ML18173A128

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United States Maritime Administration License Amendment Request No. LAR 2018-02 Technical Specification Changes to Revise Section 2.0, Radioactive Releases
ML18173A128
Person / Time
Site: NS Savannah
Issue date: 06/19/2018
From: Koehler E
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18173A102 List:
References
LAR 2018-02
Download: ML18173A128 (28)
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Text

I U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington , DC 20590 of Transportation Maritime Adminlsnatlon Ref: 10 CFR 50.90 June 19, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. SA VANNAH License Amendment Request No. LAR 2018-02 Techn ical Specification Changes to Revise Section 2.0, Radioactive Releases Reference (a) Letter from Mr. John B. Hickman, (NRC) to Mr. Erhard W. Koeh ler (MARAD),

dated April 23, 2018, Nuclear Ship SA VANNA H - Issuance ofAmendment 15 to Revise the License to Allow Dismantlement and Disposal

.Pursuant to 10 CFR 50 .90, the United States Maritime Administration (MARAD) hereby requests approval to amend the Nuclear Ship SAVANNAH (NSS) Faci lity Operating License, NS-1 (L icense) and

' incorporate the enclosed proposed changes into the NSS Technical Specifications.

The proposed li cense amendment will revise all of Technical Specification (TS) Section 2.0, Radioactive Releases from its original custom form to typical 10 CFR 50.36a Technical Specifications for effluents from nuclear power reactors. The content of the proposed Technical Specification is consistent with those of plants in advanced stages of decommissioning. The proposed changes will include a Process Control Program, an Offsite Dose Calculation Manual, a Radioactive Effluent Controls Program, a Radiological Environmental Monitoring Program and related Reporting Requirements.

The proposed amendment wi ll also delete three Technical Specifications (TSs) that are included as requ irements in STS-005-020, Offsite Dose Calculation Manual (ODCM) and therefore, are no longer necessary as standalone TSs. These three TSs include one associated with the annual report, one associated with area monitoring thermoluminescent dosimeters (TLDs) and one associated with environmental monitoring.

Finally, one proposed change is a minor change to revise TS 1.0 to delete the Possession-only license wording that is no longer correct following approval of Amendment 15 (Reference a).

The License Amendment Request is provided in five (5) enc losures to thi s letter. Enclosure I is an evaluation of the request. Enclosure 2 provides the existing Technical Specifications marked-up to show the proposed changes. Enclosure 3 provides a retyped version of the proposed Technical Specification changes. Enclosure 4 is STS-005-020, Offsite Dose Calculation Manual (ODCM). Enclosure 5 is STS-005-022, Radioactive Waste Process Control Plan.

MARAD has reviewed the proposed changes comparing them to the current license basis in accordance A [}

with 10 CFR 50.92 and concludes that they involve no significant hazards consideration. /-i:. tJ Z

JI. I(_

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Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-02 June 19, 2018 Pursuant to 10 CFR 50.91 (b ), a copy of this letter has been forwarded to the State of Maryland. The Safety Review Committee has reviewed this request.

MARAD requests approval of the proposed License Amendment by December 19, 2018, for implementation within 30 days from the date of approval.

This letter contains no commitments.

lfthere are any questions or concerns with respect to any issue discussed in this request, please contact me at (202) 366-2631 , and/or e-mai l me at erhard.koeh ler@dot.gov .

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

Executed on June 19, 20 18 Respectfully,

<:;Zµ~

Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal Enclosures (5) 2 of70

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-02 June 19, 2018

Enclosures:

1. Evaluation of License Amendment Request
2. Proposed Technical Specification Changes (marked-up)
3. Proposed Technical Specification Changes (retyped)
4. STS-005-020, RO Offsite Dose Calculation Manual (ODCM)
5. STS-005-022, RO Radioactive Waste Process Control Plan 3 of70

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-02 June 19, 2018 cc:

Electronic copy NSS ESC NSSSRC MAR-610, 612, 615 Hardcopy, cover letter only MAR-600, 640, 640.2 Hardcopy w/ all enclosures MAR- 100, 640.2 (rf)

USNRC (John Hickman, Ted Smith, Mark C. Roberts)

USNRC Regional Administrator - NRC Region I MD Department of the Environment (Eva Nair)

EK/jmo 4 of70

0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime AdmlnistYatlon Docket No. 50-238; License No. NS-1; N.S. SAVANNAH ENCLOSURE 1 EVALUATION OF LICENSE AMENDMENT REQUEST

Subject:

Technical Specification Changes to Revise Section 2.0, Radioactive Releases 1.0

SUMMARY

DESCRIPTION ....................................................................................................... 6 2.0 DETAILED DESCRIPTION OF PROPOSED CHANGES ...................................................... 6 2.1 Proposed Change 1: Revise Section 2.0 Technical Specification, Radioactive Releases ............ 6 2.2 Proposed Change 2: Delete Annual Report Technical Specification 3.4.2.1.e .......... ......... .. ....... 6 2.3 Proposed Change 3: Delete Technical Specifications 3.7.2.3, Area Monitoring Devices ........... 7 2.4 Proposed Change 4: Delete Technical Specifications 3.7.2.4, Environmental Monitoring .... .... . 7 2.5 Proposed Change 5: Revise Technical Specification 1.0 ................ ... .... .. .. ....... .. .... ................ .. ... 8

3.0 TECHNICAL EVALUATION

..................................................................................................... 8 4.0 REGULATORY SAFETY ANALYSIS ....................................................................................... 8 4.1 Applicable Regulatory Requirements/Criteria ............................................... .. ........... ..... .. ... ........ 8 4 .2 Precedent .................................... .. .... ........................................................... ........... ..... ..... ... ... ..... 10 4.3 Proposed Determination of No Significant Hazards Consideration ... ............ .... .... .... ..... .. .......... 10 4.4 Conclusions ................................................................................................................ ................. 11

5.0 ENVIRONMENTAL CONSIDERATION

................................................................................ 11

6.0 REFERENCES

............................................................................................................................. 12 5 of70

r Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-02 June 19, 2018 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Technical Specifications for the Nuclear Ship SA VANNAH (NSS).

