ML15118A540

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Us Dept of Transportation, Maritime Administration (Marad) - Submittal of Decommissioning Funds Status Report for Cy 2014
ML15118A540
Person / Time
Site: NS Savannah
Issue date: 04/23/2015
From: Koehler E W
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML15118A540 (16)
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Text

0U.S. Departmentof TransportationMaritimeAdministration1200 New Jersey Ave., SEWashington, DC 20590Ref: 10 CFR 50.75(f)(1); 50.82(a)(7) and 50.82(a)(8)(v)-(vii)April 23, 2015ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555

SUBJECT:

Docket. No. 50-238; License No. NS-1; N.S. SAVANNAHSubmittal of Decommissioning Funds Status Report for CY 2014The Maritime Administration (MARAD) hereby submits Revision 0 of the CY 2014 DecommissioningFunds Status Report for the Nuclear Ship SAVANNAH (NSS) as Enclosure 1.This letter contains no commitments.If there are any questions or concems with any issue discussed in this report, please contact me at(202) 366-2631, and/or e-mail me at erhard.koehler@dot.gov.IErhard W. KoehlerSenior Technical Advisor, N.S. SAV'ANNAHOffice of Ship DisposalEnclosuresHS'S ZAD Docket No. 50-238; License NS-1; N.S. SAVANNAHSubmittal of Decommissioning Funds Status Report for CY 2014, Revision 0April 23, 2015Enclosures1. Decommissioning Funds Status Report for CY 2014, STS -1922 Docket No. 50-238; License NS-1; N.S. SAVANNAHSubmittal of Decommissioning Funds Status Report for CY 2014, Revision 0April 23, 2015cc:Electronic copyNSS ESCNSS SRCMAR 610, 612, 615Hardcopy, cover letter onlyMAR-600, 640, 640.2Hardcopy w/ all enclosuresMAR-100, 640.2 (rf)USNRC (Ted Smith, Mark C. Roberts)USNRC Regional Administrator -NRC Region IMD Department of the Environment (Roland G. Fletcher; George S. Aburn, Jr.)NC Department of Environment & Natural Resources (Beverly 0. Hall)SC Department of Health & Environmental Control (Susan E. Jenkins; Aaron Gantt)VA Department of Emergency Management (Michael M. Cline)VA Department of Health (Leslie P. Foldesi)EWK/jmo3 0U.S. Departmentof TransportationMaritimeAdministration1200 New Jersey Ave., SEWashington, DC 20590Docket No. 50-238; License No. NS-1; N.S. SAVANNAHEnclosure 1 to Submittal of Decommissioning Funds Status Report for CY 2014DECOMMISSIONING FUNDS STATUS REPORT FOR CY 2014, STS -1924 U.S. Department of TransportationMaritime AdministrationN.S. SAVANNAHDECOMMISSIONING FUNDS STATUS REPORTFOR CY 2014STS -192Revision 0Date:Approved:Manager, N.S. SA VANNAH ProgramsPrepared by:SA VANNAH Technical Staff SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0Record of RevisionsRevision Summary of Revisions0 The original version of the Decommissioning Funds Status Report for CY 2014Revision 02 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0List of Effective PagesPage No. Rev. No. Page No. Rev. No. Page No. Rev. No.1 0 2 0 3 04 0 5 0 6 07 0 8 0 9 010 0 11 0 12 0Revision 03 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0Table of Contents

1.0 INTRODUCTION

51.1 Decommissioning Status 51.2 Decommissioning Funding Sources 62.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORT 63.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORT 73.1 Report required by 10 CFR 50.82(a)(8)(v) 73.2 Report required by 10 CFR 50.82(a)(8)(vi) 83.3 Report required by 10 CFR 50.82(a)(8)(vii) 84.0 CY 2014 FUNDING 94.1 FY 2014 94.2 FY 2015 94.3 FY 2016 95.0 REGULATORY COMMITMENTS REGARDING DECOMMISSIONING FUNDING 105.1 Annual Request for Funds 105.1.1 FY 2015 105.1.2 FY2016 115.2 Annual Submittal of New Estimate 115.3 Revised Decommissioning Cost Estimate (DCE) 115.4 Content of MARAD Budget Requests 116.0 TIME REMAINING TO COMPLETE DECOMMISSIONING 1

