J03 - SAFSTOR Implementation Plan.pdf

N.S. SAVANNAH SAFSTOR Implementation Plan Department of Transportation Source Selection Sensitive Information

Sayres and Associates Corporation May 8, 2009

COVER PAGE

SOURCE SENSITIVE

INFORMATION

SEE FAR 3.104

This document contains sensitive information related to the conduct of a Federal agency procurement, the disclosure of which is restricted by Section 27 of the Office of Federal Procurement Policy Act (41 U.S.C.

423). The unauthorized disclosure of such information may subject both discloser and recipient of the information to contractual, civil and/or criminal penalties as provided by law.

U.S. Department of Transportation Maritime Administration

Office of Ship Disposal Programs

N.S. SAVANNAH

SAFSTOR IMPLEMENTATION PLAN

STS-135

REVISION 0

May 19, 2009

Prepared by:

Sayres and Associates Corporation

SAVANNAH Technical Staff STS-135, SAFSTOR Implementation Plan, Revision 0 May 15, 2009

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0 This is the original version of the SAFSTOR Implementation Plan.

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TABLE OF CONTENTS

SECTION PAGE

1.0 EXECUTIVE SUMMARY 4

2.0 ESTIMATED COST 5

2.1 SAFSTOR COST ESTIMATE METHODOLOGY: 5

3.0 SAFSTOR IMPLEMENTATION PLAN 6

3.1 WORK TASK IDENTIFICATION 6

3.2 FUNDING RISK 7

TABLE 1 SAFSTOR ROM COST ESTIMATE 8

APPENDIX A EXCERPTS FROM PSDAR REV 1 10

APPENDIX B ROM ASSUMPTIONS 12

APPENDIX C SUMMARY OF ROM COST DRIVERS 14

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1.0 EXECUTIVE SUMMARY

The Maritime Administration of the Department of Transportation (MARAD) SAVANNAH program focuses on: a) developing and maintaining an independent and proficient licensee organization, and b) bringing the SAVANNAH nuclear facility (NSS) into conformance with contemporary NRC SAFSTOR standards.

This project was initially conceived in 2004 to promptly complete decommissioning of the NSS, however, resource shortfalls forced MARAD to defer that project and instead return the NSS to long-term retention (SAFSTOR). SAFSTOR is defined by the NRC as an intermediate decommissioning condition wherein a nuclear power facility is placed into a safe, stable condition suitable for long-term retention until it is subsequently decontaminated and dismantled to levels that permit NRC license termination. The NSS does not meet contemporary NRC SAFSTOR criteria, and requires both nuclear and conventional marine technical activities to bring the ship and nuclear power plant into a condition suitable for extended inactive retention. See STS-116, Safety Upgrade Plan for additional details.

NSS licensee competency and compliance and incremental pre-decommissioning activities designed to bring the facility into conformance with present-day standards for SAFSTOR must be accomplished before the NSS can be returned to the JRRF (or other suitable location) for long-term retention until final decommissioning and license termination by 2031.

By the end of 2009, MARAD expects to have completed development of its administrative programs, processes and procedures. It will, however, take additional time for MARAD to fully mature in the exercise of that administrative program to be fully competent and compliant with NRC standards.

In 2007, AREVA Federal Services LLC (AREVA) was tasked to develop an approach to achieving SAFSTOR compliance. That contract resulted in the development of several key plans for accomplishing SAFSTOR implementation.

STS-104 N.S. SAVANNAH SAFSTOR Plan

STS-109 Historical Site Assessment (HSA) Report

STS-110 Characterization Survey Plan Report

STS-113 Electrical Upgrade Plan

STS-114 HVAC Upgrade Plan

STS-115 Mechanical Upgrade Plan

STS-116 Safety Upgrade Plan

These plans delineate NSS conditions clearly not in SAFSTOR compliance as well as areas requiring further evaluation to determine actions required to be SAFSTOR compliant.

As a consequence of the planning reviews, it is now known that the NSS requires substantial work before it can be considered satisfactory for an additional period of extended retention. A summary of the preparations needed can be found in PSDAR REV 1, section 3.1 and 3.2 (see pages 9-10 of this report) The projected SAFSTOR implementation work effort for the NSS will complement future decommissioning activities in a substantially non-duplicative way. The NSS, in a SAFSTOR condition, can be transitioned to the DECON process at any time.

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2.0 ESTIMATED COST

The SAFSTOR nuclear and conventional work will be performed as a series of discrete technical and industrial activities; estimated to cost $8.0M (2008$ Rough Order of Magnitude estimate). Once funded, the activities will require a minimum of a two year performance period to complete.

