L-13-330, License Renewal Application Amendment No. 46 - Annual Update

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License Renewal Application Amendment No. 46 - Annual Update
ML13269A027
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 09/20/2013
From: Lieb R
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-13-3304, TAC ME4640
Download: ML13269A027 (36)
v • d • e


Text

FENOCT 5501 North State Route 2 FIrstEnergy NuclearOperatingCompany Oak Harbor,Ohio 43449 Raymond A. Lieb 419-321-7676 Vice President,Nuclear Fax: 419-321-7582 September 20, 2013 L-1 3-304 10 CFR 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 License Renewal Application Amendment No. 46 - Annual Update (TAC No. ME4640)

By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). Each year following submittal of a license renewal application (LRA) and at least 3 months before scheduled completion of the NRC review, 10 CFR 54.21(b) requires an amendment to the renewal application to be submitted identifying any change to the current licensing basis (CLB) of the facility that materially affects the contents of the license renewal application, including the Final Safety Analysis Report (FSAR) supplement.

The Attachment provides a summary of the CLB changes that materially affect the LRA.

Enclosure A provides Amendment No. 46 (Annual Update) to the DBNPS LRA as required by 10 CFR 54.21(b). Enclosure B provides a revised LRA boundary drawing.

6149$_

Davis-Besse Nuclear Power Station, Unit No. 1 L-1 3-3304 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 2-0, 2013.

Sincerely,

Attachment:

Current Licensing Basis (CLB) and Other Changes that Materially Affect the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application (LRA)

Enclosures:

A. Amendment No. 46 (Annual Update) to the Davis-Besse License Renewal Application B. Revised Davis-Besse License Renewal Application Boundary Drawing cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosures NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment L-13-304 Current Licensing Basis (CLB) and Other Changes that Materially Affect the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA).

Page 1 of 3 FirstEnergy Nuclear Operating Company (FENOC) performed a review of Davis-Besse CLB and other document changes since submittal of the 2012 LRA Annual Update provided by letter dated August 9, 2012 (ML12229A139), and identified the following items that materially affect the contents of the Davis-Besse LRA:

1. ASME Section XI Code Edition Consistent with provisions in 10 CFR 50.55a to use the ASME Code in effect 12 months prior to the start of the inspection interval, the applicable ASME Code for the current (fourth) ten-year inspection interval for Davis-Besse, which began September 21, 2012, is ASME Section XI, 2007 Edition, through the 2008 Addenda. Federal Register Notice 76 FR 36266 (June 21, 2011) states that the 2007 Edition, inclusive of the 2008 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code, Subsections IWB, IWC, IWD, IWE, IWF, and IWL, as subject to the conditions of this rule, are acceptable to be adopted as aging management programs for license renewal, and the conclusions of NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," remain valid, except where specifically noted and augmented in the GALL Report.

The ASME Section XI Code Edition and Addenda change applies to the following four aging management programs:

  • Inservice Inspection Program
  • Inservice Inspection (ISI) Program - IWE
  • Inservice Inspection (ISI) Program - IWF
  • Reactor Head Closure Studs Program As noted in the program descriptions, in-service examinations will continue to comply with the requirements of the ASME Code Section XI Edition and Addenda incorporated by reference in 10 CFR 50.55a 12 months prior to the start of the inspection interval. Therefore, no LRA changes are needed.
2. Station Blackout Recovery Path FENOC reconfigured the Davis-Besse switchyard to facilitate breaker maintenance by extending the J (East) and K (West) buses and adding two new 345kV breakers. New-f6-uhdati6ns were add-d to theD-avis-Besse swit6hyard to support-the new breakers and associated structures.

Attachment L-1 3-304 Page 2 of 3 The two 345 kV breakers are connected on either side of the new locationof the Ohio Edison line, with one breaker between the Ohio Edison line and the J Bus and one breaker between the Ohio Edison line and the K Bus. The new switchyard configuration will enable the buses to be maintained under maintenance or outage conditions, resolving concerns regarding power interruption and short outage duration time limits imposed during line or breaker maintenance activities. This configuration change provides greater operational flexibility, power transfer capability and less operational risk.

LRA Section 2.5.6.2, "Station Blackout Recovery Path Evaluation Boundaries,"

Figure 2.5-1, "Davis-Besse Station Blackout Recovery Path," and Table A-I, "Davis-Besse License Renewal Commitments," are revised to address the new Davis-Besse switchyard configuration.

LRA Section 2.4, "Scoping and Screening Results: Structures," Section 2.4.12, "Yard Structures," and Section 2.4.12.9, "Station Blackout Component Foundations and Structures in the Yard and Switchyard (Startup Transformers 01 and 02; Bus-Tie Transformers; 345-kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563 and ACB34564; air break switch ABS34625; Relay House; "J" and "K" buses) - Seismic Class I1," are revised to address the revised configuration and structural changes to the Davis-Besse switchyard.

3. Demineralized Water System The Laboratory (Lab.) demineralized water storage tank and associated level gage have been removed from the plant and therefore are no longer within the scope of license renewal nor subject to aging management review (AMR). The component type "level gage", was previously added to the LRA in the FENOC response to Nuclear Regulatory Commission (NRC) request for additional information (RAI) 2.3.3.11-01 by letter dated June 24, 2011 (ML11180A060).

LRA Table 2.3.3-11, "Demineralized Water Storage System Components Subject to Aging Management Review," Section 3.3.2.1.11, "Demineralized Water Storage System," and Table 3.3.2-11, "Aging Management Review Results -

Demineralized Water Storage System," are revised to address the removal of the two components from the plant.

