ML20255A084

Us Dept. of Transportation, Maritime Admin: Administrative Changes to Technical Specifications - License Amendment Request No. LAR 2020-01

ML20255A084
Person / Time
Site:	NS Savannah
Issue date:	09/04/2020
From:	Koehler E US Dept of Transportation, Maritime Admin
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LAR 2020-01
Download: ML20255A084 (31)

Text

0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Ref: 10 CFR 50.90 September 4, 2020 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. LAR 2020-01 Administrative Changes to Technical Specifications Reference (a) Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC), dated February 18, 2020, Notification of Delay in Painting Draft Level Stripes required by Technical Specifications (Docket No. 50-238, License-No. NS-1)

Pursuant to 10 CPR 50.90, the United States Maritime Administration (MARAD) hereby requests approval to amend the Nuclear Ship SAVANNAH (NSS) Facility Operating License, NS-1 (License) and incorporate the enclosed proposed changes into the NSS license.

The proposed license amendment will revise three Technical Specifications (TSs):

• TS 3.4.2.1 c. will be revised to "DELETED."

Currently, this TS requires reporting data in the TS 3.4.2 Annual Report that is also required to be reported in the TS 2.5.1 Annual Radiological Environmental Monitoring Report.

• TS 3.7.1.l will be revised to "DELETED."

Currently, this TS requires controlling access to the Containment Vessel (CV). The CV is a radiologically controlled area (RCA). TS 3.7.1.2 requires controlling access to all RCAs.

Because the scope of TS 3. 7.1.1 is a subset of the scope of TS 3. 7 .1.2, it is redundant to TS 3.7.1.2.

• TS 3. 7 .3 .1 will be revised to "The ship's draft will be monitored daily as an indication of hull integrity. Unexpected changes in draft are indications of compromised integrity, such as water in-leakage or flooding. If there is an unexpected change in draft, the ship shall be surveyed to determine the cause of the draft change. Ifleakage or flooding is the cause, the ship will be pumped out, and repairs made as may be required, including dry-docking if determined necessary, in order to assure that the integrity of the hull is maintained."

Currently, this TS requires painting yellow draft stripes that allow distant observers to monitor the ship's draft. The requirement is appropriate for a ship that is in protective storage and whose draft and trim are not expected to change. During active decommissioning, significant changes in the ship's draft and trim will occur as large reactor and auxiliary system components are

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2020-001 September 4, 2020 dismantled and removed from the ship. Dismantling equipment brought on and off the ship may also noticeably change the ship's draft.

The License Amendment Request is provided in three (3) enclosures to this letter. Enclosure 1 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 entire Technical Specifications that includes the proposed changes.

MARAD has reviewed the proposed changes comparing them to the current license basis in accordance with 10 CFR 50.92 and concludes that they involve no significant hazards consideration.

Pursuant to 10 CFR 50.9l(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 February 4, 2021, for implementation within 30 days from the date of approval.

This letter contains no commitments.

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

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

Executed on September 4, 2020 Respectfully, Erhard W. Koehler Senior Technical Advisor, N.S. SAVANNAH Office of Ship Disposal Enclosures (3) 2

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2020-001 September 4, 2020

Enclosures:

1. Evaluation of License Amendment Request

2. Proposed Technical Specification Changes (marked-up)

3. Proposed Technical Specification Changes (retyped) 3

Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2020-001 September 4, 2020 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 (Ted Smith, Katherine Warner)

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

EK/jmo 4

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

Subject:

Administrative Changes to Technical Specifications EVALUATION of LICENSE AMENDMENT REQUEST ......................................... 5 1.0

SUMMARY

DESCRIPTION ....................................................................................................... 6 2.0 DETAILED DESCRIPTION OF PROPOSED CHANGES ......................................................... 7 2.1 Proposed Change 1: Delete Technical Specification 3.4.2.1 c ............................................ 7 2.2 Proposed Change 2: Delete Technical Specification 3.7.1.1 ............................................... 7 2.3 Proposed Change 3: Revise Technical Specification 3.7.3.1 ............................................ 11

3.0 TECHNICAL EVALUATION

................................................................................................... 13 4.0 REGULATORY SAFETY ANALYSIS ..................................................................................... 14

-- 4.-l Applicable Regulatory_RequirementsLCriteria ........................................._......................._.... 14 4.2 Precedent ............................................................................................................................. 14 4.3 Proposed Determination of No Significant Hazards Consideration .................................... 14

5.0 ENVIRONMENTAL CONSIDERATION

.................................................................... .'............ 16

6.0 REFERENCES

............................................................................................................................ 17 PROPOSED LICENSE CHANGES (MARKED-UP) ............................................... 18 PROPOSED LICENSE CHANGES (RETYPED) ..................................................... 22 5

Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2020-001 September 4, 2020 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating License NS- I for the Nuclear Ship SAVANNAH (NSS).

