ML21050A420
| ML21050A420 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/2021 |
| From: | Bruce Watson Reactor Decommissioning Branch |
| To: | Low J US Dept of the Navy, Naval Sea Systems Command |
| Smith T | |
| References | |
| N00024-20-C-4139 | |
| Download: ML21050A420 (4) | |
Text
March 2, 2021 Mr. Jerry Low, Contracting Officer Department of the Navy, Naval Sea Systems Command 1333 Isaac Hull Avenue, SE Washington Navy Yard 20376-0001
SUBJECT:
RESPONSE TO REQUEST FOR RECOMMENDATION TO TRANSFER POSSESSION OF THE SURFACE SHIP SUPPORT BARGE TO APTIM FEDERAL SERVICES, CONTRACT N00024-20-C-4139
Dear Mr. Low:
In a February 2, 2021 letter to the Nuclear Regulatory Commission (NRC) (Agencywide Document Access and Management System [ADAMS] Accession No. ML21043A134), the Department of the Navy, Naval Sea Systems Command (NAVSEA) requested NRC staff to review a request from Aptim Federal Services (Aptim) and make a recommendation to NAVSEA as to whether to transfer possession of the Surface Ship Support Barge (SSSB) to Aptim for characterization and relocation to Mobile, Alabama prior to the hurricane season before approval of the decommissioning work plan in anticipation of decommissioning activities described in the Decommissioning Work Plan (DWP) (ADAMS Accession No. ML20269A446) dated September 2, 2020, currently under NRC review.
Upon transfer, Aptim would assume responsibility for and control over the SSSB. Aptim would then proceed to complete initial radiological characterization and conduct inspections of holds and ballast tanks in preparation for tow transport to the Alabama Shipyard in Mobile, Alabama.
Once at the Alabama Shipyard, Aptim would transfer the SSSB from the barge to land in preparation for decommissioning work. As indicated by Aptim in their request referenced in your February 2 letter, Aptim will not commence decommissioning work unless NAVSEA accepts the proposed DWP, including consideration of the NRCs evaluation and recommendation.
According to the request, Aptim will draw on the experience of individuals from decommissioning work completed on the U.S. Army Corps of Engineers Sturgis MH-1A reactor barge (Sturgis), including disposal of the Class A and Class B low-level radioactive waste and mixed low-level waste at the Waste Controls Specialists facility in west Texas. Non-radiologically contaminated portions of the Sturgis were released for unrestricted use following extensive radiological clearance surveys. The Sturgis project is comparable to or greater than the SSSB in size, scope, complexity and radiological and industrial hazard. As required under Aptims contract for decommissioning the SSSB, the Sturgis also required transfer of possession, transport from Virginia to a dismantlement site alongside the Gulf of Mexico, decontamination, dismantlement, and waste disposition.
The referenced request indicates that Aptim will directly manage work control, quality assurance, safety, and radiological programs. Although not being utilized for the SSSB project,
J. Low 2 Aptim has NRC and NRC Agreement State licenses for performing a variety of activities including site characterization, decontamination of facilities, treatment and packaging of wastes, and waste transport for transfer to authorized recipients.
Also, in its DWP, Aptim provided an organization chart showing the planned project organization. Resumes for key management personnel were also provided to document that key Aptim employees are qualified by education, training, and experience for their positions.
Aptim plans to establish an organization responsible for radiological safety, industrial health and safety, quality assurance, project administration, waste operations, and project controls. This organization would provide a management team with control over the decommissioning. The individual filling the Radiation Protection Manager position is a certified health physicist with decommissioning related experience at Naval Station Treasure Island, Hunters Point Naval Station, the Sturgis, and Humboldt Bay.
While the DWP review is ongoing, its contents are consistent with the transfer request in demonstrating the technical competency of Aptim to conduct and complete radiological decommissioning.
Based on its review of the provided transfer request and DWP, the NRC staff determined that the applicants have described a project organization that will provide the requisite experience and expertise for the decommissioning of the SSSB. Therefore, NRC concludes that Aptim has demonstrated sufficient technical competency and experience to safely complete radiological decommissioning of the SSSB. Therefore, the NRC recommends NAVSEA proceed with the transfer of possession with responsibility for SSSB to Aptim in order to complete preparations for decommissioning, including initial characterization, inspections, and transport to Alabama Shipyard in Mobile, Alabama pending the results of NRCs review and recommendation on acceptance of the DWP.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
J. Low 3 If you have any questions on this recommendation, please contact Ted Smith at theodore.smith@nrc.gov, 301-415-6721.
Sincerely, Bruce A. Watson, Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards cc: S. Picard, NAVSEA H. Duff, NAVSEA
J. Low 3
SUBJECT:
RESPONSE TO REQUEST FOR RECOMMENDATION TO TRANSFER POSSESSION OF THE SURFACE SHIP SUPPORT BARGE TO APTIM FEDERAL SERVICES, CONTRACT N00024-20-C-4139 DATED _March 2, 2021_______
DISTRIBUTION:
Public JDorfman, OCFO ADimitriadis, R1 KWarner, R1 RidsNmssDUWP Resource Rids RGN1 MailCenter Resource ADAMS Accession Number: ML21050A420 *via email NMSS/DUWP/ NMSS/DUWP NMSS/DUWP/
OFFICE OGC*
RDB/PM /RDB/BC* RDB/BC*
NAME TSmith BWatson AGendlemen BWatson DATE 2/18/2021 2/19/2021 3/2/2021 3/2/2021 OFFICIAL RECORD COPY