ML063530017

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Response to Request for Additional Information Regarding License Amendment Request No. 2006-01
ML063530017
Person / Time
Site: NS Savannah
Issue date: 12/15/2006
From: Koehler E
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, NRC/FSME
References
Download: ML063530017 (40)
v • d • e


Text

O U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration Ref: 10 CFR 50.90 December 15, 2006 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. SAVANNAH License Amendment Request No. 2006-01 Response to Request for Additional Information References (a) Letter from Mr. Erhard W. Koehler (MARAD) to Document Control Desk (NRC),

dated August 7, 2006, License Amendment Request No. 2006-01, Technical Specifications Changes to Support Pre-Decommissioning Activities (b) Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T.

Buckley (NRC), October 20, 2006, Discussion of License Amendment Request 2006-001 (c) Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T.

Buckley (NRC), November 1, 2006, Additional Discussion of License Amendment Request 2006-001 (d) Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T.

Buckley (NRC), December 4, 2006, Additional Discussion of License Amendment Request 2006-001 (e) Letter from John T. Buckley (NRC) ) to Mr. Erhard W. Koehler (MARAD), dated December 6, 2006, Request for Additional Information Regarding License Amendment Request Number 2006-01 for N.S. SAVANNAH (Docket No. 50-238, License NS-1)

On August 7, 2006, the United States Maritime Administration (MARAD) submitted the request to amend the Nuclear Ship SAVANNAH (NSS) Facility Operating License, NS-1, as detailed in Reference (a). During References (b), (c) and (d), the NRC and MARAD discussed issues that culminated in the Request for Additional Information (RAI) (Reference e) to support the License Amendment Request (LAR) 2006-001. The RAI includes additional considerations that will enhance the Technical Specifications (TS).

Enclosure I provides the Responses to the Request for Additional Information. Enclosure 2 provides an evaluation of additional considerations to the TS. Enclosure 3 provides a mark up of the current TS to show all of the Proposed Changes that result from both Reference (a) and this submittal. Enclosure (4) is a final "clean" version of the Amendment 13 of the TS that includes all changes discussed in the above references. Enclosure 5 lists all of the regulatory commitments supporting the proposed changes discussed in LAR 2006-001.

AO2_o

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. 2006-01 December 15, 2006 MARAD has reviewed the Proposed Changes comparing them to the current license basis in accordance with 10 CFR 50.92 and concludes that they do not involve a significant hazards consideration.

Pursuant to 10 CFR 50.91 (b), a copy of this letter has been forwarded to the Commonwealth of Virginia and the cities of Newport News and Norfolk, Virginia where the ship is currently located. In addition, copies have been provided to the States of Maryland, North Carolina and South Carolina since the NSS could be decommissioned in one of these states. The Review and Audit Committee has reviewed this request.

MARAD requests approval of the proposed License Amendment by January 31, 2007 for implementation within 30 days from the date of approval. Approval by this date is necessary to preclude having to return to the JRRF, following routine maintenance and drydocking.

If there are any questions or concerns with respect any issue discussed in this request, please contact me at (202) 366-2631, and/or e-mail me at erhard.koehlerodot.gov.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 15, 2006.

Respectfully, Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Operations Enclosures (5) 2

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. 2006-01 December 15, 2006

Enclosures:

1. Responses to the Requests for Additional Information
2. Evaluation of License Amendment Request
3. Proposed Technical Specification Changes (mark-up)
4. Amendment 13 of the NSS Technical Specifications
5. List of Regulatory Commitments 3

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. 2006-01 December 15, 2006 cc:

Electronic copy NSS ESC NSS RAC MRG-7600, 7700 Hardcopy, cover letter only MAR-600, 610, 610.1, 610.3, 610.5, 611, 612 (em, ship file), 613, 614 Hardcopy w/ all enclosures and attachments MAR-100, 610.4 (rf)

USNRC (John T. Buckley, Mark C. Roberts)

USNRC Regional Administrator - NRC Region I MD Department of the Environment (Roland G. Fletcher; George S. Aburn, Jr.)

NC Department of Environment & Natural Resources (Beverly 0. Hall)

SC Department of Health & Environmental Control (Henry Porter; T. Pearce O'Kelley)

VA Department of Emergency Management (Michael M. Cline)

VA Department of Health (Leslie P. Foldesi)

EK/jmo 4

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, DC. 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION

1. SPECIFIC COMMENTS ON PROPOSED REVISIONS TO TECHNICAL SPECIFICATIONS Proposed Change 1
a. In TS Section 3.1, reference is made to ANSI N18.8-1971, but the correct reference is ANSI N 18.1-1971.

Response

This reference has been corrected in the Enclosures (3) and (4).

Proposed Change 2

b. In TS Section 3.6.1, it states that, "The Committee will consist of at least four members." It also says, "Four members shall constitute a quorum..."

Please consider why it is necessary to require all Committee members to be present to transact business. Perhaps the Committee should consist of more than four, or the quorum number should be stated as a percentage of the Committee makeup.

Response

A new Technical Specification 3.6.3 has been added to address this issue. The quorum requirements have been revised to require a two-thirds (2/) majority of the members. The subsequent Technical Specifications of Section 3.6 were renumbered as appropriate.

c. In TS Section 3.6.1, the membership of the Committee is very vague. The Tech Spec should specify the titles of Committee members.

Response

A new Technical Specification 3.6.2 has been added to address this issue. It lists four permanent members of the Review and Audit Committee by title and includes Senior Technical Advisor, Decommissioning Program Manager, Facility Site Manager and an individual who meets or exceeds the qualifications of ANSI N 18.1-1971, paragraphs 4.3.2.

d. In TS Section 3.6.1, reference is made to ANSI N18.8-1971, but the correct reference is ANSI N18.1-1971.

Response

This reference has been corrected in the Enclosures (3) and (4).

5

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation -Office of Ship Operations Washington, D.C. 20590 Maritime Administration Proposed Change 3

e. In TS Section 3.7.2.2, reference is made to ANSI N18.8-1971, but the correct reference is ANSI N18.1-1971.

Response

This reference has been corrected in the Enclosures (3) and (4).

Proposed Change 4

f. No Comment Proposed Change 5
g. TS Section 3.3 states, "Any authorized ... until all radiation control area are manned or secured as required by 3.7.1.2." Section 3.7.1.2 requires that all radiation control area entrances be manned or secured. No time period is provided for areas to be unmanned or unsecured. Therefore, the first sentence in TS Section 3.3 should be removed..

Response

This sentence has been removed as shown in Enclosures (3) and (4).

