J02 - PSDAR

U.S. Department of Transportation Maritime Administration

Office of Ship Disposal Programs

N.S. SAVANNAH

POST SHUTDOWN

DECOMMISSIONING ACTIVITIES REPORT

STS-100

REVISION 1

Approved: December 10, 2008

Senior Technical Advisor Date

Prepared by:

Sayres and Associates Corporation

Erhard.Koehler Approved

Savannah Technical Staff Post Shutdown Decommissioning Activities Report, Revision 1 December 10, 2008

RECORD OF REVISIONS

Revision Summary of Revisions

0 Original version of the Post Shutdown Decommissioning Activities Report submitted on December 11, 2006 and withdrawn on January 27, 2007.

1 This version is a revision in whole of the PSDAR.

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Table of Contents

1.0 INTRODUCTION 8

1.1 Purpose 8

1.2 Arrangement of the PSDAR 8

1.3 Final Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) 9

2.0 BACKGROUND 10

2.1 Savannah Program Chronology and Summary 10

2.2 Summary of Completed Decommissioning Activities (1971 – 1976) 13

2.2.1 Reactor Vessel 13

2.2.2 Spent Fuel 13

2.2.3 Fission Chambers 13

2.2.4 Pressurizer 13

2.2.5 Control Rod Drive System 14

2.2.6 Primary Coolant System 14

2.2.7 Secondary System 14

2.2.8 Auxiliary Systems 14

2.2.9 Containment Vessel (CV) 14

2.2.10 Radiation Control Area Boundaries 15

2.3 Summary of Routine Activities after 1976 15

2.4 Reevaluation of Radiological Vulnerabilities 15

2.4.1 Decommissioning Planning and Radiological and Environmental Scoping Characterization Survey 2003-2005 15

2.4.2 Reactor Pressure Vessel Analysis 2005 16

2.5 Organizational Upgrades after 2005 17

2.6 Programmatic Upgrades after 2005 17

2.7 Current Organization 18

2.8 Current Status of N.S. Savannah 19

3.0 DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES 21

3.1 SAFSTOR Preparations 21

3.2 SAFSTOR Operations (Retention) 22

3.2.1 Retention Site Options for SAFSTOR Operations 23

3.2.2 Layberthing for “Public Use” while maintaining license conditions 23

3.2.3 Government Layberthing with Restricted Access 24

3.2.4 Reserve Fleet Lay-up and Retention 24

3.3 DECON and License Termination 24

3.3.1 DECON Preparations 25

3.3.2 Performance of DECON Activities 26

3.3.3 License Termination 26

3.4 Plans for the NSS after License Termination 26

4.0 OTHER DECOMMISSIONING ISSUES 28

4.1 Specific DECON Activities Relating to Removal of Systems and Components 28

4.2 Low-Level Radioactive Waste Disposal 28

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4.3 Hazardous and/or Mixed Waste Disposal 28

4.4 Programmatic Considerations Related to Extended SAFSTOR Retention Period 28

5.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES 30

6.0 ESTIMATE OF EXPECTED DECOMMISSIONING COSTS 31

6.1 Status of Decommissioning Funds 31

6.2 2006 ROM Decommissioning Cost Estimate 31

6.3 2008 ROM Decommissioning Cost Estimate 32

6.4 Cost Estimates for SAFSTOR / Deferred DECON 34

6.4.1 2008 SAFSTOR Preparations COSTS 34

6.4.2 SAFSTOR Operations (Retention) Costs 34

6.4.3 DECON and License Termination Costs 34

6.5 Programmatic Cost Effects Related to Deferred Decommissioning 35

7.0 ENVIRONMENTAL IMPACTS 36

7.1 Specific Environmental Issues 36

7.1.1 Radiation Dose to the Public 36

7.1.2 Occupational Radiation Exposure 37

7.1.3 Low-Level Radioactive Waste Burial Volume 37

7.1.4 Non-Radiological Environmental Impacts 38

7.1.5 Additional Considerations 38

7.2 Historic Preservation Considerations 38

7.3 Environmental Impacts Conclusion 39

8.0 REFERENCES 40

APPENDIX A. COMPARISON OF MOTHBALLING AND SAFSTOR REQUIREMENTS 41

A.1. Preparation for Protective Storage - Mothballed vs. SAFSTOR 41 A.1.1. Mothballing (Regulatory Guide 1.86) 42 A.1.2. SAFSTOR (Regulatory Guide 1.185) 42 A.1.3. Significant Differences 42

A.2. Protective Storage Requirements - Mothballed vs. SAFSTOR 42 Table A.1 Mothballing vs. SAFSTOR Requirements 42

APPENDIX B. DECOMMISSIONING PROJECT SCHEDULE 44

APPENDIX C. ALTERNATIVES FOR FUTURE CONSIDERATION 45

C.1. License Termination under 10 CFR 20.1403 Restricted Conditions Criteria 46 C.2. License Termination under 10 CFR 20.1404 Alternate Criteria 47 C.3. Maintenance of License / License Renewal 47 C.4. Technical Considerations regarding restricted release 47

List of Figures

Figure 2-1 Organization Chart

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List of Tables

Table 5-1 Schedule of Planned Decommissioning Activities Table 6-2 2008 Site-Specific Cost Estimate (in Thousands) Table 7-3 Comparison of the NSS and SNEC

