued. The Phase I work was substantially complete at the end of the reporting period.
The pandemic emergency declaration delayed the acquisition of successor contract services for DECON-LT phases II and ill. A Request for Proposal for those services was extended several times to account for the restricted access to the ship. After the RTW plan was approved, site visits for the offerors were conducted in July. As noted in Section 2.1.2, the evaluation of proposals was ongoing at the end of the calendar year reporting period.
The COVID-19 access controls and other RTW conditions remain in effect at the time ohhis report submittal.
 
==5.0      REFERENCES==
: a. Letter from Mr. John B. Hickman (NRC) to Mr. Erhard W. Koehler (MARAD), dated April 23, 2018, Nuclear Ship SAVANNAH - Issuance OfAmendment 15 to revise the License to allow Dismantlement and Disposal
: b. Regulatory Guide 1.86, Termination a/Operating Licenses for Nuclear Reactors, June 1974
: c. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated September 4, 2020, License Amendment Request No. LAR 2020-01, Administrative Changes to Technical Specifications
: d. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated February 27, 2019, Annual Report for CY2018, Revision 0
: e. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),
dated February 26, 2020, Annual Report for CY2019, Revision 0 Revision 0                                                                                              11
 
SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revision 0 Appendix A    CY2020 Radiation Sun-ey Re8ults in Radiologically Controlled Areas APPENDIX A.          CY2020 RADIATION SURVEY RESULTS IN RADIOLOGICALLY CONTROLLED AREAS Area        General Area        Highest          General Area              Highe8t Radiation    Radiation Level      Contamination        Contamination levels mR/hr    mR/hr ( milli-          Level                  Level (milli-R/hr)        R/hr)          IDPM/100cm 2)          IDPM/100cm 2)
Reactor                  <1.0            <1.0              <1000                  ~1000 Compartment Cupola Level A Deck Reactor                  <1.0            <1.0              <1000                  <1000 Compartment Upper Level B Deck Reactor          I
                        <1.0            <1.0              <1000                  <1000 Compartment Middle Level C Deck Reactor                  <1.0            <1.0              <1000                  <1000 Compartment Middle Level D Deck Reactor                  2.0            15              ,<1000                  <1000 Compartment                          Contacton Lower Level Fwd                      overhead line Reactor                  <1.0            <1.0              <1000                  <1000 Compartment Lower Level Aft Containment              <1.0            <1.0              <1000                  <1000 Vessel 1st Level Containment              1.0            1.6              <1000                  <1000 Vessel 2nd Level Containment              1.7            2.5              <1000                  <1000 Vessel 3rd Level Containment              <1.0            <1.0              <1000                  <1000 Vessel 4th Level  4.5 between U tube of both steam generators Cold Chemistry Lab and Rad                      Down posted (CCL Door locked per Tech Spec Req.)
Monitoring Rm C-Deck I Radiation                <1.0            <1.0              <1000            15200 loose surface Sampling Room                                                                  on floor at Stbd D-Deck                                                                          comer (A)
Gas Adsorption        Down posted (Encompassed within CCL Door, locked per Tech Spec Req.)
RoomD-Deck Revision 0                                                                                      12
 
SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 Appendix A        CY2020 Radiation Survey Results in Radiologically Controlled Areas Area            General Area          Highest            General.Area              Highest Radiation      Radiation Level      Contamination          Contamination levels mR/hr      mR/hr ( milli-            Level                  Level (milli-R/hr)          R/hr)            IDPM/100cm2)            (DPM/100cm 1)
Cargo Hold 4 D-              <1.0              <1.0                <1000                    <1000 DeckLLRW Sto~e NEWSDDeck                    <1.0              <1.0                <1000                    <1000 Rad Stonu;1;e Sugar and Flour              <1.0              <1.0                <1000                    <1000 Stores Hull Survey                  <1.0              <1.0                <1000                    <1000
                                    )
(Drydock)
Port Stabilizer              <1.0              <1.0          <1000 loose surface    <l000loosesurface Rooms posted as a                                                                      2000 fixed on tank Rad Material Area                                                                              top Starboard                    <1.0              <1.0                <1000                    <1000 Stabilizer Room posted as a Rad Material Area (B)
Table Data Notes (A) Loose surface in process of being removed in February 2021. Legacy fixed contamination identified and scheduled to be addressed in 2021.
(B) Posted as Rad Material Area due to the common tunnel connecting the two stabilizer rooms, due to survey identifying fixed contamination on port side on 1/8/2021.
Revision 0                                                                                              13
 