The proposed license amendment will revise all of Technical Specification (TS) Section 2.0, Radioactive Releases from its original custom form to typical 10 CFR 50.36a Technical Specifications on effluents from nuclear power reactors. The content of the proposed Technical Specification is consistent with those of plants in advanced stages of decommissioning. The proposed changes will include a Process Control Program, an Offsite Dose Calculation Manual, a Radioactive Effluent Controls Program, a Radiological Environmental Monitoring Program and related Reporting Requirements.

The proposed amendment will also delete three Technical Specifications (TSs) that are included as requirements in STS-005-020, Offeite Dose Calculation Manual (ODCM) and therefore, are no longer necessary as standalone TSs. These three TSs include one associated with the annual report, one associated with area monitoring thermoluminescent dosimeters (TLDs) and one associated with environmental monitoring.

Finally, one proposed change is a minor change to revise TS 1.0 to delete the Possession-only license wording that is no longer correct following approval of Amendment 15 (Reference a).

MARAD requests approval of the proposed License Amendment by December 19, 2018 for implementation within 30 days from the date of approval.

2.0 DETAILED DESCRIPTION OF PROPOSED CHANGES

2.1 PROPOSED CHANGE

1: REVISE SECTION 2.0 TECHNICAL SPECIFICATION, RADIOACTIVE RELEASES Currently, TS Section 2 is based on the original NSS custom TS and an addition to it in 1976 that added Patriots Point Development Authority as a co-licensee (Reference b). The current TS Section 2 is shown in Enclosure 2, "Proposed License Changes (Marked-Up)."

In acknowledgment of decommissioning activity that will be performed, MARAD has determined the existing TS Section 2 should be revised in its entirety to more closely match those of more modem plants actively in the process of decommissioning. These proposed TSs will include:

  • A Radioactive Effluent Controls Program;
  • A Radiological Environmental Monitoring Program; and,
  • Related Reporting Requirements.

2.2 PROPOSED CHANGE

2: DELETE ANNUAL REPORT TECHNICAL SPECIFICATION 3.4.2.1.E Currently, TS 3.4.2.1 requires the Annual Report to include:

e. The amount ofradioactive materials removed from the N.S. SA VANNAH by releases, discharges, and shipments of radioactive waste material ;

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018 The Proposed Section 2 TSs will include a similar reporting requirement in the Annual Radioactive Effluent Release Report. Specifically, the report shall include a summary of the quantities of radioactive liq uid and gaseous effluents and solid waste released from the NSS. This requirement is also included in the ODCM. The proposed new reporting requirement and the existing TS 3.4.2.1.e reporting requirement are essentially duplicative. MARAD proposes deleting TS 3.4.2.1.e in its entirety.

2.3 PROPOSED CHANGE

3: DELETE TECHNICAL SPECIFICATIONS 3.7.2.3, AREA MONITORING DEVICES Currently, TS 3.7.2.3 requires area monitoring thermoluminescent dosimeters (TLDs) throughout the ship. Specifically, the TS states:

3.7.2.3 Thermoluminescent dosimeters (TLDs) or equivalent monitoring devices shall be placed at strategic locations throughout the vesse l 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.

The Proposed Section 2 TSs will include a requirement for an ODCM. The ODCM requires the following:

Direct Radiation Measuring Devices Direct radiation measuring devices, such as thermoluminescent dosimeters (TLDs), optically stimulated luminescent dosimeters (OSL) 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.

Given that the current TS 3.7.2.3 will be redundant to a requirement in the ODCM , MARAD proposes deleting TS 3.7.2.3 in its entirety.

2.4 PROPOSED CHANGE

4: DELETE TECHNICAL SPECIFICATIONS 3.7.2.4, ENVIRONMENTAL MONITORING Currently, TS 3.7.2.4 requires environmental monitoring of water and sediment adjacent to the ship.

Specifically, the TS states:

3.7.2.4 Semi-annually, water samples and bottom sediment will be taken adjacent to the ship and analyzed for radioactivity.

The Proposed Section 2 TSs will include a requirement for an ODCM. The ODCM requires the following:

Water and Sediment Samples Semi-annually, water samples and bottom sediment shall be taken adjacent to the ship and analyzed for principal gamma emitting radionuclides.

Given that the current TS 3.7.2.4 wil l be redundant to a requirement in the ODCM, MARAD proposes deleting TS 3.7.2.4 in its entirety.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018

2.5 PROPOSED CHANGE

5: REVISE TECHNICAL SPECIFICATION 1.0 Currently, TS 1.0 states:

1.0 GENERAL The Nuclear Ship N.S. SAVANNAH has been in a state of protective storage since 1976 when the possession-only license was issued.