List of Acronyms

AEC (U.S.) Atomic Energy Commission

ALARA as low as reasonably achievable

CRD Control Rod Drive

CV Containment Vessel

DCGLs Derived Concentration Guideline Levels

DH Dehumidification

DHEC Department of Health and Environmental Control (State of South Carolina)

DOT (U.S.) Department of Transportation

EA Environmental Assessment

EMOS Engineering, Management and Oversight Support

ESC Executive Steering Committee

FAR Federal Acquisition Regulations

FONSI Finding Of No Significant Impact

GEIS Generic Environmental Impact Statement

GTCC Greater-than-Class-C waste

HVAC Heating, Ventilation and Air Conditioning

ICCP Impressed Current Hull Cathodic Protection

JRRF James River Reserve Fleet

LAR License Amendment Request

LLRW Low Level Radioactive Waste

LTP License Termination Plan

MARAD Maritime Administration (‘the Agency’ also “licensee”)

MSP Manager, N.S. Savannah Programs

MWth Megawatt Thermal

NEPA National Environmental Policy Act of 1969, as Amended

NHPA National Historic Preservation Act of 1966, as Amended

NPDES National Pollutant Discharge Elimination System

NRC (U.S.) Nuclear Regulatory Commission

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List of Acronyms (Continued)

NSS Nuclear Ship Savannah

NST Neutron Shield Tank

OMB Office of Management and Budget

POL Possession-only license

PPDA Patriots Point Development Authority (State of South Carolina)

PSDAR Post-Shutdown Decommissioning Activities Report

RCAs Radiation Control Areas

RG Regulatory Guide

ROM Rough Order of Magnitude

SNEC Saxton Nuclear Experimental Corporation

STA Senior Technical Advisor

STS Savannah Technical Staff

USDOE U.S. Department of Energy

Other Decommissioning Acronyms Used

DECON is the decommissioning alternative in which the equipment, structures, and portions of the licensed facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use. DECON may occur shortly after cessation of operations, or after a period of SAFSTOR.

SAFSTOR is the decommissioning alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use.

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1.0 INTRODUCTION

The United States Department of Transportation (DOT), acting through the Maritime Administration (the “Agency” also “licensee”) owns the Nuclear Ship Savannah (“NSS”), and holds License No. NS-1, Docket No. 50-238. In accordance with the requirements of 10 CFR § 50.82, "Termination of license," paragraph (a)(4)(i), this report provides Revision 1 to the Agency’s Post-Shutdown Decommissioning Activities Report (PSDAR) for the NSS.

The Agency initially submitted Revision 0 of the PSDAR to the Nuclear Regulatory Commission (NRC) on December 11, 2006 (Reference a), and withdrew Revision 0 on January 27, 2007, prior to the NRC scheduling a PSDAR public meeting. The Agency explained the principal reason for withdrawal in Reference (b), and committed to resubmit the PSDAR when a reasonably stable1 decommissioning approach could be determined.

1.1 PURPOSE

The PSDAR provides the NRC, states, and the public with a general overview of the licensee's proposed decommissioning activities. The PSDAR informs interested parties of the licensee’s expected activities, costs, and schedule, facilitating planning for inspections and decisions regarding NRC oversight activities. The PSDAR also informs the public of the proposed decommissioning activities before the decommissioning activities are conducted.

1.2 ARRANGEMENT OF THE PSDAR

This report is arranged into sections that supply the information required in a PSDAR as described in 10 CFR § 50.82 and Regulatory Guide 1.185 (Reference c). The required content and the section(s) in which it is found includes:

o A description of the licensee's planned major decommissioning activities (Section 3.0);

o A schedule for completing these activities (Section 5.0 and Appendix B);

o A discussion regarding an estimate of the expected decommissioning costs (Section 6.0); and, o A discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously-issued environmental impact statements (Section 7.0).

Unlike a land-based nuclear plant, the NSS is waterborne, mobile and of unique historic significance, thus its decommissioning presents a number of unusual factors for consideration. The Agency has included additional content and sections in the PSDAR to address these factors. Section 2.0, “Background,” provides a brief discussion of the design and history of the NSS, and a summary of the “mothballing” (decommissioning) actions completed after the ship was removed from service some 35 years ago. Section 3.0, “Description of Planned Decommissioning Activities,” discusses the retention site options that may be available during the SAFSTOR operations period. Section 4.0 discusses “Other Decommissioning Issues,” with some particular emphasis on contemporary SAFSTOR practices and their applicability to the NSS. Appendix A provides a detailed “Comparison of Mothballing and SAFSTOR Requirements” to describe the differences between the 1974 and current requirements for protective storage. Finally, Appendix C provides some discussion of potential decommissioning alternatives for the NSS. Appendix C is intended to foster future dialogue and should be considered in that light only.

1 PSDAR Rev 0 was predicated on an incrementally-funded DECON effort beginning in FY 2007 and continuing through FY 2012.

Appropriations bills for FY 2007 were not passed prior to or following the 2006 mid-term congressional elections, and the resulting Continuing Resolutions made the Rev 0 decommissioning schedule unachievable.