17.0 REFERENCES

11Revision 04 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision

01.0 INTRODUCTION

This Decommissioning Funds Status Report is submitted by the Maritime Administration (MARAD) aslicensee for the Nuclear Ship SAVANNAH (NSS) and covers the CY 2014 reporting period. This reportincorporates the guidance contained in Regulatory Guide (RG) 1.159, "Assuring the Availability of Fundsfor Decommissioning Nuclear Reactors," Rev 1, Reference (a). The report is arranged in four sectionsfollowing this introduction.In accordance with the requirements of 10 CFR 50.75(f)(1), each power reactor that has already closed isrequired to report annually the status of its decommissioning funds to the Nuclear RegulatoryCommission (NRC) on a calendar year (CY) basis. Section 2.0 of this Decommissioning Funds StatusReport includes the seven (7) reports required by 10 CFR 50.75(f)(1).In accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii), each power reactor that has alreadysubmitted its site-specific Decommissioning Cost Estimate (DCE) is required to provide a financialassurance status report annually to the NRC on a calendar year (CY) basis. MARAD submitted asummary 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 by10 CFR 50.82(a)(8)(v)-(vii).Section 4.0 of this report provides specific information regarding the funds made available to andexpended by MARAD during the reporting period.Finally, Section 5.0 of this report provides information on regulatory commitments made by MARADthat are germane to decommissioning funding.Because the Federal fiscal year (FY) does not align with the CY, each annual decommissioning fundsstatus report will include information from at least the two FYs that directly provide funds for expenditureduring the reporting period. Prior to the submission of the report on (or about) March 31, the Presidentwill submit a budget request to the Congress for the upcoming FY. Because NSS activities are funded onan annual basis, the President's budget request is an early, although not definitive, indicator of future NSSdecommissioning funding. Because that future funding can impact the decommissioning scheduledescribed in the PSDAR, MARAD includes this public information for context, and in partial satisfactionof the 10 CFR 50.82(a)(7) requirement to notify the NRC of expected changes to content in the PSDAR.1.1 Decommissioning StatusThe NSS is presently in protective storage. This phase of decommissioning activities is characterized byactive surveillance, monitoring and maintenance of the nuclear facilities housed onboard the ship, andcustody and maintenance of the ship as the primary physical boundary and protective barrier of thelicensed site. Collectively, these are referred to as MARAD's licensed activities, and are reportedannually to the NRC.As described in the PSDAR, and elsewhere, the license termination deadline for the NSS is December 3,2031.1 Final decommissioning of the NSS nuclear facilities will be performed by the DECON method.In the interim, a project to bring the NSS into conformance with contemporary NRC SAFSTOR criteria(known as "SAFSTOR Preparations") has been described and committed to in the PSDAR.This report addresses the funding status for all three of these decommissioning phases -licensedactivities, SAFSTOR Preparations, and DECON.December 3, 1971 is the de facto date of permanent cessation of operations. On that day, MARAD completed the reactor defueling bytensioning the reactor vessel head with six studs.Revision 05 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 01.2 Decommissioning Funding SourcesMARAD is a modal agency of the United States Department of Transportation (DOT). It is a Federallicensee as defined by the NRC. As such, funds for decommissioning and termination of the NSS licensewill be provided by Federal appropriations. The budget process by which such appropriations arerequested is deliberative and privileged, and is subject to Executive Branch priorities and direction.Furthermore, the legislative review and authorization / appropriation actions taken on such requests arefully within the purview of the Congress. MARAD by itself cannot guarantee that decommissioningfunds will be requested by the President or authorized and appropriated by the Congress in any givenfiscal year.2.0 STATUS OF DECOMMISSIONING FUNDS ANNUAL REPORTThis section provides a discussion of the seven items required by 10 CFR 50.75(f)(1), and incorporatesthe guidance contained in RG 1.159. The reporting requirements and corresponding MARAD informationare 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 todry-dock the NSSfor regular maintenance once during the protective storage period, in 2018,at an estimated cost of $6. 