2.ADDITIONAL CONSIDERATIONS REGARDING TECHNICAL SPECIFICATIONS

a. TS 2.1 and TS 2.4 reference U.S. Department of Transportation, Hazardous Materials Branch.

Since the title, "Hazardous Materials Branch" was changed to "Office of Hazardous Materials Standards," consider deleting "Hazardous Materials Branch," and simply refer to the U.S.

Department of Transportation.

Response

See Enclosure 2 where this issue is discussed as Proposed Change 6.

b. Due to NRC organizational changes, revise TS 3.4 by replacing "Office of Nuclear Reactor Regulation" with "U.S. Nuclear Regulatory Commission in accordance with 10 CFR 50.4."

Response

See Enclosure 2 where this issue is discussed as Proposed Change 7.

c. TS 3.4.2 specifies requirements for reportable events that are inconsistent with 10 CFR 50.4, 50.72 and 50.73. Revise the time frames for reportable events and LERs to be consistent with those in 50.72 and 50.73, respectively. In addition, immediate notifications for events specified in TS 3.4.2 should be made in accordance with 10 CFR 50.72.

Response

See Enclosure 2 where this issue is discussed as Proposed Change 8.

6

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration

d. Proposed changes to the TS include changes to the numbering format used for many sections.

The amendment request should include changes to all pages of the TS which differ from TS Amendment No. 12, dated June 29, 1994. (Please note that the Front Cover of Appendix A to Facility License No. NS-1 is dated May 26, 1994, and each page of the TS is dated June 29, 1994).

Response

Enclosure (4) is a final "clean" version of the Amendment 13 of the TS that includes all changes discussed in the above references. It also includes a list of effective pages, a list of revisions page and formatting changes to all pages of Amendment 12.

7

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to Responses to Requests for Additional Information EVALUATION OF LICENSE AMENDMENT REQUEST

Subject:

Technical Specifications Changes to Support Pre-Decommissioning Activities

1. DESCRIPTION 9
2. PROPOSED CHANGES 9
3. BACKGROUND 9
4. TECHNICAL ANALYSIS 9
5. REGULATORY SAFETY ANALYSIS 12
a. Proposed Determination of No Significant Hazards Consideration 12
b. Applicable Regulatory Requirements/Criteria 13
6. ENVIRONMENTAL CONSIDERATION 13
7. PRECEDENT 13
8. REFERENCES 14 8

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006

1. DESCRIPTION This enclosure describes a request to amend Operating License NS-1 for the Nuclear Ship SAVANNAH (NSS). In Reference (a), MARAD proposed five changes to revise the Operating License that allow MARAD to prepare for decommissioning the NSS. In References (b), (c) and (d), MARAD and NRC discussed additional considerations for the Technical Specifications. These additional considerations were listed in Reference (e). This enclosure discusses the additional considerations as Proposed Changes 6, 7 and 8.

Consistent with the request in Reference (a), MARAD requests. approval of the proposed License Amendment by December 31, 2006 for implementation within 30 days from the date of approval.

Approval by this date is necessary to preclude having to return to the James River Reserve Fleet, following routine maintenance and drydocking that is currently scheduled to be completed in April 2007.

2. PROPOSED CHANGES Proposed Change 1, 2, 3, 4, and 5 are described in Reference (a).

Proposed Change 6 Technical Specifications 2.1 Radioactive Liquid Waste Release and 2.4 Solid Radioactive Waste Release refer to regulations of the U.S. Department of Transportation, Hazardous Materials Branch. This title was changed to "Office of Hazardous Materials Standards" in 1997 (62 FR 51553). MARAD proposes to revise the language of these Technical Specifications to simply refer to regulations of the U.S. Department of Transportation (DOT).

Proposed Change 7 Technical Specification 3.4.1 specifies that the annual report shall be submitted to addressees that are inconsistent with the requirements of 10 CFR 50.4(b)(1). MARAD proposes that these reports will be submitted as required by 10 CFR 50.4.

Proposed Change 8 Technical Specification 3.4.2 specifies requirements for reportable events that are inconsistent with 10 CFR 50.4, 50.72 and 50.73. MARAD proposes revising the time frames for reportable events and LERs to be similar to those in 50.72 and 50.73 respectively. In addition, MARAD proposes that immediate notifications for events specified in Technical Specification 3.4.2 will be made to the NRC Operations Center and LERs will be submitted as required 10 CFR 50.4.

In summary, MARAD is proposing the three additional changes to the Technical Specifications in order to prepare for decommissioning the NSS.

3. BACKGROUND Proposed Changes 6, 7 and 8 resolve discrepancies in the Technical Specifications that were noted during the review of Reference (a).
4. TECHNICAL ANALYSIS Proposed Change 6: Reference to U.S. Department of Transportation
a. Detailed Explanation of the Proposed Amendment Technical Specifications 2.1 Radioactive Liquid Waste Release states 9

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006 All solidified liquid waste shall be transferred in accordance with applicable NRC (10 CFR

71) and U.S. Department of Transportation, Hazardous Materials Branch regulations and the burial facility's license and acceptance criteria.

Technical Specification 2.4 Solid Radioactive Waste Release states Transfers of solid radioactive waste may be made to a licensed burial facility in accordance with applicable regulations of the NRC (10 CFR 71), the U.S. Department of Transportation, Hazardous Materials Branch, and the burial facility's license and acceptance criteria.

During the review of Reference (a), MARAD concluded that the reference to the "Hazardous Materials Branch" was no longer valid and should be revised. This branch had been renamed in 1997 (62 FR 51553) to the "Office of Hazardous Materials Standards." In order to preclude the necessity to revise the Technical Specification due to future organization changes, MARAD proposes to revise the language of these Technical Specifications to simply refer to regulations of the U.S. Department of Transportation (DOT).

MARAD proposes the following:

1. Revise Technical Specification 2.1, Specification, to require "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."
2. Revise Technical Specification 2.4, Specification, to require "Transfers of solid radioactive waste may be made to a licensed burial facility in accordance with applicable regulations of the NRC (10 CFR 71), the U.S. Department of Transportation, Hazardous Materials Branch, and the burial facility's license and acceptance criteria."
b. Summary of Technical Analysis By removing organizational level of detail from the Technical Specifications, MARAD is eliminating a discrepancy in the current Technical Specifications and eliminating the regulatory burden of revising Technical Specifications when the DOT institutes future organizational changes. Proposed Change 6, Reference to U.S. Department of Transportation, is an administrative change.