Maritime Administration (MARAD) is a modal agency of the United States Department of Transportation (DOT). It is a Federal licensee as defined by the NRC. As such, funds for decommissioning and termination of the NSS license are provided by Federal appropriations. As a result of signing the Consolidated Appropriations Act for FY 2018, decommissioning of the NSS is fully funded with the $131 million estimated to complete decommissioning and terminate the NSS license.

The proposed license amendment will revise three Technical Specifications (TSs):

• TS 3.4.2.1 c. will be revised to "DELETED."

Currently, this TS requires reporting data in the Annual Report that is also required to be reported in the TS 2.5.1 Annual Radiological Environmental Monitoring Report.

• TS 3.7.1.1 will be revised to "DELETED."

Currently, this TS requires controlling access to the Containment Vessel (CV). The CV is a radiologically controlled area (RCA). TS 3.7.1.2 requires controlling access to all RCAs.

Because the scope of TS 3. 7 .1.1 is a subset of the scope of TS 3. 7 .1.2, it is redundant to TS 3.7.1.2.

• TS 3. 7.3. I will be revised to "The ship's draft will be monitored daily as an indication of hull integrity. Unexpected changes in draft are indications of compromised integrity, such as water in-leakage or flooding. If there is an unexpected change in draft, the ship shall be surveyed to determine the cause of the draft change. If leakage or flooding is the cause, the ship will be pumped out, and repairs made as may be required, including dry-docking if determined necessary, in order to assure that the integrity of the hull is maintained."

Currently, this TS requires painting yellow draft stripes that allow distant observers to monitor the ship's draft. The requirement is appropriate for a ship that is in protective storage and whose draft and trim are not expected to change. During active decommissioning significant changes in the ship's draft and trim will occur as large reactor and auxiliary system components are dismantled and removed from the ship. Dismantling equipment brought on and off the ship may also noticeably change the ship's draft.

MARAD requests approval of the proposed License Amendment by February 4, 2021 for implementation within 30 days from the date of approval.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 2.0 DETAILED DESCRIPTION OF PROPOSED CHANGES

2.1 PROPOSED CHANGE

1: DELETE TECHNICAL SPECIFICATION 3.4.2.1 C Currently, TS 3 .4.2.1 requires the submitting an annual report that includes items specified in the TSs.

One of these items is 3.4.2.1 c. It requires the annual report to include:

c. The summary of results of environmental sample analysis surveys.

This same information is also required by TS 2.5.1 Annual Radiological Environmental Monitoring Report which was created by Amendment 17 (Reference a). Specifically, The Annual Radiological Environmental Monitoring Report shall include the results analyses of all radiological environmental samples and of all environmental radiation measurements taken during the previous calendar year pursuant to the ODCM.

MARAD proposes that TS 3.4.2.1 c should be replaced with the word "DELETED" given that it is redundant to and a subset of the information required to be submitted by TS 2.5.1.

2.2 PROPOSED CHANGE

2: DELETE TECHNICAL SPECIFICATION 3.7.1.1 Currently, TS J. 7.1.1 requites:- --

All containment vessel entrances shall be either manned or secured.

The current TS was created in Amendment 16 (Reference b) and has evolved from the Possession-only license Technical Specifications (Reference c) from 1976 when the NSS was first placed into the Mothballed "alternative for retirement." The original TS was created to meet Regulatory Guide (RG) 1.86 1, Termination of Operating Licenses for Nuclear Reactors, Reference (d). Consistent with RG

1. 86, the underlying intent was to prevent inadvertent exposure of personnel by preventing them from accidently entering radiation areas. The original TS made entry into the containment vessel (CV) extremely difficult. As a result, no CV entries were made after 1976 until the April 2005 characterization scoping survey.