License Renewal Boundary Drawing LR-MO10C, previously revised (Revision 1) by FENOC letter dated April 29, 2011 (ML11126A016), is revised to show the new boundaries due to the removal of the Lab. demineralized water storage tank and associated level gage.

Attachment L-1 3-304 Page 3 of 3

4. New Steam Generator Storaqe Facility A new permanent warehouse-style structure was added to the Davis-Besse site in 2013. The New Steam Generator Storage Facility is an 18,000 square foot structure that will be used to house and protect the replacement steam generators until they are installed in the plant. This structure is located outside the protected area, and is not within the scope of license renewal.

LRA Table 2.2-3, "License Renewal Scoping Results for Structures," is revised to address the new structure.

LRA Appendix E, "Applicant's Environmental Report - Operating License Renewal Stage" (Environmental Report), Section 3.2, "Refurbishment," is revised to address the new permanent structure and minor changes to the plans for the Steam Generator Replacement Project.

5. License Renewal Interim Staff Guidance (ISG) LR-ISG-2011-03 NRC License Renewal ISG LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP)

XI.M41, 'Buried and Underground Piping and Tanks'," was issued in August 2012.

FENOC reviewed the ISG and incorporated the program changes into the Davis-Besse Buried Piping and Tanks Inspection Program.

LRA Sections A.1.7 and B.2.7, both titled "Buried Piping and Tanks Inspection Program," and Table A-1, "Davis-Besse License Renewal Commitments," are revised to align with LR-ISG-2011-03.

See Enclosure A to this letter for the revision to the Davis-Besse LRA.

See Enclosure B to this letter for the revised LRA Boundary Drawing.

Enclosure A Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-1 3-304 Amendment No. 46 (Annual Update) to the Davis-Besse License Renewal Application Page 1 of 29 License Renewal Application Sections Affected Table 2.2-3 Section 3.3.2.1.11 Table 2.3.3-11 Table 3.3.2-11 Section 2.4 Section A. 1.7 Section 2.4.12 Table A-1 Section 2.4.12.9 Section B.2.7 Section 2.5.6.2 Environmental Report Section 3.2 Figure 2.5-1 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected LRA Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text Ukiede-e and added text underlined.

Enclosure A L-1 3-304 Page 2 of 29 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table 2.2-3 Pages 2.2-11 1 new row; and, and 2.2-13 I revised row Based on the construction of the New Steam Generator Storage Facility, and the addition of the foundations for the new switchyard breakers and reconfiguration of the switchyard, LRA Table 2.2-3, "License Renewal Scoping Results for Structures," is revised to read as follows:

Table 2.2-3 License Renewal Scoping Results for Structures Structure Name In-Scope Screening Results / Section Provides storage space for1new steam New Steam Generator No generators before,they are installed in the plant Station Blackout Component Foundationsand Structures in the Yard and Switchyard (Startup Transformers 01 and 02, Bus-Tie Transformers, 345-kV Switchyard circuit Yes 2.4.12 breakers A CB34560, ACB34561, ACB34562, ACB34563, ACB34564, 81-B-66 and 81-B-67,-aW break sw-tch ABS3A,625, Relay House, and "J"and "K"Buses)

Enclosure A L-1 3-304 Page 3 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 2.3.3-11 Page 2.3-80 2 rows The Laboratory (Lab.) demineralized water storage tank (DB-T1 08), and the associated storage tank level gage previously added to the LRA in the FENOC response to Nuclear Regulatory Commission (NRC) request for additional information (RAI) 2.3.3.11-01 by letter dated June 24, 2011 (ML11180A060),

have been removed from the plant, and the associated rows in LRA Table 2.3.3-11, "Demineralized Water Storage System Components Subject to Aging Management Review," are deleted, as follows:

Component Type Intended Function (as defined in Table 2.0-1)

Tank Lab.. daenn. water sterage tank DB T1B) Strh'Yt-'rai integrity Levei Gage _ 4ert

_Ut~i

Enclosure A L-1 3-304 Page 4 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 2.4 Pages 2.4-1 Note:

and 2.4-2 Based on the addition of the foundations for the new switchyard breakers and reconfiguration of the switchyard, the "Note" at the end of LRA Section 2.4, "Scoping and Screening Results: Structures," previously revised by the FENOC response to NRC Supplemental RAI OIN-381 by letter dated October 7, 2011 (ML11285A064), is revised to read as follows:

Note: The yard structures evaluated for license renewal include foundations and structural arrangementsfor the Borated Water Storage Tank (including Trench);

Diesel Oil Pump House, Diesel Oil Storage Tank, Emergency Diesel Generator Fuel Oil Storage Tanks; Fire Hydrant Hose Houses; Fire Walls between Bus-Tie Transformers, between Bus-Tie and Startup Transformer 01, and between Auxiliary and Main Transformers; Fire Water Storage Tank; Nitrogen Storage Building; Station Blackout Components and Structures In the Yard and Switchyard (Startup Transformers 01 and 02, Bus-Tie Transformers, 345-kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, ACB34564, 81-B-66 and 81-B-67, air brcak s-itch AB341625, Relay House, Switchyard and Yard Towers for 345-kV distribution, "J" and "K" buses); Wave Protection Dikes; Duct Banks; Cable Trenches; and Manholes.

