ML18093A377

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Us Dept. of Transportation, Maritime Admin., License Amendment Request - Technical Specification Changes to Include the D Deck Containment Vessel Door and Cold Chemistry Laboratory Door
ML18093A377
Person / Time
Site: NS Savannah
Issue date: 03/30/2018
From: Koehler E W
US Dept of Transportation, Maritime Admin
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 2018-01
Download: ML18093A377 (24)
v • d • e


Text

U.S. Department of Transportation Maritime Admi n istration ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of Ship Disposal

SUBJECT:

Docket No. 50-238; License No. NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-01 1200 New Jersey Ave., SE Washington, DC 20590 Ref: 10 CFR 50.90 March 30, 2018 Technical Specification Changes to include the D Deck Containment Vessel Door and Cold Chemistry Laboratory Door Reference (a) Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC), dated May 30 , 2017, Availability of Funds for Decommissioning (Docket No. 50-238, License No. NS-1) Pursuant to 10 CFR 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. As described in Reference (a), the Consolidated Appropriations Act for FY 2017 provides $24 million to MARAD forN.S. S A VANN A H decommissioning.

One of the projects envisioned to support decommissioning is constructing a horizontal access portal to the Containment Vessel (CV). The through portal will provide safer access to and egress from the CV, and improve efficiency and productivity of work activities, such as removal of hazardous materials from the CV, including insulation containing asbesto s. The horizontal access portal will be secured by a marine grade watertight door installed on the outside of the CV in the vicinity of Frames 107 through 110 on D Deck starboard. The watert i ght door is called the D Deck Containment Vessel Door. Construction of the portal and door will commence when design and installation plans are complete.

The opening will be secured during construction when the opening is greater than 144 in 2. Until the requested Technical Specification change is approved , the portal and door will not be used for other than emergency access/egress or as required for installation and te s ting. The proposed licen s e amendment will revise two Technical Specifications (TSs):

  • TS 3. 7 .1.1 will be revised to "All CV entrances shall be either manned or secured."
  • TS 3.7.1.5 will be revised to " 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."

Docke t No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-01 March 30, 2018 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 change s. Enclosure 3 provides a retyped version of the proposed Technical Specification 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 50.91(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 September 30 , 2018 , for implementation within 30 days from the date of approval.

This letter contains no commitments. If there are any que s tions 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 March 15 , 2018 Enclosures (3) Erhard W. Koehler Senior Technical Advisor , N.S. S AVANNA H Office of Ship Disposal 2 Docket No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-01 March 30, 2018 Enclosures

1. Evaluation of License Amendment Request 2. Proposed Technical Specification Changes (marked-up)
3. Proposed Technical Specification Changes (retyped) 3 Docke t No. 50-238; License NS-1; N.S. SAVANNAH License Amendment Request No. LAR 2018-01 March 30, 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) EK/jmo USNRC (John Hickman, Ted Smith, Mark C. Roberts) USNRC Regional Administrator

-NRC Region I MD Department of the Environment (Eva Nair) 4 U.S. Department of Transportation Marit i me Admi n istration Office of Ship Disp osa l 1200 New Jersey Ave., SE Washington , DC 20590 Docke t No. 50-238; License No. NS-1; N.S. S AVANNA H ENCLOSURE 1 EVALUATION OF LICENSE AMENDMENT REQUEST

Subject:

Technical Specification Changes to include the D Deck Containment Vessel Door and Cold Chemistry Laboratory Door Enclosure 1 EVALUATION of LICENSE AMENDMENT REQUEST .........................................

5 1.0 SUMM ARY D E SCRIP T ION .................

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6 2.0 DETAIL E D DESCRIPTION OF PROPOSED CHANGES ................................

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6 2.1 Proposed Change 1: Revise Technical Specification

3. 7 .1.1.. ..............................................

6 2.2 Proposed Change 2: Revise Technical Specification

3. 7.1.5 Scope ...........................

.......... 8 2.3 Propo se d Change 3: Revise Technical Specification 3.7.1.5 M e thod ............

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9 3.0 TECHNICAL EV ALUATION ...........................................................................

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10 3.1 Cold Chemistry Laboratory Description

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............................... 10 3 .2 Containment Vessel Description

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12 3.3 CV Horizontal Access Portal and D Deck CV Door ......................................

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

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15 4.1 Applicable Regulatory Requirements

/Criteria .............

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15 4.2 Prec e dent. .....................................................................................................

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17 4.3 Proposed Determination of No Significant Hazards Consideration

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................. 17 4.4 Conclusions

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........................... 20 5.0 ENVIRONMENTAL CONSIDERATION

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20

6.0 REFERENCES

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......... 20 Enclosure 2 Enclosure 3 PROPOSED LICENSE CHANGES (MARKED-UP)

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21 PROPOSED LICENSE CHANGES (RETYPED)