RG.1.86 states the following regarding locked barriers:

C. Regulatory Position

3. Surveillance and Security for the Retirement Alternatives Whose Final Status requires a Possession-Only License

a. Physical security to prevent inadvertent exposure of personnel should be provided by multiple locked barriers. The presence of these barriers should make it extremely difficult for an unauthorized person to gain access to areas where radiation or contamination levels exceed those specified in Regulatory Position C.4.

To prevent inadvertent exposure, radiation areas above 5 mR/hr, such as near the activated primary system of a power plant, should be appropriately marked and should 1

MARAD understands RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12, 2016 and that its withdrawal does not impact the NSS licensing basis.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 not be accessible except by cutting of welded closures or the disassembly and removal of substantial structures and/or shielding material.

Means such as a remote readout intrusion alarm system should be provided to indicate to designated personnel when a physical barrier is penetrated.

Security personnel that provide access control to the facility may be used instead of the physical barriers and the intrusion alarm systems.

The project to dismantle the nuclear facilities of the NSS has progressed to a point where large components will be removed from the CV in the next phase of the project. To support this effort, MARAD has removed the cupola head and the associated shielding. MARAD is storing the cupola head and shielding on the adjacent pier. After dismantlement activities in the CV are complete, MARAD plans to reinstall the cupola head and shielding.

Removing the cupola and shielding prior to submitting this proposed amendment is allowed by TS 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.

This Technical Specification is implemented and administratively controlled by STS-004-01 4, Preparation of Technical Specification 3.7.1.7 Deviations. This procedure has been informally reviewed during past inspections. An assessment of this process was reviewed at the December 2019 Safety Review Committee meeting. This meeting was observed by the NRC inspector as part of the 2019-001 NRC inspection.

With the cupola head removed, there is an approximately 13.5 feet diameter opening that allows access from the A deck of the Reactor Compartment Upper Level (RCUL) into the CV. Prior to the cupola head removal in March 2020, the cupola access had not been opened since the defueling in 1971. See Figure 2-1 , Containment Vessel Location and Figure 2-2, Cupola Head Location.

FIGURE 2-1 CONTAINMENT VESSEL LOCATION 8

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 j

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FIGURE 2-2 CUPOLA HEAD LOCATION (LOOKING PORT)

The drawing is a portion of New York Ship Building Drawing 529-800-8. Frame spacing is approximately 30 inches. The drawing notates the CV as "Reactor Space."

The current FSAR states:

There are seven openings which can be used for access or equipment removal. All but one (the double-door air lock) of these openings are bolted closures. In 2018, the D-deck CV door was created by installing a watertight double door in the vicinity of Frame 108 starboard. The 42 inch double-door air lock permitted entering the containment without breaking containment integrity. In addition to the air lock, a 42 inch diameter lockable (or bolted) grating is located forward of the cupola. This hatch can also be used for access and servicing of small equipment when the plant is shutdown. The aft CV entry shield plug and forward CV portable shield cover that were part of the secondary shielding have been removed.

The FSAR continues with a discussion of the four CV accesses that were not intended as entrances:

A 13 1/2 feet, full-diameter hatch at the top of the cupola is provided for major maintenance and refueling operations. A 51/2 feet diameter hatch is located in the top of the cupola for control rod drive removal. Two combination, 18" x 24" manways and flooding hatches are located on the starboard side in the lower quarter of each hemispherical head.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 As shown in Figure 2-2 Cupola Head Location and Figure 2-3, Reactor Hatch and Cupola Head, when the cupola head is removed, there will be an approximately 13 .5 feet diameter opening from the CV to the reactor compartment upper level at A Deck.

r-f- - :i____

I Sh' IP q; CUPOLA HEAD LOOKING AFT FIGURE 2-3 REACTOR HATCH AND CUPOLA HEAD Similar to that of TS 3.7.1.1, the underlying intent of TS 3.7.1.2 is to prevent inadvertent exposure of personnel by preventing them from accidently entering radiation areas per RG 1.86.

With th is semi-permanent opening, compliance with TS 3.7.1.1 will be impossible. TS 3.7.1.1 is redundant to TS 3.7.1.2 which will continue to completely control access to radiologically controlled areas:

All Radiological Controlled Areas entrances will be manned or secured.

When not in use, the cupola head opening will be effectively secured by closing the reactor hatch.