Enclosure A L-1 3-304 Page 5 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 2.4.12 Page 2.4-38 1 1 th Bullet Based on the addition of the foundations for the new switchyard breakers and reconfiguration of the switchyard, the eleventh bullet (Station Blackout Component Foundations and Structures) in the list of Yard Structures in LRA Section 2.4.12, "Yard Structures," previously revised by the FENOC response to NRC Supplemental RAI OIN-381 by letter dated October 7, 2011 (ML11285A064), is revised to read as follows:

Station Blackout Components and Structures in the Yard and Switchyard including Startup Transformers 01 and 02; Bus-Tie Transformers; 345-kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, and-ACB34564, 81-B-66 and 81-B-67, 345 V Switc yard air br.ak switch A,BS3-!4625; Relay House, Switchyard and Yard Towers for 345-kV distribution, and the 345-k V Switchyard "J" and "K" buses

Enclosure A L-1 3-304 Page 6 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 2.4.12.9 Pages 2.4-42 "Title"; and and 2.4-43 "Structure Description" 1 st and 4 th Paragraphs Based on the addition of the foundations for the new switchyard breakers and reconfiguration of the switchyard, the Section title, and first and fourth paragraphs of LRA Section 2.4.12.9, "Station Blackout Component Foundations and Structures in the Yard and Switchyard (including Startup Transformers 01 and 02; Bus-Tie Transformers; 345 kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563 and ACB34564; air break switch ABS34625; Relay House; Switchyard and Yard Towers for 345-kV distribution ; "J" and "K" buses) - Seismic Class I1," portions of which were previously revised by the FENOC response to NRC Supplemental RAI OIN-381 by letter dated October 7, 2011 (ML11285A064), and, although not shown below, the LRA Table of Contents, are revised to read as follows:

2.4.12.9 Station Blackout Component Foundations and Structures in the Yard and Switchyard (including Startup Transformers 01 and 02; Bus-Tie Transformers; 345-kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563. and-ACB34564, 81-B-66 and 81-B-67;7..r *'h*-ak

.. s;w.ch A.345 Relay House; Switchyard and Yard Towers for 345-kV distribution; "J" and "K" buses)- Seismic Class II The station blackout component foundations and structures in the yard and switchyard (including Startup Transformers 01 and 02; Bus-Tie Transformers; 345-kV switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, apd-ACB34564, 81-B-66 and 81-B-67; air brak switch ABS34625; Relay House; Switchyard and Yard Towers for 345-kV distribution; "J"and"K" buses) are Seismic Class II structures. Startup Transformers 01 and 02, Bus-Tie Transformers, and associated breakers (circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, ACB34564, 81-B-66.and 81-B-67 and Qir break switch ABS34625) define the physical boundary that provides an offsite alternating current (AC) source for recovery from a station blackout regulated event.

Circuitbreakers A CB34560, A CB34561, A CB34562, A CB34563 a4d-A , CB34564, 81-B-66 and 81-B-67 air break switch ABS345 625; the Relay House and "J" and "K" Bus Support Structures are located within the 345-kV Switchyard. The Relay

-- House is located-just east-of-the switchyard.-

Enclosure A L-1 3-304 Page 7 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 2.5.6.2 Page 2.5-8 Last 2 paragraphs Based on the addition of the new switchyard breakers and the reconfiguration of the Davis-Besse switchyard, the last 2 paragraphs of LRA Section 2.5.6.2, "Station Blackout Recovery Path Evaluation Boundaries," are revised to read as follows:

Within the switchyard, there are two 345-kV buses - the "J" (East) bus and the "K" (West) bus. The "J" bus is closest to the plant and the "K" bus is located on the farther side of the switchyard, closer to the grid. The current switchyard configuration includes circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, a-4d-ACB34564, 81-B-66, and 81-B-67 in a ring bus configuration.

These circuit breakers and the switchyard buses are within the license renewal evaluation boundary. This configuration is shown in simplified graphical form in USAR Figure 8.2-2 and in Figure 2.5-1 below.

The control circuits and protective relays for the switchyard circuit breakers (and the equipment associated with the "J" and "K" buses), as w'le as disconnect swvitch ,A,4S334625 are within the scope of license renewal. The switchyard Relay House, where the switchyard control circuits and relays are located, is within the scope of license renewal, and is addressed in Section 2.4.12.

Enclosure A L-1 3-304 Page 8 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Figure 2.5-1 Page 2.5-9 Entire Figure Based on the addition of the new switchyard breakers and the reconfiguration of the switchyard, LRA Figure 2.5-1, "Davis-Besse Station Blackout Recovery Path," is replaced in its entirety, as follows:

[See LRA Figure 2.5-1 on page 9 of 29]

Enclosure A L-1 3-304 Page 9 of 29 Figure 2.5-1 Davis-Besse Station Blackout Recovery Path

4. 6KV ESSENTIALBUS "Cl" 4.16KV ESSENTIALBUS '0"'

4.16KV SWITCHGEAR BUS 'C2" 4. SWITSEGEARBUS "02"

_AjBUS T IE BUS I TRANSFORMER *AC*V, TRANSFOR4ER TO 4.,1 T.KV (NO3.8KV . D"U 2

FROMMAIN START-UP TRANSFORMER TRANSFORMER START-UP NO. I NO. I TRANSFORMER rA ýt -%(345KV TO 13.SKV) -- NO. 2

.AN. (345KV TO 13.8KV)

SW)TCHTABO I" I\ 345KV BUS 'J' (E'AST BJS)I_

ACB 34563 81-ACB34560 II rI-. . -

. --*

ACB 34 I56 ACS 34564 01 FII AC8 34562

. . . . -- I I I 345KYBUS V' (WESTBUS)

TOBAYSHORE TO LEMOYNE TO OHIO SUBSTATION SUBSTATION EDISONC0.

