ML19319C068

Application for SNM License Authorizing Util & Cleveland Electric Co to Receive,Possess & Store Unirradiated Fuel Assemblies & Associated Radioactive Matls

ML19319C068
Person / Time
Site:	Davis Besse, 07002151
Issue date:	11/07/1975
From:	CLEVELAND ELECTRIC ILLUMINATING CO., TOLEDO EDISON CO.
To:
Shared Package
ML19319C066	List: ML19319C065 ML19319C068
References
NUDOCS 8001310444
Download: ML19319C068 (41)

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9 BEFORE THE UNITED STATES NUCLEAR REGULATORY COM> FISSION DOCKET NO. 50-346 In the Matter of THE TOLEDO EDISON COMPANY and THE CLEVELAND ELECTRIC ILLUMINATING COMPANY APPLICATION FOR A SPECIAL NUCLEAR }iATERIALS LICENSE for Davis-Besse Nuclear Power Station Unit 1 DATE:

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3ENE.RAL INFORMATION Reactor and Fuel 1

, This application is submitted for the Davis-Besse Nuclear Power Station Unit 1, located on a site on Lake Erie in Ottawa County, Ohio, approximately six miles northeast of Oak Harbor, Ohio. The NRC docket number assigned to the project is 50-346 and the Applicant has been granted construction permit number CPPR-80.

2 The fuel assembly components, materials, and dimensions are fully, detailed in Section 4'.2.1.3 of the Applicants' Final Safety Analysis Report (FSAR) on file with the Commission. A drawing of the fuel assembly is shown in Figure 4-1 of the FSAR, reproduced in this Application as Figure 1-1.

The principal components of the fuel assembly and the material compositions are listed below:

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Fuel - - - - - - - - - - - - Low enriched Uraniuu Dioxide (UO ) sintered pellets 2

Cladding - - - - - - - - - - Zircaloy - 4 tubing End Caps - - - - - - - - - - Zircaloy - 4

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Control Rod Guide Tube - - - - - Zircaloy - 4 Instrumentation Tube - - - - - - Zircaloy - 4

-End Fittings - - - - - - - - - - Stainless Steel Spacer Grids - - - - - - - - - - Inconel-718 Spacer Sleeve - - - - - - - - - - Zircaloy - 4

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The guide tubes, spacer grids, and end fittings form a struct-ural cage that supports 208 fuel rods, 16 control rod guide tubes, and the incore instrumentation tube in a 15 x 15 array.

The fuel assembly pitch is 8.587 inches, the overall length of an assembly is 165.625 inches, and the active fuel length is 144 inches.

Each fuel rod contains uranium dioxide pellets that are 0.3675 incbes in diameter and have a nominal density of 96% of theoretical. The Zircaloy cladding,has an inner diameter of 0.377 inches and an outer diameter of 0.430 inches. The fuel rod pitch is 0.568 inches.

1.1.3 The fuel data for the 177 fuel assemblies to be used in the i

first core is as follows:

Uranium U-235 per U-238 per Uranium per Number of Enrichment Assembly Assembly Assembly I

Assemb'..ie s (W/0 U-235)

(Kg)

(Kg)

(Kg) 56 1.98 9.40 465.16 474.56 61 2.63 12.48 462.08 474.56 60 2.96 14.05 460.51 474.56 The total weight of an assembly is 1525 1 10 lbs..

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1.1.4 T1.e total number of fuel assemblies fv which a license is requested is one hundred and eighty (180) consisting of the 177 first-core fuel assemblies described above plus an allowance for 3 spare assemblies with enrichments less than, or equal to, 3.05 weight percent Uranium-235.

. Based on the preceding, a license is requested for the following:

a total amount of Uranium-235 in fuel assemblies not to exceed two thousand two hundred (2,200) kilograms, and a total weight of contained Uranium in fuel assemblies not to exceed eighty-six thousand (86,000) kilograms.

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'1.2.1 The fuel storage and handling area is located at elevations 585 and 603 of the auxiliary building which is a Seismic Class I s

structure. Arrangement of the fuel storage and handling area is shown in Figure 1-2.

The fuel will be stored in the spent fuel and new fuel storage racks. Inspection of the fuel assemblies will also be performed in the fuel storage and handling area.

1.2.2 To the extent practical, no operations other than fuel and control components storage and handling will be performed in the fuel storage area while fuel is being handled or stored.

Limited access will be necessary to the equipment hatch on elevation 603 to support construction activities and testing operations in the containment prior to fuel load.