Following Issuance ofAmendment 15 to Revise the License to Allow Dismantlement and Disposal (Reference a) on April 23, 2018, TS 1.0 is no longer correct. Given that the license is no longer a Possession-only license, MARAD has detennined the TS should be revised to state the NSS has been in a state of active decommissioning since Amendment 15 was issued.

3.0 TECHNICAL EVALUATION

Wh ile the proposed changes are purely admi nistrative in nature, there are technical issues associated with them that are unique to the NSS:

  • Radionuclides that have been included in the analysis for 1) effluents, 2) release limits and
3) dose assessments are those that have been identified by the previous radiological characterization as described in Chapter 13, Radiological and Environmental Characterization of Updated Final Safety Analysis Report (UFSAR), STS-004-002.
  • As described in the UFSAR, all primary, auxiliary and secondary systems are deactivated, disabled and perform no active function. In addition, those systems that originally contained fluids were drained to the maximum extent practical in March 1976. Given that all hull penetrations are covered by welded blank flanges and inspected each drydocking, there are no systems capable of discharging radioactive liquid or gaseous effluents.
  • There is no Radioactive Liquid Effl uent Instrumentation in service for the NSS. All liquids are controll ed on a batch basis. In addition, 1) there is limited residual liquid radioactive waste inventory, 2) activiti es generating add itional liquid waste are limited, and 3) controls are established on releases to the environment.
  • While not unexpected, recent dismantling activities have identified small amounts of liquid in some of the "drained" piping systems. Presence of these liquids is anticipated and controlled as required by Work Orders and Radiation Work Permits.
  • The only potential for airborne radioactivity and potential release to the environment would be during work activities on contaminated components. During work activities, air sampling and follow-up particulate filter radiochemical analysis shall be performed. Therefore, there is no requirement for continuous gaseous/airborne particulate radioactive effl uent monitoring.

4.0 REGULATORY SAFETY ANALYSIS 4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA These proposed changes are administrative in nature and do not alter compliance with any applicable regulatory requirements or criteria.

The current Section 2 TSs are based on the original custom NSS Technical Specifications. MARAD detennined there was no need to make these proposed changes until Amendment 15 was issued. Prior to Amendment 15, the Possession-only license did not allow dismantling and di sposal of the faci lity.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018 The Possession-only license was based on Regulatory Guide (RG) 1.86, Termination of Operating Licenses for Nuclear Reactors, Reference (c). Under this license, the NSS was "Mothballed." The 1974 RG describes the now outmoded Mothballing option of protective storage. This state of protective storage was approved in 1976 by Amendment 8 (Possession-Only) to License NS-1, Reference (d). MARAD understands RG 1.86 was withdrawn as noticed in the Federal Regi ster (81 FR 53507) on August 12, 2016 and that its withdrawal did not impact the NSS licensing basis.

RG 1.86 Regulatory Position C.2 Alternatives for Reactor Retirement states:

a. Mothballing. Mothballing of a nuclear reactor facility consists of putting the facility in a state of protective storage. In general, the facility may be left intact except that all fuel assemblies and the radioactive fluids and waste should be removed from the site.

Adequate radiation monitoring, environmental surveillance, [emphasis added] and appropriate security procedures should be established under a possession-only license to ensure that the health and safety of the public is not endangered.

RG 1.86 Regulatory Position C.3 Surveillance and Security for the Retirement Alternatives whose Final Status Requires a Possession-only License states, in part:

d. An environmental radiation survey should be performed at least semiannually to verify that no significant amounts of radiation have been released to the environment from the facility. Samples such as soil, vegetation, and water should be taken at locations for which statistical data has been established during reactor operations.

These two regulatory positions are the basis for two of the Technical Specifications that will be deleted - TS 3.7.2.3 that requires area monitoring TLDs and TS 3.7.2.4 that requires environmental monitoring.

Title 10 Code of Federal Regulations Section 50.36a (10 CFR 50.36a), Technical Specifications on effluents from nuclear power reactors requires each licensee of a nuclear power reactor to include technical specifications to keep releases of radioactive materials to unrestricted areas during normal conditions, including expected occurrences, as low as is reasonably achievable. This regulation was originally promulgated in 1970 and effective for plants licensed after January 2, 1971. By this date, NSS had shutdown and would never restart. In 1976, the NSS license was revised to prohibit operation, dismantlement and disposal of the facility. This Possession-only license was in effect from 1976 until April 23, 2018 when it was revised to allow dismantlement and disposal of the facility.

Effectively, the NSS has met the requirements of IO CFR 50.36a by the combination of TS Section 2, TS 3.4.2.1.e, TS 3.7.2.3 and TS 3.7.2.4. Compliance with 10 CFR 50.36a has been reinforced by the fact that all primary, auxiliary and secondary systems are deactivated, disabled and perform no active function. Furthermore, all hull penetrations are covered by welded blank flanges . Therefore, no systems were capable of discharging liquids or gases off of the ship.