I ---------- NOT IN SCOPEOF LICENSERCNEWAL SO RECOVERY PATH

Enclosure A L-1 3-304 Page 10 of 29 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence 3.3.2.1.11 Page 3.3-15 "Materials" subsection The Laboratory (Lab.) demineralized water storage tank level gage previously added to the LRA in the FENOC response to Nuclear Regulatory Commission (NRC) request for additional information (RAI) 2.3.3.11-01 by letter dated June 24, 2011 (ML11180A060), has been removed from the plant, and the component material listed in LRA Section 3.3.2.1.11, "Demineralized Water Storage System," is deleted, as follows:

Materials The materials of construction for subject mechanical components of the Demineralized Water Storage System are:

. Stainless steel a Steel

Enclosure A L-1 3-304 Page 11 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-11 Pages 3.3-274, Rows 28-32; and, 3.3-276 4 additional rows and 3.3-277 The Laboratory (Lab.) demineralized water storage tank (DB-T108), represented in LRA Table 3.3.2-11, "Aging Management Review Results - Demineralized Water Storage System," by row numbers 28-32, and the associated storage tank level gage, previously added to the LRA in the FENOC response to Nuclear Regulatory Commission (NRC) request for additional information (RAI) 2.3.3.11-01 by letter dated June 24, 2011 (ML11180A060), have been removed from the plant, and the associated rows in LRA Table 3.3.2-11, "Aging Management Review Results - Demineralized Water Storage System," are deleted, as follows:

Table 3.3.2-11 Aging Management Review Results - Demineralized Water Storage System Intended Aging Effect Aging NUREG-Row Component Intend Material Environment Requiring Management 1801, Table Notes No. Type Function(s) Management Program Volume Item 2 Item demin*,watef Str't'ra Sta#less ........... N 2-8 tan (....... NOAO Ae.e 030-7 Tank Lab.

ein-..ater St.,etw..a. Stak.ess Meist-aia Less-ef One Time InpeinVD 2 .. 3 steagje-tan ine4 Stee (Inemag nqater*a

/I*'Q T0132

Enclosure A L-1 3-304 Page 12 of 29 Table 3.3.2-11 Aging Management Review Results - Demineralized Water Storage System Intended Aging Effect Aging 18NUREG-Row Component Intend Material Environment Requiring Management 1801, Table Notes No. Type Function(s) Management Program Volume Item 2 Item 0em4n-Wate Str'-etwal Stamiles Tetetd vwate ess-ef L-; One-Time V 443 4 G

.te.agetanoR,te ) Stee4 (nemag 4 materiai 1speetieR Tank~ Lab.l 34 demiR.-watef StruetwaI Stainless Trcated %qt&r Less ee PJAIR Wate U- 4 3342 ste~age tan~ integr~ Steel (Internao maeiahemisti)

Tan*Labl . Air indoen

~32 de* wtaR SeeU~

integr SteFage

'Jeet'-r ta~es nOW#ell~e None None 4/11- -4 3.3.4-94 40

/IB-T4/*t* '* " '

Str-UGM~aAir kdoeeA

- Level G*.ge t.e. Glass /Nene None J8 3 A 8

- Level-Gage #nee&F# Glas (ta None None Whi 4 3.3.4-93 A8 integ~#y332

- Lee Gg Struhta Ga Troated wate. None None Vj414-- 3-3-. A integmiy OW-ema Stlassua ' deo rAir- --

- Levl ag iteg~ Glass uneont~oed Noene None 4/1S- -319 A 1=e~eI-Gege

Enclosure A L-1 3-304 Page 13 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.7 Page A-11 2 nd paragraph, 2 nd sentence; 5th paragraph, 1 st sentence; 6 th paragraph; and 7 th paragraph, 2nd and 4th sentences Based on the incorporation of program changes from NRC License Renewal Interim Staff Guidance (ISG) LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP)

XI.M41, 'Buried and Underground Piping and Tanks'," LRA Section A.1.7, "Buried Piping and Tanks Inspection Program," previously revised in response to NRC request for additional information (RAI) B.2.7-1 by FENOC letter dated May 24, 2011 (ML11151A090), is revised to read as follows:

A.1.7 BURIED PIPING AND TANKS INSPECTION PROGRAM The Buried Piping and Tanks Inspection Program manages the loss of material from the external surfaces of piping and tanks exposed to a buried environment.

The program also manages the aging of the external surfaces of underground piping. The program includes protective coatings for buried steel piping and tanks, backfill quality, and cathodic protection as preventive measures to mitigate corrosion.

The program also includes visual inspections of the pipe or tank from the exterior as permitted by opportunistic or directed excavations. If damage to the protective coatings is found and the popvg-pipe or tank surface is exposed, the pipe or tank is inspected for loss of material due to general, pitting, crevice, or microbiologically influenced corrosion. If corrosion has occurred, the wall thickness will be determined.

The program includes verification of the effectiveness of the cathodic protection system, and monitoring the jockey fire pump operation or equivalent parameter.

The program also manages buried fire protection system bolting through opportunistic inspections.

Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings and cathodic protection.

The minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one ..a. ,e . steel piping segment and .... steel piping segme.nt - ,,taining,-hazm.. -Each-inspection-will have a minimum of 10 feet of piping inspected.

Enclosure A L-13-304 Page 14 of 29 A visual and volu-metrc inspection of the underground piping within the borated water piping trench will be performed during eah 10 year per,4d beginnipg no soon years n0 p, to the tprod of extended ,peratin* the 30-40, 40-50, and 50-60 year operating periods.

Degradation or leakage found during inspections is entered into the Corrective Action Program to ensure evaluations are performed and appropriate corrective actions are taken. If adverse indications are detected, additional b'-ed in s-&epe ppi inspections will be performed in order to provide reasonable assurance of the integrity of-bured the piping and tanks. The selection of components to be examined will be based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Additional sampling continues until reasonable assurance of the integrity of-bvied the piping and tanks is provided.