Proposed Change 7: Annual Report

a. Detailed Explanatio.n of the Proposed Amendment Technical Specification 3.4.1 states A written annual report shall be submitted to the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, prior to March 1 of each year.

During the review of Reference (a), MARAD concluded Technical Specification 3.4.1 required submitting the annual report to an addressee that was inconsistent with the requirements of 10 CFR 50.4(b)(1). This regulation requires all written communications to be submitted to Document Control Desk with a copy to the appropriate Regional Office, and a copy to the appropriate NRC Resident Inspector, if one has been assigned to the site of the facility. MARAD proposes that consistent with 10 CFR 50.4(b)(1) and (e), all written communication will be submitted as required by 10 CFR 50.4.

MARAD proposes revising Technical Specification 3.4.1 to require that prior to March 1 of each year, an annual report shall be submitted as required by 10 CFR 50.4.

b. Summary of Technical Analysis 10

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006 Approval of this Proposed Change will eliminate a discrepancy in the current Technical Specifications. Proposed Change 7, Annual Report, is an administrative change.

Proposed Change 8: Reportable Events

a. Detailed Explanation of the Proposed Amendment Technical Specification 3.4.2 states A LER shall be made to the USNRC Regional Office, Region II, by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a reportable event. Reportable events are as follows:
a. The entrance of an unauthorized person or persons into any controlled radiation area.
b. A significant change in the radiation or contamination levels in the vessel.
c. Any release of radioactive material to the environment in excess of 10% of the limits of applicable sections of 10 CFR Part 20.
d. Any major damage to the vessel due to severe weather conditions or other causes.
e. Major floodings or sinking of the vessel.

Such information shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telecopier, or telegraph to the Administrator, U.S. Nuclear Regulatory Commission, Region II, Atlanta, Georgia, and followed by a written report within two weeks, with a copy to the Director, Office of Nuclear Reactor Regulation of the U.S. NRC in Washington, D.C.

During the review of Reference (a), MARAD concluded Technical Specification 3.4.2 required revision to make it consistent with the reporting requirements of 10 CFR 50.72 and 50.73. In addition to events that are reportable per these regulations, the five reportable events that are unique to NSS are listed above. Since any of these events would almost always be reportable within four hours under 10 CFR 50.72(b)(2)(xi), MARAD proposes this Technical Specification should also require the telephone report to be made within four hours.

10 CFR 50.72(b)(2)(xi) states Any event or situation, related to the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made.

Similarly, since 10 CFR 50.72(a) requires notification of all events to the NRC Operations Center, MARAD proposes these five events should also be reported to the NRC Operations Center and not reported to an NRC Regional Office.

The final paragraph of Technical Specification 3.4.2 repeats the immediate notification requirement and then allows the report to be also made by telephone, telecopier, or telegraph.

MARAD proposes eliminating the option use to a telecopier or telegraph, since 10 CFR 50.72 prefers use of a telephone as the primary means of communication when the licensee has no Emergency Notification System.

The final paragraph Technical Specification 3.4.2 also adds a requirement for written reports.

Currently, the NRC has no requirement to provide written reports on events earlier than 30 days after the event was discovered. When these reports are required within 30 days, the events of interest involve exceeding radiation dose or contamination limits of 10 CFR.20. The written reports required by 10 CFR 20.2201(b) and 10 CFR 20.2203(a) are examples.

MARAD has determined that events d and e are similar to the 60 day written report required by 10 CFR 50.73(a)(2)(iii) regarding natural phenomenon or other external conditions. Similarly, 11

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006 MARAD has determined event c is similar to the 60 day written report required by 10 CFR 50.73(a)(2)(viii) regarding radioactive releases. Therefore, consistent with 10 CFR 50.73, MARAD proposes, written reports describing all five events should be submitted within sixty days of discovery of the event.

Similarly, since 10 CFR 50.73(d) requires LERs to be prepared on Form NRC 366 and submitted to the U.S. Nuclear Regulatory Commission, as specified in § 50.4, MARAD proposes these five events should also be reported as required by 10 CFR 50.73(d). Proposed Change 8 is generally consistent with 10CFR50.73(g) which notes that "requirements contained in this section

[10 CFR 50.731 replace all existing requirements for licensees to report "Reportable Occurrences" as defined in individual plant Technical Specifications."

Finally, since this Technical Specification addresses immediate notification and LERs, MARAD proposes changing its title to "Reportable Events."

b. Summary of Technical Analysis Approval of this Proposed Change will make the NSS unique reportability requirements consistent with other NRC requirements and eliminate a discrepancy in the current Technical Specifications. Proposed Change 8, Reportable Events, is an administrative change.
5. REGULATORY SAFETY ANALYSIS
a. Proposed Determination of No Significant Hazards Consideration MARAD has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Proposed Changes 6) Reference to U.S. Department of Transportation, 7) Annual Report and

8) Reportable Events are administrative in nature and do not involve the modification of any plant equipment or affect basic plant operation.

The NSS's reactor is not operational and the level of radioactivity in the NSS has significantly decreased from the levels that existed when the 1976 Possession-only License was issued. No aspect of any of Proposed Changes is an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased.

Therefore, the Proposed Changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Proposed Changes 6) Reference to U.S. Department of Transportation, 7) Annual Report and

8) Reportable Events are administrative and do not involve any physical alteration of plant equipment that was not previously allowed by Technical Specifications. These Proposed Changes do not change the method by which any safety-related system performs its function.

12

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006 As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged. The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

Therefore, the Proposed Changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Proposed Changes 6) Reference to U.S. Department of Transportation, 7) Annual Report and

8) Reportable Events are administrative in nature. No margins of safety exist that are relevant to the ship's defueled and partially dismantled reactor. As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings that would adversely affect plant safety as a result of the Proposed Changes. The Proposed Changes involve movement of the ship, changes in the performance of responsibilities and significantly improved radiological conditions since 1976.

Therefore, the Proposed Changes do not involve a significant reduction in a margin of safety.

Based on the above, MARAD concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

b. Applicable Regulatory Requirements/Criteria These Proposed Changes do not alter compliance with any applicable regulatory requirements or criteria. Proposed Change 6 continues to ensure NSS meets DOT regulations regarding transfer of radioactive waste. Proposed Change 7 continues to ensure NSS prepares and submits an annual report that summarizes status and other significant NSS events and activities. Proposed Change 8 continues to ensure NSS events are reported in a timely manner. These changes do not alter the design or licensing basis of any system.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6. ENVIRONMENTAL CONSIDERATION The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
7. PRECEDENT None.