SAVANNAH Technical                    Staff STS - 214, Annual Report for CY2020, Revision 0 Appendix B                  CY2020 Radiological Environmental Sampling Results APPENDIXB.                            CY2020 RADIOLOGICAL ENVIRONMENTAL SAMPLING RESULTS
,.  ,. . ' ,_..$* >' '  '    ~ ** :/  , ' ' . ~1*
                                                      '.' '{} ;"'  *.~*- ~mple.
* typ*e of  ' .. . (pCVg)*.
Co-60'**  :.*~137 .Y
  ~
          *. **:, Sample Locati~n *
                          ..                      '    .      .      **Date    *sample  .
                                                                                                                  . . (pCi/~{': .
Pier # 13 in the vicinity of the forward ,                                                              <MDA Water location of the ship (Prior to return from                                                          (minimum 02/07/2020                                    <MDA drydock),                                                                                            detectable (A)
Canton Marine Terminal, Baltimore, MD                                                                  activity)
Pier # 13 in the vicinity of the forward                                                                            9.0lE-02 (C) location of the ship (Prior to return from                                          Sediment 02/07/2020                      <MDA drydock),                                                                            (A)(B)
MDA=
Canton Marine Terminal, Baltimore, MD 8.26E-02 Pier # 13 in the vicinity of the aft location of the ship (Prior to return from 02/07/2020  Water(A)            <MDA          <MDA drydock),
Canton Marine Terminal, Baltimore, MD Pier # 13 in the vicinity of the aft location of the ship (Prior to return from                                                  Sediment 02/07/2020                      <MDA          <MDA drydock),                                                                            (A)(B)
Canton Marine Terminal, Baltimore, MD Pier #13, Canton Marine Terminal, Water(A)            <MDA          <MDA Baltimore, MD NSS Stbd Side, Forward                                  10/22/2020 1.0lE-01 (C)
Pier #13, Canton Marine Terminal,                                                  Sediment
                                                                                                        <MDA Baltimore, MD NSS Stbd Side, Forward                                  10/22/2020      (A)(B)
MDA=
5.99E-02 Pier #13, Canton Marine Terminal, Water (A)          <MDA          <MDA Baltimore, MD NSS Port Side, Aft                                      10/22/2020 Pier #13, Canton Marine Terminal,                                                  Sediment
                                                                                                        <MDA        <MDA(C)
Baltimore, MD NSS Port Side, Aft                                      10/22/2020      (A)(B)
Table Data Notes (A) Calculated MDAs are a-posteriori values at the 95% confidence level.
(B) Activity is reported on a dry weight basis unless otherwise indicated in the case narrative and is decay corrected to the sample collect date.
(C) Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)
Revision 0                                                                                                                    14}}

Latest revision as of 19:23, 19 January 2022

Tote Services, Inc., Annual Report for CY2020, Revision 0
ML21063A240
Person / Time
Site: NS Savannah
Issue date: 02/26/2021
From:
Tote Services
To:
Office of Nuclear Reactor Regulation
Shared Package
ML21063A238 List:
References
STS - 214, Rev 0
Download: ML21063A240 (14)


Text

U.S. Department of Transportation Maritime Administration N.S. SAVANNAH ANNUAL REPORT FOR CY2020 STS - 214 Revision 0 Approved: ~ £ ~ ~ L - - - - - . . ! :D::!!a:::te-:,_::February 26, 2021 Manager, N.S . SAVANNAH Programs Prepared by:

TOTE Services, Inc.

SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revision 0 RECORD OF REVISIONS Revision Summary of Revisions 0 The original version of the 2020 Annual Report License NS-1 LIST OF EFFECTIVE PAGES Pll!!eNo. Rev.No. Pll!!eNo. Rev. No. Pll!!e No. Rev.No.

1 0 2 0 3 0 I

4 0 5 0 6 0 7 0 8 0 9 0 10 0 11 0 12 0 13 0 14 0 Revision 0 2

SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revisic::m 0 Table of Contents