This will involve activity in the fuel handling area to the west of the fuel storage area but will not affect the safety of fuel storage.

l 1.2.3 The fuel storage and handling systems are fully described in, Section 9.1 of the FSAR.

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The new fuel storage area provides dry storage for eighty (S0)

I fue1' assemblies. The fuel assemblies are stored in Seismic

Class I storage racks that are securely anchored to the floor

of the building. The racks are designed so that the assemblies can be placed only.in the' designated storage rack positions.

These racks are located in parallel rows and provide a minimum center-to-center distance of 21 inches in both horizontal e

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' directions. This arrangement'provides" for upright storage of the fuel assemblies in a non-critical array even in the event of flooding the storage pool with unborated water. The design seismic, toraado, and thermal loads are discussed in Sections 3.7 and 3.8 of the FSAR. The applicable codes and standards incorporated in the design are addressed in Section 9.1.1.3 of the FSAR.

The spent fuel pool is sized to hold 260 fuel assemblies and will be used to store the remaining fuel assemblies not stored in the new fuel storage area or, depending on desirability and/or construction status of support systems, may be used to store'the entire first core. The storage pool is a reinforced concrete pool lined with 1/4-inch-thick stainless steel.

The auxiliary building, as well as the storage pool, is a Seismic Class I structure which is designed to withstand seismic, tornado, and thermal loads as discussed in Sections 3.7 and 3.8 of the FSAR. The spent fuel storage racks are also Seismic Class I structures installed in parallel rows with centar-to-center spacing of 21 inches in either horizontal direction.

Initial storage in the spent fuel pool of first core fuel assemblies is intended to be dry. Should it become advantageous or desirable, the fuel in the spent fuel pool will be stored wet by using demineralized water. The safety of the storage i

system does not depend.on the boron concentration of the pool water. Should wet storage be utilized, the spent fuel pool cooling and cleanup system described in Section 9.1.3 of the

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FSAR would be employed to maintain the spent fuel pool water quality and clarity.

In addition to the pools and racks described above, other major equipment which will be utilized during receipt, trans-fer, inspection and storage of the fuel assemblies include:

1) spent fuel handling bridge and hoist mechanism, 2) spent fuel cask crane, 3) new fuel handling tool for use with the auxiliary hook of the spent fuel cask crane, and 4) new fuel elevator located in the fuel transfer tube pit.

Both the spent fuel handling bridge and the spent fuel cask crane are Seismic Class I designed equipment, and are designed to prevent them from becoming dislodged from their railings.

Interlocks and travel limits for the bridge and crane are described in Sections 9.1.2 and 9.1.4 of the FSAR.

1.2.4 The station fire protection system, is fully described in Section 9.5.1 of the FSAR. The fire protection system is 1

designed, installed, and tested in compliance with the re-quirements of the National Fire Protection Association Codes (NFPA), Nuclear Energy Liability Property Insurance Asso-ciation (NEL-PIA), the Uniform Building Code, and the area Fire Department codes and regulations.

Within the fuel storage area, carbon dioxida extinguishers will be used for fire protection.

Signs will be posted to warn against the use of fog and foam fighting equipment within the storage area. -

The amount of combustible material in the fuel storage area will be at a minimum.

1.2.5 Access to the fuel storage area on elevation 603 of the auxiliary building will be restricted to authorized Toledo Edison employees and agents a need-to-enter basis. For prevention of unauthorized access into the fuel storage area, temporary physical barriers will be erected as shown on Figure 1-2.

An armed guard will be utilized to enforce the restric-tions of access into this bounded area. A special station administrative procedure AD 1808.14, "Special Provision for Protecting Initial Fuel Load", will be implemented. This procedure will describe the necessary special security ceasures to be followed during storage of the initial core.

The above measures will be in effect upon fuel receipt and until the full Davis-Besse Industrial Security Plan (on file with the NRC) is implemented at least one month prior to fuel

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.1.3 ' Physical Protection 4

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The quantity of special nuclear material requested to be licensed is less than that defined by-10CFR573.1(b).

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1.4 Transfer of Special Nuclear Material 1.4.1 The Babcock & Wilcox Company has fabricated the fuel assemblies covered by this Application, and they are also responsible for shipment of the assemblies to the Davis-Besse Unit I site. The shipping containers are B&W Model B and are licensed with the NRC under License No. SNM-Il68.

1.4.2 Should a fuel assembly be damaged or otherwise unacceptable for use, the applicant will be responsible for packaging the Q

fuel for return to the fuel fabricator (B&W). The fuel will be reloaded into the Model B shipping centainers per station procedure SP1506.03, " Fresh Fuel Shipping Container Operating Procedure". Administrative procedure ADIS26.01, " Preparation and Distribution of AEC Form-741", will also be utilized should the need arise to return a fuel assembly.