MARAD has concluded now that the license has been amended to allow decommissioning, it is appropriate to revise the Technical Specifications such that they are consistent with those of plants in advanced stages of decommissioning. In addition to the proposed TSs, MARAD has developed and approved the following procedures to support them:

  • STS-005-022, Radioactive Waste Process Control Plan
  • STS-005-018, Radiological Environmental Sampling and Monitoring
  • STS-005-013, Radioactive Material Shipping and Handling 9 of70

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018 4.2 PRECEDENT MARAD is not aware of any recent precedent of a former Possession-only licensee converting their Technical Specifications from the Mothballed requirements of RG 1.86 to the requirements of 10 CFR 50.36a, Technical Specifications on effluents from nuclear power reactors.

4.3 PROPOSED DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION MA RAD 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.

The proposed amendment is administrative and does not involve modification of any plant equipment or affect basic plant operation. The proposed amendment revises all of Technical Specification Section 2.0, Radioactive Releases from its original custom form to typical 10 CFR 50.36a, Technical Specifications on effluents from nuclear power reactors that are consistent with those of plants in advanced stages of decommissioning. The proposed amendment also deletes three Technical Specifications whose requirements are included in STS-005-020, Ojfsite Dose Calculation Manual and therefore, are no longer necessary as standalone Technical Specifications. These three Technical Specifications include one associated with the annual report, one associated with area monitoring thermoluminescent dosimeters and one associated with environmental monitoring.

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 final shutdown was completed on November 8, 1970. No aspect of any of the 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.

All of the proposed changes are administrative and do not involve physical alteration of plant equipment that was not previously allowed by Technical Specifications. The proposed amendment revises all of Technical Specification Section 2.0, Radioactive Releases from its original custom form to typical 10 CFR 50.36a, Technical Specifications on effluents from nuclear power reactors that are consistent with those of plants in advanced stages of decommissioning. The proposed amendment also deletes three Technical Specifications whose requirements are included in STS-005-020, Ojfsite Dose Calculation Manual and therefore, are no longer necessary as standalone Technical Specifications. These three Technical Specifications include one associated with the annual report, one associated with area monitoring thermoluminescent dosimeters and one associated with environmental monitoring.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018 These proposed changes do not change the method by which any safety-related system performs its function given that all primary, auxiliary and secondary systems are deactivated, disabled and perform no active function . 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.

All of the proposed changes are administrative in nature. The proposed amendment revises all of Technical Specification Section 2.0, Radioactive Releases from its original custom form to typical IO CFR 50.36a, Technical Specifications on effluents from nuclear power reactors that are consistent with those of plants in advanced stages of decommissioning. The proposed amendment also deletes three Technical Specifications whose requirements are included in STS-005-020, Offsite Dose Calculation Manual and therefore, are no longer necessary as standalone Technical Specifications. These three Technical Specifications include one associated with the annual report, one associated with area monitoring thermoluminescent dosimeters and one associated with environmental monitoring.

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.

As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings that would adversely affect plant safety or are relevant to the ship' s defueled and partially dismantled reactor as a result of the proposed changes.

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.

4.4 CONCLUSION

S 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment request is confined to (1) changes to surety, insurance, and/or indemnity requirements, or (2) changes to recordkeeping, reporting, or administrative procedures or requirements.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in IO CFR 51 .22(c)( I 0). Therefore, pursuant to IO CFR 5 l .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 June 19, 2018

6.0 REFERENCES

a. Letter from Mr. John B. Hickman, (NRC) to Mr. Erhard W. Koehler (MARAD), dated April 23 ,

2018, Nuclear Ship SAVANNAH - Issuance ofAmendment 15 to Revise the License to Allow Dismantlement and Disposal

b. Letter from Mr. John F. Stolz, (NRC) to Dr. Zelvin Levine (MARAD) and Mr. J. E. Guerry (PPDA), dated August 14, 1981 , No Title [Iss uance of Amendment 9, Adds Patriots Point Development Authority as a co-licensee]
c. Regulatory Guide 1.86, Termination of Operating Licenses/or Nuclear Reactors, June 1974
d. Letter from Mr. Robert W. Reid (NRC) to U.S. Department of Commerce, Maritime Administration, dated May 19, 1976, No Title [Issuance of Amendment 8, Possession-only License]

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U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Admtnlsnatlon Docket No. 50-238; License No. NS-1; N.S. SAVANNAH ENCLOSURE2 PROPOSED LICENSE CHANGES (MARKED-UP)

Strikethrough indicates deletions. Text Boxes include insertions when needed.

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Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 Proposed Change 5: Note deletion and insert: active decommissionin since Amendment 15" 1.0 GENERAL The Nuclear Ship N.S. SAVANNAH has been in a state of f}teteetive sterage siAee 1976 wher, the J36Ssessiefl et'lly lieeflse was issued.

Proposed Change 1: Note deletion of 2.0 RADIOACTIVE RELEASES all Sections 2.1 through 2. 4 and insert the following pages .

Raaieeetive Liei1:1ia ¥'.'aste Release Af:JJ:llieeBility '°'13J:llies eflly te Faaieeetive liei1:1ia waste aisf:)esel. ~le Feaieaetive liei1:1ias will Be J:)fed1:1eea es e Fes1:1lt ef efly fereseeA eJ:lePBtiefls eeeefa u~e SRif:l eF fl'effl !Ae s"1iJ:)'s eJ:leffitiefl. lfleiaefltel effiet:1F1ts ef liei1:1ia FABY 19e gefleffitea ifl t"1e t:1flliltely eveAt aeeeAleffiiAetitm is fetma Aeeessaf)' iA Ref:lielegieel CeAtrellef:l Areas.