Annual husbandry funding of $3.0M will still be required during SAFSTOR implementation to continue activities required maintain and safeguard the NSS, including planning and technical actions necessary to complete the process of ensuring NSS licensee compliance and competency.

Four funding options were considered:

Option 1 - $8 million SAFSTOR full funding, Option 2 - $4 million SAFSTOR funding for each of two years, Option 3 - $2 million SAFSTOR funding for each of four years and Option 4 - No SAFSTOR funding.

Option “1” and “2” will accomplish the work in the most effective manner, reducing by two years, ship husbandry cost of about $3 million annually over Option “3”.

Option “4” could result in Agency, Federal, State or Local jurisdiction environmental violations and NRC violations if NSS is moved to a location where the ship is not continuously maintained and monitored by STS staff and crew. This is not considered to be an acceptable option unless NSS is placed in a layberth location where NSS can be continuously maintained and monitored by STS staff and crew.

MARAD’s intention to prepare NSS for SAFSTOR is documented in the PSDAR Rev 1 submitted by MARAD to the NRC on December 11, 2008. If plans change in a significant manner, the Maritime Administration must inform the U. S. Nuclear Regulatory Commission (NRC) in accordance with 10 CFR 50.82(a)(7).

When the SAFSTOR technical program is completed, the NSS can transition to inactive retention, and annual funding can be reduced to a level commensurate with maintaining the facility and license in that retention status.

SAFSTOR long term retention costs will be approximately $1.6M (2008 $) annually. A drydocking will be required in 2018 at a cost of about $6M (2008 $). These SAFSTOR long term retention costs are not included in the SAFSTOR ROM.

2.1 SAFSTOR COST ESTIMATE METHODOLOGY:

The methodology used to develop the May 2009 SAFSTOR cost estimate for NSS used a combination of SAFSTOR Plans prepared by AREVA, previously developed Decommissioning ROM data and MARAD NSS position papers. Commitments by MARAD in the PSDAR REV 1 are also included in the SAFSTOR Implementation Plan.

The SAFSTOR Implementation Plan ROM provides opportunities to capitalize on activities such as asbestos remediation. The cost to remediate asbestos for retention period may not be cost effective because the asbestos must be removed as an initial step to begin DECON. The decision to remove asbestos versus remediation may result in a significant total program cost savings. Removal of asbestos as part of SAFSTOR preparations will make Characterization of Reactor Compartment and Containment Vessel more efficient and significantly reduces both radiological and industrial safety risks.

This is not a detailed engineering estimate, but a cost estimate prepared for rough order of magnitude estimating purposes prior to development of the detailed engineering estimate to carry out SAFSTOR preparations.

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3.0 SAFSTOR IMPLEMENTATION PLAN

3.1 WORK TASK IDENTIFICATION

All work tasks identified in the SAFSTOR ROM is required to meet Agency, Federal and Nuclear Regulatory (NRC) requirements. SAFTOR tasks will be identified and prioritized to plan and execute work in the most effective and efficient manner recognizing the possibility of delayed or reduced program funding.

Initial review by the MARAD STS indicates that it is likely that the majority of the SAFTOR tasks can be accomplished under the current Technical Specification, including the use of a 10CFR50:59 review and screening process. This approach to some work such as work falling under “dismantlement”, such as removal of the Charge Pumps and associated piping, will require NRC concurrence. If the NRC will not allow some portions of the SAFSTOR work to be done under the existing Technical Specifications and 10CFR50:59 review and screening process, a License Amendment Request (LAR) will be required. The LAR process typically takes about 6 to 12 months. Other SAFSTOR work tasks may continue while the LAR is processed.

Task “100” work includes ship and personnel safety tasks. These include:

Alarm and Security Systems Upgrades Electrical Systems Upgrades Personnel Safety Upgrades Fire Loading Management Hazardous Material Management Removal of environmental contaminates from Salt Water Ballast #4, Center Line Tank Characterization to identify Radiological and Hazardous Materials risk in normally occupied spaces

Task “200” work includes reducing immediate radiological exposure risk: These include:

Characterization to identify Radiological and Hazardous Materials risk in Radiologically Controlled Areas. (Not normally Occupied spaces.)

Reducing Radiologically Controlled Areas (RCA) Reducing radiation dose sources Identifying, Controlling and Reducing radiological risks

Task “300” work includes upgrades to support SAFSTOR long term safety and viability. These include:

Removal of environmentally and radiologically contaminated water from NSS tanks.