When the reactor hatch is shut, entry into the CV first requires entering the reactor compartment through one of its entrances or through the D deck CV Door. In all cases, these are entrances to RCAs and therefore, access through them is controlled by TS 3.7.1.2 A safety benefit of this proposal is the forward and aft 42 inch CV accesses will no longer be required to be locked or guarded. Currently, these two openings are secured with chains and quicklinks (a threaded chainlink). In an emergency, access to and egress from the CV via the 42 inch accesses is improved when these chains are removed.

MARAD proposes that TS 3.7.1.1 should be replaced with the word "DELETED" given that it is redundant to and a subset of TS 3. 7 .1.2.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020

2.3 PROPOSED CHANGE

3: REVISE TECHNICAL SPECIFICATION 3.7.3.1 Currently, TS 3.7.3.1 requires:

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

This ship surveillance specification dates to a period after final shutdown in 1971. In Reference ( e),

TSs were revised to allow an extended defueled condition anticipating the reactor may be refueled.

Regarding the ship's draft, TS 7.10 B included a check of the ship's draft marks [Emphasis added] on a daily basis on normal work days. .

In 1976 when the Possession-only License (POL) (Reference c) was issued, the TSs first included a requirement to paint draft level stripes and observe them on a daily basis. The POL was written in anticipation of the ship's relocation to a MARAD National Defense Reserve Fleet site, where the ship would not be staffed. The draft level stripes and other ship surveillances added in Section 3.8 of the POL TS reflected MARAD practices for ships in long-term layup. When the NSS was permanently defueled and in long term protective storage, there was no expectation of significant changes to the ship's draft and trim that would then require repainting the draft level stripes.

The underlying intent of these daily ship surveillances [check of ship's draft marks and observe draft level stripes] is to discover water in-leakage or flooding so that corrective actions can be taken. There is a distinction between the ship's draft marks, as described in the Reference (e) surveillance, and the draft stripes described in Reference (c) through and including the current TS.

FIGURE 2-4 DRAFT MARKS AND LEVEL STRIPES 11

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 Ship's Draft Marks The ship's draft marks are Arabic numerals, six (6) inches in height whose outlines are welded to the ship's hull and are painted in colors that contrast with the hull surface paint.

See Figure 2-4. The draft marks are legible with the naked eye at sh01t distances only, such as from the edge of a pier at which the ship is berthed. It is common maritime practice that these are observed and recorded on a daily basis.

TS 3.7.3.1 Draft Level Stripes The draft level stripes are intended to be visible over long distances. They are routinely employed in MARAD reserve fleet sites, where ships are nested in rows, and observed from small boats or from a shore facility (distances of one mile or more). The contemporary MARAD specification for draft stripes states:

All vessels shall have waterline markings painted on the hull. Four (4) inch wide stripes along the waterline extending horizontally thirty-six (36) inches toward midships from the bow and stern on both sides of the vessel. Markings shall be of two coats of highly visible (e.g., reflective white or international orange) paint and applied to perform wefl over a long period of time. A second marking stripe shall be applied approximately two feet above the waterline.

For ships in a reserve fleet anchorage, the draft level stripes allow distant roving patrols and shore observers to detect flooding without having to employ risky, close-in small boat operations to monitor, record and compare-dran marks from day:.to-day. Note-that when-the NSS-was located at the James River Reserve Fleet at Fort Eustis, VA, the ship was in the middle of an approximately two mile wide section of the James River. In this situation, on shore personnel observed the draft level stripes by video camera and a roving river patrol.

Effective with the issuance of License Amendment 15 (Reference t), the NSS status changed from protective storage to active decommissioning. During active decommissioning significant changes in ship's draft and trim will occur as large reactor and auxiliary system components are dismantled and removed from the ship. Dismantling equipment brought on and off the ship may also noticeably change the ship's draft. The resulting significant changes in draft and trim will require routinely repainting draft level stripes that only should have been appropriate for a protective storage condition.

Throughout active decommissioning, the NSS will be berthed at a pier where the ship's fore and aft draft marks will be readily observable from the pier and, remotely, by video cameras. In addition, active flood detection systems will be functional in all the ship's compartments that are contiguous with the sea. These flood detectors will alarm locally and, remotely, at a 24/7 central alarm monitoring station.