1.0 INTRODUCTION

4 l

2.0 ITEMS REQUIRED BY TECHNICAL SPECIFICATIONS 4 2.1 TS 3.4.2.1.a. Status of the Facility 4 2.1.1 License Activities 5 2.1.2 Organiz.ation 5 2.1.3 Review of Other Technical Specification Requirements 5 2.2 TS 3.4.2.1.b. Radiation Surveys and Monitoring Station Dosimeter Readings 6 2.2.1 Radiation Surveys 6 2.2.2 Monitoring Station Dosimeter Results 7 2.3 TS 3.4.2.1.c. Environmental Sample Analysis Surveys 7 2.4 TS 3.42.1.d. Quarterly Intrusion Alarm System Checks 7 2.5 TS 3.4.2.1.f. Principal Decommissioning and Maintenance Activities 7 2.6 TS 3.4.2.1.g. Unauthorized Entry Into Radiologically Controlled Areas (RCAs) 9 2.6.1 Event Discussion 9 2.6.2 Improvements to Access Control 9 2.7 'fS 3.4.2.1.h. Inspection of Primary, Secondary and Auxiliary Systems Degradation 9 2.8 TS 3.4.2.1.i. Summary of Occupational Exposure 9 3.0 OTHER NRC REPORTS 9 3.1 10 CFR 50.59(d)(2) Report of Changes, Tests or Experiments 9 3.2 10 CFR 50.54(wX3) Insurance Annual Report ,_ 9 3.3 Commitment Management 9 4.0 SIGNIFICANT MARAD ISSUES 10 4.1 Remaining Decommissioning Timeline 10 4.2 Public Events, Visitation and Training 10 4.3 Historic Stewardship 10 4.4 National Historic Preservation Act Consultation 10 4.5 COVID-19 Pandemic National Emergency 10 I

5.0 REFERENCES

11 APPENDIX A. CY2020 Radiation Survey Results in Radiologically Controlled Areas 12 J

APPENDIX B. CY2020 Ra~iological Environmental Sampling Results 14 Revision 0 3

SAVANNAH Technical Staff STS- 214, Annual Report for CY2020, Revision 0

1.0 INTRODUCTION

This Annual Report is submitted by the Maritime Administration (MARAD) as licensee for the Nuclear Ship SAVANNAH (NSS) and covers the Calendar Year (CY) 2020 reporting period. This report is arranged into three sections following the introduction. Section 2.0 provides the discussion of the various reporting items required by the Technical Specifications (TSs). Section 3.0 includes other periodic reports required by the NRC, and issues of regulatory significance. Section 4.0 includes facility issues that MARAD believes may be of interest to the NRC, including the COVID-19 pandemic national emergency.

In accordance with the requirements of TS 3.42.1, the written annual report shall be submitted prior to March 1 of the following calendar year, and shall specifically include the eight (8) reporting items listed in that specification. These items are addressed in Sections 2.1 through 2.8 inclusive. In addition, TS 3.6.3 requires the Safety Review Committee (SRC) to review ten (10) items, one of which is this annual report. Section 2.1.3 includes the status of these ten (10) SRC review items.

2.0 ITEMS REQUIRED BY TECHNICAL SPECIFICATIONS The eight (8) TS 3 .4.2.1 items specifically required to be included in the written annual report are as follows:

a The status of the facility (see 2.1).

b. The results of the radiation surveys and monitoring station dosimeter readings (see 22).
c. The results of environmental sample analysis surveys (see 2.3).
d. The results of quarterly intrusion alann system checks (see 2.4 ).
e. A description of the principal maintenance performed on the vessel (see 2.5).
f. Any unauthorized entry into radiation control areas by visitors or employees and corrective action taken to improve access control (see 2.6).
g. Any degradation of one of the several boundaries which contain the radioactive materials aboard the NSS (see 2.7).
h. Results of occupational exposure indicated by personal dosimetry (see 2.8).

The status of these subject items were reviewed by the Safety Review Committee at its annual meeting on December 17, 2020 and by the Executive Steering Committee members during its concurrence routing prior to submission of this annual report to the NRC.

2.1 TS 3.4.2.1.A. STATUS OF THE FACILITY During CY2020, the ship was berthed at Pier 13, Canton Marine Terminal, 4601 Newgate Avenue, Baltimore, MD after February 14, 2020 when it returned, under tow, from Philadelphia Ship Repair, LLC, (PSR) in Philadelphia, PA. The ship had been located at PSR starting on September 10, 2019 for drydocking.

MARAD holds a Possession-only license for the NSS nuclear utilization facilities that was modified by License Amendment 15 (Reference a) to allow dismantlement and disposal. As a result of License Amendment 15, the status of the facility is "Dismantlement."

Dismantlement is defined in Regulatory Guide (RG) 1.86, "Termination of Operating Licenses for Nuclear Reactors," Reference (b). This 1974 RG describes the now outmoded Dismantling option of decommissioning. MARAD understands RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12, 2016 and that its withdrawal does not impact the Revision 0 4

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 NSS licensing basis. MARAD uses the words 'active decommissioning' and 'dismantlement' interchangeably.

Dismantlement is characterized by removal of radioactive fluids, radioactive wastes and other _

materials having activities above accepted unrestricted activity levels. Mothballed activities continue to be performed. These include 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.

Decommissioning activities conducted during the reporting period are described in Sections 2.1.1 and 2.5 below.