80 million.2b) The December 2014 revised SAFSTOR project cost estimate is $11.7 million.c) The December 2014 revised site-specific DECON-License Termination cost estimate is$105. 00 million.2.2 The amount accumulated to the end of the calendar year preceding the date of the report.Accumulation of funds is not applicable to the NSS. As a Federal licensee,10 CFR 50.75(e)(1)(iv) allows fundingfor decommissioning activities to be obtained byappropriations when necessary.2.3 A schedule of the annual amounts remaining to be collected.Annual collection of funds is not applicable to the NSS. As a Federal licensee,10 CFR 50. 75(e)(1)(iv) allows fimdingfor decommissioning activities to be obtained byappropriations when necessary.2.4 The assumptions used regarding rates of escalation in decommissioning costs, rates of earningson decommissioning funds, and rates of other factors used in funding projections.The 2014 revised site-specific DECON-License Termination cost estimate used 5. 00% escalationfor disposal of low level radioactive waste (LLRW). Transportation costs were escalated at0. 00%. Electric costs were escalated at 7.02%. All other industrial task costs were escalated at2.18%. Escalation factors were determined referencing NUREG 1307, Revision 15 (WasteDisposal costs) and by direct data from Bureau of Labor Statistics from http://www. bis. gov/data/Series ID for the latest 2014 values available at the time of the calculation:1. Wpu0543 (Industrial electric power)2. Wpu0573 (Light fuel oils)3. CIU20100000002101 (Total compensation, private industry, Northeast region).2 The drydocking cost estimate is escalated to a 2018 basis from the $4.1 million contract cost for drydocking the NSS in CY 2008.Revision 06 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0Due to funding constraints in FY 2014, the NRC was unable to fund the Pacific NorthwestNational Laboratories contract and consequently there was no December 2014 revision toNUREG-1307. As noted in Reference (c), licensees may use LLRW burial charge data containedin Revision 15 of NUREG-1307 when preparing the CY 2014 decommissioning funds statusreport. MARAD has disposal sites available at substantially less cost than the Washington andSouth Carolina disposal site costs in NUREG-1307. Therefore, MARAD has conservatively used5% escalation for LLRW disposal for this report.Transportation escalated costs for 2014 was a negative value. Due to the highly volatile natureof this factor, a conservative value of 0. 0% escalation was used for Transportation cost for 2014estimate purposes.Based on the above factors, the simple escalation rate from 2013 to 2014 was 2.65%. TheSAFSTOR project cost estimate was revised by escalating the 2013 estimate at 2.65%.There are no rates of earnings on decommissioning funds.2.5 Any contracts upon which the licensee is relying pursuant to paragraph (e)(1)(v) of this section.Not applicable because MARAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(1)(iv)method.2.6 Any modifications occurring to a licensee's current method of providing financial assurance sincethe last submitted report.There have been no modifications to MAR4D 'sfinancial assurance methodology, which islimited to the use of Federal appropriations. Please refer, however, to the response in Section4.1 below for more information.2.7 Any material changes to trust agreements.Not applicable because MARAD, as a Federal licensee, is funded per the 10 CFR 50. 75(e)(1)(iv)method. Consequently, no trust agreements exist.3.0 FINANCIAL ASSURANCE STATUS ANNUAL REPORTThis section provides a discussion of the ten items required by 10 CFR 50.82(a)(8)(v)-(vii). EffectiveDecember 17, 2012, Section 50.82 imposed new reporting requirements on licensees who previouslysubmitted to the NRC site-specific decommissioning cost estimate (DCE). The reporting requirementsand 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 calendaryear,Within the context ofprotective storage as a phase of decommissioning activities, all ofthe funds spent by MARAD in CY 2013 and preceding years (FY 2005 -present) havebeen spent for decommissioning purposes. As a practical matter, no funds have beenspent on major actions described in either the SAFSTOR Implementation Plan or theDECON Cost Estimate. As described in STS-191, the CY 2014 Annual Report (Referenced), MARAD planned and completed minor environmental remediation tasks within threeradiologically controlled areas during the reporting period. The budgeted cost for theseactivities was $65,000.2. The remaining balance of any decommissioning funds, andRevision 07 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0Not applicable because MARAD, as a Federal licensee, is funded per the10 CFR 50. 