0Bjeetive Te ess1:1re !Aet liei1:1ia ltiaieeeti*v1e waste releases ae Aet J:)FeseAt efl 1:1re1:1e hazard to the geAeral public or the emtiroAmeAt.

SJ:)eeif.ieatiefl Raaieaetive liei1:1ia waste releases s"1ell Be es law es reeseAeBly aeRievel:lle aAd shall AOt e>meed teA pe,eeAt (10%) of limits specified iA U.S. Nuclear Reg1:1letef)* GeffiffiissieA (~lRG) (10 GFR 20) er et"1er Sf:lf:llieel:lle Feaerel Fegt:JletieAS. Reaieeeti¥e liE1t:JiEl waste sl'lell ee seliaifiea iA eppre¥eel fl'leelie eflel may be lraAsferrod to a properly licxmsed burial facility. All solidified liquid waste s"1all be tmflsferred ifl accerdaflee wilh applicable NRG (10 CFR 71) efld U.S. Depel'tFl'leAt efTreASJ:leftetiet'l reg1:1letieAs, eAel lhe l:lt:1riel faeilifyt's lieeAse eAEI aeeef:)leflee eritefia.

Reaieaetive AiFBeFAe Peftiet:Jlete Releases Af3J:llieeeilit)* A'f3plies eflly te Feelieeetive aireeFAe J:)Brtiet:Jlete releases t"1et fl'IBY eeet:1F elt:10 te fl'leiAteAeAee reei1:1iFeffiefla st:1e"1 es et.tttir,g efld weldiflg ef eeAtefl'liAeteel 08fflJ98fleAB.

Objeeti'te To assuFe lhat radioaoti,.*e airbome particulate Feleases do Aot preseAt aA t:1flelt:1e "1e~Fel te tl'le geAeFel f:lt:1Blie er tl'le CflrwoireAfl'ICAt.

8peoificatioA No aoti'tities shall be ooAduoted that would result iA a Felease of radioaoti'>1 e aiFBeFAe paftiet:Jletes ifl C)(CCSS sf 10% ef ~fl'lits Sf:leeif.ieel iA 10 GFR 20, Appeflefilt 8, eF e!Aer epf:llieel:lle Feeleral regt:1letiet'ls.

Raf:lieaetive Liquid Waste Release Surv*eillar,ee Applicability Applies to lhe suF¥eillaAoe roquiremeAls fer ooAtrolliAg mdioactive liquid waste released te the hydrosphere.

0Bjeetwe Te ..-eFify tl'let liE:Jt:1id reaieeeti*,*e waste aisel'lBF@eel te tl'le hydrespl'leFe will Aet e>teeed 10% of limits specified ifl 10 CFR 20 or ether applicable Fede ml regtiletieAS.

Note deletion and insert Amendment 44 appropriate amendment

/\f'Fil 3 , 2008 number and date.

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Docket 50-238; License No. NS-1 ; N.S. SAVANNAH E nclosure 2 to License Am endment Requ est No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 SpeeffieetieA Liei1:11iel wastes res1:11ltifl~ freffi raeliele~ieel eleeeAtaffiiAatieA sRall ae aflal~el prior to disel'large. CMcer,tratior,s of radioactive li~uid waste sl'lall f'lOt e,teeed 19% ef tl'le applieeale liffiie ef 19 GFR 29 er etAer applieaale Feeleral regulations. RecoFds of analyses and amounts of wastes discharged shall be maintained.

Seliel Raelieaeti*,e Waste Release Applieeailff)1 Applies eAly te U:iese solia r-aelieaeti'w'e wastes 9eAer-atea as tAe res1:111t ef 9m'lerel aeeeAteffiiAetieA af Reeliele~ieel GeAtrelleeJ /1,rees , sRip Sblf'f'eillaAee ,

eAeJ eAtry iAte Reaiele~ieel GeRtrelleeJ Areas .

Oajeeti't1e Te ess1:11re lflet seliel reelieeetive waste preseAts Ae blASble Reti!erel te tRe 9eAerel p1:11alie er eA'w'ireAffieAt.

SpeeffieetieA All selia reelieeeti¥e waste sRell be ffieiAtaiAeeJ iA epprepriete eeAteiAers iA eeeer<'leRee w1tR 19 GFR 29 eAeJ etAer 01:1plieeale Feaerel re9tlletieAs eReJ sea.red in looked storage areas. TFansfers of solid radioactive ,..,aste rnay be ffieele tee lieeAseel a1:11riel feeility iA eeeereleAee witR epplieeale NRG (19 GFR

71) eAel U.S. Departffient ef TreAspertatieA re~1:11letieRs; eAel tl'le a1:11Ael feeility's license and occcptanee eFitOFia.

3.0 ADMINISTRATIVE CONTROLS 3.1 Administrative Responsibility 3.1.1 The N.S. SAVANNAH NS-1 License is held by the Senior Technical Advisor, as the responsible official for the U.S. Maritime Administration , Washington , D.C.

3.1.2 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.

3.1.3 Radiological surveys and environmental sampling will be the responsibility of MARAD and performed by an individual who meets or exceeds the qualifications of ANSI N18.1-1971 ,

paragraphs 4.3.2 or 4.5 .2. Laboratory analyses of environmental samples will be the responsibility of MARAD and reviewed in accordance with the Decommissioning Quality Assurance Plan.