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23 5 Docket No. 50-238; License NS-1; N.S. SAVA N NAH Encl o s u re 1 t o License Amen dm ent Req u est No. LAR 2018-01 Marc h 30, 2018 1.0 SUMMA R Y D E S C RIP TION This evaluation supports a request to amend Operating License NS-1 for th e Nuclear Ship SA VANN AH (NSS). Maritime Admini s t ra tion (MARAD) is a modal agency of the United Stat e s 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 described in Reference (a), the Consolidated Appropriations Act for FY 2017 provides $24 million to MARAD for N.S. S AV A N N A H decommiss i oning. One of the projects envisioned to support decommis s i o ning is constructing a horizontal acce s s portal to the Containment Vessel (CV). The walk-throu g h portal will provide safer access to and egre ss from the CV , and improve efficienc y and productivity of work activities , such as removal of hazardou s materials from the CV, including insulation containing asbestos. The horizontal access portal will be secured by a marine grade watertight door insta ll ed on the outside of the CV in the v icinity of Frames 107 through 110 on D Deck starboard. The watertight door is called the D Deck Containment Vessel Door. Construction of the portal and CV D Deck Door will commence when de s ign and installation plans are complete. The opening will be secured during construction when the opening is greater than 144 in 2* Until the requested T echnical Specification change is approved , the portal and door will not be used for other than emergen cy access/egress or as required for insta ll ation and testing. The proposed licen s e amendment will revise two Technica l Specifications (TSs):

  • TS 3. 7 .1.1 will be revised to "All CV entrances shall be either manned or secured."
  • TS 3.7.1.5 will be revised to " The B Deck Reactor Compartment Door at Frame 122 , the C Deck Door to the Cold C h emistry 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." MARAD request s a pproval of the proposed License Amendment by September 30 , 2018 for implementation within 30 days from the date of approval.

2.0 D E TA IL ED DESCRIPTION OF PROPOSED CHANGES 2.1 P ROP OS ED CHANGE 1: REVISE TECHNICAL SPECIFICATION 3.7.1.1 Currently , TS 3.7.1.1 applies to only the two 42 in. diameter vertical accesses to the CV and states: The 4 2 in. containment vessel entrances shall be manned or secured. Note that ther e are six original accesses to the CV. The other fo u r entrances were bo l ted or welded shut during mothballing preparations in the 1970s , and, therefore , are not specifica ll y called out in the current TS. The aft 42 in. ac cess w a s fitted with a 26-inch diameter airlock assembly , and historically was the pr i mary personnel access point into the CV. The airlock assemb l y wa s reactivated circa 2005, and had been the only entrance into the CV since approval of Amen d ment 14. When not in use , it is se c ured by a lo c ked grate. In 2017 , to improve per s onnel a ccess and egress , th e forward 42 in. 6 Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 en t rance was opened by permanently removing it's bolted manway cover (including portable shield cover) and replacing it with a locked or bolted grate. Also in 2017, the forward 18 in. by 24 in. manway/flooding hatch was removed and fitted with a bolted ventilation duct cover as part of a modification to the CV ventilation system. In acknowledgment of additional SAFSTOR activity that will be performed , MARAD has determined the existing scope of TS 3.7.1.1 sho uld be expanded to address all accesses to the CV. MARAD will continue to define "sec ured" as described in LAR 2006-001 (Reference b) to include "allowing entrances to be bolted, welded, locked via a chain and/or hasp, or another equivalent means to prevent access." The original design basis of the CV was to be the final barrier of releasing to the environment any fission products that had breached the fuel cladding and reactor coolant pressure boundary during a core-damaging acc ident. With issuance of the Possession-only license (Reference c), the CV design basis was revised to become a barrier to prevent inadvertent access to a radiologically controlled area where a majorit y of the remaining radioactive material on the NSS was located i.e., the reactor pressure vessel. While this change is not explicit, it can be inferred from pages 1 and 2 of the Safety Evaluation Report: The two access ports to the containment vessel have been sealed with shield plugs. Lifting equipment for the shield plugs has been partially disassembled to prevent unauthorized access into the containment vessel. [Page 1] Access to the pressure vessel, which contains over 99 percent of the radioactive material , is prevented by shielding and the massive steel head which is bolted in place. Removal of the bolts which are tensioned in place would require special equipment.

In addition, removal of concrete shielding blocks above the pressure vessel would require the use of lifting equipment that is not available on the ship. [Page 2] Access to the containment vessel is possible only through the forward and aft manways on the top of the vessel. These man ways are sealed by concrete and steel plugs which can be removed only with the u se of the chain hoist lifting equipment.

The lifting chains and hooks for the manway chain hoists have been removed to prevent unauthorized access. [Page 2] The inference is consistent with Regulatory Position C.3. of Regulatory Guide (RG) 1.861, "Termination of Operating Licenses for Nuclear Reactors ," Reference ( d). Regulatory Position C.3 Surveillance and Security for the Retirement Alternatives whose Final Status Requires a only License states, in part: Physical security to prevent inadvertent exposure of personnel should be provided by multiple locked barriers ... To prevent inadvertent exposure, radiation areas above 5 rnR/hr , such as near the activated primary system of a power plant, should be appropriately marked and should not be accessible except by cutting of welded closures or the disassembly and removal of substantial structures and/or shielding material.

When the CV was no longer needed to meet its original design functions , the Possession-only license effectively rev ise d its design function to become that "substantial structure" to " prevent inadvertent exposure of personnel" to radiation areas. 1 MARAD understands RG 1.86 was with drawn as noticed in the Federal Register (81 FR 53507) on A ugu s t 1 2 , 20 16 and th at its withdrawal does not imp act the NSS licensing basis. 7 Docket No. 50-238; License NS-1; N.S. SAV ANNA H Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 The proposed change expands the scope of the TS to include all accesses to the CV. The expanded scope will include the D Deck CV Door described in 3.2 below. 2.2 PROPOSED CHANGE 2: REVISE TECHNICAL SPECIFICATION 3.7.1.5 SCOPE Currently, the scope of TS 3.7.1.5 is one access to the reactor compartment.