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1.3 FINAL ENVIRONMENTAL ASSESSMENT (EA) AND FINDING OF NO

SIGNIFICANT IMPACT (FONSI)

On May 14, 2008 (see Reference d), the Agency published notice of the availability of the Finding of No Significant Impact (FONSI), Reference (e), derived from a March 2008 Environmental Assessment (EA) regarding the Decommissioning of the Nuclear Ship Savannah, Reference (f). The FONSI documents the Agency’s conclusion that the proposed federal action to decommission the NSS is consistent with existing national environmental policies and objectives as set forth in Section 101(a) of the National Environmental Policy Act of 1969, as amended (NEPA). The Agency concluded that the proposed action will not significantly affect the quality of the human environment or otherwise include any condition requiring consultation pursuant to Section 102(2)(c) of NEPA.

Because the NSS is a federally-owned facility, NEPA required that the Agency evaluate the available alternatives for the NSS prior to making an executive decision on decommissioning. The Agency released a draft EA documenting its evaluation of alternatives for public comment in 2006. As with Revision 0 of the PSDAR, that EA emphasized the DECON approach. The 2008 final EA incorporates public comments received, and expands the discussion and evaluation of the SAFSTOR decommissioning alternative. The EA has been independently evaluated and determined to adequately and accurately discuss the environmental issues and impacts of the proposed project. Because the Agency concluded that the proposed action will not significantly affect the quality of the human environment or otherwise include any condition requiring consultation, preparation of an Environmental Impact Statement, pursuant to NEPA, was not required. The FONSI was published instead.

See Section 7.0 for additional detail.

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2.0 BACKGROUND

2.1 SAVANNAH PROGRAM CHRONOLOGY AND SUMMARY

The Maritime Administration is owner and licensee of NSS, the world's first nuclear powered merchant ship. Conceived in the 1950’s as part of President Eisenhower's "Atoms for Peace" program, the NSS was designed, constructed and operated as a joint research and development project of the Department of Commerce, Maritime Administration and the Atomic Energy Commission (AEC). The Maritime Administration’s contribution was the ship while the AEC’s was the nuclear fuel, reactor and related nuclear systems. The NSS was designed with three primary goals:

Demonstration of America’s interest in the peaceful use of atomic energy;

Use of the NSS as an atomic exhibit; and, Establishment of port entry criteria and worldwide acceptance of a nuclear merchant ship.

The NSS was not designed to be economically competitive with conventional ships.

The 80 MWth reactor was first brought to power in 1961. Seagoing trials followed in 1962, with experimental operations and foreign voyages continuing into mid-1965. The AEC ended its participation in the project in 19652, transferring liability and title to the reactor to the Maritime Administration. NSS was operated in commercial demonstration service throughout the 1960’s.

The only refueling was conducted in August to October 1968 at the Maritime Administration’s Nuclear Servicing Facility, located at Todd Shipyards, Galveston, TX. This refueling was a “fuel shuffle” to extend the life of Core I. In this operation, the four center fuel elements were removed and replaced with four spare elements. The remaining 28 elements were rearranged to address fuel burnup (i.e., normal consumption). In general, the inner fuel elements were moved outwards, the outer fuel elements were moved inwards, and all elements were rotated 180o relative to the core center. The new core design was designated Core Ia. Additionally, one control rod was replaced.

Having completed its research and commercial development program objectives, the ship was returned to Galveston, TX, and removed from service in the summer of 1970. The ship transited to New Orleans, LA, in October 1970 for drydocking, and the reactor was last operated in November of that year on the return voyage to Galveston. By the end of 1971 when alternatives for the immediate re-use for the ship failed to materialize, its nuclear power plant was defueled and prepared for long-term lay-up under contemporary best practices. Some minor, reversible decommissioning activities were undertaken at that time. The ship was moved to its homeport of Savannah, GA, in January 1972, as part of a plan to establish an “Eisenhower Peace Memorial” in that city. The intention of this effort was to permanently transfer title of the ship and the AEC license to the State of Georgia. The effort was not successful, and the ship was later moved to a Government berth at the North Charleston Army Terminal, SC.

In the interim the Agency concluded that the NSS would not be refueled and returned to service as a nuclear-propelled vessel3. The AEC issued a license amendment (Technical Specification Change 13) on January 29, 1973, that recognized the ship was in a “Fuel Removed Condition.” Although the final reactor shutdown had occurred in November 1970 and the defueling was completed in fall 1971, these actions were not considered to be permanent until early 1973 when the decision was finally made to not

2 The joint program terminated effective with the issuance of License NS-1, and the NSS became the sole subsequent responsibility of the Maritime Administration as owner and licensee.

3 Studies to re-use the ship continued into the mid-1970’s. A serious proposal to convert the Savannah into an Oceanographic Research Vessel held the most promise for re-use under nuclear propulsion. In 1974 a brief study was made to reactivate the ship to demonstrate its potential cost-savings during the first middle-east oil crisis. Studies to remove the reactor compartment and re-use the ship under conventional power continued into the late 1970’s; the last of which was a proposal to convert Savannah into a hospital ship for the Rapid Deployment Force.

Revision 1 10 load Core II4. Therefore, the fall 1971 defueling retroactively became the de facto permanent defueling and cessation of operations with the issuance of Technical Specification Change 13.

Decommissioning activities resumed in 1975, when the NSS was “mothballed” per the contemporary requirements of Regulatory Guide (RG) 1.86, “Termination of Operating Licenses for Nuclear Reactors,” Reference (g). This RG describes the now outmoded Mothballing option of protective storage. In 1988, the NRC formally identified the term SAFSTOR in the Generic Environmental Impact Statement (GEIS), NUREG-0586, Reference (h)5. The major difference between the two approaches (described more fully in Appendix A) is that the Mothballing process is a simplistic and prescriptive methodology that does not include the comprehensive and programmatic aspects of SAFSTOR.