Removal of residue Reactor Coolant System (RCS) water Install HVAC system for Reactor Compartment and Containment Vessel

Project management control methods will be determined based on the SAFSTOR program funding and actual task sequencing and durations. There are two primary method options:

Engineering Management Oversight (EMOS) – EMOS contractor will develop SAFSTOR statement of work (SOW) used by MARAD procurement to obtain contractor resources to accomplish the SAFSTOR tasks. EMOS would provide oversight of the contractor selected to perform the contracted SAFSTOR tasks. This option is most suitable for complex amounts of concurrent SAFSTOR preparations work being done in a short time frame (two years or less).

MARAD STS and General Agent managed. This approach is appropriate for longer duration SAFSTOR funding, (in excess of 2 years), and for work primarily of a maritime nature.

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3.2 FUNDING RISK

MARAD has committed to preparing NSS for SAFSTOR. It is imperative that MARAD properly fund the SAFSTOR effort before NSS is moved to a location where the ship is not continuously monitored by STS staff and crew. MARAD’s specific intentions to prepare NSS for SAFSTOR are documented in the PSDAR Rev. 1 submitted by MARAD to the NRC on December 11, 2008. If these intentions are not completed, then MARAD is likely to violate Agency and Federal requirements, as well as NRC requirements. Additionally, if NSS SAFSTOR program plans change in a significant manner, the Maritime Administration must inform the U.S. Nuclear Regulatory Commission (NRC) in accordance with 10 CFR 50.82(a)(7).

Much of the “100” work is currently required by Agency and federal requirements, regardless of whether or not NSS achieves full SAFSTOR compliance in a timely manner.

Radioactively contaminated items removed from NSS under the “200” and “300” tasks may require disposal at a licensed radioactive materials receiver site. Costs for these services are historically escalating at 2 to 3 times the rate of general inflation.

The SAFSTOR technical program scope and sequencing will require prudent risk assessment and risk mitigation if full SAFSTOR funding is not provided.

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TABLE 1 SAFSTOR ROM COST ESTIMATE

N.S. SAVANNAH SAFSTOR Implementation Program

LEVEL TASK

NON RCA

SPACES

RCA

SPACES

TOTAL

Personnel Safety

100 SAFSTOR Environmental Monitoring Program 10,000 20,000 30,000

100 Security Camera System 5,000 5,000

300 Security Camera System 15,000 15,000

Housekeeping/Transient Fire Loading material mitigation 60,000 60,000

Housekeeping/Transient Fire Loading material mitigation 40,000 40,000

Personnel Safety Barrier Upgrades; normally occupied spaces 20,000 20,000

200 Personnel Safety Barrier Upgrades, RCA spaces 30,000 30,000

100 Lighting Upgrades 50,000 50,000

200 Lighting Upgrades 75,000 75,000

100 Flooding Detection Upgrades 10,000 10,000

300 Flooding Detection Upgrades 20,000 20,000

100 Fire & Smoke Detection System Upgrades 75,000 75,000

200 Fire & Smoke Detection System Upgrades 20,000 20,000

Asbestos (ACM) Abatement in normally occupied spaces 100,000 100,000

Asbestos (ACM) Abatement in not normally accessible spaces 100,000 100,000

Asbestos (ACM) Abatement in not normally accessible spaces 560,000 560,000

100 Lead Paint Abatement in normally occupied spaces 50,000 50,000

Lead Paint Abatement in not normally accessible spaces 25,000 25,000

Lead Paint Abatement in not normally accessible spaces 80,000 80,000

100 Lead Shielding Materials Abatement 20,000 20,000

200 PCB Abatement in normally occupied spaces 20,000 20,000

300 PCB Abatement in not normally accessible spaces 50,000 50,000

300 PCB Abatement in not normally accessible spaces 125,000 125,000

200 Remove hydraulic oil from Stabilizer rooms. 20,000 20,000

Remove and Process contents of Salt Water Ballast Tank #4 Center Line 80,000 80,000

Subtotal 700,000 920,000 1,620,000

Electrical Safety

100 Shore Power Panel & Hookup 150,000 150,000

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100 Electrical Distribution Upgrades 300,000 300,000

200 Electrical Distribution Upgrades 160,000 160,000

Subtotal 450,000 160,000 610,000

Radiological Safety

100 SAFSTOR Radiological Monitoring Program 10,000 20,000 30,000

100 Characterization 75,000 75,000

Characterization (includes DCGLs) 250,000 250,000

300 RC/CV HVAC Upgrades 200,000 200,000

200 Collapse HP Lab RCA Boundary space 30,000 30,000

200 Collapse Hot Chem Lab RCA Boundary space 20,000 20,000

Collapse Cargo Hold #4 RCA Boundary spaces;