The TS states: 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. The proposed change will increase the scope of TS 3. 7 .1.5 to include 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. Note that the other four accesses to the Reactor Compartment (RC) are controlled as required by TS 3.7.1.2 which states " All radiation control area (RCA) entrances will be manned or secured." Consistent with this requirement, all other RC entrances are secured from the insi de by a chain connected by a removable chain link (quicklink).

These four doors are as follows:

  • The C Deck door inside the Cold Chemistry Laboratory 2 (CCL) to the RC.
  • The C Deck door access to the RC at the decontamination shower.
  • The A Deck door to the Cupola.
  • The B Deck door to the CCL from the B Deck fan room. A modification has been completed to improve personnel access to the RC Lower Level by restoring the original forward access between the CCL at D Deck and the RC Lower Level. Until this modification had been completed, there was only one access to the RC Lower Level -one approximately 36 ft. vertical ladder access. Given that this modification effectively expands the boundary of the RC to include the CCL, MARAD proposes increasing the scope of TS 3.7.1.5 to include the C Deck entrance to the CCL. Currently and since November 1995 , the C Deck entrance to the Cold Chemistry Laboratory has been controlled in a manner equivalent to the B Deck RC entrance; locked from the outside and fitted with an intrusion alarm that alerts a security monitoring station. When opened, the door has been manned and protected.

Finally, MARAD proposes increasing the scope of TS 3.7.1.5 to include the planned D Deck CV Door. The modification to construct a horizontal access portal that will be secured by the D Deck CV Door is described in Section 3 below. Based on these modifications, MARAD has determined the sc ope of TS 3.7.1.5 should apply to all active entrances into the RC, and consequently the scope of TS 3. 7 .1.5 should be increased to include the C Deck Door to the Cold Chemistry Laboratory and the D Deck Containment Vessel Door (when it is fitted). Note that on approval of the requested change "the C Deck door inside the Cold Chemistry Laboratory (CCL) to the RC" (first bullet above) will be a door inside of the effectively expanded boundary of the RC that includes the CCL. Therefore, this door will no longer be required to be secured and will be left open as needed for access between the RC and CCL. 2 Note that in this document the term Co ld Chemistry Laboratory includes the com m on ope n s p ace fro m C Deck to D D eck betwee n Frames 99 and 10 3 traditionally called th e Co ld C h e mi stry Laboratory for the s p ace on C D eck port side, th e R adia tion Monitoring R oom o n C Deck star b oa rd side, the Gas Adsorp ti o n Equi pm e nt Room on D Deck port s id e and th e R adiatio n Sampling Room on D Deck starboar d s id e. 8 Docket No. 50-238; License NS-1; N.S. SAVANNAH Encl o su r e 1 to License Ame n dment Request N o. LAR 2018-01 March 30, 2018 Recall that the t w o reactor refueling hatche s on the Promenade Deck that provide access to the RC are weld e d shut a nd th e A Deck hatch to the Auxiliary Reactor A cces s Trunk is bolted, w e ighs approximately 1300 lbs. and requires heavy lifting e quipm e nt for rem o val. Therefore , these hatches me e t Regulato ry Position C.3 of RG 1.86 to control access. Specifically , they are either substantial welded closure s or substantial structures that require disassembly and removal. Note that as required by future decommissioning activities, these hatches wi ll be opened as needed and controlled as required by TS 3.7.1.2 "All Radiologica l Controlled Areas entrances wi ll be manned or s ecured." 2.3 PROP OS ED CHANGE 3: REVISE TE C HNICAL SP E CIFICATION 3.7.1.5 ME T H OD The current me t hod of implementing TS 3. 7 .1.5 is the "B Deck Reactor Compartment entrance at Frame 122 will b e fitt e d with an intrusion alarm with audibl e and vi s ual s ignal s that wi ll al e rt a mann e d sec uri ty guard post [ emphasis added]." The proposed change will revise the method of implementing TS 3. 7 .1.5 to The B Deck Reactor Compartment Door at Frame 122 , the C Deck Door to the Co l d Chemistry Laboratory and the D Deck Containment Vessel Door shall b e e ith er: a) M a nn e d or b) L oc k e d from th e out si d e and fitt e d with an intru s ion ala r m that al e rt s a sec urity mo n itoring s tation. [e mpha s is add e d] T h e method of i mp l ementing the access contro l requirements for t he B Deck door was estab li shed by the Possession-on l y l icense (Reference b) and has evo l ved to the current TS as fo ll ows: Possession-onl y license (Amendment 8 , 1976): TS 3.8.2 Al l entrances into the reactor compartment wi ll b e secured from the inside except the B Deck entry at Frame 122 which will be chained , posted , sea l ed , and double locked. TS 3.8.5 The norma l entrances in items [3.8.]2 and 4, above , w ill be fitted with intrusion alarm s with audible and visual signals. Patriots Point Development Authority (Amendment 9, 1 981) (Reference e) 3.3 An intrusion alarm with an interlock will be maintained on the B Deck entry door into the reactor c ompartment with audible and visual signals located at a manned security guard post. This shall be both seen and heard by the security guard on duty. 3. 7 .1.2 All entrances into the reactor compartment will be secured from the outside except t h e B Deck entry at Frame 122 which will be chained , posted , sealed , and doub l e locked. 3. 7.1.5 The entrance in Item 1.2 above , will be fitted wit h an int ru sion alarm with audible a n d visual signals located at a location that is manned by a guard or security officer. Move from James River Reserve Fleet (Amendment 13 , 2007) (Reference f) TS 3. 7 .1.2 All Radiological Controlled Areas entrances will be manned or secured. TS 3. 7 .1.5 The B Deck Reactor Compartment entrance at Frame 122 will be fitted with an intru si on alarm with audible and visua l signa l s that will a l ert a manned security guard post. Note that the requirement to lock the B Deck entrance was i ncluded in the Amendment 13 Technical Specification 3.7.1.2. By current practice , the only RC door locked from outside is the B Deck entrance.