In mid-1975 the ship was taken to Baltimore, MD, for routine drydocking. The NSS was returned to the North Charleston Army Terminal and maintained at layberth while the State of South Carolina pursued a new effort to place the ship into museum service.

By April 1976, additional decommissioning activities such as 1) disposing of primary purification system ion-exchanger resins, 2) removing the three primary purification system ion-exchangers and 3) dewatering the primary, auxiliary and secondary systems had been performed. The NSS possession-only license, Reference (i), was issued on May 19, 1976, for a ten-year term, and imposed the requirements associated with the Mothballed protective storage option. During the intervening 30 years, the ship has remained in the Mothballed condition.

The effort to make the ship a museum succeeded in 1981. The NSS was bareboat chartered6 to the Patriots Point Development Authority (PPDA) of the State of South Carolina, for public display at the Patriots Point Naval and Maritime Museum, near Charleston, SC. During that period the PPDA was designated a "co-licensee" for the reactor and exercised custody of the ship and full management of the license. The vessel remained owned by the Maritime Administration, however. The bareboat charter was renewable on five year terms.

In 1981 the Maritime Administration was reorganized and transferred from the Department of Commerce to the Department of Transportation. From a licensing and funding standpoint this was an administrative change only.

In 1986 the NS-1 license was renewed for a ten-year term.

Shortly after the second bareboat charter renewal in 1991, a hull leak developed. After a series of surveys and inspections, it was concluded in 1993 that deterioration of the underwater hull body necessitated a drydocking, for which funding was requested from Congress. Unrelated to the underwater hull issue was internal deterioration from excessive water intrusion from the upper decks. The water intrusion condition began with Hurricane Hugo in 1989 and gradually worsened over time. In light of these issues and the effects they had on use of the ship, PPDA informally notified the Agency that it would exercise its right to terminate the charter effective with the ship’s removal for drydocking.

Museum operations ended in early 1994, when industrial topside and internal repairs commenced in preparation for the drydocking and subsequent transfer of the Savannah to a reserve fleet. The NSS was

4 Core II was fabricated but never possessed by the Maritime Administration.

5 Draft Generic Environmental Impact Statement (GEIS) on Decommissioning Nuclear Facilities, NUREG-0586, January 1981, appears to be the first NRC document to introduce the term.

6 A bareboat charter is an arrangement in which the bare ship is chartered without crew. The charterer becomes, for the period of the arrangement, practically the owner of the hired vessel. The charterer 1) appoints the captain, 2) engages the crew and pays their wages, 3) provisions and equips the ship, 4) becomes liable for all running charges 5) maintains the hull and machinery in efficient repair. The principal obligations of the charterer are to pay the owners an agreed sum and to redeliver her in the same condition as when chartered, ordinary wear and tear excluded. The statutory charter between the Agency and the PPDA was based on a bareboat concept, wherein PPDA exercised all custodial and “operational” (principally maintenance and repair) responsibility for the ship without remuneration to the Agency.

Revision 1 11 removed from the museum site on May 24, 1994 and in June 1994 was drydocked (again in Baltimore, MD) for hull maintenance and repair. Extensive repairs to deteriorated underwater hull plating were completed, and in July 1994 the Savannah was placed in the Agency’s James River Reserve Fleet (JRRF) at Fort Eustis (Newport News), VA. License Amendment 12 was issued in July 1994, and among other things removed the PPDA as a co-licensee, and established the vessel’s location as the JRRF. The NSS remained in protective storage there until August 15, 2006.

To prepare the ship for layup at JRRF, a number of conventional preservation measures were put into place. These included fitting a Dehumidification (DH) system to preserve the ship’s interior, renovations to the Impressed Current hull Cathodic Protection (ICCP) system, and overhaul of the ship’s existing fire, flooding and intrusion alarm systems. These modifications included long runs of portable ductwork and electrical cabling which generally obstructed the doorways, passageways and ladders throughout ship.

Externally, deck drains were blanked off to reduce water intrusion into the ship’s interior. No funds were available to correct the interior water damage effects; however, the DH did arrest any further degradation.

In preparation for, and during the lay-up period at the JRRF, no changes were made to radiological surveillance or monitoring plans and no substantive radiological work was performed. Radwork consisted exclusively of passive surveillance and monitoring in accordance with the circa 1981 surveillance plan. Only minimal modification, maintenance and testing of the alarm and monitoring systems required by Technical Specifications (“TS”) were performed.

The Agency experienced a gradually diminishing institutional capacity to manage nuclear license operations through continuing retirements of experienced personnel, complacency with the absence of any significant radiological work and the routine renewal of health physics contracts7. In 1996 the Agency undertook its last substantive licensing action when it submitted a license renewal application that was returned by the NRC because new regulations were being implemented at that time (the “Termination of License” rulemaking, see Appendix A).

In early 2001 the NRC issued two Notices of Violation for failures to maintain emergency health physics support and an emergency radiological assistance team in accordance with the Technical Specifications.