Enclosure A L-1 3-304 Page 15 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Pages A-55 Commitment No. 3 thru A-57 Based on the incorporation of program changes from NRC License Renewal ISG LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and Tanks'," License Renewal future Commitment No. 3 of LRA Table A-i, "Davis-Besse License Renewal Commitments," previously revised in response to NRC RAI B.2.7-1 by FENOC letter dated May 24, 2011 (ML11151A090), is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Commitment Source Section No./

Number Schedule Con.ments

_ I -

3 Enhance the Buried Piping and Tanks Inspection Program to: Prior to LRA A.1.7

  • Add 1) bolting for buried Fire Protection System piping, and April 22, 2017 and B.2.7
2) the emergency diesel fuel oil storage tanks (DB-T1 53-1, FENOC and DB-T1 53-2) to the scope of the program. Letters
  • Conduct annualgroundpotential surveys of the cathodic L-11-153- NRC RAes protection systemi using the aGceptanca Grieria listed in and B.2.7-1 from NACE RP0285 2002 and NACE SP0469 2007. Monitor cathodic L-13-160 NRC Letter protection voltage and current monthly to determine the and effectiveness of cathodic protection systems and, thereby, L-13-304 Ated the effectiveness of corrosion mitigation. Trend voltage,

Enclosure A L-1 3-304 Page 16 of 29 Table A-1 Davis-Besse License Renewal Commitments I Related LRA Item Commitment Implementation Source Section No./

Number ________I Schedule

____________Comments Soucents current, and ground potential readings and evaluate for A.1-1 from adverse changes. NRC Letter dated

" Require that the activity of the jockey fire pump or equivalent March 26, parameter be monitored on at least a monthly interval. 2013 Conduct a flow test by the end of the next refueling outage when unexplained changes in jockey pump activity are observed.

  • Require that the directed buried pipe inspection locations be selected based on risk.

" Require that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel-safy-relatedpiping segment and enestoel pipin* ... g..nt c,.o.tng hazard.u. material. Perform the directed buried steel pipe and tank inspections each ten year interval based upon -thefellewing table 4a, "Insnectionsof Buried Pipe," in the Xl. M41 aging management program described in LR-ISG-2011-03. Each inspection will have a minimum of 10 feet of piping inspected.

P"Feentive # of insocrtions of safot # of -- m*a- inmpctio flns A -ties related pping4oranks or-%of pie-on gth

-A- (Nete 24 -4 ONete-24

Enclosure A L-13-304 Page 17 of 29 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Iter Commitment Source Section No./

Number ScheduleComments

-4 -4 S -B -4

--D -0 *0 A/ote 4: Pro ventivo actions ar categeorzod v as follos:

m

  • dB Jm A. iat*n*liV pr.ot'eon, in accordano* wMiMl of etended ope*ratn and was perfational for 90% eo the time during that 5 ye9ar-s or-cathodis protoction was operational for 090% of th.e Itime sinee the last insection conducted under-this program.

NAC4_E= SPO-1690 20-07 -orNAC1E RP0295 2002, was installed for leos than 5 years prior to entering the period of extended oporation or-was operatinal for less thanF 90% of the time during that 5 years or-Gathedic inspection sine thVeve int oper*aonnal wasnsocu v o for l*es c.'v*end~eted than 90% of the time

  • vundmerevthi n/rVeoaV Gl P-roteetive enn tinas arei plaee aind no meehanicGi I-.

11 titpel V UOMCISM ttUtf MO V V 00 Mt, UUt t1attIVUttr protection is not pr*o/v*il or not in aotrrdance Wlth

.11V VV " VT " crivam " CIO not been entered.

Enclosure A L-1 3-304 Page 18 of 29 Table A-1 Davis-Besse License Renewal Commitments ItemImplmenttionRelated LRA Item Commitment Implementation Source Section No./

Number Schedule Cmet Com ments D. Critoria of A, 9, and C not met.

Note 2:. On-y one nWeG;tion s required for-piping which is both safet related and contains hazardous material

" Require that the EDG Fuel Oil Storage Tanks (DB-T1 53-1 and DB-T1 53-2) be inspected prior to entering the period of extended operation. The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks.

These inspections are not required if it is demonstrated that the tanks are cathodicallyprotected in accordance with NA CE International(NA CE) Standard Practice SP0169-2007, "Control of External Corrosionon Undergroundor Submerged Metallic Piping Systems." or NACE Standard Recommended Practice RP0285-2002, "CorrosionControl of Underground Storage Tank Systems by Cathodic Protection."

" OnR tre. thatf a W-s, .nl anrd .,n*l, ,rnrfrir, m; pnr firn thre underqrr s'nd "'"' 1..

.i the*& berated water ".ni.. -.. n.h w.ll 5,

Mn nflrfr.ininnnrl inn trirte a, h /,, ti n r na in/nt ;n r;n,,,n/,-,nle

  • nn rrr beon p 1"l inoier nr enr in ea-hn n-n, in fhn nar-e,- n'0 ,erfn,-,innanr

Enclosure A L-13-304 Page 19 of 29 Table A-I Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number ScheduleComments

_______ents Add a requirement that undergroundpiping in the decay heat removal and low pressure injection system located in the borated water oiving trench will be visually insvected durina the 30-40. 40-50. and 50-60 year ooeratina Deriods to confirm the absence of aqing effects.