3.1.4 MARAD shall have a health physicist on duty or on call to provide health physics support and direction for all entries into Radiological Controlled Areas.

3.1.5 MARAD shall have a health physicist on duty or on call within two hours to provide health physics support and direction for radiological emergencies. MARAD shall provide an Emergency Radiological Assistance Team which will provide health physics direction and Note deletion and insert Amendment 44 appropriate amendment April a, 2998 number and date.

15 of 70

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 Proposed Change 1: Insert this page 1 of 3 in place of the deleted sections 2 .1 through 2.1 Process Control Program (PCP)

The PCP shall describe the administrative and technical controls for liquid and solid radioactive waste systems management. Changes to the PCP will be outlined in the Annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain :

2.1.1. Information to support the rationale for the change and the changed pages of the PCP or a statement there were no changes; 2.1.2 A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; 2.1.3 Documentation that the change has been reviewed and found acceptable by the Safety Review Committee and approved by the Senior Technical Advisor, U.S. Maritime Administration; and, 2.1.4 Each change shall be identified by markings in the margin of the affected pages; clearly Indicating the area of the page that was changed; and , shall indicate the date (i.e., month and year) the change was implemented.

2.2 Offsite Dose Calculation Manual (ODCM)

The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents; in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints; and in the conduct of the radiological environmental monitoring program. Changes to the ODCM will be outlined in the Annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.2.1 A complete copy of the ODCM with an accompanying criteria and justification for the changes or a statement there were no changes; 2.2.2 A determination that the change(s) maintain the levels of radioactive effluent control required and by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.2.3 Documentation that the change has been reviewed and found acceptable by the Safety Review Committee and approved by the Senior Technical Advisor, U.S. Maritime Administration ; and, 2.2.4 Each change shall be identified by markings in the margin of the affected pages ; clearly indicating the area of the page that was changed ; and, shall indicate the date (i.e., month and year) the change was implemented.

2.3 Radioactive Effluent Controls Program A program shall be provided conforming to 10 CFR 50.36a for control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1 ) shall be contained in the 16 of70

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 Proposed Change 1: Insert this page 2 of 3 in place of the deleted sections 2.1 through 2.4 ODCM , (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded . The program shall include the following elements:

2.3.1 Limitations on the operability of radioactive gaseous monitoring instrumentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; 2.3.2 Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR 20, Appendix B, Table 2, Column 2; 2.3.3 Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters described in the ODCM; 2.3.4 Limitations on the annual doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas conforming to 10 CFR Part 50, Appendix I; 2.3.5 Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar year in accordance with the methodology and parameters in the ODCM at least every year; 2.3.6 Limitations on the annual doses to a member of the public from all radionuclides in particulate form in gaseous effluents released to unrestricted areas conforming to 10 CFR Part 50, Appendix I; and ,

2.3.7 Limitations on the annual dose or dose commitment to any member of the public due to release of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

2.4 Radiological Environmental Monitoring Program A program shall be provided to verify the adequacy of the programs and procedures in-place for limiting and controlling radioactive effluents and doses in unrestricted areas.

The program shall include the sampling and analysis of environmental media and pathways of exposure that are considered important, considering the scope of activities being performed . The program shalt (1) be contained in the ODCM; (2) conform to the guidance of 10 CFR 50, Appendix I; and (3) include the following :

2.4.1 Monitoring , sampling , analysis, and reporting of radiation and radlonuclides in the environment in accordance with the methodology and parameters described in the ODCM .

2.4.2 Participation in an lnterlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in the environmental sample matrices are performed as part of the Decommissioning Quality Assurance Plan for environmental monitoring.

17 of 70

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 Proposed Change 1: Insert this page 3 of 3 in place of the deleted sections 2.1 through 2.4 2.5 Reporting Requirements In addition to applicable reporting requ irements of Title 10, Code of Federal Regulations, the following reports shall be submitted prior to April 1 of each year in accordance with 10 CFR 50.4.

2.5.1 Annual Radiological Environmental Monitoring Report The Annual Radiological Environmental Monitoring Report shall include summaries ,

interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the previous calendar year. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM),

and in 10 CFR 50, Appendix I, Section IV.B.2.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the previous calendar year pursuant to the ODCM .

In the event that some Individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.

The missing data shall be submitted in a supplementary report as soon as possible.

2.5.2 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Report shall include a summary of the quantities of 1) radioactive liquid and gaseous effluents and 2) solid waste released from the NSS. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

18 of70

Docket 50-238; License No. NS-1 ; N.S. S AVANNA H to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 3.3.2.2 Visitors shall be escorted by MARAD's designated personnel.

3.3.2.3 Security for the vessel shall be provided by the license holder at all times.

3.4 Reports and Notice of Ship Movement 3.4.1 The Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C. shall make the following reports :

3.4.2 Annual Report 3.4.2.1 Prior to March 1 of each year, a written annual report shall be submitted to the NRC in accordance with 10 CFR 50.4. The report shall include the following:

a. The status of the facility;
b. The summary of results of the radiological surveys and monitoring station dosimeter readings; The summary of results of environmental sample analysis surveys; C.

d.