Action to address these violations was in-progress when the terrorist attacks of September 11, 2001 took place. In the wake of the attacks, the Maritime Administration expanded its license violation corrective actions to include an assessment of the ship’s existing radiological vulnerabilities. In response the Maritime Administrator approved the February 2002 staff recommendation to advance the decommissioning of the ship’s nuclear facilities and terminate the license. Initial activities undertaken in this decommissioning program included correcting the violations, basic engineering and planning, conducting a radiological and environmental characterization scoping survey, and implementing organizational and programmatic upgrades as described in sections 2.4 through 2.6. By early 2006 the decommissioning program was moving forward rapidly, with a draft Environmental Assessment completed, engineering support contracts under solicitation, and decommissioning site evaluation and selection in progress.

On August 15, 2006, the NSS was moved to Colonna’s Shipyard, Norfolk, VA, for pre-decommissioning topside maintenance. By the end of the calendar year, emergent budgetary developments forced a reassessment of the decommissioning program (see section 6.1 for further detail). The NSS was maintained in a layberthed condition at facilities in the Hampton Roads area during the reassessment period. The reassessment eventually concluded that the NSS should be returned to protective storage until such time as a stable budgetary environment could support decommissioning and license termination. To place the ship into extended retention, a contemporary SAFSTOR compliance program is

7 During the JRRF lay-up period, the Savannah was nested alongside the Army Corps of Engineers nuclear power barge Sturgis. NSS health physics / rad protection was provided by the Army Corps under a reimbursable agreement and addendum to the Sturgis health physics contract.

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December 10, 2008 being developed and implemented. The program includes technical and industrial activities to be performed to the ship, and administrative activities to ensure the Agency maintains full compliance with all terms and conditions of its license.

On January 19, 2008, the NSS was drydocked at BAE Systems’ Norfolk Ship Repair facility in South Norfolk, VA, for hull maintenance and exterior surface cleaning and preservation. Acting through its assigned General Agent, the Maritime Administration solicited competitive bids for a layberth to provide a secure retention site where SAFSTOR and license compliance activities could be completed. On May 7, 2008, the NSS left South Norfolk, VA, and arrived at Pier 13, Canton Marine Terminal at 4601 Newgate Ave., Baltimore, MD 21224 on May 8, 2008.

Calendar Year 2008 marks the beginning of a series of 50th Anniversary milestones for the ship and program. The anniversary of the ship’s keel laying ceremony was commemorated on National Maritime Day, May 22, 2008. Milestone events will be commemorated through the August 2012 anniversary of the ship’s maiden voyage to Savannah, GA.

Future planned activities are described in Section 3.0, “Description of Planned Decommissioning Activities.”

2.2 SUMMARY OF COMPLETED DECOMMISSIONING ACTIVITIES (1971 –

1976)

The following discussion is a summary contained in Maritime Administration letters that supported issuance of Reference (i). An annotated explanation of the primary coolant system status is added to item 2.2.6.

2.2.1 REACTOR VESSEL

All 32 Core Ia fuel elements were removed from the reactor vessel to the spent fuel pool at the Agency Refueling Facility, Todd Shipyards, Galveston, TX. All reactor internal components were reinstalled, i.e., twenty-one control rods, core basket, upper grid plate, upper flow baffle. Thirty-six upper flow transition pieces and one additional irradiated control rod (cut in three pieces) were loaded into six fuel element channels in the core basket. Thirty-two upper flow transition pieces were from Core I and four were from Core Ia (i.e., the 1968 fuel shuffle). The additional control rod was the one replaced during the 1968 fuel shuffle. The reactor head was reinstalled with six of the original 48 reactor head hold down studs tensioned.

2.2.2 SPENT FUEL

Thirty six spent fuel elements (Core I plus the four “new” elements of Core Ia) were shipped from Galveston, TX to the AEC, now U.S. Department of Energy (USDOE), Savannah River Site, Aiken, SC, in nine shipments from October 4 through December 21, 1972.

2.2.3 FISSION CHAMBERS

All five fission chambers were removed and shipped to the Maritime Administration maintenance facility in Galveston, TX, in May 1973. On June 28, 1973, these five and an additional three stored on the NSV Atomic Servant (the nuclear services vessel for NSS) were shipped to Chem-Nuclear Systems, Inc., Barnwell, SC, for disposal.

2.2.4 PRESSURIZER

Relief valve PR-1V was removed. The nozzle flange was fitted with an absolute filter vent to allow for pressure equalization.

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2.2.5 CONTROL ROD DRIVE SYSTEM

a. Electrical

The breakers for the rod drives were opened and tagged in the control rod drive electrical cubicle and the control room. The cables between the junction boxes on the control rod drive (CRD) structure and the junction boxes located around the periphery of the cupola were disconnected, coiled and secured on the CRD structure in the containment vessel (CV). The support wireways were removed, packaged and stored in Hold No. 4. In addition, the 21 buffer seal flow meter cables and the vibration monitor cables were disconnected.

b. Mechanical

All hydraulic oil was drained and the piping disconnected between the cupola and the CRD structure. Buffer seal system valves were closed and tagged out. The inlet and outlet header spool pieces between the cupola and structure were removed. The buffer seal system was drained.

The 21 control rods were disconnected from their respective CRD extension shafts and remain in their fully inserted position between the empty fuel location channels. The CRD extension shafts were disconnected from their lead screws and are fully inserted. The CRD lead screws were withdrawn and pinned in place. Steel caps were placed onto the 21 reactor head nozzles to completely seal the nozzle from the CV atmosphere and mechanically separate the CRD mechanism from the control rod.

2.2.6 PRIMARY COOLANT SYSTEM

The system was drained as completely as practical. All loop isolation inlet and outlet valves are open and back seated.