" Require that if adverse indications arc detected, additinal buried in scope piping inspections b. prfrmd ineorder F'to provi4de reasonab'o asua.n... e of the ,#,-,-gtyof buried piping Base the selection of com~ponents to be examined o r ~u e.aminati. n resuls, trending, isk .anking, and ares o eathedie nrofhetion failures or gaps, if appnliable. Continue additional s*ampling until reasonable assurance of the itegrity of buried piping is p iovided.

" Require that if adverse indications are detected, the insp~ection sample sizes, within the affected piping categories, are initially doubled and if adverse conditions are discovered in the expanded sample, the size of the follow-on inspections is determined by establishing the extent of condition and extent of

(~nnRi5dRnt with th~ FFNfl(7 flnrmctiv~ A~tinn Prnnr~m Scheduling of additional examinations is based on the severity of the degradation identified and commensurate with the conseguences of a leak or loss of function, but in all cases, the expanded sample inspection should be completed within the

_____________ I 10-year interval in which the nric7inal adverse3 indication was

j ___________________ I __________ I ________________

Enclosure A L-1 3-304 Page 20 of 29 Table A-1 Davis-Besse License Renewal Commitments ItemImplmenttionRelated LRA Item Commitment Implementation Source Section No.!

Number Schedule Comments identified. Furtherinspections are conducted in locations with similarmaterials and environment, or the piping is replaced on a schedule based upon either the station's need to return the system to service for non-Technical Specification-related systems or the allowed outage time for Technical Specification-related systems.

  • Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.
  • Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

" Include the following acceptance criteriain the program procedure:

o The cathodicprotection survey acceptance criteria are the

-850 mV relative to a copper/coppersulfate reference electrode (CSE). instant off or -lOOm V minimum polarization testing criterialisted in NACE SP0169 2007 and limiting criticalpotential not more negative than 1200 mV, o For coated piping or tanks, there should be either no evidence of coating degradationor the type and extent of coating degradationshould be insiqnificantas evaluated by

Enclosure A L-1 3-304 Page 21 of 29 Table A-1 Davis-Besse License Renewal Commitments Item Commitment Implementation Source Related Section LRA No./

Number Schedule Cmet Comments an individualpossessing a NACE Coating Inspector Program Level 2 or 3 inspector qualification or an individual has attended the Electric Power Research Institute (EPRI)

Comprehensive Coatings Course and completed the EPRI Buried Pipe Condition Assessment and Repair Training Computer-Based Training Course. Where damage to the coating has been evaluated as significant and the damage was caused by nonconforming backfill, an extent of condition evaluation should be conducted to ensure that the as-left condition of backfill in the vicinity of observed damage will not lead to further degradation:

o If metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained:

and, o Changes in iockey pump activity or equivalent parameter that cannot be attributedto causes other than leakage from buried piping are not occurring.

Enclosure A L-13-304 Page 22 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.7 Pages B-40 Program Description; thru B-42 NUREG-1801 Consistency; and, Enhancements Based on the incorporation of program changes from NRC License Renewal ISG LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL)

Report Revision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and Tanks'," LRA Section B.2.7, "subsections titled "Program Description," "NUREG-1 801 Consistency," and "Enhancements,"

previously revised in response to NRC RAI B.2.7-1 by FENOC letter dated May 24, 2011 (ML11151A090), are revised to read as follows:

Program Description The Buried Piping and Tanks Inspection Program manages the loss of material from the external surfaces of piping and tanks exposed to a buried environment.

The program also manages the aging of the external surfaces of underground piping. The program includes protective coatings for buried steel piping and tanks, backfill quality, and cathodic protection as preventive measures to mitigate corrosion.

The program also includes visual inspections of the pipe or tank from the exterior as permitted by opportunistic or directed excavations. If damage to the protective coatings is found and the piping surface is exposed, the pipe or tank is inspected for loss of materialdue to general,pitting, crevice, or microbiologicallyinfluenced corrosion. If corrosion has occurred, the wall thickness will be determined.

The program includes verification of the effectiveness of the cathodic protection system, and monitoring the jockey fire pump operation or equivalent parameter.

The program also manages buried fire protection system bolting through opportunistic inspections.

Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings and cathodic protection.

The minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one-&afety-i steel piping segment and O. steel . piping

.egM.nt "ontai"inghazma,. Each inspection will have a minimum of 10 feet of piping inspected.

Enclosure A L-1 3-304 Page 23 of 29 A visual and volumetric inspection of the underground piping within the borated water piping trench will be performed during each 10 year period beginning no sooner than 10 years pr"or" to the en"t into the pero4d of extended operation the 30-40, 40-50, and 50-60 year operating periods.

Degradation or leakage found during inspections is entered into the Corrective Action Program to ensure evaluations are performed and appropriate corrective actions are taken. If adverse indications are detected, additionalb'ried in seope pipig inspections will be performediRee to provide reasonable assuranceof the integrity of-rie# the_.hepiping and tanks. The selection of components to be examined will be based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Additional sampling continues until reasonable assurance of the integrity of-bu*4ed the piping and tanks is provided.

The Buried Piping and Tanks Inspection Program ensures that the intended function of the subject components will be maintained consistent with the current licensing basis during the period of extended operation.

The buricd piping and pi'ping components within the scope of this progamar- :

the fWlowing plant sy-stems.

SEmergency Diesel Gener.ator.s E*DG) S*ysem fuel oil ,subsystem

. Fire Protieto Systemg SeippeWatr-System The buried tanqks within the scope of the proegram are the E-DG Fuel Oil Storage Tankrs (ig T-53 I and 9B T-53 2).

The buried bolting within the scope ef the program is asisociated With Fire ProectonSystem piping.