13

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 December 15, 2006

8. REFERENCES
a. Letter from Mr. Erhard W. Koehler (MARAD) to Document Control Desk (NRC), dated August 7, 2006, License Amendment Request No. 2006-01, Technical Specifications Changes to Support Pre-Decommissioning Activities
b. Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T Buckley (NRC),

October 20, 2006, Discussion of License Amendment Request 2006-001

c. Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T Buckley (NRC),

November 1, 2006, Additional Discussion of License Amendment Request 2006-001

d. Telephone Conference between Mr. Erhard W. Koehler (MARAD) and John T Buckley (NRC),

December 4, 2006, Additional Discussion of License Amendment Request 2006-001

e. Letter from John T. Buckley (NRC) to Mr. Erhard W. Koehler (MARAD), dated December 6, 2006, Request for Additional Information Regarding License Amendment Request Number 2006-01 for N.S. SAVANNAH (Docket No. 50-238, License NS-1) 14

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

Strikethrough indicates deletions. Underlining indicates additions.

15

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 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 controlled areas.

All radioactive liquids have been removed from the primary and auxiliary systems.

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 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, Hazardous Materials Branch regulations; and the burial facility's license and acceptance criteria.

16

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 2.4 Solid Radioactive Waste Release Applicability Applies only to those solid radioactive wastes generated as the result of general decontamination of controlled areas, ship surveillance, and entry into controlled areas.

Objective To assure that solid radioactive waste presents no undue hazard to the general public or environment.

Specification All solid radioactive waste shall be maintained in appropriate containers in accordance with 10 CFR 20 and other applicable Federal regulations and secured in locked storage areas.

Transfers of solid radioactive waste may be made to a licensed burial facility in accordance with applicable regulations of thez NRC (10 CFR 71)-, and .t-he U.S. Department of Transportation-,

H.azardus*.. Ma-ter-i.als Branch, regulations; and the burial facility's license and acceptance criteria.

17

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.0 Administrative Controls 3.1 Administrative Responsibility The N.S. Savannah NS-l License is held by the Senior Technical Advisor, as the responsible official for the U.S. Maritime Administration, Washington, D.C.

At all times, inGl*diRg -he d nf la..p at the Mari4time Admnisraions am;es River= Reserver Fleet- (JRRF) and any periods wsx-h-enp- the vessel may be relcc"ated7 to an off site ship repair facility,-the custody and responsibility for access control, security, environmental surveillance, radiological monitoring, reporting to the U.S. Nuclear Regulatory Commission and maintenance will be with the Senior Technical Advisor, U.S.

Maritime Administration (MAR-AD), Washington, D.C.

The annual radiation surveys, semi-annual environmental sampling and surveillance, and laboratory analyses will be the responsibility of MARAD and performed for MARAD by the U.S. Army Center for Publir Works, Humphries Engineerngg Center (foSrmerly the U.S. Army Engineering and Hou-sing Support Center, Safety and 60 GUUpaU~LOQ +/-

aA-1A a UI=

-4+1': ~I )= . a aL-LI LLLL M M.=0= Q= QQ +1f Q4QL pe-rsonnel performing the-se- _funcQtioJns for= MAA will be health phyrsicists w4ith at least two ears specialized t-r-aining in healt phyrSics or equivallent and three years of woxrk experienc~e rel ated to radiological health and safety. by an individual who meets or exceeds the qualifications of ANSI N18.1-1971, paragraphs 4.3.2 or 4.5.2.

MARAD shall have a health physicist on duty or on call within two (2) hours to provide health physics support for radiological emergencies or entry into radiation control areas. In addition to the services of a health physicist, MARAD shall provide an Emergency Radiological Assistance Team in the event of radiological emergencies.

18

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.3 Radiological Criteria for Radiation Control Areas Any' authorized*

  • visto abar he ship Will be accompanied by representatives of the license holder until all radiation control area are locked and sealed. All entries into radiation control areas by visitors or employees shall be under the direction of a health physicist in accordance with the licensee's health physics procedures manual. However, in the event of fire, entry may be made into all radiation control areas except the reactor containment vessel, without the direction of a health physicist.

A radiation control area is defined as an area of the ship with radiation levels from reactor generated radioactive materials in excess of 0.25mR/hr above natural background as measured at one meter from any surface, and/or surface contamination in excess of those limits prescribed in Table I of NRC Reg. Guide 1.86.

Fo~r radiological protection o-f visitors anfd employees, all rPadliation cont:rol1 area. entrances Will be poste;Qd- wXit~h appropriat caution an9ann signs, loke-d and secre with cans and sealled wqith nu-3m~be~red seals. Key's and seaswill be miain-tained b y a designated repre-sent-ative- of the lic~ense ho~lder, and a log m.a.i nt;a.i ne9d-.

-AM intrusion alarm with an interlock will be maintained on the Deck- entry dr into the reac.tor cmpartment with a.udible and viulsignals located_ a-t- a aneRecurity guard post. These Signals shall b:e; both seen and heard by the secu11rity guard on duty'.

19

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.3.2 Access Control and Security The license holder shall control all access to the vessel through assignment of designated personnel with appropriate administrative procedures and physical security provisions.

Whe*n* in la.p Following 30 days written notice to the U.S.

Nuclear Regulatory Commission in accordance with 10 CFR 50.4, the vessel can be towed, berthed, moored or drydocked in any U.S.

domestic location having a U.S. Maritime Administration approved Port Operating Plan. Shall be poSition@ed in a@ sec.ure position in thRe Jame R.ier ReRer-. Fleet, Fort Eustis, Virginia, alongside Or in close proximity toQ the_ decmmssine U.S. Army M4--lA Floating Nuclear Power Plant STURGIS. Security for the vessel shall be provided by the license holder at all times, whether in laup in th6e RRF or off-site for infrequent required ship maintenance, in which ca.se 3-days prior notice in writing Shal be given to NRC Region II.

20

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.4.1. A written annual report shall be submitted to t Office of Nu**lpar RacrtQ Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C. 2055, pri Prior to March 1 of each year, a written annual report shall be submitted to the U.S. Nuclear Regulatory Commission in accordance with 10 CFR 50.4. The report shall include the following:

a. The status of the facility.
b. The results of the radiation surveys and monitoring station dosimeter readings.
c. The results of environmental sample analysis surveys.
d. The results of quarterly intrusion alarm system checks.
e. The amount of radioactive materials removed from the N.S.

Savannah by releases, discharges, and shipments of radioactive waste material.

f. A description of the principal maintenance performed on the vessel.
g. Any unauthorized entry into radiation control areas by visitors or employees and corrective action taken to improve access control.
h. Any degradation of one of the several boundaries which contain the radioactive materials aboard the N.S. Savannah.
i. Results of occupational exposure indicated by personal dosimetry.