2.1.1 LICENSE ACTIVITIES No License Amendments were issued in CY 2020.

MARAD submitted License Amendment Request (LAR) 2020-001 (Reference c) on September 4, 2020. The LAR proposes three administrative changes: 1) eliminate a redundant reporting requirement; 2) eliminate a redundant security requirement; and, 3) revise a requirement to monitor the ship's draft marks instead of draft stripes. NRC acceptance review was noticed in the Federal Register (85FR63146) on October 6, 2020.

2.1.2 ORGANIZATION There were no significant organizational changes during 2020. The 2018 bridge contract awarded to TOTE Services on September 28, 2018 [see Annual Report for CY2018 (Referenced)] was extended several times during CY 2020 and remained in effect at the end of 2020. Staffing levels under the contract fluctuated during the year; the principal factors being the completion of work covered by the contract, and the temporary suspension of decommissioning activities because of the COVID-19 pandemic national emergency (See Section 4.5). As in previous years, the organization is staffed by MARAD direct employees, contractors, and consultants.

The acquisition of a successor contract to carry out MARAD's 2nd and 3ni decommissioning phases was ongoing at the end of the reporting period.

2.1.3 REVIEW OF OTIIBR TECHNICAL SPECIFICATION REQUIREMENTS In accordance with the TS 3.6.3, the Safety Review Committee (SRC) is specifically required to review the following items with or without a formal meeting:

a. Proposed changes to Technical Specifications The committee reviewed (LAR) 2020-001 prior to its submittal.
b. Evaluations required by 10 CFR 50.59 Safety Evaluation Screenings were performed as required and forwarded for committee review for information. No screening determined that a 10 CFR 50.59 Evaluation was required; consequently, none were performed. Additional information regarding 10 CFR 50.59 Evaluations is found in Section 3.1 of this report.
c. Proposed changes or modifications to a Radiologically Controlled Area entry alarm system or reactor containment vessel system The Safety Review Committee reviewed all changes to alarm systems and reactor containment vessel system prior to their implementation. These are summarized in Section 2.5 of this report.

Revision 0 5

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0

d. Evaluations of substantive changes to the results ofradiological swveys There were no substantive changes to the results of radiological surveys.
e. Procedures and revisions per TS 3.5 Procedures and their revisions were reviewed prior to approval.
f. Evaluations ofreported violations of Technical Specifications There were no NRC reportable violations to Technical Specifications in 2020.
g. Evaluations of reportable events per TS 3.4.3.1 There were no NRC reportable events in CY2020.
h. Evaluations of deviations allowed by TS 3. 7.1. 7 One new deviation was approved in 2020:
  • STS-004 Deviation - Cupola Head Removed for an extended period.

The deviation associated with alann monitoring while the ship is moving to and from Philadelphia, PA was cancelled after the ship returned to Pier 13.

Other deviations in effect at the end of CY 2020:

  • STS-004 Deviation - Severe Weather prevents daily security patrols.
  • STS-004 Deviation - B deck door unlocked and unguarded during RC/CV entry.
1. Audits and self-assessments to verify the effectiveness of the Decommissioning Quality Assurance Plan Assessments were performed in the following functional areas in the reporting period:
  • QSA-2020-002, Commitment Periodic Review
  • QSA-2020-003, 2019 Annual Radiation Protection Program Assessment
  • QSA-2020-004, 2020 Annual Radiation Protection Program Assessment J. Annual reports to the NRC During CY2020, the following reports were reviewed prior to their submission to the NRC:
  • CY2019 Annual Report (STS-209).
  • CY2019 Decommissioning Funds Status Report (STS-210).
  • CY2019 Annual Radiological Environmental Monitoring and Radioactive Effluents Release Reports (STS-212).

2.2 TS 3.4.2.1.B. RADIATION SURVEYS AND MONITORING STATION DOSIMETER

' READINGS 2.2.1 RADIATION SURVEYS A routine radiological survey program continued to be followed in CY2020. Radiological survey measurements were taken in various RCAs and non-RCAs. All readings in non-RCAs were insignificant as compared to background radiation levels.

The results of the CY2020 Radiation Survey Results in RCAs are listed in Appendix A.

Revision 0 6

SAVANNAH Technical Staff STS- 214, Annual Report for CY2020, Revision 0 2.2.2 MONITORING STATION DOSIMETER RESULTS Forty-five (45) permanently placed thermo-luminescent dosimeter (TLD) monitoring stations are dispersed throughout the non-RCAs of the NSS and in those areas of the NSS that are routinely occupied. Fixed point radiation surveys are performed during TLD change outs. Results from the TLDs from all monitoring stations indicated that readings were insignificant as compared to the background radiation levels. No fixed-point radiation dose rate exceeded 5 µR/hr (micro-R/hr).