75(e)(1)(iv) method. Although funds appropriated to MARAD's ShipDisposal account are "available until expended, "any year-to-year carryover is appliedto immediate requirements. No balance is maintained3. The amount provided by other financial assurance methods being relied upon;None. M4RAD, as a Federal licensee, relies solely on the 10 CFR 50. 75(e)(1)(iv)method.(B) An estimate of the costs to complete decommissioning, reflecting any difference between actualand estimated costs for work performed during the year, and the decommissioning criteria uponwhich the estimate is based;MARAD's CY 2014 estimate to complete decommissioning is $105 million based onescalation from the 2013 estimate (see Section 2.4 above for the escalation basis). Thisestimate is effective as of December 2014. This estimate does not credit any work performedduring the reporting period.(C) Any modifications occurring to a licensee's current method of providing financial assurance sincethe last submitted report; andThere have been no modifications to MARAD 's financial assurance methodology, which islimited to the use of Federal appropriations. Please refer, however, to the response inSection 4.1 below for more information.(D) Any material changes to trust agreements or financial assurance contracts.Not applicable because A1fRAD, as a Federal licensee, relies solely on the10 CFR 50.75(e)(1)(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 fundscalculated at not greater than a 2 percent real rate of return, together with the amount provided byother financial assurance methods being relied upon, does not cover the estimated cost tocomplete the decommissioning, the financial assurance status report must include additionalfinancial 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 licenseemust annually submit to the NRC, by March 31, a report on the status of its funding for managingirradiated fuel.The final disposition and status of the Atomic Energy Commission's nuclear fuel utilized bythe NSS is described in the September 21, 1973, Operations Report and also in Section 1.3.1of the Final Safety Analysis Report as follows:Thirty six spent fuel elements (Core I and Ia) were shipped from Galveston, TX to the USAtomic Energy Commission (AEC) -Savannah River Plant, Aiken, SC in nine shipmentsfrom October 4 through December 21, 1972 via a lowboy trailer using the Piqua/ElkRiver Shipping cask.The 10 CFR 50.82(a)(8)(vii) report must include the following information, current through theend of the previous calendar year:Revision 08 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0(A) The amount of funds accumulated to cover the cost of managing the irradiated fuel;AfRAD is storing no irradiated nuclear fuel and, therefore, has no accumulated funds tocover such costs.(B) The projected cost of managing irradiated fuel until title to the fuel and possession of the fuelis transferred to the Secretary of Energy; andMARAD is storing no irradiated nuclear fuel and, therefore, has no need to project suchcosts.(C) If the funds accumulated do not cover the projected cost, a plan to obtain additional funds tocover the cost.MARAD is storing no irradiated nuclear fuel and, therefore, has ito need to obtain additionalfunds to cover such cost.4.0 CY 2014 FUNDINGThe NSS was maintained in mothballed protective storage throughout CY 2014. Approximately $2.80million in appropriated funds were available to MARAD to maintain the NSS during the period. Fundswere sourced from within MARAD's Ship Disposal appropriations for FY 2014 (January 1 -September30, 2014) and 2015 (October 1 -December 31, 2014).4.1 FY2014FY 2014 began on October 1, 2013 and ended on September 30, 2014. Funding for the 1Q of FY 2014falls before the reporting period; however, the events of that quarter are important in context. In theabsence of an approved budget and appropriations, a partial Government funding gap was imposedbeginning on October 1, 2013. MARAD's Ship Disposal Program had sufficient carryover fundsavailable to maintain staffing. Service contracts were funded in FY 2013 with performance periodsthrough November 2013, and were