Shield/ Remove dose sources in Cold Chem Lab spaces 50,000 50,000

200 Remove 14' Flat passageway Charge Pump line 20,000 20,000

300 Remove Port & Starboard Charge Pumps 200,000 200,000

Remove and Process contents of Fresh Water Shield Tank 90,000 90,000

Remove and Process contents of Reactor Compartment Sump 10,000 10,000

Remove & process residual Reactor Coolant System water 400,000 400,000

200 Radiological Waste Packaging & Disposal 650,000 650,000

Rad Protection Technician Support, Tools and Materials 250,000 200,000

Rad Protection Technician Support, Tools and Materials 1,200,000 1,250,000

Subtotal 75,000 3,390,000 3,465,000

Other

100 SAFSTOR Plans & Engineering 100,000 200,000 300,000

100 Engineering Support 400,000 375,000 775,000 100 Project Management and Administration 300,000 400,000 700,000

100 Facilities & Miscellaneous Support 375,000 375,000

Subtotal 1,350,000 925,000 2,275,000

TOTAL COST 2,615,000 5,300,000 7,915,000

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APPENDIX A EXCERPTS FROM PSDAR REV 1

3.3 SAFSTOR PREPARATIONS

The circumstances which prompted the withdrawal of PSDAR Revision 0 are briefly described in Section

1.0. Section 6.1 provides a more detailed explanation of the appropriations shortfalls and budgetary instability that have hampered the NSS decommissioning effort. With the withdrawal of the PSDAR Revision 0, the Agency notified the NRC that the NSS would be remain in protective storage for at least a short-term period while longer-term options were being evaluated. Because the ship had already been removed from its reserve fleet site in preparation for drydocking, the protective storage condition was maintained at several Norfolk, VA berthing locations while the drydocking availability was solicited, negotiated and performed.

An early recognition by the Maritime Administration was that any long-term activities must be conducted in manner fully consistent with contemporary industry standards and practices, and in full compliance with all terms and conditions of the NS-I license and regulations (see Section 2.6). Consequently, if the selected long-term option was deferred DECON, the necessary protective storage period would need to be conducted in accordance with current SAFSTOR criteria; not the circa 1974 Mothballing condition. In order to accomplish this objective it was necessary to perform a detailed comparison of the two sets of criteria, and identify the substantive differences between them. The resulting analysis is included in Appendix A - Comparison of Mothballing and SAFSTOR Requirements.

In 2007 the Maritime Administration revised its plans to pursue near term DECON in favor of a return to protective storage. The rationale for this decision is described in more detail in Section 6.1. The decision to return the NSS to protective storage after bringing it into contemporary SAFSTOR compliance does not preclude the Agency from making a subsequent decision to pursue a DECON approach, principally because the SAFSTOR activities to be accomplished are pre-requisites for, or non-duplicative of DECON.

In 2007, the Agency tasked its EMOS contractor to prepare a SAFSTOR Plan, Reference (1), that includes the following work activities.

Performing a detailed Historical Site Assessment. This assessment will follow current regulatory guidance in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). It will consider all available data on radiological and hazardous contaminants. It will include as much information as possible obtained from former crewmembers during the crew reunion held in May 2008.

Developing Derived Concentration Guideline Levels (DCGLs) for residual radioactivity. These DCGLs will be developed using various computer codes to support the NRC standards for unrestricted release.

Performing a characterization survey of the ship. A characterization survey is a type of survey that includes facility or site sampling, monitoring, and analysis activities to determine the type and extent of residual radioactivity on or in structures, residues, and environmental media. The survey should be sufficiently detailed to provide data for planning decommissioning actions, including necessary technical information to develop, analyze, and select appropriate cleanup (i.e., remediation) techniques, projected schedules, costs, waste volumes, and health and safety considerations during remediation. The characterization survey program will follow MARSSIM guidance.

Hazardous and toxic contaminants, such as asbestos, will be addressed as part of the characterization survey.

Making safety improvements. These activities will involve improving access to and egress from several areas, verification of electrical system safety, removal of dangerous substances (such as

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Improving ventilation in radiologically controlled areas. This will include the containment vessel.

Further draining of the primary coolant system. As much as practicable of the approximately 1500 gallons of water remaining in the system will be drained and processed as low-level radioactive waste.