The other doors to the RC are locked from the inside: 9 Docket No. 50-238; License NS-1; N.S. SAV ANNA H Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018

  • The C Deck door inside the CCL to the RC.
  • The C Deck door access to the RC at the decontamination shower.
  • The A Deck door to the Cupola.
  • The B Deck door to the CCL from the B Deck fan room. The intrusion alarm Technical Specifications were not revised after the NSS was moved to the James River Reserve Fleet in 1994. However, because the NSS was moored approximately one mile off shore in the middle of the James River, MARAD supplemented the audible and visual signals with a line of sight remote alarm system. This alarm system notified security personnel in the James River Reserve Fleet office. During subsequent relocations of the NSS, either
  • A guard was stationed in a location where they could see and hear the flood, fire and intrusion alarms, or
  • MARAD contracted with an alarm monitoring service to continuously monitor NSS flood , fire and intrusion alarms. Numerous NRC reviews of the security controls at the NSS since 1994 have concluded the NSS administrative procedures and processes have met the requirements of past and current intrusion alarm Technical Specifications.

Regardless, MARAD has now decided to request revising the Technical Specification language to specifically allow modem security monitoring methods. In summary, these Technical Specifications were originally devised in a time when a security guard was the most reliable method of monitoring and reporting intrusion events to appropriate supervision. Today , more reliable methods exist. For example, the 1976 system could only inform the guard that at least one intrusion device was in an alarm condition. With the current system, the monitoring station can identify which device has actuated and report that condition to a MARAD designated individual for ap propriate evaluation and response.

The proposed change is intended to allow utilization of these improved security monitoring technologies and also accommodate futur e changes in security monitoring technology. 3.0 TECHNICAL EVALUATION 3.1 COLD CHEMISTRY LABORATORY DESCRIPTION MARAD has completed a modification to improve personnel access to the RC Lower Level by restoring the forward access between the Cold Chemistry Laboratory (CCL) at D Deck and the RC Lower Level. The modification removed the large and small Auxiliary Reactor Access Trunk Plugs in the D Deck (D Deck Plugs), and installed an access ladder from the CCL D Deck opening to the Tank Top of the RC Lower Level similar to the original ladder depicted in Figure 3-1. Remo ving the D Deck plugs also improves the ability to remove an injured person from the RC Lower Level. The opening created by removing the D Deck plugs is secured from the top by the C Deck Door to the CCL. From the bottom , it is secured by the B Deck RC door as described in the next paragraph. Prior to this modification, there was one access to the RC Lower Level -via a 12 in. radius access trunk down an app roximately 36 ft. ladder from B Deck of the RC to the RC Lower Level at the Tank Top. This ladd er, which also pro vides access to the bottom of the CCL D Deck opening, is secured by the B Deck RC door. 10 D o c k et No. 50-238; License NS-1; N.S. SAVANNAH En clo sure 1 to License Amen d ment Request N o. LAR 2018-01 Marc h 30, 2018 Following permanent shutdown and defueling, the D Deck plugs no longer provided any safety function beyond fall protection.

Likewise , the CCL D Deck opening has no safety function.

A safety grating insert into the large plug opening maintains the fall protection function of the removed plug. The original de s ign and operation required the access plugs to be installed when the reactor was operating since the plugs formed part of the reinforced concrete portion of the secondary shie l ding described in FSAR 5.3.2, Secondary Shield as follows: The secondary shield is the concrete or lead and polyethylene surrounding the containment vessel a s shown in Figures 4-3 and 4-4. The figures show the relationship between the containment vessel and the upper and lower reactor compartment.

Below the containment vessel equator , the shield is a v e rtica l [ emphasis added] bulkhead of reinforced concrete with a maximum thickness of 4 feet and is extended at the forward end to form the lower reactor compartment (secondary shie l d area) for the l ow press u re primary auxiliary syste m s l ocated outside of the containment vessel. Note that only the vertical portion of the concrete s hield is " credited" as forming part of the safety function of the secondary shield when the reactor was operating.

Regardless , given that the reactor is permanent l y shutdown , the secondary shield performs no safety function.

Therefore , remova l of the D Deck plugs does not adversely affect any FSAR described design function.