similarly unaffected during the funding gap. During the ContinuingResolution (CR) that followed, funding was sufficient to maintain NSS operations without impact. Afterpassage of the Bipartisan Budget Act of 2013, the Consolidated Appropriations Act, FY 2014, providedfunding for NSS activities at the original budget request level of $2.80 million.Based on the revised decommissioning schedule submitted in Reference (e), the funding for FY 2014 didnot result in a change to the content of the PSDAR, and consequently no 10 CFR 50.82(a)(7) notificationwas submitted.4.2 FY2015FY 2015 began on October 1, 2014 and will end on September 30, 2015. Funding for FY 2015 wasinitially provided by a Continuing Resolution (CR) that was effective to December 11, 2014. TheConsolidated and Further Continuing Appropriations Act of 2015 provided a lump sum of $4.00 millionfor activities funded by the Ship Disposal account. A nominal breakdown of the lump sum provides$2.00 million for NSS operations, with the balance of program activities funded by prior year carryover.Based on'the revised decommissioning schedule submitted in Reference (e), the projected funding for FY2015 did not result in a change to the content of the PSDAR during the reporting period, andconsequently no 10 CFR 50.82(a)(7) notification was required.4.3 FY 2016FY 2016 will begin on October 1, 2015 and will end on September 30, 2016. Although this falls outsidethe reporting period, MARAD includes this information for context. The President's FY 2016 BudgetRequest for the Maritime Administration was submitted to the Congress on February 2, 2015. TheRevision 09 SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0request for NSS activities is $3.00 million. No funds are requested for either SAFSTOR Preparations orDECON.Based on the revised decommissioning schedule submitted in Reference (e), MARAD anticipates that theprojected funding for FY 2016 will not result in a change to the content of the PSDAR, and consequentlyno 10 CFR 50.82(a)(7) notification is anticipated based on the FY 2016 budget request.5.0 REGULATORY COMMITMENTS REGARDINGDECOMMISSIONING FUNDINGThere are four (4) recurring commitments regarding decommissioning funding that are reported on ineach annual Decommissioning Funds Status Report. The resolution of any one-time commitments will bedescribed as required. The recurring commitments are described in the following sections.5.1 Annual Request for FundsIn Reference (f), MARAD made the following regulatory commitment:Annually, MARAD will request funds specifically for decommissioning. The NRC will be informed ofthese decommissioning funding requests annually by March 31. [Continuing action]Beginning in the PSDAR, and in periodic correspondence thereafter, MARAD has reiterated itsunderstanding of its responsibility to request and obtain decommissioning funds in sufficient quantity andtime to meet the NS-1 license termination deadline of December 3, 2031. Given the inherent nature of thebudget process, MARAD defines its commitment to be satisfied annually when it makes a request fordecommissioning funds to the Office of the Secretary of Transportation. MARAD has no independentauthority to seek decommissioning funds if the request is not made part of the President's Budget Requestfor the Department of Transportation. Documentation regarding the annual request is maintained by thelicensee, and is available for inspection.Two budget requests are normally in process during any reporting period. The first is the President'sRequest that is submitted to the Congress during the first quarter of the CY for the FY beginning onOctober 1st of the reporting period. The second is the deliberative and privileged internal process thatbegins in April, continues throughout the reporting period, and culminates in the President's Request toCongress in the following year. Although the submission of the outyear (or second) budget request fallsoutside of the reporting period, it does normally occur prior to the reporting deadline of March 31. Asnoted in Section 1.0, this outyear request is a reasonable predictor of future decommissioning funding andactivity, and publicly available information about the request is included in this report for context.Each year in its Decommissioning Funds Status Report, MARAD includes a statement regarding thebudget requests prepared during the reporting period.5.1.1 FY 2015The President's FY 2015 Budget Request for the Maritime Administration was submitted to the Congresson March 4, 2014. As with