Primary Pump motors and impellers were removed. Blank flanges were installed over the volute openings. The grating, piping, valves, ducting, etc., disconnected while removing the pump motors and impellers, were left in the removed condition within the CV.

2.2.7 SECONDARY SYSTEM

Both steam generators and piping were drained of water as completely as practical. The non-radioactive water on the secondary side of the steam generators was transferred to a double bottom tank below the reactor compartment. The isolation valves outside of the CV were closed. There were no modifications to the secondary system.

2.2.8 AUXILIARY SYSTEMS

All nuclear related auxiliary systems were drained as completely as practical.

The three primary purification system ion-exchangers and their resins (28 Ci) were physically removed from the ship and their lines capped.

Non-radioactive water from the neutron shield tank was transferred to a double bottom tank below the reactor compartment. The equipment drain and waste collection system tanks were drained as completely as practical.

2.2.9 CONTAINMENT VESSEL (CV)

The forward and aft manway shield plugs were put in place with security seals installed. Entries into the CV were expected to be made through the aft airlock. The lifting chains and hooks were removed from the chain hoists used to handle the shield plugs to minimize the possibility of unauthorized CV

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December 10, 2008 entry. The CV bilge was wiped clean. The inerting piping in the CV cupola head was disconnected outside and valves closed so that the integrity of the vessel was maintained.

2.2.10 RADIATION CONTROL AREA BOUNDARIES

Secured boundaries were established to prevent unauthorized access into Radiation Control Areas (RCAs). The secured entrances included the following spaces:

a. The Reactor Compartment;

b. The Port and Starboard Stabilizer rooms;

c. The Forward Control Areas (aka the Cold Water Chemistry Laboratory);

d. The Port and Starboard Charge Pump rooms; and,

e. The Hot Chemistry Laboratory, in the Control Room Area.

2.3 SUMMARY OF ROUTINE ACTIVITIES AFTER 1976

Until 2005, no significant decommissioning activities were performed following issuance of the Possession-only license (POL) in 1976. Routine activities under the POL included equipment corrective and preventive maintenance, inspection activities and housekeeping / ship husbandry operations conducted in accordance with established marine practices and the Technical Specifications.

Systems/structures were monitored and maintained, as needed, to control the spread of radioactive material. A cathodic protection system was used to protect the underwater areas of the vessel's hull to minimize corrosion damage. Underwater inspections of the hull were conducted at least every four years to identify problems such as localized severe pitting, underwater plate thinning or other damage that would require corrective action.

When routine access was not required, the ship was locked and secured. Areas containing radioactive materials or other contamination were secured to prevent accidental intrusion and make deliberate intrusion difficult. Radiation protection activities were generally limited to those activities necessary to maintain exposures as low as reasonably achievable (ALARA).

In accordance with the NSS Technical Specifications, radiological and environmental surveillances were performed outside of the CV to ensure that radioactivity was not spread in the ship. Additionally, these surveillances ensure potential releases of radioactive material to the environment are detected and controlled.

2.4 REEVALUATION OF RADIOLOGICAL VULNERABILITIES

After the September 11, 2001, terrorist attacks, the Maritime Administration concluded actions should be taken to reassess the ship’s existing radiological vulnerabilities.

The general conclusion was that active decommissioning should be pursued with the goal of terminating the NS-1 license. At a minimum, the Agency concluded that contaminated structures, systems and components outside of the reactor compartment should be removed and decontaminated to reduce radiological hazards.

2.4.1 DECOMMISSIONING PLANNING AND RADIOLOGICAL AND

ENVIRONMENTAL SCOPING CHARACTERIZATION SURVEY 2003-2005

A decommissioning planning contract was awarded in 2003, with performance continuing into mid-2004.

A series of preliminary engineering studies was conducted, and an assessment of the radiological condition of the primary and auxiliary systems was made based on an analysis of the reactor power history. From this a summary bounding analysis against the NRC GEIS was performed, with a preliminary conclusion that the NSS decommissioning was bounded by the GEIS.

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A follow-on contract was awarded in late 2004 to perform a radiological and environmental characterization scoping survey of the NSS. That survey was conducted in March and April 2005, while the ship lay at the JRRF. This characterization task was intended to provide a basis for estimating the cost of decommissioning and to determine the general level of contamination and induced activity in ship structures and systems. This survey is documented in NSS Radiological and Non-Radiological Spaces Characterization Survey Report, Reference (j).

The principle findings of the characterization scoping survey include the following:

The CV entries were the first in over thirty years. The observed conditions generally supported the reported conditions of 1976. However, discrepancies were noted such as presence of hydraulic oils, migration of primary system water, significant quantities of trash/debris and superficial surface corrosion of components and lighting fixtures.

Absence of fission products (other than trace quantities of cesium-137), uranium and its daughter isotopes, as well as transuranics (e.g., plutonium), indicates there were no significant fuel failures;

Crud contribution to total curie content is minimal;

No contamination was found in the non-radiological spaces;

Minimal contamination was found in radiological spaces;

Overall dose rates were much lower than calculated;

Sites previously identified as radiologically contaminated were found uncontaminated; and, CV systems, structures and components were exceptionally radiologically clean.