2.3 TS 3.4.2.J.C. ENVIRONMENTAL SAMPLE ANALYSIS SURVEYS Environmental water and sediment samples were taken adjacent to the ship at various times during the calendar year as required by TS. The environmental sample results indicate that any changes in the radiological conditions in the environment surrounding NSS are insignificant as compared to the samples taken shortly before the NSS arrived at Pier 13. Therefore, based on the results of the radiological environmental monitoring program, NSS operations at Pier 13 did not have any adverse effects on the health and safety of the public or on the environment in 2020.

The results of the CY2020 Radiological Environmental Sampling Results are listed in Appendix B.

2.4 TS 3.4.2.J.D. QUARTERLY INTRUSION ALARM SYSTEM CHECKS Routine security surveillances were conducted as required by TS 3.7.2.1. On a quarterly basis, the staff performed SIC-TS-Q-1, RCA Entrances Secured, Lock, Key and Seal Number Verification Inspection.

Other monitored doors were tested.

Redundant security alarms were removed from the fire alarm system.

2.5 TS 3.4.2.J.F. PRINCIPAL DECOMMISSIONING AND MAINTENANCE ACTIVITIES At the beginning of CY 2020, NSS was on drydock at PSR. The drydocking availability included some component removals from RCAs that were performed in CY 2019, and described in Reference (e). Most of the drydock work completed during CY 2020 involved steel repairs to the ship's exterior shell plating; surveys and repairs to double bottom ballast tanks; painting of the ship's underwater hull; and other tasks associated with maintenance of the ship's hull structure and mooring equipment. The drydock maintenance and repairs were performed under survey by the American Bureau of Shipping (ABS) for third party accreditation of the hull and equipment material condition. During the dry docking period, PSR also performed several Phase I decommissioning work activities, including:

  • Work to reactivate the Reactor Compartment Hatch and install a new hatch lifting assembly (whose design is based on a similar installation fitted for the 1971 defueling).
  • Temporary removal of the Containment Vessel Cupola Shield Ring to provide access to the CV Cupola Head bolts; most bolts were removed to facilitate future removal of the cupola head.
  • Modifications to the A Deck Fan Room to receive a new high capacity HEPA exhaust fan for the future decommissioning HVAC system.
  • Fabrication and installation of two watertight stair tower enclosures as the exterior termini for the future cargo hold fire stair installation.
  • Installation of penetrations and stub piping in the CH 4 Port and Stbd double bottom ballll$t tanks for combined suction and discharge connections, tank level indicators, and cross-over tank venting for the future heel control system.

The ship was refloated on February 8, 2020. On February 11, an inclining experiment was conducted with the ship afloat inside the drydock basin. The inclining experiment was performed to determine the ship's lightship stability characteristics, and to aid in developing ballasting plans for decommissioning.

Revision 0 7

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 Ballast conditions were later developed that account for the removal of the fixed weight of the nuclear power plant major components, systems and structures associated with DECON-LT, while maintaining a positive stability range for the ship. NSS departed the PSR facility on the morning of February 13, 2020, and was towed directly to Pier 13 via the Delaware River, Chesapeake and Delaware Canal, Elk River, Upper Chesapeake Bay and the Patapsco River into Baltimore Harbor. NSS arrived at Pier 13 at approximately 10pm February 13, and was secured to the pier with shore power restored early in the morning of February 14.

In the immediate weeks following the return to Pier 13, work to complete the Phase I decommissioning infrastructure and ship outfitting progressed rapidly. However, by mid-March, the effects of the COVID-19 pandemic were becoming visible. Shutdowns in Pennsylvania preceded those in Maryland, and affected several subcontractors providing service to NSS. As noted in Section 4.5, MARAD itself suspended work activities on March 31. None of the projects were physically complete by March 31, and remained suspended until the NSS Return to Work plan was approved in late June (see Section 4.5).

After work resumed, the balance of the infrastructure and outfitting could be completed. The work performed in CY 2020 after the ship's return from PSR included the following:

