ML19091A087

U.S. Department of Transportation Maritime Administration Decommissioning Funds Status Report for CY2018

ML19091A087
Person / Time
Site:	NS Savannah
Issue date:	03/28/2019
From:	Tote Services, US Dept of Transportation, Maritime Admin
To:	Office of Nuclear Material Safety and Safeguards
References
STS-2015, Rev 0
Download: ML19091A087 (11)

Text

U.S. Department of Transportation Maritime Administration N.S. SAVANNAH DECOMMISSIONING FUNDS STATUS REPORT FOR CY2018 STS - 205 Revision 0 Approved:

~--

Manager, N.S. SAVANNAH Programs Date: March 28, 2019 Prepared by:

TOTE Services, Inc.

SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 Record of Revisions Revision Summary of Revisions 0 The original version of the Decommissioning Funds Status Report for CY2018 Revision 0 2

SA VANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, 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 - 205, Decommissioning Funds Status Report For CY2018, 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 8 3.1 Report required by 10 CPR 50.82(a)(8)(v) 8 3.2 Report required by 10 CPR 50.82(a)(8)(vi) 8 3.3 Report required by 10 CPR 50.82(a)(8)(vii) 9 4.0 CY2018 FUNDING 9 5.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING 9 5.1 Annual Request for Funds 10 5.2 Annual Submittal of New Estimate 10 5.3 Revised Decommissioning Cost Estimate (DCB) 10 5.4 Content of MARAD Budget Requests 10 6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING 10

7.0 REFERENCES

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SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, 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 2018 (CY2018) 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. In most years, 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 funding. Since future funding can impact the decommissioning schedule described in the PSDAR, MARAD includes this public information, to the extent that it may be available, 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 holds a Possession-only license that was modified by License Amendment 15 (Reference c) to allow dismantlement and disposal. As a result of License Amendment 15, the ship's status changed from "Mothballed" to "Dismantlement."

Dismantlement is defined in Regulatory Guide (RG) 1.86, "Termination of Operating Licenses for Nuclear Reactors," Reference (d). 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 NSS licensing basis.

MARAD uses the words 'active decommissioning' and 'dismantlement' interchangeably.

Amendment 15 removed the license condition (LC) 2.C.(2), which prevents dismantling and disposing of the ship without prior approval of the Nuclear Regulatory Commission. In 1976, the NSS license was revised to prohibit operation, dismantlement and disposal of the facility. This version of the Possession-only license was in effect from1976 until April 23, 2018 when Amendment 15 was issued. The amendment also allows use of 10 CFR 50.59 to evaluate decommissioning activities.

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 Revision 0 5

SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 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. Collectively, these are referred to as MARAD's licensed activities, and are reported annually to the NRC. Reference (e) is the most recent Annual Report.

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.

An interim project to bring the NSS into conformance with contemporary NRC SAFSTOR3 criteria (known as "SAFSTOR Preparations") was described and committed to in the PSDAR, but prior to CY2017 implementation funding was never appropriated.

The Consolidated Appropriations Act for FY 2018 was signed on March 23, 2018. It provides $107 million to MARAD for N.S. SAVANNAH decommissioning. This amount is in addition to the $24 million provided by the Consolidated Appropriations Act for FY 2017 that was reported in Reference (f). The total amount appropriated equals the $131 million that was described in MARAD's FY 2017 Budget Request as the amount required to complete decommissioning and terminate the NSS license.

Fully funding the project has allowed MARAD to begin decommissioning and license termination activities. In 2018, MARAD completed many of the decommissioning preparation activities that were part of SAFSTOR Preparations. Reference (e) includes a description of the activities that were completed.

This report addresses the funding status for all decommissioning activities.

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 are provided by Federal appropriations.

2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT This section provides a discussion of the seven items required by 10 CFR 50.75(f)(l), and incorporates the guidance contained in RG 1.159. 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. 00 million annually. MARAD plans to drydock the NSS in 2019 for regular maintenance during the protective storage period at an estimated cost o/$6.80 million. 4 b) The revised SAFSTOR project cost estimate is $14.1 million5.

1 December 3, 1971 is the de facto date of permanent cessation of operations. 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. I, Decommissioning of Nuclear Power Reactors.

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 defmed by Regulatory Guide 1.184, Rev. I, Decommissioning of Nuclear Power Reactors.

4 The drydocking cost estimate was escalated to a 2018 basis from the $4.10 million contract cost for drydocking the NSS in CY 2008. The 2018 cost estimate is adequate for the activity to be performed in 2019.

5 The scope of the SAFSTOR project will be completed in CY 2019. Separate reporting for this project estimate will be discontinued.

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SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 c) The revised site-specific DECON-License Termination cost estimate is $124.9 million6.

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/or decommissioning activities to be obtained by appropriations when necessary. As noted above, the project is fully funded.

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, JO CFR 50. 75(e)(l)(iv) allows funding for decommissioning activities to be obtained by appropriations when necessary. As noted above, the project is fully funded.

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 2018 revised site-specific DECON-License Termination cost estimate escalation for disposal of low level radioactive waste was 12.9%). Transportation cost estimate escalation was 33%.

