Industry_Day__SSSB_Dismantlement_and_Disposal_Presentation__vFinal.pdf

Ray Duff, PAPM

CVN Inactivation & Disposal

PEO Carriers

202-781-2129

Surface Ship Support Barge (SSSB)

Dismantlement and Disposal

November 6, 2018

Forrest Tucker

Contracting Officer

Branch Head, Sub, CVN, and LCS Repair Support

202-781-3183

Agenda

Introduction and Welcome Remarks

– Forrest Tucker (NAVSEA 02)

– Ray Duff (PMS 312)

Announcement of Ground Rules

– Forrest Tucker (NAVSEA 02)

Requirements of “Draft” SOW

– Ray Duff (PMS 312)

– Stephen Picard (NAVSEA 08)

Notional Regulation Construct

– Stephen Picard (NAVSEA 08)

– Theodore Smith/Bruce Watson (Nuclear Regulatory Commission)

Potential Contract and Solicitation Process

– Forrest Tucker (NAVSEA 02)

Closing Remarks

– Forrest Tucker (NAVSEA 02)

NAVSEA 02:

Contracts and Acquisition Directorate

NAVSEA 08:

Naval Nuclear Propulsion Directorate

PMS 312:

Program Executive Office Aircraft Carriers

Admin Announcements

All attendees must sign in

Briefing is unclassified

Turn cell phones OFF

Ground Rules

The objective for today’s industry day is to have an open discussion for the

“Surface Ship Support Barge (SSSB) Dismantlement and Disposal” competition, specifically clarifying particular aspects that received input from the RFI

Dialogue is encouraged in both the plenary and one-on-one sessions. Note, however, that none of today’s dialogue is binding on any party

All technical and contract requirements within the presentation should be considered notional and pre-decisional in nature

NAVSEA will lead this presentation. However, we are very serious about stakeholder input with an eye to better refining the requirement and subsequent solicitation

If there are any differences between this brief and the solicitation, the final solicitation will govern

Submit all questions in writing to the contracting officer at forrest.tucker@navy.mil and the contract specialist at stephanie.little@navy.mil by 20 November 2018 mailto:forrest.tucker@navy.mil mailto:stephanie.little@navy.mil

Government will provide the SSSB to the contractor for local movement only while floating. Transport outside the inland waters of the Hampton Roads area shall be by heavy lift ship or barge

Disposition large volume (~160,000 gal) of radioactive liquid waste (RLW) currently in former spent fuel water pool and support systems. RLW contains activated corrosion products (e.g., predominantly Cobalt-60 and low concentrations of Tritium) but no fuel material. Install a cover over drained water pool

Dismantle the onboard equipment, process scrap metals for recycling and dispose of all hazardous materials and solid waste:

– Hull and all remaining equipment/systems

– Disposal of radiological components/systems/spaces

– Sale of scrap metals permitted if desired and as permitted by NRC

All work must be accomplished in accordance with federal, state, and local environmental, occupational safety & health laws and/or regulations

Contractor shall provide all the personnel, equipment, tools, vehicles, materials, facilities, supervision, security services and other items as required by the RFP

The contractor may use any part of the SSSB during dismantlement. However, the SSSB will be provided “as is”, and the contractor will need to make any assessment of the usefulness and safety of any equipment used

Statement of Work

Initial Preparation for Shipment

RFI stated “Removal and disposition of contaminated water is expected to be performed at the current site of the SSSB, Government Contractor facility/Newport News Shipbuilding, prior to transporting the SSSB to the dismantlement site.”

– The draft Statement of work had similar language

– NAVSEA’s intent was that the water removal and cover installation be done before the SSSB leaves the Hampton Roads area

– Performance of these activities may occur outside of the Newport News Shipbuilding facility

– If done at a location other than the Newport News Shipbuilding facility, oversight in accordance with the Notional Framework will be required, and the water removal and cover installation will be required to be included in the Decommissioning Work

Plan reviewed with the NRC

– Disposition of the contaminated water is via NRC authorized methods as selected by the Contractor (disposal as-is, volume reduction, filtration / resin exchange decontamination, decay in storage, etc.)