The removed D Deck Plugs are stored on the ship and can be reinstalled , if needed. FIGUR E 3-1 P LUG S T ARBOARD LOOKIN G TO CENTERLINE

/ 0 * ' ' l C...T'~ -. ....... *~** ; / / ..... -~:+ / 'f

  • CONTAINMENT Vf:SSE L. FOU N DATJOM.:.JU:F.: 'Z c* . *. . I , . A } * . J * * ... 4,
  • J 6. ' . t ,,,, D Deck P l ugs (inside red oval) Ladder from CCL to RC Lower Level 4.C.O .. ...,, ..,.,, ..... ..... a 11 Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 3.2 CONTAINMENT VESSEL DESCRIPTION Th e CV vessel is a horizontal cylinder with hemispherical ends having an outside diameter of 35 ft. 4% in. and a length of 50 ft. 8 Yi in. The gross volume of the containment is approximately 40,000 cubic ft. and the net free volume is approximately 31 , 200 cubic ft. The containment vessel bulkhead thicknesses vary from a minimum of 1 ~in.at the hemispherical ends to 3% in. in the cylindrical portion of the vessel. The CV structure is also shielded with lead and polyethylene and protected by an exterior construction composed of concrete, steel and redwood. The CV lies fore and aft on the ship's center line , 18 in. above the inner bottom. It rests in a shaped support, which is integral with the ship's structure and is secured only at the bottom at the after end of the cylindrical section. This connection provides resistance to rotational forces and and-aft motion. The support can thus accommodate thermal expansion.

Lateral support is provided at mid length by the collision mat , thereby preventing movement due to the roll of the ship. See Figure 3-2. The collision mat itself is composed of six alternating layers of one ( 1) in. steel plates and three (3) in. slabs of redwood (24 in. total) and one fmal one (I) in. layer of steel plate. Each layer of redwood alt e rnates horizontal and vertical.

Structural chocks at C Deck level provide lateral support and en s ure that the containment remains in place at critical angles, including those in the capsized condition.

The collision mat is "backed" by approximately 2 to 3 ft. of ordinary concrete which is backed by more redwood (approximately 4 in.) and fmally the 3 % in. containment vessel steel. The CV currently has six vertical accesses and no horizontal accesses:

  • A 13 Yi ft., full-diameter hatch at the top of the cupola is provided for major maintenance and refueling operation.
  • A 5 Yi ft. diameter hatch in the top of the cupola for control rod drive removal.
  • Two 18 in. by 24 in. manway/flood ports on the starboard side in the lower quarter of each hemispherical head the RC lower level.
  • A 42 in. opening, with a 26 in. airlock insert, aft of the cupola.
  • A 42 in. opening forward of the cupola. The aft 42 in. access has been the only entrance into CV since approval of Amendment
14. When not in use, it is secured by a locked grate. To improve access and egress, the forward 42 in. entrance has been opened by permanently removing the forward CV 42 inch bolted manway cover (including portable shield cover) and replacing it with a locked or bolted grate. In addition, the forward 18 in. by 24 in. manway/flooding hatch has been removed and fitted with a bolted ventilation duct cover. 12 Docke t No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 FIGURE 3-2 COLLISION MAT AT FRAME 113 LOOKING FORWARD ._ I HA\C.M I I I +=**, r f--... k-l -----------'-'--"'<::---'-I ~A~!!.LNS,e..Q. .S.!,. o * .s "-e::.,...,.

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_~~ Ordinary Concrete Collision Mat Approximate CV horizontal access portal location 3.3 CV HORIZONTAL ACCESS PORTAL AND D DECK CV DOOR The CV horizontal access portal will be constructed on the starboard side of D Deck b y cutting through the collision mat, 2 to 3 ft. of ordinary concrete, approximately 4 in. of redwood and finally the 3 % in. of CV steel. The approximate portal location i s shown in Figure 3-2. A 10 CFR 50.59 Screening to construct the portal has been performed and documented per STS procedures. In s ummary , the screening concludes that constructing the CV Horizontal Access Portal 13 Docke t No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 does not adversely affect Final Safety Analysis Report described design functions, does not change evaluation methodologies and does not involve a test or experiment.

The screening does conclude tha t a change to TS 3.7.1.1 and 3.7.1.5 is required.

Specifically, it concludes given that current accesses to the RC and CV locked from the outside are addressed in the TS, it is implicit new accesses locked from the outside should also be addressed in the TS. The horizontal access portal will be secured by a marine grade watertight door installed on the outside of the RC boundary (also the outside surface of the collision mat) in the vicinity of Frames 107 through 110 on D Deck starboard.

This door is called the D Deck CV door. The frame spacing is 30 m. The nominal 80 in. wide by 80 in. tall portal and door is sized to allow the following:

1. Safe personnel access to the CV , 2. Safe removal of personnel during a medical emergency, 3. Passage of personnel hand carrying tools and equipment, and 4. Worker transport of removed asbestos containing materials (ACM) for disposal.

Following removal of all fuel in 1970, the CV system has not been required to meet its original design criteria. The CV and its penetrations have not been leak or pressure tested since 1970. The current design function of the CV is to perform as a security barrier to prevent entry into the CV. The do o r will be secured as stated in the proposed Technical Specification

3. 7 .1.5. The current draft of the ship in the vicinity of Frame 110 is approximately 18 ft. Given that the D Deck is at approximately 23 ft., MARAD has determined the D Deck CV door will be similar to the ex i sting engine room equipment access double door at C Deck frame 145 centerline.