Electric Power estimate cost escalation was 2.5%. All other industrial tasks cost estimate escalation was 2.97%.

Escalation factors were determined referencing NUREG 1307, Revision 17 (Waste Disposal costs) and by direct data from Bureau ofLabor Statistics.from http://www.bls.gov/data/, Series ID for the latest 2018 values available:

I. Wpu0543 (Industrial electric power)

2. Wpu0573 (Light fuel oils)

3. CIU2010000000210l (J'otal compensation, private industry, Northeast region).

Based on the above factors, the DECON -License Termination cost estimate escalation rate from 2017 to 2018 is 5. 7%. The SAFSTOR project cost estimate was revised by escalating the 2017 estimate at 5. 7%.

The overall 2018 escalation rate is greater than escalation rates experienced over the past several years. Three factors account for this increase: I. the wage inflation factor increase, 2.

the fuels inflation factor and 3. the NUREG 1307 Rev 17 direction for cost escalation for licensees that have not affiliated with any of the established waste compacts, resulting in the conservative waste burial cost escalation increase.

There are no rates of earnings on decommissioning funds.

2.5 Any contracts upon which the licensee is relying pursuant to paragraph (e)(l)(v) of this section.

Not applicable because MA.RAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(l)(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 MA.RAD '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.

2. 7 Any material changes to trust agreements.

6 MARAD does not presently expect to require additional budgetary resources due to formula-based escalation of the decommissioning estimate.

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SA VANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 Not applicable because MA.RAD, as a Federal licensee, is funded per the JO CFR 50. 75(e)(l)(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 a site-specific DCB to the NRC. 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 the funds spent by MA.RAD in CY2018 and preceding years (FY2005 - present) have been spent for decommissioning purposes. MA.RAD 's budget requests through FY2019 have continued to provide for a baseline protective storage component of cost. This strategy is designed to provide sufficient resources to MA.RAD to maintain the NSS if there is an interruption in the decommissioning-license termination project for any reason.

During the CY 2018 reporting period, MA.RAD obligated approximately $21. 0 million.

The cumulative obligations since CY 2017 are approximately $23.0 million.

2. The remaining balance of any decommissioning funds, and After subtracting the total obligated funds ($23 million) from the total appropriated funds

($131 million), the remaining balance to complete decommissioning is $108 million.

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 2018 site-specific DECON-License Termination cost estimate is $124.9 million based on escalation from the 2017 estimate (see Section 2.4 above for the escalation basis).

This estimate is effective as ofDecember 2018. This estimate does not credit any work performed during the reporting period.

(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'sfinancial assurance methodology, which is limited to the use ofFederal appropriations.

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

Not applicable because MA.RAD, as a Federal licensee, relies solely on the 10 CFR 50. 75(e)(l)(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 Revision 0 8

SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 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 fuel elements (Core I and Ia) 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 offunds 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 fuel and, therefore, has no need to obtain additional funds to cover such cost.

4.0 CY2018 FUNDING As noted in section 1.1 above, the NSS decommissioning project received an appropriation of $107 .0 million in CY 2018, and is now fully funded. The congressional appropriations in FY 2017 and FY 2018 did not follow the content of MARAD's budget requests, which began with the FY 2017 request and envisioned an incremental funding process through FY 2023. The total amount appropriated, $131.0 million, is equal to the seven-year projection contained in the FY 2017 budget request. The FY 2018 action supersedes the description contained in MARAD's Decommissioning Funds Status Report for CY 2017, Reference G).

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.

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SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0 5.1 Annual Request for Funds In Reference (g), MARAD made the following regulatory commitment:

Annually, MARAD will request funds specifically for decommissioning. The NRC will be informed of these decommissioningfunding requests annually by March 31. [Continuing action]

Given that the project has been fully funded, this commitment has been met and is now considered closed.

5.2 Annual Submittal ofNew Estimate In Reference (h), 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 CY2018 estimate is provided in Sections 2.1 and 2.4 of this report.

5.3 Revised Decommissioning Cost Estimate (DCE)

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

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

The site specific DCE is scheduled for full revision in CY2020.

5.4 Content ofMARAD Budget Requests In Reference (i), MARAD made the following regulatory commitment:

Because the privily ofthe 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 10 CFR 50.82(a)(7) notifications will be submitted under a 10 CFR 2.390 request for withholding.

Given that the project has been fully funded, this commitment has been met and is now considered closed.

6.0 TIME REMAINING TO COMPLETE DECOMMISSIONING As of December 3, 2018, 47 years of protective storage had elapsed; more than 75% of the allowed 60-year protective storage - DECON - license termination period.

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. 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

d. Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974

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

dated February 27, 2019, Annual Report for CY2018, Revision 0 Revision 0 10

SAVANNAH Technical Staff STS - 205, Decommissioning Funds Status Report For CY2018, Revision 0

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

dated May 30, 2017, Availability ofFunds for Decommissioning

g. 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

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

i. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated June 4, 2010, Submittal ofDecommissioning Funds Status Update for CY 2009 and Governmental Statement ofIntent for Decommissioning Financial Assurance

j. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, dated March 26, 2018, Submittal ofDecommissioning Funds Status Report for CY 2017 Revision 0 11