– This will be clarified in the RFP Statement of Work

Loading onto Barge or Heavy Lift Ship

Transfer of possession of the SSSB will occur in the James River just outside of the Newport News Shipbuilding facility

NAVSEA intends to require that loading onto a heavy lift ship or barge take place somewhere in the Hampton Roads area prior to any long distance or ocean transit

– Technical concern is the RLW in the spent fuel water pool during an open ocean transit to the dismantlement site

– Transport outside of the Hampton Roads area without draining the SSSB spent fuel water pool and installing a cover will not be permitted

NAVSEA does not intend to specify whether an in-water or drydock loading is performed in the Statement of Work

The SSSB has been floated locally for movements with the spent fuel water pool full

The contractor will be required to develop the plan for loading and moving the SSSB

Radioactive Waste Disposal

Disposal of any radioactive waste at an NRC or Agreement State-licensed and regulated commercial disposal facility is possible

NAVSEA does not intend to authorize the use of Federal disposal sites

Contractor is responsible for determining how and where the radioactive waste would be disposed of and making appropriate arrangements for the disposal consistent with applicable compacts and requirements

Regulated and Hazardous Material Waste Removal and Disposal

Contractor is sole generator of non-radiological hazardous waste; Government will not be a co-generator on any permits

Contractor shall provide the Government with copies of hazardous/non-hazardous material/waste manifests, bills of lading, and other waste shipping documents in final report

Upon completion, Contractor will certify all hazardous material removal complied with Federal, State, and local laws

Contractor shall be responsible for:

– Obtaining all necessary licenses and permits; provide copies to Government upon request

– Accomplishing all notification and manifesting requirements

– Complying with any applicable Federal, State, and local laws and regulations

– Taking any necessary corrective actions resulting from work performed in violation of applicable Federal, State, and local laws and regulations

– Providing immediate notification and results of any regulatory agency inspection or visit and any citations or cautionary notices received

Only regulation of radiological dismantlement will be in accordance with the

Notional Framework. All other regulated activities will be governed by existing

Federal, State, or local laws and regulations

Radiological and Hazardous Material Characterization

NAVSEA is obtaining representative radiological characterization samples within the spent fuel water pool, including:

– Analysis of a small quantity of wipes from the side walls

– Direct underwater radiation level measurements at the pool bottom where contamination levels are expected to be the highest

– This information would be made available during the solicitation process

The SSSB was converted from a WWII-constructed ship in the 1960s. As such, it is likely to have typical hazardous materials of ships of that era – asbestos, PCBs in paint, cable insulation and other materials, and lead containing paints

– For non-nuclear aircraft carrier disposal and recycling contracts, the Navy has been able to obtain competitive fixed price proposals without complete characterization of all hazardous materials present on the ship

– The Contractors have performed more complete characterization following contract award. There is sufficient understanding of the potential hazardous materials in old ships to allow for realistic bid preparation

– The SSSB would be made available for ship checks

The additional representative radiological data, the ship check results, and the overall experience base developed within the ship recycling industry for ships of this vintage, should be adequate for developing a fixed price proposal for SSSB dismantlement and disposal

Dismantling MUST be accomplished in the United States

The vessel and site MUST be available at all times for Government oversight

Information Security Requirements

The SSSB in its current physical condition has no classified material onboard, and no Unclassified Naval Nuclear Propulsion Information (U-NNPI)

No facility clearance or personnel security clearances will be required for actual dismantlement of the SSSB

Much of the technical documentation for the SSSB, including the Technical

Manual for the SSSB and many drawings, are controlled at the U-NNPI level, largely because they contain descriptions of what work was performed on the barge

Availability of drawings and the SSSB Technical Manual becomes effective upon issuance of the RFP. U-NNPI information on the SSSB will be provided to potential bidders subject to the requirements of OPNAVINST N9210.3, Safeguarding of Naval Nuclear Propulsion Information

RADIOLOGICAL

DISMANTLEMENT - NOTIONAL

FRAMEWORK

BACKGROUND AND

OBJECTIVES

Why Not Direct Naval Reactors Regulation?

The recent history of commercial nuclear dismantlement demonstrates that NRC regulation is a well understood rule set, and companies are willing to undertake technically complex and high-value projects on a fixed price basis

NRC regulatory objectives for decommissioning activities support Naval

Nuclear Propulsion Program objectives of protection of the public and environment during dismantlement and disposal of the SSSB

As a matter of National Security, the Naval Nuclear Propulsion Program maintains a very heavy workload supporting nuclear-powered warships in the active fleet

• Verify all radiological safety programs are adequate.