NUREG-1801 Consistency The Buried Piping and Tanks Inspection Program is an existing Davis-Besse program that, with enhancement, will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section X..M3 M41, "Buriedand UnderqroundPiping and Tanks-k apeetieL," as revised by NRC License Renewal Interim Staff Guidance (ISG) LR-ISG-2011-03, "Changes to the Generic Aginq Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and--Tanks'." --- -

Enclosure A L-1 3-304 Page 24 of 29 Enhancements The following enhancements will be implemented in the identified program elements prior to entering the period of extended operation.

  • Scope Add the emergency diesel fuel oil storage tanks (DB-T1 53-1, DB-T1 53-2) to the scope of the program. The existing program scope includes only buried piping.

Add bolting for buried Fire Protection System piping to the scope of the program.

  • Parameters Monitored or Inspected Add a requirement that annual ground potential surveys of the cathodic protection system will be conducted and tho accoptance criteria are isted in NA, CE RP0285 2002 and SF0169 2007. Cathodic protection voltage and current, will be monitored monthly to determine the effectiveness of cathodic protection systems and, thereby, the effectiveness of corrosion mitigation. Voltage, current, and ground potential readings will be trended and evaluated for adverse changes.
  • Detection of Aging Effects Add a requirement that the activity of the jockey fire pump or equivalent parameter be monitored on at least a monthly interval. When unexplained changes in jockey pump activity are observed, a flow test will be conducted by the end of the next refueling outage.

Add a requirement that the directed buried pipe inspection locations be selected based on risk. -

Add a requirement that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel-safety -e4 piping segment and one steel piping segment "ontain*n* hazmat. The directed buried steel pipe and tank inspections are performed each ten year interval based upon-the-f eewkg table 4a, "Inspections of Buried Pipe," in the Xl. M41 aging management program described in LR-ISG-2011-03. Each inspection will have a minimum of 10 feet of piping inspected.

Enclosure A L-1 3-304 Page 25 of 29 P-revepte # of insections ot # of Hazmqat insections o9

.4 -tipssafot related piping 9F *%-ef-pipe-length

-A- (Nete 24 471 e(te- 2

-B- 4-24

- -- 4- O

_ _ _ _ _ -1 _ _ _ _ _ _

Net 4 _ _ _ _ _

PrFeVentivez actions are categorized .sfol8 s

.4. Ca-;th od,' protectien, in accor-dancc with 4ACE= SPO6 16 07orF NACG RPR0285 2002, was inistalled for- at least 5 years prior- to the period et ex tended opera t~on and was operational for 90% of the time durig that years Or cathodic protect6on was oper-ational for-90% of the time Since the last inspection con dIutod under-thi6 proagram.

. Catod... p.r 3otetn, in accordance wi.th NA GC= SPO 1 69 2007 Or NACE Mnl-tnn"Or nn)f~'J,) .  ; 1. 1*.I-- .r-- 1-- 4"-- C -. -- _;__ 44-* 4t.- .  ;* -4 extended operation or-rwas operational for iess than 90% of the tirm*e during that 5 years or- inspection was Ope*raional for loss than

.athodic 90% Of the tfire sRince the last inspecto Gconducted under-this progr-am C. PRote~fiVe ccatingg arc in place and no mechanical coating dfamag-e 14 I-RI 4 k,4-11 1 ;I " P --.. . . .  ;

aDB-Tda5-2) wiith breinaseA Br and the period ofextended operationh not been entered.

D. Criteria of A, B, and C not met.

Note-Ontlyoe inspection i n igd forU piping waich is both sat related ane con tains hazmat.

Add a requirement that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T1 53-2) will be inspected prior to the period of extended operation.

The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom, or an internal inspection consisting of UT measurements with at least one measurement per square foot of the surface of the tanks. These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE International (NACE)

Standard Practice SP0169-2007, "Control of External Corrosion on Underqround-orSubmerqed Metallic Piping -Systems," or NACE-Standard

Enclosure A L-1 3-304 Page 26 of 29 Recommended PracticeRP0285-2002, "Corrosion Control of UndergroundStorage Tank Systems by Cathodic Protection."

A4dda regwre*m;en*t that a vOi-sal -;Pd volumetr÷c inSpe6t6P Of the-r4d~

un ig within the bora tad water piping trench wil be pedoreddrg each 10 year-period begi-ng' ;eonor-than 10 years prior to the enty into the perod ofd Add a requirement that underground piping in the decay heat removal and low pressure iniection system located in the borated water piping trench will be visually inspected during the 30-40, 40-50, and 50-60 year operating periods to confirm the absence of aging effects.

Add a reqirement that if adverse indications are detected, additional buriedf in.scope pf.fipig inspectionS Wi4 be po~forrned in order to provide rcFenabl-9he assuranGe oAf the integrity of buried piping. The seleton-ho ot co)mponents to b- exmnd wi4 be based on Previous exam nination results, tre*nin&, rikl rFankng, and oer-a of Gathodic pFrtect6on failPres or gaps, if applicable. Addepitn samplig contiues Unt4 reasonable a;ssurance of the integr~ty o~f bur~ed piping is provided.-

Add a requirement that if adverse indications are detected, the inspection sample sizes, within the affected piping categories, are initially doubled and if adverse conditions are discovered in the expanded sample, the size of the follow-on inspections is determined by establishinq the extent of condition and extent of cause, consistent with the FENOC Corrective Action Program. Scheduling of additional examinations is based on the severity of the degradation identified and commensurate with the consequences of a leak or loss of function, but in all cases, the expanded sample inspection should be completed within the 10-year interval in which the original adverse indication was identified. Further inspections are conducted in locations with similar materials and environment, or the piping is replaced on a schedule based upon either the station's need to return the system to service for non-Technical Specification-related systems or the allowed outage time for Technical Specification-related systems.