Given that during active decommissioning when the ship's draft will routinely change and numerous methods to detect unanticipated changes in the ship's draft are available, MARAD proposes revising TS 3.7.3.1 as follows:

The ship's draft will be monitored daily as an indication of hull integrity. Unexpected changes in draft are indications of compromised integrity, such as water in-leakage or flooding. If there is an unexpected change in draft, the ship shall be surveyed to determine the cause of the draft change. If leakage or flooding is the cause, the ship will be pumped out, and repairs made as may be required, including dry-docking if determined necessary, in order to assure that the integrity of the hull is maintained.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020

3.0 TECHNICAL EVALUATION

As described in Section 2, all three proposed changes are administrative in nature and involve no technical issues.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 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.

MARAD holds a Possession-only license for the NSS nuclear utilization facilities that was modified by License Amendment 15 (Reference f) to allow dismantlement and disposal. As a result of License Amendment 15, the status of the facility is "Dismantlement."

The Possession-only license was based on RG 1.86, Reference ( d). 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-I, Reference ( d). MARAD understands RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12, 2016 and that its withdrawal did not impact the NSS licensing basis.

As the project has progressed into active decommissioning, MARAD continues to discover issues in the Technical Specifications that were appropriate to the mothballed protective storage condition that are not appropriate during dismantling and require changes. Proposed Changes 2 and 3 are both examples. Proposed Change 1 will eliminate a redundancy introduced by License Amendment 17, Reference (a).- - ---- -

4.2 PRECEDENT These proposed changes invoke no specific precedents.

4.3 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 IO CFR 50.92, "Issuance of amendment," as discussed below.

I) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes are administrative and do not involve 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.

14

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020 All of the proposed changes are administrative and do not involve physical alteration of plant equipment that was not previously allowed by Technical Specifications. These proposed changes do not alter the method by which any safety-related system performs its function. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is not altered. 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. No margins of safety exist that are relevant to the ship's defueled and partially dismantled reactor. As such, no changes are 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.

Therefore, the proposed changes do not involve a significant reduction in any margin of safety.

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-wilLnotbe inimical to the common_defens~ an_dst;!~urjty or to the health a~d s_afe~_of the public.

Based on the above, the proposed changes present no significant hazards consideration under the standards set forth in IO CPR 50.92( c), and, accordingly, a finding of "no significant hazards consideration" is justified.

15

Docket No. 50-238; License NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 September 4, 2020

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment request 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.

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Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure *1 to License Amendment Request No. LAR 2020-001 September 4, 2020

6.0 REFERENCES

a. Letter from Mr. Theodore B. Smith (NRC) to Erhard W. Koehler (MARAD), dated June 11, 2019, Nuclear Ship SAVANNAH - Issuance of Amendment 17 to Revise the Technical Specifications to Revise the Radioactive Effluent Controls and Make an Administrative Change

b. Letter from Mr. John B. Hickman (NRC) to Erhard W. Koehler (MARAD), dated June 12, 2018, Nuclear Ship SAVANNAH - Issuance of Amendment 16 to Revise the Technical Specifications to Establish Controls for all Accesses to the Containment Vessel in support of Two Structural Modifications

c. 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]

d. Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974

e. Letter from Mr. Peter A. Morris (NRC) to Mr. D. L. Crook (MARAD), dated April 13, 1971, No Title [Issuance of Change No. 11 to the Technical Specifications]

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

2018, Nuclear Ship SAVANNAH - Issuance of Amendment 15 to revise the License to allow Dismantlement and Disposal 17

0 U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration 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 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARKED-UP)

September 4, 2020 3.3.1.2 All entries into Radiological Controlled Areas shall be in accordance with the licensee's radiation protection program.

3.3.2 Access Control and Security 3.3.2.1 The license holder shall control all access to the vessel through assignment of designated personnel with appropriate administrative procedures and physical security provisions.

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 ~he 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,....;t;;..;.h.;;;..e...;..ra=d;;...io.;;;..l=o..,..;.;;...........;;;;..;;......;...;;;..<-.;;...;;;;.....;................;;..;..;;;.................__...._,

dosimeter readings; Replace crossed-out text with the word "DELETED:"

C. Tl=le SUFflf'flary ef res~ f environFRental saFR~le analysis surveys;

d. The results 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 19

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARKED-UP)

September 4, 2020

b. Evaluations required by 10 CFR 50.59;

c. Proposed changes or modifications to a Radiological Controlled Area entry alarm system or reactor containment vessel system;

d. Evaluations of substantive changes to the results of radiological surveys;

e. Procedures and revisions per Technical Specification 3.5;

f. Evaluations of reported violations of Technical Specifications;

g. Evaluations of reportable events per Technical Specification 3.4.3.1 ;

h. Evaluations of deviations allowed by Technical Specification 3. 7.1.7;

i. Audits and self assessments to verify the effectiveness of the Decommissioning Quality Assurance Plan; and,

j. Annual reports to the NRC.