See Figure 3-3. Note that the engine room double door has only four dogs. FIGURE 3-3 EXISTING ENGINE ROOM EQUIPMENT ACCESS DOUBLE DOOR 14 Docket No. 50-238; License NS-1; N.S. SAVA NNA H Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 The D Deck CV Door will be a manually operated watertight double door. See Figure 3-4. Note that the number of dogs in the D Deck CV door is more than the existing engi ne room equipment access doubl e door. FIGURE 3-4 D DECK CONTAINMENT VESSEL DOOR FIG. "A" CLEAR OPNG. 0 z a.. 0 1 8 w ...J 0 DETAIL OF HASP pl 0 u:: 8 COTicRPIN DETAIL OF HINGE R I GHT HAND DOOR SHOWN The design and manufacture of the D Deck CV door will meet U.S. Coast Guard safety regulations fo r cargo ships. Appropriate administrative procedures governing the use and operation of the door will be developed. When it is in use, the door will be manned and prot ecte d. The prevention of the free exchange of water in a space where decommissioning activities may potentially create temporary loose surface contamination is addressed by shutting the watertight door. When not in use , the door will be locked from the outside and fitted with an intrusion alarm that alerts a security monitoring station. Construction of the portal and door will commence when design and installation plans are complete.

The opening will be secured during construction when the opening is greater than 144 in 2. Until the requested Technical Specification change is approved, the portal and door will not be used for other than emergency access/egress or as required for installation and testin g. In summary, the D Deck Containment Vessel Door is designed to pro v ide appropriate sec urity and floodin g protec tion. Flooding protection will minimize radioactive release due to a flooding event. 4.0 REGULATORY SAFETY ANALYSIS 4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA The NSS is "Moth balled" per the guidance of Regula t ory Guide (RG) 1.86, "Termination of Operating Licenses for Nuclear Reactors," Referenc e (d). This 1974 RG describes the now outmoded 15 Docke t No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 Mothballing option of protective storage. This state of protective storage was approved in 1976 by Amendment 8 (Possession-Only) to License NS-1 , Reference (c). MARAD understand s RG 1.86 was withdrawn as noticed in the Federal Register (81 FR 53507) on August 12 , 2016 and that its withdrawal doe s not impact the NSS licensing ba sis. RG 1.86 Regulatory Position C.2 Alternatives.for R eac tor R eti r e m e nt states: a. Mothballing.

Mothballin g of a nuclear reactor facility consists of putting the facility in a state of prot ec tive storage. In general , the facility may be left intact except that all fuel assemblies and the radioactive fluids and waste should be removed from th e site. Adequate radiation monitoring, environmental surve illance , and appropriate security pro ce dures should be established under a possession-onl y license to ensure that the health and sa fety of the public is not endangered.

RG 1.86 Regulatory Position C.3 Surveillance and Security for the Retirement Alternatives whose Final Status R equires a Possession-only License states: A facility which has been licensed under a Possession-only license ma y contain a significant amo unt of radioactivity in the form of activated and contaminated hardware and structural materials.

Surveillance and commensurate sec urity should be provided to assure that public health an d safety are not endangered.

a. Ph ysica l security to prevent inadvertent exposure of personnel should be provided by multiple locked barrier s. The presence of these barriers should make it extremely di ffic ult for an unauthorized person to ga i n 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 not be accessible except by cutting of we l ded closures or the disa ssem bly and remo va l of substantial st ructures and/or shielding material.

Means such as a remote readout intrusion alarm system sho uld be provided to indicate to de signa ted personnel when a physical barrier is penetrated.

Security personnel that provide access control to the faci lity may be used instead of the physical barriers and the intrusion alarm systems. b. The physical barriers to unauthorized entrance into the facility, e.g., fences, buildings , welded doors , and access openings , should be inspected at least quarterly to assure that these barriers have not deteriorated and that locks and locking apparatus are intact. LAR 2018-001 describes two modifications.

One modification improves personnel access to the RC Lower Level by restoring access between the Cold C hemi stry Laboratory at D Deck and the RC Lower Level. The second modification improves personnel access to the CV by constructing a horizontal access portal that will be secured by the D Deck CV Door. 16 Docket No. 50-238; License NS-1; N.S. SAVANNAH Encl o s u re 1 to License Amend m ent Request N o. LAR 2018-01 Marc h 30, 2018 MARAD has determined these modifications require the changes to two Technical Specifications (TSs) and proposes the following changes: TS 3. 7 .1.1 will be revised to "All CV entrances shall be either manned or secured." TS 3.7.1.5 will be revised to "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 a l arm that alerts a security monitoring station." The proposed changes meet the intent of the Regulatory Position C.2 in that they provide appropriate security to assure that public health and safety are not endangered.

These proposed changes meet the intent of the Regulatory Position C.3 in that they prevent in a dvertent exposure of personnel to radiation areas greater than 5 mR/hr. When the ship is un a ttended , for example , after normal work hours, on weekend and holidays, the main access door shall be locked and a l armed. During all times when no access is needed to any of the three doors in the proposed change, these doors sha ll be locked and a l armed. When access to these ship spaces is required these doors shall be manned and protected.

Currently and since November 1995, the C Deck Door to the Cold Chemistry Laboratory has been locked from the outside and fitted with an intrusion a l arm that alerts a security monitoring station. When opened, the door has b een manned and protected.