• Verify there are no unevaluated safety hazards or environmental conditions

• Ensure radiological material is safely managed, stored, transported, and disposed

• Ensure decommissioning methods do not preclude unrestricted release

• Examine trends in licensee safety performance

Objectives of the NRC Decommissioning Program

NRC’s role for SSSB No direct regulatory role over NAVSEA radiological decommissioning

NAVSEA contract to direct D&D to follow NRC regulations

NRC provides recommended actions to NAVSEA

Review planning documents, procedures, and work plans

Participate in teleconferences and meetings supporting work planning and implementation

NRC provides Technical Evaluation Reports and draft NEPA documentation to

NAVSEA

Conduct onsite inspections and radiological surveys

Review final radiological survey documents

NRC evaluation of suitability for unrestricted release in final closure letter to

NAVSEA

○ Review final inspections, confirmatory surveys and technical reviews

Decommissioning Reviews Decommissioning Work Plans and procedures

Planned preparatory work

Worker Health and Safety Plans

Radiation Protection Program Plans, including

ALARA

Radioactive Waste Management Plans

Quality Assurance Programs

Site Security Plans

Survey Procedures

Transfer of SSSB to contractor Review of Dose Modeling and DCGLs, including use of screening values

Final Status Survey Plan

Final Status Survey Reports

Developing Clean up Criteria

NUREG 1757, Vol 2, Consolidated Decommissioning Guidance Agency Wide Documents Access and Management System [ADAMS]

Accession Number ML063000252

1) Complex Cleanups Develop Source Term Model

○ Site Characterization

Utilize computer codes to develop Derived Concentration Guideline Levels (DCGLs) for cleanup

○ RESRAD, RESRAD-Build, RESRAD-Probabilistic, D&D

2) Simplified Criteria Validate assumptions of Screening Criteria

3) “No-Detect” methodologies (FC 83-23, ADAMS ML003745523; IE Notice 81-07)

• Description of site conditions, Radiological, HAZMAT, confined spaces

• Description of planned decommissioning activities (e.g., D&D Methods & Techniques, Rad Waste

Management Plans)

• Description of methods for protecting workers and the environment from radiological hazards

• Description of the planned final radiation survey

• Change Control Criteria

Decommissioning Work Plan Contents (From NUREG 1757, Vol 1, ADAMS ML063000243)

Radiological Survey Reporting

Contractor provides technical report documenting acceptable final radiological condition

May be divided into a Survey Plan (pre-survey) and Final Report (Post-Survey)

Contents:

Description of instrumentation selection, calibration, and explanation of appropriate detection capabilities

Development of statistical methods utilized for survey design

○ MARSSIM (NUREG-1575), MARSAME, surrogates

Computer modeling simulation runs, including justification of parameters

Validation of assumptions for screening criteria

ALARA justification

All Survey Data

NRC Decommissioning Inspection Program

Oversight and monitoring conducted over the entire period of decommissioning process

Oversight program is described in Inspection Manual Chapter (IMC) 2561 & 2690

• Through observation, objectively verify safe conduct of decommissioning activities and oversight

• Verify adequacy of controls

• Ensure safety problems and violations are promptly identified and corrected and effective actions are taken to prevent recurrence

• Examine trends in safety performance

Objectives of the NRC Inspection Program

• Routine inspection schedule

– Planned about a year in advance

– Coordinated with the NMSS program office

– Inspection planning and execution

– Inspection Plans

– Inspection Procedures

– Exit Meetings

– Inspection Reports

Inspection Planning and Reports

• Decommissioning Power Reactor Inspection Program:

- 11 Core Inspection Procedures

- 58 Discretionary Procedures

• Generally scheduled during periods of higher risk activities

– Includes security and emergency preparedness

• Independent radiological surveys,

– Requires safe and unfettered access for NRC inspectors and survey teams

Decommissioning Inspection Activities

– During and after remediation activities, NRC conducts independent radiological measurements to confirm

– survey methodologies, and

– acceptable final site radiological condition

– NRC may perform sampling and request split sampling with the contractor

– NRC may employ Oak Ridge Institute for

Science and Education (ORISE aka ORAU) to perform independent verification surveys and sampling

Inspection and Confirmatory Survey Activities

• Prompt inspection debrief with NRC and NAVSEA management

• Determination of any significant findings

• Issue inspection report to NAVSEA

• Reports are publicly available, see http://www.nrc.gov/reading-rm/adams.html

• NAVSEA will use NRC input and inspection reports for assessing the Contractor’s performance