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

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 to review evaluations of Reportable Events per Technical Specification 3.4.3.1 .

3.6.6 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 Radiological Controlled 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.

3.7.1 Access Control ~ Replace crossed-out text with the word "DELETED."

3.7.1.1 /\II oontainment ..-eosel entranoes shall l:le either manned or seo1:1red.

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.

20

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARKED-UP)

September 4, 2020

3. 7.1.5 The B Deck Reactor Compartment Door at Frame 122, the C Deck Door to the Cold Chemistry Laboratory and the D Deck Containment Vessel Door shall be either:

a) Manned or b) Locked from the outside and fitted with an intrusion alarm that alerts a security monitoring station.

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.

3.7.2 Surveillance 3.7.2.1 Periodically and at least once a quarter, MARAD's designated 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.

Replace crossed-out text with the following: "The ship's draft will be 3.7.2.3 DELETED. monitored daHy as an indication of hull integrity. Unexpected changes In draft are indications of compromised integrity, such as water in-leakage or flooding. If there is an Wlexpecled change in draft, the ship shall be 3.7.2. 4 DELETED. surveyed to determine the cause of the draft change. If leakage or flooding is the cause, the ship will be pumped out, and repairs made as 3.7.3 Vessel and System Maintenance may be required, including dry-docking if determined necessary, in order

~ to assure that the integrity of the hull is maintained ."

3.7.3.1 Two EIFaft le'f'el stripes will be peiRted f.ere eAEI aft (at tl=le draft FAOFIEs), oRe will be just abe't*e tl=le water le*,*el aREI tl=le upper stripe will be eRe foet abe*te tl=le lewer. Tl=lese will be ebsePt*eEI Eleily te el=leek if tl=le dFaft Meo iAereased . Betl=I stripes FAust always be 'f'isible. If tl=le lower stripe is Ret visible, tl=le sl=lip sl=lell be suFYeyeEI aREI tl=le *water leakai:,e leeateEI. Tl=le seuree ef lealEai:,e will be EleterFAiAeEI, tl=le sl=lip puFAped eut, aAd repairs FAede as FASY be re~uired ,

iReh:1EliA§ Elry EleelEiA§ if deteFFAiAeEI Aeeessery, iA ereer te assure tl=lat tl=le iAtei:,rity ef tl=le Mull is Fl'IOiAtaiAeEI.

3.7.3.2 A cath odic 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.

3.7.3.3 An underwater inspection of the hull will be conducted at least every four (4) years. The vessel will be dry~ocked 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.

21

U.S. Department Office of Ship Disposal 1200 New Jersey Ave., SE Washington, DC 20590 of Transportation Maritime Administration Docket No. 50-238; License No. NS-1; N.S. SAVANNAH ENCLOSURE3 PROPOSED LICENSE CHANGES (RETYPED) 22

Docket 50-238; License No. NS-1; N.S. SAVANNAH Enclosure 3 to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 1.0 GENERAL The nuclear ship N.S. Savannah has been in a state:of active decommissioning since Amendmemt 15 was issued.

2.0 RADIOACTIVE RELEASES 2.1 Process Control Program (PCP)

Ttie 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 Reiease *Rep_ort Rer. Sectiqn_ 2.5.2. This submitt~I sh_all 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 rec;luce 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-Comrriittee-and-approved.by.cthe-Senior-TechnicaLAdvisor,--- ------- ---

U.S. Maritime Administration; and';

• 2.1.4 Each_ change shciil be ide11tified by mar~ings ,i,i 'the ,rn_argjri of the a.ff~cted pages; clea_rly indi~ting the area of the,page that w_as changed; an.d, shali indlcate the date (i.e., month and -year) the change was implemented.