21

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.4.2. Licensee Event Report (LER)Reportable Events

-A LER shall be miade to the USNR.C Regional1 Of f ice, RegiOn 11, by' telephonea wAithin 24 hou~rs, of a reportable event. Reportabl-e eve~nts, areL as follows:

In addition to those events that are reportable in accordance with the regulations of the U.S. Nuclear Regulatory Commission, the following additional events are reportable:

a. The entrance of an unauthorized person or persons into any controlled radiation area.
b. A significant change in the radiation or contamination levels in the vessel.
c. Any release of radioactive material to the environment in excess of 10% of the limits of applicable sections of 10 CFR Part 20.
d. Any major damage to the vessel due to severe weather conditions or other causes.
e. Major floodings or sinking of the vessel.

Such information s*hall b reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone,-

telecopier, or telegraph to the dmnsrtUS.Nuc-lear Regulatory Commission, Region TI, Atlanta, Georgia, and _followe;sXd by a written report w-Aithin twoe weeks, with a copy to the Director, O-fficea of Nuc-leaar R-eacgtor Regulation of thes U.S. -NRC-in Washington, D.C.

Within four (4) hours of discovery, the U.S. Nuclear Regulatory Commission will be notified of any reportable event, listed above, in accordance with 10 CFR 50.72.

Within 60 days of discovery, any reportable event, listed above, will be reported to the U.S. Nuclear Regulatory Commission in accordance with 10 CFR 50.73(d).

22

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.6 Review and Audit Committee 3.6.1 The Review and Audit Committee shall report to the Senior Technical Advisor. The Committee will consist of at least four members. Membership shall be approved by the Senior Technical Advisor. In aggregate, the membership experience shall include an appropriate balance of both maritime and commercial nuclear (operating and/or decommissioning) expertise. The permanent members of the Review and Audit Committee include the following:

Senior Technical Advisor; Decommissioning Program Manager; Facility Site Manager; and, An individual who meets or exceeds the qualifications of ANSI N18.1-1971, paragraphs 4.3.2.

3.6.2 A two-thirds ( ) majority of the members shall constitute a quorum of which one shall be the Senior Technical Advisor or their designated representative and one shall be an individual that meets or exceeds the qualifications of ANSI N18.1-1971, paragraphs 4.3.2.

!. There shall be a Review and Audit Committee (Committee)

.onSstingas a mnimu..m of the following personnel:

a. Com~m.ittee Chairm.an: SeniJor TcnclAdviso~r, U.S.

Maritime Administration, Washington, D.C.

b. Alter-nate Chairma: Chief, Diision of Ship Mantnaceand- -Repair,U.S. Ma~riJtime Administration, Washington, D.C. 20590
c. Member: Fleet Superintendent, James River Reserve
d. Member: Fleet Captain or Fleet Engineer, James River Reserve Fleet.
e. Designated representative of U.S. Army Center for Public Works, Humphries Engineering center (formerly t~he U.S. Army Engineering and Hou1--s-ing Support Center, Safety and Occupational Health Office)
f. Four members shall constitute a qucorum provided that at legast:

23

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006

!. Oe m pecncr dfsurh quorum halrI be ditheithr tnionr Mn =4r.arnnna eA U. 9- -*_I Mnr r 4Shi 7*M-aJPn4 and--4nR^pai, 1"n4-,r,,r

1. 12M r ")

t: 'Ie TT. One member of such quaorum shall be either the Chief, Division of Ship Main~tenance anPd. Repair U.S. Ma-ritime dmntrioWashingto~n, D.C.

20590, or the Superintendent, JRRF, or the Fleet Engineer, JRRF, or his designated alternate.

III. One member of such quorum shall be either the designated representative of U.S. Army Center for -PublicJrWorks, Humphries Engineering Center (formerly the U.S. Army Engineering and Housing Supporzt Center, Safety' and Occupa@tio~nal He4alth Offic~e) , r his designated alternate.

3.6.32.- Members of the Committee shall conduct audits, on-the-spot checks, and evaluations to assure that all work .is being done safely and in accordance with established procedures. If a deficiency is discovered, the Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C., is to be notified immediately. The license holder is to take the necessary immediate corrective action, and a written report of the deficiency is to be prepared for review by the Committee.

3.6.4-3-The Committee will review all of the following, including the determination of whether any proposed change involves.

an unreviewed safety question as defined in 10 CFR 50.59.

These reviews may be accomplished and concurred with by members of the Committee without a formal meeting.

a. Proposed changes to Technical Specifications.
b. Proposed changes or modifications to the vessel's controlled radiation area entry alarm system or containment system.
c. Substantive changes to radiation surveys or security surveillance procedures.
d. Reported violations of Technical Specifications.
e. Licensee Event Reports.
f. Annual reports to the NRC.

24

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 3.6.54- The Committee shall be convened by the Chairman and shall meet annually to review and discuss events of the preceding period. The Committee will meet when necessary in the event of grounding or sinking of the vessel.

Written minutes of all meetings shall be prepared and distributed to all committee members.

3.7 Ship Access Control and Surveillance Applicability Applies to routine access control and surveillance of the ship.

Objective To prevent unauthorized entry into radiation control areas by manning or securing their entrances and to determine change in radiation levels or integrity of the ship. An entrance is secured by bolting, welding, locking via a chain and/or hasp, or preventing access via an equivalent method.

Specification 3.7.1. Access Control 3.7.1.1 The 42 inch containment vessel entrances shall be manned or secured. Containment vessel entry shield plugs will be in place, sealed, and the l-iftIng eqjuipment partially disassembled.

3.7.1.2 All radiation control area entrances will be manned or secured. All entrances into the reactor compartment: ill be secured from the outside except the BR Deck entry a-t -Fra-me 122, which will be chained, posted, sealed, and do-uble locked.

3.7.1.3 All radiation control areas entrances will be posted with appropriate caution and warning signs, locked anpd. ealed.

3.7.1.4 All entrances to the ship not in use will be secured at all times.

3.7.1.5 The B Deck Reactor Compartment entrance at Frame 122 in Item 1.2 above, will be fitted with an intrusion alarm with audible and visual signals located at a location.that.is manned by a guard or securit 25

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 offier, that will alert a manned security guard post.

3.7.1.6 Security personnel will patrol the vessel at least once during a twenty-four (24) hour period.

3.7.1.7 Deviations from the above access control conditions will be in accordance with appropriate parts of Section 3 of these Technical Specifications, Administrative Controls.