  • Repairs and reconditioning of the CH 4 Main Deck hatch covers and installation of new electric winches and controls for operation of the hatch.
  • Completion of the Reactor Hatch lifting assembly including rigging, testing, and fitting of a locking mechanism for the hatch when it is in the raised position.
  • Removal of the CV cupola head and shield ring to facilitate access to the CV for component and waste material removals during future dismantlement activities (cupola head and shield ring are stored under cover on Pier 13).
  • Completion of Fire Haz.ards Analysis action items including the replacement of the forward emergency egress ladder system; aft emergency egress ladder system; paint locker fire suppression system; expansion of the fire and smoke detection and general alarm systems, with expanded annunciation throughout the working areas of the cargo holds and on the weather decks.
  • Completed the Heel Control System in Cargo Hold 4. The system cross connects the port and starboard double bottom tanks to allow ballast water transfers between the tanks to minimize the ship's list (heel) during major lifting operations, such as the future Reactor Pressure Vessel removal.
  • Completed construction of three stair towers in Cargo Holds 2 (aft) and 4 (forward and aft stairs) for personnel access and egress to the working areas of Cargo Holds 3 and 4; two of the stairs are enclosed with termini on the main deck for fire safety/ egress.
  • Installed and tested a decommissioning Heating, Ventilation and Air Conditioning (HVAC) system encompassing Cargo Holds 3 and 4, and the Reactor Compartment (RC). The RC and lower levels of Cargo Holds 3 and 4 are serviced by the high capacity HEPA exhaust fan to keep those working areas at a slight negative pressure during dismantlement and waste material handling activities. Several structural boundaries were erected to segregate the negative pressure zones from normal HVAC supply.
  • Completed safety barrier improvements within the CV, and replaced the interim ladder access to the RC Lower Level with a permanent installation.
  • Implemented the Cold and Dark Panel survey for the RC to sever electrical cables and remove redundant panels, as needed, to establish Cold and Dark conditions inside the RC.

Lighting and alarm systems inside the RC were isolated from original sources of power and the old sources were verified deenergized.

Revision 0 8

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 2.6 TS 3.4.2.1.G. UNAUTHORIZED ENTRY INTO RADIOLOGICALLY CONTROLLED AREAS (RCAS)

No unauthorized entries were made into any RCAs in CY2020.

2.6.1 EVENT DISCUSSION None 2.6.2 IMPROVEMENTS TO ACCESS CONTROL None

2. 7 TS 3.4.2.1.H. INSPECTION OF PRIMARY, SECONDARY AND AUXILIARY SYSTEMS DEGRADATION The annual inspection required by TS 3.7 3.4 was completed on December 22, 2020. It is documented in SIC-TS-A-2 RO Structures, Systems and Components Annual Inspection 2020. There was no notable degradation of the primary, secondary or auxiliary systems since the last inspection in 2019. The report noted many improvements in areas throughout the ship that corrected long standing issues.

2.8 TS 3.4.2.1.L

SUMMARY

OF OCCUPATIONAL EXPOSURE Because the NSS has been permanently shutdown for more than 45 years, no individual is expected to receive in one year from sources external to the body, a dose in excess of 10 percent of the limits specified in 10 CFR 20.1201. In 2020, the number of individuals monitored with Tills during their entries into RCAs was 95. No individual received more than 10 mRem from occupational sources during the monitoring period.

3.0 OTHER NRC REPORTS 3.1 10 CFR 50.59(D)(2) REPORT OF CHANGES, TESTS OR EXPERIMENTS The regulations require each power reactor licensee to submit, at intervals not to exceed 24 months, a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. ,

No Changes, Tests or Experiments were proposed in CY2020 that would require a 10 CFR 50.59 evaluation, and, consequently, no evaluations were completed.

Screenings are forward~d to Safety Review Committee members for information.

3.2 10 CFR 50.54(W)(3) INSURANCE ANNUAL REPORT The regulations require each power reactor licensee to obtain insurance available at reasonable costs and on reasonable terms from private sources or to demonstrate to the satisfaction of the NRC that it possesses an equivalent amount of protection covering the licensee's obligation. MARAD adheres to the Federal rules of self-insurance as a matter of established policy. '

3.3 COMMITMENT MANAGEMENT No Regulatory Commitments were made or revised in CY2020.

Revision 0 9

SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revision 0 4.0 SIGNIFICANT MARAD ISSUES 4.1 REMAINING DECOMMISSIONING TIMELINE The license termination deadline for the NSS is December 3, 2031 1, based on the Permanent Cessation of Operations milestone date of December 3, 1971. Decommissioning is scheduled to be complete well within the allowed 60-year license termination period.

4.2 PUBLIC EVENTS, VISITATION AND TRAINING As a result of the COVID 19 Pandemic, MARAD suspended its traditional program of public access and training support for local, state and federal agencies during CY2020.

4.3 HISTORIC STEWARDSHIP The NSS was designated as a National Historic Landmark (NHL) in 1991, and is the only directly-owned, managed and maintained NHL property in the Department of Transportation inventory. Under the provisions of the National Historic Preservation Act (NHPA) of 1966, as amended, the highest standard of care for historic objects falls upon federal owners of NHLs. MARAD maintains a continuous focus on its historic stewardship responsibilities when conducting activities on the NSS site. All work on the ship, whether radiological or not, is sensitive to maintaining the historic fabric and appearance of the ship.