Removing a limited amount of contaminated equipment. Equipment under consideration to be removed is the Buffer Seal System outside of the reactor compartment including three Buffer Seal Charge Pumps, two booster pumps and associated valves and piping.

Reducing radiologically controlled areas. Selected areas - such as the Health Physics Lab on A Deck and the Hot Chemistry Lab on D Deck - will be decontaminated and released from radiological controls.

Adding a new shore power switchboard. Moving power panel lighting load centers from the Main and Emergency switchboards to the new switchboard to allow deenergizing the Main and Emergency switchboards.

3.3 SAFSTOR OPERATIONS (RETENTION)

SAFSTOR Operations (Retention) is the extended time period of safe storage of the facility prior to DECON.

This period may continue until 2023-2025 which will allow sufficient time to develop and implement all actions necessary to terminate the license by December 2031. Unlike the previous Mothballing period, the SAFSTOR retention period will be characterized by an active nuclear operations culture, albeit at activity levels commensurate to the facility location and condition.

Adequate staffing will be provided to ensure the Maritime Administration is compliant in (with?) all aspects of the license. Trained personnel will be available to maintain required systems, provide security and perform radiological surveillance to ensure that radioactivity is not spread from the ship to the environment.

Equipment corrective and preventive maintenance, inspection activities, and routine operations will be performed. Systems/structures needed to support security, fire protection, and environmental and radiological monitoring will be maintained in a safe condition and in accordance with Technical Specifications and regulatory requirements. Abandoned systems will be monitored and maintained, as needed, to control radioactive material. Systems and equipment no longer needed may be removed from the site. In addition, the structural integrity of the ship will be monitored and maintained.

Areas that do not require routine access will be locked and secured. Areas containing radioactive materials or other contamination will be secured to prevent accidental intrusion. Shielding will be added, where necessary, to maintain radiation exposure to plant personnel as low as reasonably achievable (ALARA).

Routine periodic radiological inspections of contaminated areas will be conducted.

Decontamination activities will be generally limited to those necessary to maintain exposures ALARA.

Radiological and environmental surveillance programs will be carried out during the SAFSTOR Operations (Retention) period to ensure that potential releases of radioactive material to the environment are detected and controlled. The surveillance programs will be conducted in accordance with the facility Operating License, Technical Specifications, Final Safety Analysis Report and Offsite Dose Calculation Manual.

Throughout this and all subsequent phases of the work, the NSS will remain in the active custody and husbandry of the Maritime Administration at a safe and secure berthing site.

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APPENDIX B ROM ASSUMPTIONS

Assumptions provide the basis for the SAFSTOR Implementation estimate. Assumptions are based on or include known information such as SAFSTOR Plans, Decommissioning ROM, historical data and current industry practices.

The following assumptions were used to develop the NSS SAFSTOR ROM cost estimate:

1. ROM Scope

The ROM scope will include costs for known activities required to place the NSS in a state of protective storage as defined in the NRC SAFSTOR requirements and the PSDAR REV 1 submitted by MARAD to the NRC on December 11, 2008. Protective storage must also meet Agency requirements for a ship in long term storage.

2. SAFSTOR Management Team

The two (2) phases of the project are:

a. Phase I – SAFSTOR Preparations MARAD will have the primary responsibility for public health and safety, budget, security, quality assurance and general oversight of the work, including review of programs, procedures and techniques to be used during Phase I and II.

MARAD may elect to utilize a Health Physics Contractor to perform the radiological services required for Phase I.

MARAD may elect to utilize an Engineering, Management and Oversight (EMOS) contractor to provide Project Technical Support and Planning and Management Services during Phase I.

MARAD will conduct a competitive bidding process to select a SAFSTOR Technical Contractor to manage the field work associated with SAFSTOR implementation industrial activity. The SAFSTOR Contractor will have primary responsibility for selecting and managing crew performance, planning and scheduling craft workers, overseeing occupational health and safety, waste management and obtaining necessary tools and equipment during Phase I.

Extended or reduced funding will require an evaluation of the cost effectiveness of having both EMOS and SAFSTOR Contractor organizations. Another viable option is to implement a combination of management by MARAD (for radiological work) and General Agent (for ship husbandry work) to complete the SAFSTOR program implementation.

b. Phase II – SAFSTOR Retention

For the necessary period of retention, the agency plans to retain a competent licensee staff to actively manage the NRC license and oversee the SAFSTOR condition of the nuclear facilities onboard the ship.