3.7.2. Surveillance 3.7.2.1 Periodically and at least once a quarter, MARAD's designated personnel will inspect the seals nth control area deers radiation control area entrances to verify they are appropriately secured and test the intrusion alarm in Item 3.7.1.5.

3.7.2.2 Radiation surveys of the ship shall be made annually, and environmental surveillance shall be made semi-annually by the designated representative o-f U.S. Army Center -for -Public Works,' Humphrie Engineering Center (formerly the U.S. Army Engineering and Housing Support Center, Safety and Occupation__al HeRal-th Office) Or alternPative conracorpersonnel designated by the licrense hede~r.-an individual who meets or exceeds the qualifications of ANSI N18.1-1971, paragraphs 4.3.2 or 4.5.2.

3.7.2.3 Radiological surveys will be made:

a. In unrestricted and restricted employee areas of the ship.
b. In the compartment below the containment vessel for radiation levels and water leakage.
c. In the Port and Starboard Stabilizer rooms.
d. In the Forward control areas.
e. In Charge pump rooms.
f. In the Hot Chem. Lab. in the control room area.
g. In the accessible areas adjacent to the entries to the controlled areas.

3.7.2.4 In addition to the periodic radiological surveys, thermoluminescent dosimeters (TLDs) or equivalent 26

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

December 15, 2006 monitoring devices shall be placed at strategic locations throughout the vessel to monitor the radiation from reactor generated materials. MARAD shall determine these locations on the vessel and shall require dosimeter readings at least semi-annually.

3.7.2.5 Semi-annually, water samples and bottom sediment will be taken adjacent to the ship and analyzed by a qualified laboratory for radioactivity.

27

O U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 AMENDMENT 13 OF THE NSS TECHNICAL SPECIFICATIONS 28

U.S. Department of Transportation Maritime Administration Office of Ship Operations N.S. SAVANNAH TECHNICAL SPECIFICATIONS STS-004 January 2007 Prepared by:

SAVANNAH Technical Staff

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 RECORD OF REVISIONS Revision Summary of Revisions Following Cessation of Operations Change 12 Technical Specification changes to permit the ship to be towed, berthed, moored or drydocked in the defueled condition at any domestic location having an approved port entry and docking plan. December 20, 1971 Change 13 Technical Specification changes to acknowledge all nuclear fuel has been removed and the power plant and the ship are no longer operational. January 29, 1973 Amendment 8 Possession only License and Technical Specification.changes. May 19, 1976 Amendment 9 License and Technical Specification changes to add Patriots Point Development Authority as a co-licensee. August 14, 1981 Amendment 10 License and Technical Specification changes to reflect transfer of MARAD from the U.S. Department of Commerce to the U. S. Department of Transportation.

February 2, 1983 Amendment 11 Renewal of the Possession only License. July 15, 1986 Amendment 12 License and Technical Specification changes to remove the Patriots Point Development Authority as a co-licensee and locate the NSS to the James River Reserve Fleet. June 29, 1994 Amendment 13 Technical Specification Changes to support preparations for Decommissioning activities. January 2007 Amendment 13 2

SAVANNAH Technical Staff Technical Specifications (STS-004) ~~LIL_

January 2007 LIST OF EFFECTIVE PAGES Page No. Rev. No. Page No. Rev. No. Page No. Rev. No.

I Amendment 13 8 Amendment 13 2 Amendment 13 9 Amendment 13 3 Amendment 13 10 Amendment 13 4 Amendment 13 11 Amendment 13 5 Amendment 13 6 Amendment 13 7 Amendment 13 Amendment 13 3

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 Table of Contents Record of Revisions 2 List of Effective Pages 3 1.0 GENERAL 5 2.0 Radioactive Releases 5 2.1 Radioactive Liquid Waste Release 5 2.2 Radioactive Airborne Particulate Releases 5 2.3 Radioactive Liquid Waste Release Surveillance 5 2.4 Solid Radioactive Waste Release 6 3.0 Administrative Controls 6 3.1 Administrative Responsibility 6 3.2 Records 6 3.3 Radiological Criteria for Radiation Control Areas 7 3.3.1 Radiological Criteria for Unrestricted Areas 7 3.3.2 Access Control and Security 8 3.4 Reports 8 3.5 Procedures and Operating Instructions 9 3.6 Review and Audit Committee 9 3.7 Ship Access Control and Surveillance 10 3.7.1 Access Control 10 3.7.2 Surveillance 10 Amendment 13 4

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 1.0 GENERAL The nuclear ship N.S. SAVANNAH is in a state of protective storage. All fuel assemblies, radioactive fluids, demineralizer resins and contaminated trash have been removed from the ship. Adequate radiation monitoring, environmental surveillance, access control and security procedures will be established under the possession-only license to ensure that the health and safety of the employees, visitors and the public are not endangered.

2.0 RADIOACTIVE RELEASES 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 controlled areas. All radioactive liquids have been removed from the primary and auxiliary systems.

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 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.

2.2 Radioactive Airborne ParticulateReleases Applicability Applies only to radioactive airborne particulate releases that may occur due to maintenance requirements such as cutting and welding of contaminated components.

Objective To assure that radioactive airborne particulate releases do not present an undue hazard to the general public or the environment.

Specification No activities shall be conducted that would result in a release of radioactive airborne particulates in excess of 10% of limits specified in 10 CFR 20, Appendix B, or other applicable Federal regulations.

2.3 Radioactive Liquid Waste Release Surveillance Applicability Applies to the surveillance requirements for controlling radioactive liquid waste released to the hydrosphere.

Amendment 13 5

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 Objective To verify that liquid radioactive waste discharged to the hydrosphere will not exceed 10% of limits specified in 10 CFR 20 or other applicable Federal regulations.

Specification Liquid wastes resulting from radiological decontamination shall be analyzed prior to discharge.

Concentrations of radioactive liquid waste shall not exceed 10% of the applicable limits of 10 CFR 20 or prescribed by other applicable Federal regulations. Records of analyses and amounts of wastes discharged shall be maintained.

2.4 Solid Radioactive Waste Release Applicability Applies only to those solid radioactive wastes generated as the result of general decontamination of controlled areas, ship surveillance, and entry into controlled areas.

Objective To assure that solid radioactive waste presents no undue hazard to the general public or environment.

Specification All solid radioactive waste shall be maintained in appropriate containers in accordance with 10 CFR 20 and other applicable Federal regulations and secured in locked storage areas. Transfers of solid radioactive waste may be made to a licensed burial facility in accordance with applicable NRC (10 CFR 71) and U.S. Department of Transportation regulations; and the burial facility's license and acceptance criteria.