Add a requirement that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Add a requirement that the inspections of buried piping be conducted

-using visual (VT-3 or-equivalent-)-inspection -methods_ Also,-to-ensure that a sufficient inspection area of the buried component is exposed, the

Enclosure A L-13-304 Page 27 of 29 excavation shall be a minimum of 10 linear feet of piping, with all surfaces of the pipe exposed.

Acceptance Criteria The principal aGeta~ Griteria associated with the inspeG6GP; contained with this AMP foi!;-:

The program procedure will be enhanced to state that:

a. Criteria for sol to pipe potential are listedin sACureP285 200t2 and SPe0169 2007. The cathodic protection survey acceptance criteria are the -850 mV relative to a copper/copper sulfate reference electrode (CSEr. instant off or -l01m6V minimum polarization testing criteria listed in NACE SF0169 2007 and limiting criticalpotential not more negative than 1200 mV.
b. For coated piping or tanks, there should be either no evidence of coating degradation or the type and extent of coating degradation should be insignificant as evaluated by an individual possessing a NACE operator qUalification or o-thos..e meeting the qualifi..tions to evaluate coatings as contained in 49 192

,FR and 195 Coating Inspector Program Level 2 or 3 inspector qualification or an individual has attended the Electric Power Research Institute (EPRI) Comprehensive Coatings Course and completed the EPRI Buried Pipe Condition Assessment and Repair Training Computer Based Training Course. Where damage to the coating has been evaluated as significant and the damage was caused by non-conforming backfill, an extent of condition evaluation should be conducted to ensure that the as-left condition of backfill in the vicinity of observed damage will not lead to further degradation.

c. If metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained.
d. Changes in jockey pump activity or equivalent parameter that cannot be attributed to causes other than leakage from buried piping are not occurring.

Enclosure A L-13-304 Page 28 of 29 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Environmental Page 3.2-2 2nd paragraph, 3 rd sentence Report Section 3.2 Page 3.2-3 2nd-paragraph, Ist & 2 nd bulleted items 4 paragraph, 1st (& only) sentence Page 3.2-4 2 nd paragraph, 1 st sentence Based on the construction of the New Steam Generator Storage Facility, LRA Appendix E, "Applicant's Environmental Report - Operating License Renewal Stage" (Environmental Report), Section 3.2, "Refurbishment," is revised to include the name of the previously-built Storage Facility, address the new permanent structure, and provide an update to the plans for the Steam Generator Replacement Project, to read as follows:

PAGE 3.2-2 FENOC-i.nl, t* replaced the reactorvessel head in 2011 (see ,N* 2014) and plans to replace the two originalsteam generators in 2014. FENOC has determined that the most cost-effective method for long-term management of the replaced reactorvessel head, steam generators,and other large irradiatedplant equipment, is to store them on-site in a dedicated storage facility, and then disposition them along with the remaining plant equipment when Davis-Besse is decommissioned. Therefore, a new permanent structure, the Old Steam GeneratorStorage Facililtyes planned to be was constructed in 2011, which-will provides approximately 12, 000 square feet of space to house indefinitely the GUep-replaced(Midland) reactorvessel head, and later house the original steam generatorsand the Reactor Coolant System hot legs (see below). A permanent multi-story office building was also .i planned to be constructed in 2011 adjacent to the Auxiliary Building to house personnel that-wil supported the replacement activities for the reactorvessel head and will support the replacement activities for the steam generators.

Enclosure A L-1 3-304 Page 29 of 29 PAGE 3.2-3 The replacement steam generators are being manufactured in Cambridge, Ontario, Canada by Babcock and Wilcox Canada, Ltd., and will be transported to Davis-Besse. The steam generators are planned to ship separately, and transport is expected to involve the following methods of transportation and routes:

  • Rail transportfrom Cambridge, Ontario, to-The Por of Terent9 Hamilton, Ontario

" Ba~ge-Shiptransportacross Lake Ontario, through the Welland Canal, and across Lake Erie to the Port of Toledo; and,

  • Rail transport from the Port of Toledo to Davis-Besse.

After the replacementsteam generatorsarrive at Davis-Besse, FENOC plans to transportthe steam generators on a heavy-duty self-propelled modular transporter,and move them to thea temper-a 18,000 square foot New Steam GeneratorStorage Facility (included in the 80,000 square feet of facilities described below) te- e constructed at Davis-Besse in 2013.

PAGE 3.2-4 To perform the steam generatorreplacement, FENOCplans for a temporary construction opening approximately-24 23 feet wide by-3-9 31 feet high to be createdin the Shield Building and free-standing Containment Vessel. The Shield Building is composed of reinforced concrete walls approximately two and one-half feet thick, and the free standing Containment Vessel is approximately 1.5 inches thick steel. The process of creating the opening would include activities such as removing concrete, cutting rebar, and cutting and removing a section of the steel Containment Vessel. A hydro-demolition (high pressure water) process or other mechanical methods are being considered to remove the Shield Building concrete, and mechanical methods are being considered to cut the Containment Vessel opening. After installation of the new steam generators, the openings would be sealed and the Containment Vessel and Shield Building returned to their original configurations and integrity.

Enclosure B Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-1 3-304 Revised Davis-Besse License Renewal Application Boundary Drawing 1 Page Follows The following License Renewal Application Boundary Drawing is revised and is enclosed:

LR Drawing LR-MO10C Revision 2

THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:

DAVIS-BESSE NUCLEAR POWER STATION UNIT NO.1 THE TOLEDO EDISON COMPANY DRAWING NO. M-01OC WITHIN THIS PACKAGE...

D-01X

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