1.4.3 In support of the above activities, Toledo Edison hereby makes a request to register as a user of the B&W Model B container (Certificate of Compliance No. USA /6206/AF) in accordance with the provisions of 10 CFR Part 71.

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-s 1.5 Financial Protection and Indemnity 1.5.1 The Applicants shall maintain financial protection in the amount of $1,000,000 as specified in 10CFR Part 140.13 in the form of a liability insurance policy written by NEL-PIA. A copy of this policy is attached as Exhibit A and is submitted as proof of financial protection under 10CFR Part 140, Section 15, Paragraph (a), Proof of Financial Protection.

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!F ~ l C,/ [ _.J r j EM6.EMT % ' -RStutP C23 PLAN THE TOLEDO EDISCN CO. STAT 10h1 GRACE - ELiv. 5 B 5' FUEL STOR?-SE AREA FIG U R C~~ 1 ~" SCM E W. : l ' DRAWN SY l h A"PitOVED BY l CHECKED BY h ll l l ons { cwo. uo.

'2.0 -HEALTH AND SAFETY - 2.1 Radiation Control 2.1.1-The training and experience of those persons under the Davis-Besse Station organization (described in Section 13.1.2.2 of the FSAR) responsible for radiation safety is summarized below: David W. Briden, Chemist & Health Physicist Graduated from Temple University with a MS in Health Physics. His research project involved neutron dosimetry, and used 5 Ci Pu-Bc and 20 ug Cf-252 seal sources, and a 25-MeV betatron. j Peior to MS, he worked seven years in a radiochemistry lab-oratory at the Dow Chemical Co., and obtained experience in handling activatiot product radionuclides produced by 2-MeV Van de Graaff and a 14-MeV accelerators, and a 100 KR TRIGA reactor, also used a 1200 Ci Co-60 source for cross-linking studies. He has also had on the job training at the Ginna Nuclear Station for a period of two months in actual use of handling curie quantities of fission product radionuclides, and two weeks at Three Mile Island Nuclear Station where part of the training _ involved the use of 50 Ci Cs-137 and 5 Ci Am-241-Be sources used for portable instrument es11bration. Richard D. Kwiatkowski, Chemistry and Health Physics Foreman l He has cttended several two week nuclear health physics re-lated courses-including Basic Radiological Health, Occupational

f~. = Radiation Protection, Radionuclide Analysis by Gamma SpIctroIcopy, and Operational Aspects of Radiation Surveillance which were conducted by the PHS and the EPA. In addition, Mr. Kwiatkowski completed a seventeen week training course for nuclear power plant personnel. He has had experience in health physics at several nuclear power stations. While on eight weeks training at the Palisades Station, he had an opportunity to use a 130 C1 Cs-137 source, in addition to actual use of handling curie quantities of fission product radionuclides. During a two week period at Three Mile Island Nuclear Station, part of the training involved the use of 50 Ci Cs-137 and 5 Ci Am-241-Be sources used for portable instrument calibration. He has also had two weeks on-the-job training in health physics at the Ginna Nuclear Station. John W. Taplev, Chemical & Radiation Tester Group Leader He has completed a seventeen week course in training for nuclear power plant personnel which included principles and practices of radiation protection, instrumentation, and calculations basic to use and measurement ci radioactivity. Additional training included a one week course in radiation surveys given by instructors from the University of Michigan, Radiological Health Department. He has had on-the-job training working for nine weeks in the Health Physics Section at the Ginna Nuclear Station in actual use of handling curie quanitites of fission product radionuclides. 12-s

Ronald J. Scott,-Associate Stat.on Technical Assistant d Mr. Scott has had eleven years experience working in the Radiochemistry Section at the Plum Brook Reactor Facility; in this work he gained considerable experience in handling curie quantities of byproduct material. He has completed the following training: Nuclear Technology for Power Plant Engineers (3 weeks), given by the General Physics Corporation, and a course in Radiation Surveys (2 weeks) given at the University of Michigan. He has also completed six weeks <>n-the-job training inhealthphysibsat the Ginna Nuclear Station. 2.1.2 Swipe sampling to check for contaminacion is included in the station system procedure SP1503.02, "New Fuel Receipt, Inspection, and Storage of B&W Mark B2 Fuel Assembly". Swipe samples are taken, progressively, from the outside of the shipping con-tainers, the inside of the shipping containers and on the fuel assembly itself. The method of collecting, counting and recording of the smears is outlined in Station Procedure PT5179.02, " Contamination Surveys". The detector systems used ~ to count the samples are generally described in Section 12.3.2.2 of the FSAR and the make and model numbers are listed in the Application for Byproduct Material License (Form AEC-313) identified under condition item 15 of Material License Number 34-16538-01 dated July 1, 1975. Contamination levels exceeding those specified in SP 1503.02 and PT5179.02 (limits set in accordance with D.O.T. and NRC'