MARAD's Federal Preservation Officer (FPO) provides expert advice and guidance to licensee staff in these matters, particularly with respect to the implementation of the Secretary of the Interior's Standards for the Treatment of Historic Properties and Historic Vessel Preservation Projects.

4.4 NATIONAL HISTORIC PRESERVATION ACT CONSULTATION As discussed in previous annual reports, MARAD initiated consultation under Section 106 of the NHPA in April 2018 to address the potential adverse effects and harm to the NSS as a NHL arising from decommissioning and license termination activities. NRC is one of four federal agencies and state organizations that are parties to the consultation. The other entities include the Advisory Council on Historic Preservation (ACHP~, the National Park Service (NPS) and the Maryland Historic Trust (MIIT), ,

acting as the State Historic Preservation Officer. Consulting efforts were affected by the pandemic, and completion of a Programmatic Agreement (PA) to cover the aspects of the undertaking were still incomplete at the end of the CY2020 reporting period.

4.5 COVID-19 PANDEMIC NATIONAL EMERGENCY As reported to the NRC in an email dated March 30, 2020, MARAD temporarily suspended its decommissioning Phase I projects at the onset of the COVID-19 emergency. Operations essentially reverted to the pre-decommissioning baseline, with onboard staff limited to essential personnel and all visitations restricted. Modified access controls were established to include pre-boarding medical screening of all personnel; the watchstanding function was relocated to the pier to facilitate this.

MARAD confirms its TSIM contractor maintained core staff, and performed all necessary surveillances and inspections during the suspension period. The Savannah Emergency Radiological Assistance Team (SERAT) capability was also maintained as required to meet Technical Specification (TS) requirements.

MARAD implemented a phased return-to-work (RTW) program beginning on June 22, 2020. Under RTW-2, the shipboard complement was increased to thirty (30) persons, with density controls established to limit personnel concentrations within working spaces. Decommissioning work activities were resumed in July to complete the Phase I work scope. Two Monday-Friday production shifts and regular Saturday shifts were required from August through the end of November to make up for both the lost time (months 1

December 3, 1971 IS the de facto date of permanent cessation of operat.lons date based on completmg the reactor defueling that date by tensmning the reactor vessel head with six studs Revision 0

SAVANNAH Technical Staff STS- 214, Annual Report for CY2020, Revision 0 of April-June) and RTW ship density limitations. The RTW-2 shipboard complement was further increased to forty-five (45) persons in early December, at which time the multiple shifts were discontinued. The Phase I work was substantially complete at the end of the reporting period.

The pandemic emergency declaration delayed the acquisition of successor contract services for DECON-LT phases II and ill. A Request for Proposal for those services was extended several times to account for the restricted access to the ship. After the RTW plan was approved, site visits for the offerors were conducted in July. As noted in Section 2.1.2, the evaluation of proposals was ongoing at the end of the calendar year reporting period.

The COVID-19 access controls and other RTW conditions remain in effect at the time ohhis report submittal.

5.0 REFERENCES

a. Letter from Mr. John B. Hickman (NRC) to Mr. Erhard W. Koehler (MARAD), dated April 23, 2018, Nuclear Ship SAVANNAH - Issuance OfAmendment 15 to revise the License to allow Dismantlement and Disposal
b. Regulatory Guide 1.86, Termination a/Operating Licenses for Nuclear Reactors, June 1974
c. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),

dated September 4, 2020, License Amendment Request No. LAR 2020-01, Administrative Changes to Technical Specifications

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

dated February 27, 2019, Annual Report for CY2018, Revision 0

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

dated February 26, 2020, Annual Report for CY2019, Revision 0 Revision 0 11

SAVANNAH Technical Staff STS-214, Annual Report for CY2020, Revision 0 Appendix A CY2020 Radiation Sun-ey Re8ults in Radiologically Controlled Areas APPENDIX A. CY2020 RADIATION SURVEY RESULTS IN RADIOLOGICALLY CONTROLLED AREAS Area General Area Highest General Area Highe8t Radiation Radiation Level Contamination Contamination levels mR/hr mR/hr ( milli- Level Level (milli-R/hr) R/hr) IDPM/100cm 2) IDPM/100cm 2)

Reactor <1.0 <1.0 <1000 ~1000 Compartment Cupola Level A Deck Reactor <1.0 <1.0 <1000 <1000 Compartment Upper Level B Deck Reactor I