• NRC is not a party to the contract between

NAVSEA and the decommissioning contractor

Post Inspection Activities

Core Inspection Topics at Permanently

Shutdown Reactors

Organization, Management and Cost Controls

Safety Reviews, Design Changes, and Modifications

Self-Assessment, Auditing, and Corrective Action

Maintenance and Surveillance

Decommissioning Performance and Status Reviews

Occupational Radiation Exposure

Inspection of Remedial and Final Surveys

Radioactive Waste Treatment, and Effluent and Environmental

Monitoring

Solid Radioactive Waste Management and Transportation of

Radioactive Materials

Adverse Weather Preparations

Spent Fuel Pool Safety

• Discretionary inspections augment the core inspection program and assess particular functional areas, safety concerns, or aspects of licensee performance

• Discretionary Inspections can be reactive (to inspect an event) or initiative (to inspect an infrequent or high risk activity)

• Inspection procedures may come from other inspection programs

Use of Discretionary Inspections

Typical Discretionary Inspections

Radiological Controls

Training and Qualifications: General Employee Training, Radiation Safety, Plant Chemistry, Radwaste and Transportation

External Occupational Exposure Control and Personal Dosimetry

Internal Exposure Control and Assessment

Control of Radioactive Materials and Contamination, Surveys and

Monitoring

Maintaining Occupational Exposures ALARA

Radioactive Waste Management-Inspection of Waste Generator

Requirements of 10 CFR Part 20 and 10 CFR Part 61

Inspection of Transportation Activities

Summary

NRC’s Reactor Decommissioning Inspection

Program IMC 2561 – over 20 years of experience

Regional Inspectors perform inspections, supplemented by Headquarters subject matter experts

Allows Flexibility to adjust NRC resources

Allows inspectors to focus on necessary and discretionary inspections based on plant conditions and planned actions

Inspection results will be used NAVSEA for their purposes

Structure and Intent of the Notional Framework

Under the Notional Framework, the NRC technical support extends to nearly everything the NRC would do under NRC regulation, with one key exception:

the NRC would not take any regulatory action directly with the contractor. The

NRC would pass its recommendations on to the Navy, and the Navy, would implement those recommendations through administration of the contract

The Navy’s intent would be to implement the NRC’s recommendations without adding to or subtracting from them with minimal delay

The result is intended to be as close as possible to direct NRC licensing and regulation

Contractual incorporation of NRC’s recommendations would mean that the contractor would be contractually obligated to correct any NRC identified non-compliance with NRC regulations without adjustment to contract price

Contractual implementation of NRC recommended financial penalties (i.e., fines if this were NRC-licensed work) would be enforced by reductions in a contract incentive fee

Open Items Related to the Notional Framework

Perception of potential regulatory action by NAVSEA disproportional from NRC recommendations

– NAVSEA recognizes potential Contractor concern with NAVSEA providing enforcement of NRC regulations via contract

– This potential will be minimized by the “neither add nor detract” policy

– Strong assurance of the “neither add nor detract” policy will be needed. NAVSEA will investigate whether this assurance can be a provision of the contract; if included, the

Navy would be bound by the contract not to impose corrective actions or incentive fee reductions disproportionate from those recommended by the NRC

Perception that NRC’s provision of regulatory services to NAVSEA could cause delay in implementing corrective actions

– Potential for extensive deliberation on implementing NRC recommended corrective actions or incentive fee reductions will be minimized by the “neither add nor detract” policy above

– Intent of NAVSEA to minimize the time between NRC identifying a problem and

NAVSEA taking action

APPLICABILITY OF THE ZION

DECOMMISSIONING PROJECT

MODEL TO THE SSSB

Zion Model Applied to SSSB Dismantlement and Disposal

NAVSEA has observed commencement of several large-scale commercial nuclear power station decommissioning projects; the Zion nuclear power station license transfer is of particular interest

Contractual arrangements between the commercial utility operator and decommissioning contractor that facilitated transfer of the NRC license for the Zion nuclear power station provided several assurances and guarantees to mitigate technical and financial risks and ensured the Public’s interest in the decommissioning was upheld

– Performance bond

– Radioactive waste disposal easement

– Commercial liability insurance

– Corporate guarantee of contract completion

– Dedicated decommissioning fund

NAVSEA views the multi-faceted assurances and guarantees from the Zion decommissioning could be adapted to the SSSB dismantlement to achieve similar mitigation for technical and financial risks, with one important difference: the