MARAD may elect to utilize a Health Physics Contractor to perform the radiological services required for Phase I.

3. SAFSTOR Implementation Schedule

The SAFSTOR implementation schedule is currently estimated to be between 24 and 48 months, depending on funding allocations:

4. SAFSTOR Preparations Site Location

The current SAFSTOR preparation site is Pier 13, Canton Marine Terminal, Baltimore, Maryland.

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5. Staff, Layberth and Hotel Services

Costs for STS Staff, Layberthing, General Agent and ships electrical services are not included in the SAFSTOR implementation ROM.

6. Ship Towing and Drydocking

Towing services to move NSS to a new SAFSTOR preparations location or to move NSS to a SAFSTOR retention location are not included in the ROM.

A Drydocking scheduled during the projected SAFSTOR retention period is not covered in the ROM.

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APPENDIX C SUMMARY OF ROM COST DRIVERS

The ROM is a summation of the line item costs associated with SAFSTOR Preparations. The major categories of costs, generally defined below, were used to develop the SAFSTOR (ROM) Estimate.

1. SAFSTOR Environmental Monitoring

During the retention period, monitoring is required to verify that hazards are being controlled. This includes posting areas and periodic sampling.

2. Security Camera system

Camera systems are part of the enhanced security system. This is especially important when NSS is not manned. Security cameras are now in place. Additional cameras and a method for remote viewing of the cameras will be required.

3. Housekeeping

There are many left over materials stored on NSS. The transient combustible materials are a fire hazard.

Many of the spaces requiring cleaning are in the cargo holds.

4. Safety Barriers

Openings in decks, elevator shafts and missing handrails present a safety hazard for crew and personnel required to be in certain spaces.

5. Access and Egress Lighting

Lighting fixtures in passageways and confined spaces require repair including possibly running new electrical power supplies.

6. Flooding Detection Upgrades

Flooding detection sensors are deteriorated and need to be replaced. Installing detection in the Reactor Compartment is a consideration.

7. Fire and Smoke Detection System Upgrades

Fire and Smoke Detection system is needed. Some parts of the ship have been fitted with a new system.

There are currently no detectors in radiological areas. Installing detection in the Reactor Compartment is a consideration.

8. Environmentally Hazardous Waste Disposal

The 2005 Characterization Survey identifies several hazardous materials to be removed during the decommissioning process. Detailed decommissioning planning must address specific aspects of compliance with laws such as Toxic Substances Control Act (TSCA 1976) and other Environmental Protection Agency regulations.

There will be environmental hazardous waste to dispose of as part of SAFSTOR implementation.

a. Asbestos Materials

There are numerous areas of the ship that contain asbestos. Work will include asbestos containing materials (ACM) abatement. An evaluation will be made as to the cost effectiveness of removing insulation, versus abatement by repairing and posting and environmentally monitoring all ACM areas.

All insulation in radiation controlled areas will ultimately have to be removed. Removal of this insulation during SAFSTOR preparations will result in cost savings over the life of the program.

Removal of insulation following SAFSTOR retention will result in higher costs as well as the possibility of increased regulations.

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b. PCB Materials

There are no PCB containing Transformers. The 2005 Characterization Survey did not attempt to confirm the existence of PCB in electrical insulation, adhesives or paint. This is an area requiring specific sampling prior to equipment and material removal for disposal.

c. Lead Paint

The 2005 Characterization Survey found that all lead paint samples in the CV contained lead in a percentage requiring special controls. Disposal of lead paint will be done in accordance with controls specified by the results of Toxicity Characteristic Leaching Procedure (TCLP).

d. Bulk Shielding Lead

Bulk lead is typically not disposed of by using shallow surface burial disposal methods. Bulk lead and contaminated bulk lead may be disposed of by licensed metal melt waste processing facilities. Disposal of lead will be done in accordance with controls specified by the results of Toxicity Characteristic Leaching Procedure (TCLP).

e. Mercury

There may be some minor amounts of mercury containing equipment, e.g., fluorescent lights and instrumentation.

f. Hydraulic Oil

The Stabilizer rooms and Containment Vessel have areas where hydraulic oil has collected and is open to the biosphere.

g. Residual fuels, oils and solvents

There will be some minor amounts of residual fuels, oils and solvents. All materials must be removed for SAFSTOR implementation.

9. Salt Water Ballast Tank #4 Center Lime

During the topside layberth, it was determined that Salt Water Ballast Tank #4, Center Line (~38,300 gals) contained a material that is not radioactively contaminated, but is chemically contaminated.