the FY 2014 request, no funds were requested for either SAFSTORPreparations or DECON; however, the budget request narrative includes the following new languagerelated to future decommissioning funding:While funding at this level does not allow MARAD to begin (decommissioning), this resource-intensive requirement is a near-term concern and the agency is developing formal decommissioningproject execution plans and multi-year budget estimates.For the NSS, there is no technical reason to continue to defer the multi-year decommissioning projectand seek license termination.Revision 010 SA1,4NNAH Technical StaffSTS -192, Decommissioning Funds Status'Report For CY 2014, Revision 0From a total cost perspective, ... continued deferral of this project can on/v increase its total cost tothe Government, with no corresponding benefit.5.1.2 FY 2016The President's FY 2016 Budget Request for the Maritime Administration was submitted to the Congresson February 2, 2015. As with the FY 2015 request, no funds were requested for either SAFSTORPreparations or DECON; however, the budget request narrative merely acknowledges the DECONrequirement without the additional affirmative language found in the FY 2015 request (see above). Thisapparent reversion is the result of continuing discussion with responsible Office of the Secretary ofTransportation (OST) and Office of Management and Budget (OMB) budget officials, and the balancingof priorities for the FY 2016 budget cycle. Nevertheless, MARAD, OST and OMB are cognizant of theresponsibilities and funding commitment requirements for DECON, and these obligations will continue tobe examined and balanced during future annual budget development cycles.5.2 Annual Submittal of New EstimateIn Reference (e), MARAD made a regulatory commitment that was subsequently revised as follows:Submit a new estimate annuall/ by either revising the site specific estimate based on circumstancesthat affect its underlying assumptions, or by using cost escalation factors no smaller than those in themost recent revision to NUREG 1307.The CY 2014 estimate is provided in Sections 2.1 and 2.4 of this report.5.3 Revised Decommissioning Cost Estimate (DCE)In Reference (e), MARAD made the following regulatory commitment:The site specific DCE will be revised at least even-vfive (5) years.The site specific DCE is scheduled for full revision in CY 2015.5.4 Content of MARAD Budget RequestsIn Reference (g), MARAD made the following regulatory commitment:Because the privity of the Federal budgeting process precludes public notifcation of the content ofagency budget requests prior to their submittal to the Congress, M4RAD has determined that fiautre10 CFR 50.82(a)(7) notifications will be submitted under a 10 CFR 2.390 request fbr withholding.Based on the revised Decommissioning Activities Schedule submitted to the NRC in Reference (e),MARAD determined that no 10 CFR 50.82(a)(7) notification (change to the content of the PSDAR,particularly the decolmnissioning schedule) was required during CY 2014.6.0 TIME REMAINING TO COMPLETE DECOMMISSIONINGAs of December 3, 2014, 43 years of protective storage had elapsed; more than two-thirds of the allowed60-year protective storage period.

7.0 REFERENCES

a. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning NuclearReactors, Revision 1, October 2003b. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC),dated December 11, 2008, Submittal of Post Shutdown Decommissioning Activities Report,Revision IRevision 0I1I SAVANNAH Technical StaffSTS -192, Decommissioning Funds Status Report For CY 2014, Revision 0c. NRC Regulatory Issue Summary 2014-12: Decommissioning Fund Status Report Calculations-Update To Low-Level Waste Burial Charge Information, October 14, 2014d. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, datedFebruary 28, 2015, Annual Report for CY2014, Revision 0e. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, datedMarch 31, 2011, Submittal of Decommissioning Funds Status Report for CY 2010 and updatedGovernmental Statement of Intent for Decommissioning Financial Assurancef. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, datedMarch 9, 2011, Response to Receipt of Decommissioning Funds Status Update (CY 2009) for N.S.SA VANNAHg. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission, datedJune 04, 2010, Submittal of Decommissioning Funds Status Update for CY 2009 andGovernmental Statement of Intent for Decommissioning Financial AssuranceRevision 012
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