Contractor would not hold title to the SSSB

Desired Financial Assurances and Guarantees

Overall goal – mitigate technical, financial, and reputational risks to the Navy by ensuring dismantlement and disposal of the SSSB will be completed by a technically qualified contractor. A technically compliant proposal would include these financial assurances and guarantees

Performance bond of 20% of contract price

Commercial nuclear liability insurance

– Small amounts of radioactivity and routine processing activities

– Commercial nuclear liability insurance available for these activities

– Navy does not consider the notional scope of work involves risk necessitating indemnification under PL 85-804

Radioactive waste disposal easement

– Zion decommissioning Contractor owned disposal site

– Alternative arrangements to ensure adequate disposal capacity acceptable

Corporate guarantee of contract completion

– Public company with market capitalization at least equal to the total contract price, or equivalent value if corporation is privately owned

Dedicated decommissioning fund

– Equivalently provided by a fully-funded fixed price contract

POTENTIAL CONTRACT AND

SOLICITATION PROCESS

NAVSEA considering evaluation of and awarding a Firm Fixed Price contract with a radiological regulatory compliance incentive fee

NAVSEA is also considering a “net price award” under Firm Fixed Price contract terms with a radiological regulatory compliance incentive fee, where:

– Contractor applies proceeds from the sale of scrap and reusable equipment to offset price of performance

– These estimated proceeds must be factored into proposed price

Mandatory “shipcheck participation” at Newport News, VA required for proposal submission

CLIN structure still being evaluated; project notionally involves two phases:

– Application and approval to transfer possession of the SSSB from the Navy to the disposal Contractor under the Notional Framework

– Transportation, dismantlement and disposal activities

Radiological regulatory compliance incentive fee will be a predetermined amount, to be paid on the successful completion of the dismantlement/disposal of the SSSB

– Full incentive is reduced if monetary penalties (i.e., fines if this were NRC-regulated work) are assessed under the Notional Framework during the contract period of performance

Potential Contract

Potential Contract

Award would be made to the responsible offeror:

– Whose proposal, conforming to the solicitation, represents the best value (trade off, not LPTA) to the Government considering the following:

• Technical approach

• Management approach

• Schedule

• Past performance

• Price (price becomes more important as the difference in non-price factors diminishes)

– Determination of whether an offeror is technically qualified will include the capabilities and past experience of the offeror on similar or more challenging work

– A technically compliant proposal will include the demonstrated ability of the offeror to meet the strong financial guarantee requirements

– Price is the firm fixed price to complete the project, and the radiological regulatory compliance incentive fee

Proposal – Required Technical Content

As part of the solicitation process, Contractors should expect Government to request at a minimum the following to evaluate the technical adequacy of the proposal:

Plans covering:

– Transfer of Possession in accordance with Notional Regulatory Framework

– Preparing the SSSB for open-ocean transport, including disposition of 160,000 gallons of RLW in spent fuel water pool and installation of a cover

– Loading the SSSB onto heavy lift ship or barge for transport to dismantlement site

(if not in Hampton Roads region)

– Environmental and radiological remediation

– Sale of scrap and reusable equipment/materials

– Overarching management and management approach

Procedures and techniques used to dismantle and dispose of the SSSB

Measures to maintain stability during over-water transport

Measures to prevent fire, flooding, and sinking during dismantlement

Proposal

Evaluation

SSSB Disposal Solicitation Process

Competitive Range

Determined

(if needed)

Release

RFP

Spring 2019

Discussions

(if needed)

Request for

Final Proposal

Revisions

(FPR)

Evaluates FPR/

Source Selection

Decision

Notice of

Apparent

Awardee

Apparent

Awardee

Referred

To DSS

Contract

Award

Spring 2020

Proposals

Submitted

Closing Remarks

A copy of today’s brief will be posted to www.fbo.gov (FedBiz)

Submit all questions in writing to the contracting officer at forrest.tucker@navy.mil and the contract specialist at stephanie.little@navy.mil by 20 November 2018

Thank you for attending and your interest in NAVSEA’s

Surface Ship Support Barge (SSSB) Disposal Project.

NAVSEA values your input http://www.fbo.gov/ mailto:forrest.tucker@navy.mil mailto:stephanie.little@navy.mil