The scoping survey concluded that the Nuclear Steam Supply System (primary system) is in very good condition from a physical and radiological perspective to support decommissioning. Of particular note was the discovery during the assessment that, in addition to the previously-known and earlier-documented water in the reactor vessel lower plenum up to the bottom of the cold leg inlets, primary coolant was present in several other port and starboard primary loop low points. These low points included short piping runs and the steam generator plenums and tubes. There was no water in the pump volutes or pressurizer pipe as these locations were above the natural drained level. The current state of the primary system is that it drained as completely as possible with the loop isolation valves opened wide and back seated. There is no reactor vessel low point drain valve in the system.

The water inventory in the loop piping and steam generator plenums adds several hundred gallons to the volume in the vessel, for an estimated total of approximately 1,470 gallons. The quantity was calculated by measuring the depth of water in the pipes and reactor vessel steam generator plenums (different in each loop) and calculating the water in the plenums, pipes and tube sides of the team generator "U" tube heat exchangers.

2.4.2 REACTOR PRESSURE VESSEL ANALYSIS 2005

As a direct result of overall dose rates being much lower than calculated in 2004, the Maritime Administration concluded the RPV and internals could be classified as Class A waste. To confirm the waste classification, intrusive sampling and analysis was conducted on the reactor pressure vessel and related components in August 2005, Reference (k).

The objective of this project was to refine the 2004 analysis and obtain a more accurate set of radionuclide activation measurements. These measurements are based on the 2005 RPV and internals conditions as observed from actual metal sampling in the reactor internals. All earlier analyses dating back to the late 1950’s were based on theoretical design values which were very conservative.

This 2005 sampling and analysis found that if the reactor pressure vessel and related components were disposed as an intact package, the waste class would be Class A radioactive waste material at qualifying radioactive waste disposal facilities for land disposal purposes per 10 CFR § 61.55.

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2.5 ORGANIZATIONAL UPGRADES AFTER 2005

In 2005, the Maritime Administration re-established the Savannah Technical Staff (STS) as an organizational entity within the Office of Ship Operations. Overall responsibility for the NS-1 license remained with the Senior Technical Advisor (STA). The initial STS organization included the Manager, N.S. Savannah Programs (MSP), supported by the Decommissioning Program Manager and Documentation Manager. The MSP functions as the administrative head of the STS, and executes all program functions. A single incumbent has been assigned to both the STA and MSP position since the latter was established.

In 2006, the technical capabilities of the STS were further improved by filling the following positions with experienced personnel:

Facility Site Manager;

Quality Assurance Manager;

Licensing and Compliance Manager;

Risk Manager;

Marine Surveyor; and, Ship’s General Agent (Keystone Shipping).

In addition, relationships were established with the DOT Volpe Center, Argonne National Laboratory (DOE Facility) and U.S. Merchant Marine Academy at Kings Point (Engineering Department) to provide additional technical support.

The 2006 decommissioning effort anticipated a three-phase approach to DECON, and two major contracts. An Engineering, Management and Oversight Support (EMOS) contractor would develop the decommissioning technical packages during the first phase; provide direct licensee oversight during the second phase (dismantlement), and finally would work directly with the licensee during the license termination phase. A second contractor would be acquired to dismantle the nuclear facilities and package and ship radiological waste during the second DECON phase. The EMOS solicitation was released in 2006, and eventually awarded to Areva Federal Services in early 2007. By that time the scope of the EMOS work was revised based on the decommissioning reassessment, and the contractor now principally performs the planning and engineering required to support the SAFSTOR program.

In 2007, MARAD continued its on-going efforts to improve the technical capabilities of the STS by filling the following positions with nuclear and/or maritime experienced staff:

Nuclear Advisor;

First Engineer;

Electrician; and, Two General Vessel Assistants.

The current organization is shown in Figure 2-1, below.

2.6 PROGRAMMATIC UPGRADES AFTER 2005

In September 2005, the Maritime Administration performed an analysis to identify compliance with current NRC regulations and expectations. The results of the analysis allowed the Maritime Administration to prioritize efforts to bring the NSS licensing activities into compliance. It was initially intended to pursue and complete these compliance activities within the first phase of the DECON effort.

As part of the 2007 decommissioning reassessment, the Agency adopted a strict compliance philosophy, and developed an ongoing license compliance implementation program.

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The regulatory analysis identified maintenance of license basis documents as an area requiring major upgrade. Three significant licensing actions were completed in 2006 to address regulatory gaps identified in the assessment, of which two addressed outdated (or missing) basis documents.

A license amendment request (LAR) was submitted to allow more efficient performance of pre-decommissioning activities (Amendment 13 was issued 1/31/2007);

The Decommissioning Quality Assurance Plan was submitted to the NRC (following a discussion with NRC, Revision 1 to the plan was submitted 2/27/2007);

The PSDAR, Revision 0, was submitted (As previously described in Section 1.0, the report was withdrawn on 1/27/2007).

In a concurrent action, the Agency prepared a Draft Environmental Assessment (EA) analyzing the impacts associated with the full radiological decommissioning of the NSS. The availability of this draft EA was noticed in the Federal Register on September 11, 2006. In the preceding month, the Agency conducted public “town hall” type meetings in the cities of Norfolk, VA; Wilmington, NC; and North Charleston, SC, to support selection of a future decommissioning site.