3.0 ADMINISTRATIVE CONTROLS 3.1 Administrative Responsibility The N.S. SAVANNAH NS-I License is held by the Senior Technical Advisor, as the responsible official for the U.S. Maritime Administration, Washington, D.C.

At all times, the custody and responsibility for access control, security, environmental surveillance, radiological monitoring, reporting to the U.S. Nuclear Regulatory Commission and maintenance will be with the Senior Technical Advisor, U.S. Maritime Administration (MARAD), Washington, D.C.

The annual radiation surveys, semi-annual environmental sampling and surveillance, and laboratory analyses will be the responsibility of MARAD and performed by an individual who meets or exceeds the qualifications of ANSI N 18.1-1971, paragraphs 4.3.2 or 4.5.2.

MARAD shall have a health physicist on duty or on call within two (2) hours to provide health physics support for radiological emergencies or entry into radiation control areas. In addition to the services of a health physicist, MARAD shall provide an Emergency Radiological Assistance Team in the event of radiological emergencies.

3.2 Records In addition to the records required by applicable regulations, the Senior Technical Advisor, U.S.

Maritime Administration, Washington, D.C., and other assigned personnel shall maintain the following records:

Amendment 13 6

SAVANNAH Technical Staff Technical Specifications (STS-004) -.

January2007 ------

3.2.1 Health Physics Records

a. Personnel Exposure
b. Ship's Radiological Surveys
c. Environmental Surveillance and Laboratory Analyses 3.2.2 Radioactive Liquid Waste Disposal Log 3.2.3 Solid Radioactive Waste Disposal Log 3.2.4 Quarterly Inspections of Physical Barriers and Intrusion Alarms 3.2.5 Licensee Event Reports (LER) 3.2.6 Records of Review and Audit Committee Meetings 3.2.7 File of Annual Reports to the U.S. Nuclear Regulatory Commission 3.2.8 Drawings, prints, layouts and specifications for the ship.

3.3 RadiologicalCriteriafor Radiation ControlAreas All entries into radiation control areas by visitors or employees shall be under the direction of a health physicist in accordance with the licensee's health physics procedures manual. However, in the event of fire, entry may be made into all radiation control areas except the reactor containment vessel, without the direction of a health physicist.

A radiation control area is defined as an area of the ship with radiation levels from reactor generated radioactive materials in excess of 0.25mR/hr above natural background as measured at one meter from any surface, and/or surface contamination in excess of those limits prescribed in Table I of NRC Reg. Guide 1.86.

3.3.1 Radiological Criteria for Unrestricted Areas An unrestricted area is defined as an area that is accessible to employees, contractor personnel, escorted guests and official visitors. These areas include those areas not previously defined as Radiation Control Areas (Section 3.3). The radiation levels from reactor generated radioactive materials for unrestricted areas shall be less than 5ýtR/hr above natural background as measured at one meter from any surface. All surfaces shall be decontaminated and maintained at levels less that those prescribed in Table I of NRC Reg.

Guide 1.86.

The radiation levels from reactor generated radioactive materials for all areas of the ship identified as being restricted to only employees, contractor personnel, escorted guests and official visitors shall be less than 5[tR/hr above natural background as measured at one meter from any surface except as discussed below. Surface contamination levels shall be less that those prescribed in Table I of NRC Reg. Guide 1.86 in all cases, however.

Restricted areas of the ship with radiation levels in excess of 511R/hr but less than 0.25mR/hr may be entered without health physics supervision under the following conditions:

a. A health physicist has determined that potential exposures to any individual will not exceed 5% of 10 CFR 20.101 exposure limits.
b. The Review and Audit Committee has reviewed and accepted the proposed use of the space.

Amendment 13 7

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 Prior to any areas being opened for uncontrolled access, the licensee shall survey the areas for radiation levels with appropriate portable instrumentation and make a contamination survey of the areas in accordance with his established health physics procedures to determine that the areas meet the criteria for access. Records of these surveys shall be maintained for inspection and review by the Review and Audit Committee.

3.3.2 Access Control and Security The license holder shall control all access to the vessel through assignment of designated personnel with appropriate administrative procedures and physical security provisions.

Following 30 days written notice to the U.S. Nuclear Regulatory Commission in accordance with 10 CFR 50.4, the vessel can be towed, berthed, moored or drydocked in any U.S. domestic location having a U.S. Maritime Administration approve Port Operating Plan. Security for the vessel shall be provided by the license holder at all times.

3.4 Reports The Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C. shall make the following reports:

3.4.1 Prior to March 1 of each year, a written annual report shall be submitted to the U.S Nuclear Regulatory Commission in accordance with 10 CFR 50.4. The report shall include the following:

a. The status of the facility.
b. The results of the radiation surveys and monitoring station dosimeter readings.
c. The results of environmental sample analysis surveys.
d. The results of quarterly intrusion alarm system checks.
e. The amount of radioactive materials removed from the N.S. SAVANNAH by releases, discharges, and shipments of radioactive waste material.
f. A description of the principal maintenance performed on the vessel.
g. Any unauthorized entry into radiation control areas by visitors or employees and corrective action taken to improve access control.
h. Any degradation of one of the several boundaries which contain the radioactive materials aboard the N.S. SAVANNAH.
i. Results of occupational exposure indicated by personal dosimetry.

3.4.2 Reportable Events In addition to those events that are reportable in accordance with the regulations of the U.S.

Nuclear Regulatory Commission, the following additional events are reportable:

a. The entrance of an unauthorized person or persons into any controlled radiation area.
b. A significant change in the radiation or contamination levels in the vessel.
c. Any release of radioactive material to the environment in excess of 10% of the limits of applicable sections of 10 CFR Part 20.
d. Any major damage to the vessel due to severe weather conditions or other causes.
e. Major floodings or sinking of the vessel.

Amendment 13 8

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 Within four (4) hours of discovery, the U.S. Nuclear Regulatory Commission will be notified of any reportable event, listed above, in accordance with 10 CFR 50.72.

Within 60 days of discovery, any reportable event, listed above, will be reported to the U.S. Nuclear Regulatory Commission in accordance with 10 CFR 50.73(d).

3.5 Proceduresand OperatingInstructions All modifications and maintenance of the vessel which may affect the safety of visitors, employees, or maintenance personnel shall be carried out in accordance with written procedures that cover the following:

a. Emergency conditions involving potential or actual release of radioactivity, e.g., fire and flooding.
b. Surveys in controlled areas.
c. Access control.
d. Radiation protection.