2.2 Offsite Dose Calculation Manual (ODCM)

The ODOM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous am,! liquid effluents; in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints; and in the conduct of the radiological ehvirohmental monitoring program. Changes to the ODCM will be outlined in the Annual Radioactive* Effh.u~nt Release Report per Section 2.5.2. This submittal shall _contain:

2.2.1 A corn,plete COPY ofthe ODCM with an accompanying criteria c1nd j1,Js\1fication 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 CF.R 50, Appendix I, and not adversely impact the accuracy or reliability of effh.ient, dose, or setpoirit calculations; 2.2.3 Documentation that the change has been reviewed and found acceptable by-the Safecy Review Committee and approved by the Senior Technical Advisor, U,S. Maritime Ad!Jiinistration; and, 2.2.4 Each cha.nge sha_ll be identified by markings irdhe margin of the affected pages; clearly indicating _the area of the page that was changed; and, shail indicate the date (i.e., month and year) the change was implemented.

23

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 2.3 Radioactive Effluent Controls Program Aprogram shall be provided conformi11g to 1J) CFR 5Q.36a for control of radioactive effiuents 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 lirnits are exceeded. The program shall include thefollowing elements:

2.3.1 Limitations on the operability of r'ijdioactive gaseous monitoring instn.imentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; 2.3.2 Lin,itations on the concentrations of radioactive material released in liquid efflue11ts to unrestricted areas conforming to 10 CFR 20, Appenqix 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- --[imitations on tne ahnuart:loses or close-commitment b 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 an_d projected dose contributions frorr1 radioactive effluents for the current calendar year i11 accordance witJ1 the n.,ethodology and parameters in the ODCM at least every year; 2.3.6 Limitations on the annual doses to a member of the public from an*

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 commitmenno 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 Envirol')mental Monitoring Program

~ progran, shall be pn;>vided to verify the adequacy of the programs a_nd procequres in-place for limiting and controliing 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 I; and (3) include the following:

2.4.1 Monitoring, sampling, analysis, and reporting bf radiation and radibriuclides in the environment iri accordance with the methodology and parameters described in the ODCM. .

24

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 l

I PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 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 Fecieral 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 Radidlogical Environment~! Monitor:ing Report shall inclwde summaries,

,n,teri:'.!retaU~ns, and analyses of trenc~s of t_he results of the radiological environmental monitoring program for the previous calendar year. The material. provided shall be consistentwith the objectives.outlined in theOffsite Dose Calculation Manual (ODCM),

and in 10 CFR 50,.Appendix I,Section IV.8.2.

- - -+he Annual-Radiological"Environmental Monitoring Report shall include. the results.of_

analyses qf all radiological environmental samples and of all environmental radiation measurements taken dur,ing the previous calendar year pursuant to the ODCM.

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

Ttie missing data s.hal! be submitted in a supp,ernentary 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 arid in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

3.0 ADMINISTRATIVE CONTROLS 3.1 Administrative Respcmsibility 3.1.1 The N.S. Savannah NS-1 License is held by the Senior Te~hnipal Advisor; as t'1e responsible officiE;il for the U.S. Maritime Admihistraticm, 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, paragrc1phs 4.3.2 or 4.5.2. Laboratory analyses of environmental samples will be 25

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 the responsibility of MARAD and reviewed in accordance with the Decommissioning Quality Assurance Plan.

3.1.4 MARAD shall have a health physicist on dQty 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 support in the event of an on-board emergency such as fire, flooding or intrusion. In the event of fire, entry may be made into the effected Radiological Controlled Areas except the reactor containment vessel, without the support and direction of a health physicist.

3.2 Records 3.2.1 In addition to the records and documents required by applicable regulations, the Senior Technical Advisor, U.S. Maritime Administration, Washington, D.C., and other assigned personnel shall maintain the following records and documents in accordance with the Decommissioning Quality Assurance Plan:

-a Health-Physics Records:-

(i) Personnel Exposure; (ii) Ship's Radiological Surveys; and (iii) Environmental Surveillance and Laboratory Analyses;

b. DELETED;

c. DELETED;

d. Quarterly Inspections of Physical Barriers and Intrusion Alarms;

e. Licensee Event Reports (LER);

f. Records of Safety Review Committee Meetings;

g. File of Annual Reports to the NRC; and

h. Drawings, prints, layouts and specifications for the ship.

3.3 Radiological Criteria, Access Control and Security 3.3.1 Radiological Controlled Areas 3.3.1.1 Radiological Controlled Areas are "Restricted areas" as defined in 10 CFR 20 and in the radi~tion protection program developed in accordance with 10 CFR 20.

26

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 3.3.1.2 All entries into Radiological Controlled Areas shall be in accordance With the licensee's radiation protection program.