Proposed Change 2: Note The results of quarterly 1ntrus1on alann system ch~.5- deletion and insert "DELETED"

~

e. TF!e effleuAt ef fElaieeetive ffl8teFiels rnffle't'ea freffl ~ens. 6,AMA~~NAH ey Feleeses, aise"18Ff!1eS, eAa s"1i~ffleAts ef Feaieeetir,*e waste ffleleFiel;
f. A description of the principal maintenance performed on the vessel;
g. Any unauthorized entry into Radiological Controlled Areas 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; and
i. Results of occupational exposure indicated by personal dosimetry.

3.4.3 Reportable Events 3.4.3.1 In addition to those events that are reportable in accordance with the regulations of the NRC , the following additional events are reportable:

a. Any major damage to the vessel due to severe weather conditions or other causes ; and
b. Major flooding or sinking of the vessel .

Note deletion and insert Amendment 44 appropriate amendment Af!Fil 3, 2008 number and date .

19 of70

Docket 50-238; License No. NS-1; N.S. SAVANNA H to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

June 19, 2018 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 Radiological Controlled Areas entrances will be manned or secured.

3.7.1.3 All Radiological Controlled Area 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 MARAD trained 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.

Proposed Change 3: Note deletion and 3.7.2 Surveillance insert "DELETED" 3.7.2.1 Periodically and at least once a quarter, MARAD's designated personnel will inspect the Radiological Controlled ':-/~a entrances to verify they are properly secured and test the intrusion alarm in Tech ical Specification 3.7.1.5.

3.7.2.2 Radiological surveys of the ship will be performed at least annually and as necessary to support ship activitie in accordance with 10 CFR 20.

3.7.2.3 Thermoluminesccnt dosimeters (TLDs) or equivaleRt monitoring devices shall be placed at strate!jlie loeations throughout tho 't'essel to monitor the radiation fi:om rooster

~eRerateeJ fl"!ateAals . MARAD sMII eJeterfl"liFle U:iese leeatieRs ef'l tfie vessel SAel sRall reeit:1ire elesifl"leter reaeliFl~S at least sefl"li aF1F1t:1ally.

3.7 .2.4 Sefl"li aF1F1t:1ally, water SSFFl(:lles aF1eJ eetl:effl seeliFFleAt will be tal<en aajaeentte ti-le sRif:1 anel anal~eel fer radieaetivity.

Proposed Change 4: Note deletion 3.7.3 Vessel and System Maintenance and insert "DELETED" 3.7.3.1 Two draft level stripes will be painted fore and aft (at the draft marks), 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 Note deletion and insert appropnate amendment Amendment 44 number and date . A1=1ril 3, 2<308 20 of 70

U.S. Department Office of Ship Disposal 1200 New Jersey Ave ., SE Washington , DC 20590 of Transportation Maritime Admlnlsnatlon Docket No. 50-238; License No. NS-1; N.S. SA VANNAH ENCLOSURE3 PROPOSED LICENSE CHANGES (RETYPED)

Without footer indicating Amendment Number and Date 21 of70

Docket 50-238; License No. NS-1 ; N.S. S AVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 1.0 GENERAL The nuclear ship N.S. Savannah has been in a state of active decommissioning since Amendment 15 was issued.

2.0 RADIOACTIVE RELEASES 2.1 Process Control Program (PCP)

The PCP shall describe the administrative and technical controls for liquid and solid radioactive waste systems management. Changes to the PCP will be outlined in the Annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.1.1. Information to support the rationale for the change and the changed pages of the PCP or a statement there were no changes; 2.1.2 A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; 2.1.3 Documentation that the change has been reviewed and found acceptable by the Safety Review Committee and approved by the Senior Technical Advisor, U.S. Maritime Administration; and, 2.1.4 Each change shall be identified by markings in the margin of the affected pages; clearly indicating th e area of the page that was changed ; and, shall indicate the date (i.e., month and year) the change was implemented.

2.2 Offsite Dose Calculation Manual (ODCM)

The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents; in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints; and in the conduct of the radiological environmental monitoring program. Changes to the ODCM will be outlined in the Annua l Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain :

2.2.1 A complete copy of the ODCM with an accompanying criteria and justification for the changes or a statement there were no changes; 2.2.2 A determination that the change(s) maintain the levels of radioactive effluent control required and by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a , and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.2.3 Documentation that the change has been reviewed and found acceptable by the Safety Review Committee and approved by the Senior Technical Advisor, U.S. Maritime Administration ; and, 22 of 70

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 2.2.4 Each change shall be identified by markings in the margin of the affected pages; clearly indicating the area of the page that was changed ; and , shall indicate the date (i.e. , month and year) the change was implemented.

2.3 Radioactive Effluent Controls Program A program shall be provided conforming to 10 CFR 50.36a for control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable . The program ( 1) shall be contained in the ODCM , (2) shall be implemented by operating procedures , and (3) shall include remedial actions to be taken whenever the program limits are exceeded . The program shall include the following elements:

2.3.1 Limitations on the operability of radioactive gaseous monitoring instrumentation ,

including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; 2.3.2 Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR 20, Appendix B, Table 2, Column 2; 2.3.3 Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters described in the ODCM ;

2.3.4 Limitations on the annual doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas conforming to 10 CFR Part 50, Append ix I; 2.3.5 Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar year in accordance with the methodology and parameters in the ODCM at least every year; 2.3.6 Limitations on the annual doses to a member of the public from all radionuclides in particulate form in gaseous effluents released to unrestricted areas conforming to 10 CFR Part 50 , Appendix I; and, 2.3.7 Limitations on the annual dose or dose commitment to any member of the public due to release of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

2.4 Radiological Environmental Monitoring Program A program shall be provided to verify the adequacy of the programs and procedures in-place for limiting and controlling radioactive effluents and doses in unrestricted areas.