Since 2015, radiation surveys identify all general area dose rates in the RC and CV are less t h an 1 mR/hr. Slightly hig h er dose rates can be found in the immediate vicinity of the steam generators, pressurizer and other plant componen t s. Current l y, the only known dose rate greater than 5 mR/hr is i n the RC Lower Level where a contact reading of 36 mR/hr is found on a pipe 8 ft. in the overhead, circa 2013. Accesses to other l ocations where th e dose rates may be greater than 5 mR/hr require the removal of manways or other substantial barriers.

4.2 PR E C EDE NT MARAD is not aware of a precedent for insta lli ng a CV horizonta l access portal where none previously existed. 4.3 PROPO S ED DETERMINATION OF NO SIGNIFICANT HAZA R DS CONSIDERATION MARAD has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92 , " Iss u ance of amendment," as discussed below. 1) Does the proposed amendment involve a significa n t increase in the pro b ability or consequences of an accident previous l y evaluated?

Response:

No. The proposed changes will modify the Technical Specifications (TSs) to include all CV accesses in t o TS 3. 7 .1.1 and add two additiona l accesses into TS 3. 7 .1.5. The proposed changes are required by two modifications to p l ant eq u ipment. The comp l eted modification improved personnel access to the RC Lower Level by restoring access between the CCL at D Deck and the RC Lower Level and the proposed modification will improve personnel access 17 Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 to the CV by constructing a horizontal access portal that will be secured by the D Deck CV Door. Neither the proposed changes to the TSs nor the modifications that require those changes affect basic plant operation of a permanently shutdown and defueled facility.

The completed modification restored the original forward access between the CCL at D Deck and the RC Lower Level to improve normal personnel access to the RC Lower Level. It also improved the ability to remove an injured person from the RC Lower Level. Prior to completing the modification, the only access to the RC Lower Level was via a 12 in. radius access trunk down an approximately 36 ft. ladder from B Deck of the RC to the RC Lower Level at the Tank Top. Emergency personnel egress from the RC Lower Level will be available through either the D Deck opening or the 12 in. radius access trunk down an approximate l y 36 ft. ladder from B Deck of the RC to the RC Lower Level at the Tank Top. This modification effectively expanded the boundary of the RC to include the CCL and therefore, requires the proposed change to TS 3. 7 .1.5 to include the C Deck entrance to the CCL. The proposed modification

-to construct a horizontal access portal that will be secured by the D Deck CV Door -is an improvement in personnel safety. Emergency personnel egress from the CV , in addition to that provided by existing ladders, will be avai l able through the open D Deck CV Door. The proposed modification will add an access to the CV that has not previously existed and therefore, requires the proposed change to TS 3.7.1.5 to include the D Deck CV Door. Note that this door will open into a passageway sim ilar to the B Beck RC door that is currently the only door listed in TS 3.7.1.5. However , since the proposed D Deck CV Door will provide a direct access to the CV , a change is also proposed to TS 3. 7 .1.1 to include all CV entrances into its scope. If any even t requires shutting any door to the CV or RC, the limiting closure time is the time it would take for the door guard to simply swing the door shut and secure it with installed dogs or quick closure operators.

The worst case time to secure any door is the time to secure the D Deck CV Door, a watertight double door. The time to secure it is estimated to be approximately 120 seconds after the CV and RC have been checked to be free of personnel.

Administrative contro l s will be put in place to ensure that 1) the swing path of the door is not blocked , 2) the door shall not be foule d and 3) trained personnel will be in the immediate vicinity of the door and available to close it in a timely manner following any event where closing the door is appropriate.

The NSS 's reactor is not operationa l and the l evel of radioactivity in the NSS has significant ly decreased from the levels that existed when the 1976 Possession-only License was issued. No aspect of any of the proposed changes is an initiator of any accident previously evaluated.

Consequently, the probability of an accident previously eval uated is not significantly increased. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

18 Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No. The proposed changes will modify the Technical Specifications (TSs) to include all CV accesses into TS 3. 7 .1.1 and add two additional accesses into TS 3. 7 .1.5. The proposed changes are required by two modifications to plant equipment.

The completed modification improved personnel access to the RC Lower Level by restoring access between the CCL at D Deck and the RC Lower Level and the proposed modification will improve personnel access to the CV by constructing a horizontal access portal that will be secured by the D Deck CV Door. Neither the proposed changes to the TSs nor the modifications that require those changes affect basic plant operation of a permanently shutdown and defueled facility.

In both cases, the physical alteration of plant equipment is similar to that which was previously allowed by Technical Specifications. Specifically , since November 1995, the C Deck Door to the Cold Chemistry Laboratory has been locked from the outside and fitted with an intrusion alarm that alerts a security monitoring station. When opened, the door has been manned and protected.

Likewise, the D Deck CV Door shall be locked from the outside and fitted with an intrusion alarm that alerts a security monitoring station; when opened the D Deck CV Door shall be manned and protected.

Neither of the proposed changes to TS 3.7.1.1 and TS 3.7.1.5 will change 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 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. The proposed changes will modify the Techn i cal Specifications (TSs) to include all CV accesses into TS 3. 7 .1.1 and add two additional accesses into TS 3. 7 .1.5. The proposed changes are required by two modifications to plant equipment.