Additional activities to implement recommendations of the assessment included the following:

Developing and implementing a comprehensive action item tracking system;

Developing the training programs for General Employee Training and Radiation Protection

Training;

Developing a prioritized procedure development program;

Upgrading the Radiation Protection Program; and, Conducting an independent review of the NSS document control system, In 2007, two significant licensing actions were completed:

License amendment request (LAR) 2007-001 was submitted to redefine RCAs, require visitors to be escorted, and resolve conflicts resulting from implementation of the Decommissioning Quality Assurance Plan; (Amendment 14 was issued on April 3, 2008) and, Revision IV of the Updated Final Safety Analysis Report (FSAR) was submitted on May 1, 2007 (first update since Revision III in 1968).

2.7 CURRENT ORGANIZATION

The STS is now the organizational unit within the Agency that is responsible for all NSS program activities. In an Agency-wide reorganization that was implemented in April 2007, the STS was administratively transferred from the Office of Ship Operations to the Office of Ship Disposal Programs.

Both offices report to the Associate Administrator for National Security. The transfer better aligned the STS with the source of its appropriated funding and broader organizational functions.

Administration and execution of the NS-1 license is vested by the Maritime Administrator in a designated official holding the title Senior Technical Advisor (STA). This official may oftentimes be designated at or below the level of Office Director in the MARAD organization. The N.S. Savannah Executive Steering Committee (ESC) was re-established in 2006 to provide a framework for senior Agency officials to provide guidance to, and receive inputs from, the STA. A previous ESC existed from 1971 to about 1976 to oversee the initial NSS defueling and mothballing activities undertaken at that time.

The execution of all program activities including routine radiation surveillance, ship custody decommissioning and historic preservation is performed by the Manager, N.S. Savannah Programs (MSP), with guidance and oversight provided by the STA. The Maritime Administration may assign a single incumbent to both positions. This individual is assisted by a Decommissioning Program Manager, a Documentation Manager and a Facility Site Manager.

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FIGURE 2-1 ORGANIZATION CHART

A significant portion of the decommissioning project work is intended to be performed by contractors.

Maritime Administration personnel, reporting directly to the MSP, will be responsible for assigned contractors and providing the contractor direction, coordination and interfacing communications.

The QA Manager will provide independent verification of the contractors’ work and the contractors’ QA Manuals which will be approved by the NSS Project. Individuals from the Argonne National Laboratory and the Volpe National Transportation Systems Center were contracted to provide additional expertise in Decommissioning, Environmental and Maritime issues. The Safety Review Committee is a Technical Specification-required committee that provides independent oversight of licensed activities.

2.8 CURRENT STATUS OF N.S. SAVANNAH

The ship is in a Mothballed state of protective storage. Many weather openings are sealed. Almost no mechanical systems or equipment are functional. The functional systems include a significant portion of the electrical distribution system, the hull cathodic protection system, the DH system, the intrusion, fire and flooding alarm system and the anchor windlass. The DH system was newly-installed in 1994 and is mechanically independent of any other ship’s system. Likewise, the alarm system was substantially renewed in 1994 and is isolated from any other ship’s system except electrical distribution. Note that modifications associated with the DH and alarm systems (i.e., vent ducting and cabling) obstruct doors, passageways and ladders throughout the ship as is typical in the marine industry for deactivated ships.

Before 2007 the electrical distribution system, the hull cathodic protection system and the anchor windlass were the only functional portions of the ship’s original outfit. Between 1994 and 2007, there was minimal maintenance and testing to the ship’s electrical system. After 2007, electrical and

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December 10, 2008 mechanical systems and components have been surveyed by qualified personnel prior to energizing and operating them. Since moving to Pier 13, Canton Marine Terminal, the aft mooring capstans have been repaired and returned to service (electrically and mechanically).

Equipment and systems independent of the original ship’s outfit have been installed since 2006. The principal new equipment is an electro-mechanical stores davit fitted on the aft portside corner of the Promenade Deck. This 7.15 ton davit has an electrical hoist and mechanical swing. A simple weathertight stores hatch was fitted on the Main Deck with access into the number 7 cargo hold. A new Heating, Ventilation and Air Conditioning (HVAC) system is being adapted to original ductwork serving staterooms and the conference (training) room on B Deck aft of Frame 168 (cargo hold 6). The same system covers a block of spaces on C Deck between Frames 148 and 168 (cargo hold 5); which include the ship’s Technical Library, Baggage Room (used for records storage) and the new Records Vault (combined from 6 staterooms). The system will provide climate-controlled storage for retention records.

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3.0 DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES

The NSS has been maintained in a partially decommissioned, protective storage condition since 1976.

From 2002 to 2006 the Maritime Administration planned to complete decommissioning and license termination of the NSS facility using the DECON method. From 2007 onwards the Agency was forced to reassess the DECON project, and at present has adopted a plan to return the NSS to protective storage by bringing the facility into full compliance with contemporary SAFSTOR requirements and criteria. After a period of SAFSTOR operations, the Maritime Administration will resume DECON with the intention of completing decommissioning and license termination no later than the defined regulatory completion date of December 2031.

The Agency’s primary goal is to decommission the NSS in a safe and cost-effective manner. The overall plan for completing decommissioning of the NSS has been divided into six periods:

o SAFSTOR Preparations;

o SAFSTOR Operations (Retention);

o Preparations for DECON;

o Performance of DECON Activities;

o License Termination; and, o Future Plans for the NSS.

The following provides a discussion of the current decommissioning plan, the significant specific activities and the general sequencing for each of the above periods. The planning required for each decommissioning activity, including the selection of the process to perform the work, will be completed prior to the start of work for that activity.