The program shall include the sampling and analysis of environmental media and pathways of exposure that are considered important, considering the scope of activities being performed. The program shall (1 ) be contained In the ODCM; (2) conform to the guidance of 10 CFR 50, Appendix l; and (3) include the following :

23 of70

Docket 50-238; License No. NS-1; N.S. S AVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 2.4.1 Mon itoring , sampling, analysis, and reporting of rad iation and rad ionuclides in the environment in accordance with the methodology and parameters described in the ODCM.

2.4 .2 Participation in an lnterlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in the environmental sample matrices are performed as part of the Decommissioning Quality Assurance Plan for environmental monitoring.

2.5 Reporting Requirements In addition to applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted prior to April 1 of each year in accordance with 10 CFR 50.4.

2.5.1 Annual Radiological Environmental Monitoring Report The Annual Radiological Environmental Monitoring Report shall include summaries ,

interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the previous calendar year. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM),

and in 10 CFR 50, Appendix I, Section IV.B.2.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of all radiological environ mental samples and of all environmental radiation measurements taken during the previous calendar year pursuant to the ODCM.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.

The missing data shall be submitted in a supplementary report as soon as possible.

2.5.2 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Report shall include a summary of the quantities of 1) radioactive liquid and gaseous effluents and 2) solid waste released from the NSS. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50 , Appendix I,Section IV.B.1.

24 of 70

Docket 50-238; License No. NS-1; N.S. SAVANNA H to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 3.0 ADMINISTRATIVE CONTROLS 3.1 Administrative Responsibility 3.1.1 The N.S. Savannah NS-1 License is held by the Senior Technical Advisor, as the responsible official for the U.S. Maritime Administration , Washington , D.C.

3.1.2 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.

3.1.3 Radiological surveys and environmental sampling will be the responsibility of MARAD and performed by an individual who meets or exceeds the qualifications of ANSI N18.1-1971 , paragraphs 4.3.2 or 4.5.2. Laboratory analyses of environmental samples will be the responsibility of MARAD and reviewed in accordance with the Decommissioning Quality Assurance Plan.

3.1.4 MARAD shall have a health physicist on duty or on call to provide health physics support and direction for all entries into Radiological Controlled Areas .

3.1.5 MARAD shall have a health physicist on duty or on call within two hours to provide health physics support and direction for radiological emergencies. MARAD shall provide an Emergency Radiological Assistance Team which will provide health physics direction and 25 of 70

Docket 50-238; License No. NS-1; N.S. S AVANNAH to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 3.3.2.3 Security for the vessel shall be provided by the license holder at all times.

3.4 Reports and Notice of Ship Movement 3.4.1 The Senior Technical Advisor, U.S. Maritime Administration , Washington , D.C. shall make the following reports:

3.4.2 Annual Report 3.4.2.1 Prior to March 1 of each year, a written annual report shall be submitted to the NRC in accordance with 10 CFR 50.4. The report shall include the following :

a. The status of the facility;
b. The summary of results of the radiological surveys and monitoring station dosimeter readings;
c. The summary of results of environmental sample analysis surveys;
d. The resu lts of quarterly intrusion alarm system checks;
e. DELETED;
f. A description of the principal maintenance performed on the vessel;
g. Any unauthorized entry into Radiological Controlled Areas 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; and
i. Results of occupational exposure indicated by personal dosimetry.

3.4.3 Reportable Events 3.4.3.1 In addition to those events that are reportable in accordance with the regulations of the NRC, the following additional events are reportable:

a. Any major damage to the vessel due to severe weather conditions or other causes; and
b. Major flooding or sinking of the vessel.

26 of 70

Docket 50-238; License No. NS-1; N.S. S AVANNA H to License Amendment Request No. LAR 2018-02 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

June 19, 2018 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 Rad iological Controlled Areas entrances will be manned or secured .

3. 7.1.3 All Radiological Controlled Area entrances wi ll 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 vis ual signals that will alert a manned security guard post.

3.7.1.6 MARAD trained 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 Technica l Specifications , Administrative Controls.

3.7.2 Surveillance 3.7 .2 .1 Periodically and at least once a quarter, MARAD's desig nated personnel will inspect the Radiological Controlled Area entrances to verify they are properly secured and test the intrusion alarm in Technical Specification 3. 7 .1.5.

3.7.2.2 Radiological surveys of the ship will be performed at least annually and as necessary to support ship activities in accordance with 10 CFR 20.

3.7.2.3 DELETED.

3.7.2.4 DELETED.

3.7.3 Vessel and System Maintenance 3.7.3.1 Two draft level stripes will be painted fore and aft (at the draft marks), one will be j ust 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 27 of70

0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave ., SE Washington , DC 20590 of Transportation Maritime AdmlnfstJatlon Docket No. 50-238; License No. NS-1; N.S. S AVANNAH ENCL0SURE4 STS-005-020, RO OFFSITE DOSE CALCULATION MANUAL (ODCM)

The procedure is the following 20 pages.

28 of70

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