Removal of this water requires special processing.

10. Electrical Switchgear and Distribution Systems

The electrical breakers and distribution panels have not been maintained. Distribution wiring has deteriorated. A new shore power panel and breakers is being installed. It is anticipated that new distribution wring will be required to safely power ships loads, including systems upgrades to support SAFSTOR long term retention.

11. SAFSTOR Radiological Monitoring

During the retention period, monitoring is required to verify that hazards are being controlled. This includes posting areas and periodic sampling.

12. Site Surveys

Costs associated with Characterization surveys to identify and document (1) the radiological contamination on the site before any cleanup activities associated with SAFSTOR or decommissioning take place, (2) a detailed historical site assessment description of site operations, spills, and accidents, (3) a map of contamination levels and contamination locations, and (4) a description of the survey instruments and supporting quality assurance practices used in the site-characterization program.

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13. RC/CV HVAC Upgrades

The original HVAC system for NSS is deteriorated and not operable. Before radiological work associated with SAFSTOR preparations begins, the ventilation system in use for the containment vessel and other radiologically controlled areas will be evaluated and modified as necessary in support of the radiological work and the SAFSTOR period that will follow. Modifications are expected to include installation of high-efficiency particulate air filters at appropriate points. Modifications will be evaluated for radiation effluent monitoring and will include appropriate monitoring as necessary. During long term retention, temperature and humidity controls are required for the Reactor Compartment and Containment Vessel.

14. Collapse Radiation Controlled Area Boundaries

MARAD plans to decontaminate certain radiologically controlled areas and release them from radiological controls. This effort will effectively reduce the perceived threat posed by the ship to the public and the environment. It is anticipated that these areas will include the health physics laboratory on A Deck, the hot chemistry laboratory on D Deck, and Cargo Hold #4 D Deck. Reducing spaces that are currently radiologically controlled areas will reduce radiological risk by removing sources of radioactivity contamination and dose sources.

15. Removal of Charge Pumps and associated piping

Removing selected radioactively contaminated equipment, including the three buffer seal charge pumps, booster pumps and associated piping.

16. Remove and process residue Reactor Coolant Water

Although the primary coolant system was drained in 1976, measurements made in 2005 indicate that approximately 1450 gallons of contaminated water remains in the system, with about one-half of the amount within the reactor vessel (WPI 2006b). Evaluation showed that it is desirable and practical to remove most of this remaining water during preparations for SAFSTOR

17. LLRW Management

LLRW disposal is an issue of concern throughout the nuclear industry. NSS does not currently have a contract for a LLRW disposal site. Licensees are allowed to store LLRW for a period of time. An option to be considered, due to the very low level and quantity of LLRW generated during SAFSTOR, is to store the LLRW on NSS, pending availability of a LLRW disposal site.

The current NRC regulations for LLRW storage are defined in:

Radioactive Waste: Production, Storage, Disposal (NUREG/BR-0216, Rev. 2)

EXCERPT: Storage of low-level radioactive waste requires an NRC or Agreement State license.

NRC or Agreement State regulations require the waste to be stored in a manner that keeps radiation doses to workers and members of the public below NRC-specified levels. Licensees must further reduce these doses to levels that are as low as reasonably achievable. Actual doses, in most cases, are a small fraction of the NRC limits.

Low-level radioactive waste is packaged in containers appropriate to its level of hazard. Some low-level radioactive wastes require shielding with lead, concrete or other materials to protect workers and members of the public.

Workers are trained to maintain a safe distance from the more highly radioactive materials, to limit the amount of time they spend near the materials, and to monitor the waste to detect any releases.

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Nuclear power plants may store waste in special buildings that provide an extra degree of shielding.

Safe distances must be maintained between the buildings containing radioactive material and the fence restricting public access to licensee property.

Radioactive waste storage areas are posted to identify the radioactive waste so that workers and the public will not inadvertently enter the area.

Low-level waste may be stored to allow short-lived radionuclides to decay to innocuous levels and to provide safe-keeping when access to disposal sites is not available. The NRC believes storage can be safe over the short term as an interim measure, but favors disposal rather than storage over the long term.

a. Potential Waste Disposal Locations

There are limited sites available for direct burial disposal of radioactive wastes. MARAD does not currently have a disposal site selected.

a. EnergySolutions, Clive, UT

b. Nevada Test Site, NV

c. Barnwell, NC (No longer an option for NSS)

The Atlantic Interstate Low-Level Radioactive Waste Management Compact (formerly the Northeast Compact) was approved by Congress in January 1986. In 2000, South Carolina joined Connecticut and New Jersey as the third member state.