<1.0 <1.0 <1000 <1000 Compartment Middle Level C Deck Reactor <1.0 <1.0 <1000 <1000 Compartment Middle Level D Deck Reactor 2.0 15 ,<1000 <1000 Compartment Contacton Lower Level Fwd overhead line Reactor <1.0 <1.0 <1000 <1000 Compartment Lower Level Aft Containment <1.0 <1.0 <1000 <1000 Vessel 1st Level Containment 1.0 1.6 <1000 <1000 Vessel 2nd Level Containment 1.7 2.5 <1000 <1000 Vessel 3rd Level Containment <1.0 <1.0 <1000 <1000 Vessel 4th Level 4.5 between U tube of both steam generators Cold Chemistry Lab and Rad Down posted (CCL Door locked per Tech Spec Req.)

Monitoring Rm C-Deck I Radiation <1.0 <1.0 <1000 15200 loose surface Sampling Room on floor at Stbd D-Deck comer (A)

Gas Adsorption Down posted (Encompassed within CCL Door, locked per Tech Spec Req.)

RoomD-Deck Revision 0 12

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 Appendix A CY2020 Radiation Survey Results in Radiologically Controlled Areas Area General Area Highest General.Area Highest Radiation Radiation Level Contamination Contamination levels mR/hr mR/hr ( milli- Level Level (milli-R/hr) R/hr) IDPM/100cm2) (DPM/100cm 1)

Cargo Hold 4 D- <1.0 <1.0 <1000 <1000 DeckLLRW Sto~e NEWSDDeck <1.0 <1.0 <1000 <1000 Rad Stonu;1;e Sugar and Flour <1.0 <1.0 <1000 <1000 Stores Hull Survey <1.0 <1.0 <1000 <1000

)

(Drydock)

Port Stabilizer <1.0 <1.0 <1000 loose surface <l000loosesurface Rooms posted as a 2000 fixed on tank Rad Material Area top Starboard <1.0 <1.0 <1000 <1000 Stabilizer Room posted as a Rad Material Area (B)

Table Data Notes (A) Loose surface in process of being removed in February 2021. Legacy fixed contamination identified and scheduled to be addressed in 2021.

(B) Posted as Rad Material Area due to the common tunnel connecting the two stabilizer rooms, due to survey identifying fixed contamination on port side on 1/8/2021.

Revision 0 13

SAVANNAH Technical Staff STS - 214, Annual Report for CY2020, Revision 0 Appendix B CY2020 Radiological Environmental Sampling Results APPENDIXB. CY2020 RADIOLOGICAL ENVIRONMENTAL SAMPLING RESULTS

,. ,. . ' ,_..$* >' ' ' ~ ** :/ , ' ' . ~1*

'.' '{} ;"' *.~*- ~mple.

  • typ*e of ' .. . (pCVg)*.

Co-60'**  :.*~137 .Y

~

  • . **:, Sample Locati~n *

.. ' . . **Date *sample .

. . (pCi/~{': .

Pier # 13 in the vicinity of the forward , <MDA Water location of the ship (Prior to return from (minimum 02/07/2020 <MDA drydock), detectable (A)

Canton Marine Terminal, Baltimore, MD activity)

Pier # 13 in the vicinity of the forward 9.0lE-02 (C) location of the ship (Prior to return from Sediment 02/07/2020 <MDA drydock), (A)(B)

MDA=

Canton Marine Terminal, Baltimore, MD 8.26E-02 Pier # 13 in the vicinity of the aft location of the ship (Prior to return from 02/07/2020 Water(A) <MDA <MDA drydock),

Canton Marine Terminal, Baltimore, MD Pier # 13 in the vicinity of the aft location of the ship (Prior to return from Sediment 02/07/2020 <MDA <MDA drydock), (A)(B)

Canton Marine Terminal, Baltimore, MD Pier #13, Canton Marine Terminal, Water(A) <MDA <MDA Baltimore, MD NSS Stbd Side, Forward 10/22/2020 1.0lE-01 (C)

Pier #13, Canton Marine Terminal, Sediment

<MDA Baltimore, MD NSS Stbd Side, Forward 10/22/2020 (A)(B)

MDA=

5.99E-02 Pier #13, Canton Marine Terminal, Water (A) <MDA <MDA Baltimore, MD NSS Port Side, Aft 10/22/2020 Pier #13, Canton Marine Terminal, Sediment

<MDA <MDA(C)

Baltimore, MD NSS Port Side, Aft 10/22/2020 (A)(B)

Table Data Notes (A) Calculated MDAs are a-posteriori values at the 95% confidence level.

(B) Activity is reported on a dry weight basis unless otherwise indicated in the case narrative and is decay corrected to the sample collect date.

(C) Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

Revision 0 14