These procedures and any subsequent revisions shall be reviewed and approved by the Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C. or his designated alternate, and the Review and Audit Committee.

3.6 Review and Audit Committee 3.6.1 The Review and Audit Committee shall report to the Senior Technical Advisor. The Committee will consist of at least four members. Membership shall be approved of by the Senior Technical Advisor. In aggregate, the membership experience shall include an appropriate balance of both maritime and commercial nuclear (operating and/or decommissioning) expertise. The permanent members include the following:

Senior Technical Advisor; Decommissioning Program Manager; Facility Site Manager; and, An individual who meets or exceeds the qualifications of ANSI N18.1-1971 paragraphs 4.3.2.

3.6.2 A two-thirds (%) majority of the members shall constitute a quorum of which one shall be the Senior Technical Advisor or their designated representative and one shall be an individual that meets or exceeds the qualifications of ANSI N18.1-1971, paragraphs 4.3.2.

3.6.3 Members of the Committee shall conduct audits, on-the-spot checks, and evaluations to assure that all work is being done safely and in accordance with established procedures. If a deficiency is discovered, the Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C., is to be notified immediately. The license holder is to take the necessary immediate corrective action, and a written report of the deficiency is to be prepared for review by the Committee.

3.6.4 The Committee will review all of the following, including the determination of whether any proposed change involvesan unreviewed safety question as defined in 10 CFR 50.59.

These reviews may be accomplished and concurred with by members of the Committee without a formal meeting.

a. Proposed changes to Technical Specifications.

Amendment 13 9

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007

b. Proposed changes or modifications to the vessel's controlled radiation area entry alarm system or containment system.
c. Substantive changes to radiation surveys or security surveillance procedures.
d. Reported violations of Technical Specifications.
e. Licensee Event Reports.
f. Annual reports to the NRC.

3.6.5 The Committee shall be convened by the Chairman and shall meet annually to review and discuss events of the preceding period. The Committee will meet when necessary in the event of grounding or sinking of the vessel. Written minutes of all meetings shall be prepared and distributed to all committee members.

3.7 Ship Access Control and Surveillance Applicability Applies to routine access control and surveillance of the ship.

Objective To prevent unauthorized entry into radiation control areas by manning or securing their entrances and to determine change in radiation levels or integrity of the ship. An entrance is secured by bolting, welding, locking via a chain and/or hasp, or preventing access via an equivalent method.

Specification 3.7.1 Access Control 3.7.1.1 The 42 inch containment vessel entrances shall be manned or secured.

3.7.1.2 All radiation control area entrances will be manned or secured.

3.7.1.3 All radiation control areas entrances will be posted with appropriate caution and warning signs.

3.7.1.4 All entrances to the ship not in use will be secured at all times.

3.7.1.5 The B Deck Reactor Compartment entrance at Frame 122 will be fitted with an intrusion alarm with audible and visual signals that will alert a manned security guard post.

3.7.1.6 Security personnel will patrol the vessel at least once during a twenty-four (24) hour period.

3.7.1.7 Deviations from the above access control conditions will be in accordance with appropriate parts of Section 3 of these Technical Specifications, Administrative Controls.

3.7.2 Surveillance 3.7.2.1 Periodically and at least once a quarter, MARAD's designated personnel will inspect the radiation control area entrances they are properly secured and test the intrusion alarm in Item 3.7.1.5.

Amendment 13 10

SAVANNAH Technical Staff Technical Specifications (STS-004)

January 2007 3.7.2.2 Radiation surveys of the ship shall be made annually, and environmental surveillance shall be made semi-annually by an individual who meets or qualifications of ANSI N18.1-1971, paragraphs 4.3.2 or 4.5.2.

3.7.2.3 Radiological surveys will be made:

a. In unrestricted and restricted employee areas of the ship.
b. In the compartment below the containment vessel for radiation levels and water leakage.
c. In the Port and Starboard Stabilizer rooms.
d. In the Forward control areas.
e. In Charge pump rooms.
f. In the Hot Chem. Lab. in the control room area.
g. In the accessible areas adjacent to the entries to the controlled areas.

3.7.2.4 In addition to the periodic radiological surveys, thermoluminescent dosimeters (TLDs) or equivalent monitoring devices shall be placed at strategic locations throughout the vessel to monitor the radiation from reactor generated materials.

MARAD shall determine these locations on the vessel and shall require dosimeter readings at least semi-annually.

3.7.2.5 Semi-annually, water samples and bottom sediment will be taken adjacent to the ship and analyzed by a qualified laboratory for radioactivity.

3.7.3 Two draft level stripes will be painted fore and aft (at the draft markers), one will be just above the water level and the upper stripe will be one foot above the lower. These will be observed daily to check if the draft has increased. Both stripes must always be visible. If the lower stripe is not visible, the ship shall be surveyed and the water leakage located.

The source of leakage will be determined, the ship pumped out, and repairs made as may be required, including drydocking if determined necessary, in order to assure that the integrity of the hull is maintained.

3.7.4 A cathodic protection system will be provided and properly maintained to protect the underwater areas of the vessel's hull to minimize corrosion damage to the hull.

3.7.5 An underwater inspection of the hull will be conducted at least every four (4) years. The vessel will be drydocked if the inspection determines that such action is necessary due to localized severe pitting, underwater plate thinning in excess of 40 percent, or other damage that would require corrective action and/or removal of the vessel to an off-site ship repair facility.

3.7.6 An inspection will be conducted at least annually by MARAD's designated personnel to determine any degradation of the primary and secondary systems.

Amendment 13 I1I

0 U.S. Department SAVANNAH Technical Staff 400 Seventh Street, S.W.

of Transportation Office of Ship Operations Washington, D.C. 20590 Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. 2006-01 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by MARAD in Reference (a) of the cover letter and this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Erhard Kohler (202) 366-2631, and/or erhard.koehler(2dot.gov.

TYPE (Check One)

REGULATORY COMMITMENT One Time Continuing DUE DATE Action Action In order to prepare for decommissioning, a number of January 15, preparatory activities must be completed. These 2007 activities include surveys, system walkdowns, inspections, etc. required for developing a detailed decommissioning plan, schedule and cost estimate. RI The activities will be administratively limited to allowing no opening of reactor or auxiliary systems or other activities that could reasonably be expected to generate airborne contamination.

When RCA entrances are secured by locks, keys and January 15, seals will be maintained by MARAD or their designee. 2007 A log of the keys and seals will be maintained by LI MARAD or their designee.

I

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