The Compact was formed in response to the Federal Low-Level Radioactive Waste Policy Act, 1980, which invited states to form interstate compacts for the disposal of radioactive waste. The Atlantic Compact regional disposal facility in Barnwell County, South Carolina, will be limited to waste generated within the three-state region beginning July 2008.

b. Potential Waste Processor Disposal Locations

There are several options available for disposing of LLRW by using a waste processor. The waste processor will sort, decon and other wise treat LLRW to reduce the amount of material requiring direct burial disposal. This option may be useful in disposing of reactor coolant residue water in a more cost effective manner that is currently required to be used by Technical Specifications.

c. Component LLRW Disposal

Large component disposal will be limited to the three (3) Buffer Seal (Charge Pumps) to be removed and disposed of as radioactive waste. Pump disassembly and extensive rigging will be required to remove components from the two engine room accessible pump spaces (2-pumps in one compartment and 1-pump in another).

d. LLRW Transportation Containers

All radioactive waste from the decommission process must be packaged in accordance with 49 CFR 172 and 173, as well as 10 CFR 61. Specific shipping requirements will be developed as part of the detailed SAFSTOR implementation planning process.

e. LLRW Removal Ship Preparation

Includes costs for worker access to Containment Vessel (CV) and Cargo Hold #4 Waste Processing areas. Other accesses will be considered on a case by case basis in accordance with good marine engineering practices.

f. Liquid LLRW Waste http://www.atlanticcompact.org/

May 15, 2009

Revision 0 18

Radioactive waste water is typically cleaned for free release by on site processing or by shipment by tanker truck to a liquid waste processing facility. Assumptions include:

The 2005 Characterization Survey estimated the existence of about 1500 gallons of reactor system water (RPV, lower sections of both Steam Generator U-Tube, U-Shell Heat exchangers and in miscellaneous Reactor Cooling System primary cooling system piping).

The Fresh Water Shield Tank (~43,200 gals) has evidence of Tritium contamination.

The Reactor Compartment Sump (~200 gals) has evidence of PCB and radioactive contaminates.

Current Technical Specifications define restrictions on liquid waste disposal:

2.1 Radioactive Liquid Waste Release

Applicability Applies only to radioactive liquid waste disposal. No radioactive liquids will be produced as a result of any foreseen operations aboard the ship or from the ship's operation.

Incidental amounts of liquid may be generated in the unlikely event decontamination is found necessary in Radiological Controlled Areas. Objective To assure that liquid radioactive waste releases do not present an undue hazard to the general public or the environment.

Specification Radioactive liquid waste releases shall be as low as reasonably achievable and shall not exceed ten-percent (10%) of limits specified in U.S. Nuclear Regulatory Commission (NRC) (10 CFR 20) or other applicable Federal regulations. Radioactive liquid waste shall be solidified in approved media and may be transferred to a properly licensed burial facility. All solidified liquid waste shall be transferred in accordance with applicable NRC (10 CFR 71) and U.S. Department of Transportation regulations, and the burial facility's license and acceptance criteria.

NRC concurrence will be required to process waste water through use of on-site deminerlizer for waste water clean-up or by shipping waste water by tank truck to a liquid waste processing facility.

18. Project Management and Administration

The SAFSTOR Implementation Plan will require use of contractors to accomplish the work in a timely manner.

Engineering, Management and Oversight (EMOS) Contractor

The Engineering, Management and Oversight (EMOS) Contractor will act as the representative for the various licensee/owner activities during the SAFSTOR implementation. MARAD will continue to have the licensee owner primary responsibility for public health and safety, budget, security, quality assurance and general oversight of the work, including review of programs, procedures and techniques to be used during the decommissioning. ROM includes costs for EMOS engineering and oversight of SAFSTOR preparations Contractor.

SAFSTOR Contractors

Includes the costs associated with Contractor management of the direct day to day removal, packaging and shipping of the equipment and components removed during SAFSTOR implementation such as:

Safety Upgrades Electrical Upgrades Removal of Charge Pumps and associated piping Asbestos and hazardous materials abatement/disposal Decontamination of facility surfaces, equipment, components and piping systems as required Package, ship and properly dispose/store of LLRW materials

May 15, 2009

Revision 0 19

19. Facilities and Miscellaneous Support

Includes costs that do not fit under another cost category. “Other” includes costs such as meeting support, travel, telephone, internet, personal communications, postal services, copying services, personal protection equipment, etc.