3.3.2 Access Control and Security 3.3.2.1 The license holder shall control all access to the vessel through assignment of designated persormel with appropriate adm.!11istrative procedures and physical security provisions.

3.3.2.2 Visitors shall be escorted by MARAD's clesjgnatecl 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 NRG 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. DELETED;

d. The results of quarterly intrusion alarm system checks;

e. DELETED;

f. A description of the principal maintenance performed on the vessel;

g. Any unauthorized entry irito Radiological Controlled Areas and corrective action taken to improve access control_;

h. Any degradation of one of the several b0undaries 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 add_ition 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 27

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

Septem her 4, 2020

b. Major flooding or sinking of the vessel.

3.4.3.2 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.

3.4.3.3 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).

3.4.4 Notice of Ship Movement 3.4.4.1 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 dry-docked in any U.S. domestic location having a U.S. Maritime Administration approved Port Operating Plan.

3.5 Procedures and Operating Instructions 3.5.1 Activities which are designated as within the scope of the Decommissioning Quality Assurance Plan shall be prescribed by written, reviewed and approved procedures of a

-type appropriate~to the circumstances. -

3.5.2 Procedures and any subsequent revisions shall be reviewed and approved as required by the Decommissioning Quality Assurance Plan.

3.6 Safety Review Committee 3.6.1 The Safety Review 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 membershJp experience shail include an appropriate balance of bqth maritime and commercial nuclear (operating anq/or decommissioning) expertise. The permanent members include the following:

a. Senior Technical Advisor;

b. Decommissioning Program Manager;

c. Facility Site Manager;

d. Quality Assurance Manager; and,

e. An individual who meets or exceeds the qualifications of ANSI N18.1-1971 paragraphs 4.3.2.

3.6.2 A minimum of three 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 review all of the following items:

a. Proposed changes to Technical Specifications; 28

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020

b. Evalu~tions required by 10 CFR 50.59;

c. Proposed changes or modifications to a Radiological Controlled Area entry alarm system or reactor containment vessel system;

d. Evaluations of substantive changes to the results of radiological surveys;

e. Procedures and revisions per Technical Specification 3.5;

f. Evaluati6ns of reported violations of Technical Specifications;

g. Evaluations of reportable events per Technical Specification 3.4.3.1;

h. Evaluations of deviations allowed by Technical Specification 3.7.1.7;

i. Audits and self assessments to verify the effectiveness of tile Decommissioning Quality Ass'-'rance Plan; and,

j. Annual reports to the NRC.

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

3.6.5 The Committee shall be co-nvened oy the Chairman and shall meet annually to review -

and discuss events of the preceding period. The Cornmittee will rneet when necessary to review evaluations of Reportable Events per Technical Specification 3.4.3.1.

3.6.6 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 Radiological Controlled 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.

3. 7.1 Access Control 3.7.1.1 DELETED.

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.

29

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020

3. 7 .1.5 The B Deck Reactor Compartment Door at Frame 122, the C Deck Door to the Cold Chemistry Laboratory and the D Deck Containment Vessel Door shall be either:

a} Manned or b} Locked from the outside arid fitted with an intrusion alarm that alerts a security monitoring station.

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 conditi,ons will be i.n 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 Radiological Controlled Area eritrances 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 activ.ities-in accordance with 10 CFR20:

3.7.2.3 DELETED.

3.7.2.4 DELETED.

3. 7 .3 Vessel and System Maintenance

3. 7 .3.1 The ship's draft will be monitored daily as an indication of hull integrity.

Unexpected changes in draft are indications of compromised integrity, such as water in-leakage or flooding. If there is an unexpected change in draft, the ship shall be surveyed to determine the cause of the draft change. If leakage or flooding is the cause, the ship will be pumped out, and repairs made as may be required, including dry-docking if determined necessary, in order to assure that the integrity of the hull is maintained.

3. 7 .3.2 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.

3.7.3.3 An underwater inspection of the hull will be conducted at least every four (4) years. The vessel will be dry-docked 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.

30

Docket 50-238; License No. NS-1; N.S. SAVANNAH to License Amendment Request No. LAR 2020-001 PROPOSED TECHNICAL SPECIFICATION CHANGE (RETYPED)

September 4, 2020 3.7.3.4 An inspection will be conducted at least annually by MARAD's designated p~rsonnei ~o determine any degradation of the primary, auxi(iary and secondary systems.

31