The completed modification improved personnel access to the RC Lower Level by restoring access between the CCL at D Deck and the RC Lower Level and the proposed modification will improve personnel access to the CV by constructing a horizontal access portal that will be secured by the D Deck CV Door. Neither the proposed changes to the TSs nor the modifications that require those changes affect any margins of safety that are r elevant to the ship's defueled and partially dismantled reactor. The completed modification improved personnel access to the RC Lower Level by restoring access between the CCL at D Deck and the RC Lower Level. The proposed modification will improve personnel access to the CV by constructing a horizontal access portal that will be secured by the D Deck CV Door. 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. 19 Docket No. 50-238; License NS-1; N.S. SAVANNAH Enclosure 1 to License Amendment Request No. LAR 2018-01 March 30, 2018 Additionally, when any door to the CV or RC door is open, administrative controls will be put in place to ensure that 1) the swing path of the door is not blocked, 2) the door shall not be fouled and 3) trained personnel will be in the immediate vicinity of the door and available to close it in a timely manner following any event where closing the door is appropriate.

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 saf ety of the public. 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 5 l .22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

a. Letter from Mr. Erhard W. Koehler (MARAD) to U.S. Nuclear Regulatory Commission (NRC), dated May 30, 2017, Availability of Funds for Decommissioning (Docket No. 50-238, License No. NS-1) b. Letter from Mr. Erhard W. Koehler (MARAD) to Document Control Desk (NRC), dated August 7, 2006, License Amendment Request No. 2006-01, Technical Specifications Changes to Support Pre-Decommissioning Activities
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. John F. Stolz , (NRC) to Dr. Zelv i n Levine (MARAD) and Mr. J. E. Guerry (PPDA), dated August 14, 1981, No Title [Issuance of Amendment 9, Adds Patriots Point Development Authority as a co-licensee]
f. Letter from John T. Buckley (NRC) to Mr. Erhard W. Koehler (MARAD), dated January 31 , 2007, Issuance of Amendment No. 13 (License Amendment Request No. 2006-01) for NS Savannah (Docket No. 50-238 , License No. NS-1) 20 U.S. Department of Transportation Marit i me Administration Office of Ship Disposal Docket No. 50-238; License No. NS-1; N.S. SAVANNAH 1200 New Jersey Ave., SE Washington, DC 20590 ENCLOSURE2 PROPOSED LICENSE CHANGES (MARKED-UP)

Strikethrough in dicate s deletions. Text Boxes include in sertio n s when needed. 2 1 Docket 50-238; License No. NS-1; N.S. S AVANN AH Enclosure 2 to License Amendment Request No. LAR 2018-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKED-UP)

March 30 , 2018 Proposed Changes 2 and 3: Note deletion and insert -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 3.7.1 Access Co n trol b) Locked from the outside and fitted with an intrusion alarm that alerts a securitv monitorinq station. 3.7.2 3.7.1.1 Tti e 42 i ncti oont oi n A'le nt v es s el e n tFO ne e s s tioll be A'l o n ned or s e c ure d. i cal Controlled Areas entrances will be manned or secured. ical Controlled Area entrances wi ll be posted with appropriat to the sh i p not i n use will be secured at all times. rsonnel will patrol the vessel at least once during a twenty-four (24) hour period. 3. 7.1.7 Dev i ations from t appropriate parts above access control conditions will be in accordance with Section 3 of these Technical Specifications , Administrative Con tr ols. ------------------------.

Proposed Change 1: Note deletion and insert "All CV Surveillance entrances shall be either manned or secured." 3.7.2.1 Pericxiically and at least once a quarter , MARAD's designated personnel will inspect the Radiologica l Controlled Area entrances to verify they are properly secured and test the in trusion 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 Thermoluminescent dosimeters (TLDs) or equivalent monitoring devices shall be placed at strategic locat i ons throughout the vessel to monitor the radiation from reactor generated materials.

MARAD shall determine these locations on the vessel and shall require dosimeter readings at least semi-annually. 3.7.2.4 Sem i-annually , water samples and bottom sediment will be taken adjacent to the ship and analyzed for radioactivity.

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 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 inc r eased. Both stripes must always be visible. If the lower stripe is not visible , the ship shall be surveyed and the water Changes 1 , 2 and 3: Note deletion and insert appropriate Amendment number and date. Amendment 44 ~Fi l a. 200s 22 U.S. Department of Transportation Maritime Administration Office of Ship Di sposal Docke t No. 50-238; License No. NS-1; N.S. S AVANNA H ENCLOSURE3 PROPOSED LICENSE CHANGES (RETYPED) 1200 New Jersey Ave., SE Washington, DC 20590 23 D o cket 50-238; License No. NS-1; N.S. SAVANNAH En clo s u re 3 t o License Amen d me n t Req u est N o. LAR 2018-01 PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

March 30, 2018 3.7.1 Access Control 3. 7 .1.1 All containment vessel entrances shall be e i ther 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 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 cond i tions 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 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. 3.7.2.3 Thermolumin e scent dosimeters (TLDs) or equivalen t monitoring devices shall be p l aced at strategic locations throughout the vessel to monitor the radiation from reactor generated materials.

MARAD shall determine these locations on the vessel and shall require dosimeter readings at least semi-annually. 3.7.2.4 Semi-annually , water samples and bottom sed i ment will be taken adjacent to the ship and analyzed for radioactivity. 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 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 24

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