regulations) will be reported as required and appropriate action will follow under the direction of trained Chemistry & Health Physics personnel. 2.1.3 Survey instruments and counting room equipment will be calibrated at six-month intervals. These calibrations will be performed ~ on-site using certified sources and standard solutions currently licensed under Meterial License Number 34-16538-01 dated July 1, 1975. O e o e 9 h e e e g e 14-4 }

-s 2.2 Nuc1'er.r Criticality Safety 2.2.1 All fuel assemblies will be stored in either the new fuel storage racks or the spent fuel pool storage racks described in Section 1.2.3 of this Application. The 21 inch center-to-center spacing of the racks provides for upright storage of the fuel assemblies in a non-critical array even in the event of flooding the storage pool with unborated water. The Seismic Class I racks are constructed from non-corrosive stainless steel and are designed to withstand the seismic, tornado, and thermal loads discussed in Sections 3.7 and 3.8 of the FSAR. 2.2.2 Consideration was also given to the condition of moderation within the assemblies and less than full water reflection between the assemblies. This condition is not credible since:

1) only carbon dioxide extinguishers will be used for fire protection, no foam or fogging equipment; 2) no sprinklers are in the fuel storage area; 3) no packaging material is placed with in the assemblies at anytime; and 4) though each fuel assembly in dry storage will have a fire-resistant plastic cover to prevent dust and dirt accumulation on the assemblies, the covers contain filters at the lower end to allow water to drain from the assemblies, if needed, thus preventing water from being retained within the assemblies if the area were fl. 4ed and then drained.

2.2.3 Only one fuel assembly will be handled at any given time in the spent fuel pool or new fuel storage areas. During handling. e

cf c fual'ccceably in tha spint fual psol stortg3 crcs by tha fuel handling bridge, the overhead crane can be employed for movement of a second assembly for inspection purposes and for placing the second assembly in the new fuel elevator. All other fuel assemblies shall be located either in the storage racks or in an approved shipping container. Station procedures written to specifically describe each handling step in detail and to allow testing of the equipment to be used in fuel handling will be followed. General fuel handling procedures and operations for handling and storing new fuel assemblies are listed below: A. Dry Storage (New Fuel or Spent Fuel Pools) 1. Verify fuel assembly identification and documentation. 2. Upright fuel assembly in the shipping container. I 3. Attach new fuel handling tool to crane hook and secure tool to fuel assembly. 4. Remove assembly from shipping container. 5. Remove plastic cover and transfer fuel assemb;.y to the fuel inspection area (see Figure 1-2). 6. Move the assembly up and down in the selected inspection space as necessary to complete the inspection of the assembly. 7. Remove assembly from the inspection space, replace original plastic cover (low chloride content) and place second fire resistant covering over first cover. Provide drain holes covered with filter l [ paper like those of the original cover. 1 16-V W

8. Move the assembly to its designated place in the storage rack and lower the assembly until seated in the rack. 9. Disengage new fuel handling tool from assembly. 10. Record fuel assembly location. 11. Repeat procedure for remaining fuel assemblies. ~ B. Wet Storage (Spent Fuel Pool Only) 1. Repeat steps 1 through 6 of the dry storage procedure. 2. Remove fuel assembly from inspection area and move the fuel assembly to the new fuel elevator at the edge of the fuel transfer tube pit. 3. Lower the fuel assc=bly into the neu fuel container attached to the new fuel elevator. 4. Disengage new fuel h'andling tool from assembly. 5. Lower new fuel elevator to the bottom of the fuel transfer tube pit. 6. Move fuel storage handling bridge.directly over the new fuel elevator and lower the mast with the fuel Srapple. 7. Engage the grapple to the new fuel assembly and remove the assembly from the new fuel elevator. 8. . Maneuver the. handling bridge into the spent fuel pool area to a designated storage rack location and lower the assembly until seated in the rack. e

._= 9. Disengage the grapple and' move the handling bridge to its normal location. 10. Record fuel assembly location.

11. Repeat procedure for remaining fuel assemblies.

All the fuel handling methods will be accompanied by appropriate administrative and document controls. Personnel ue1112ed in the handling of new fuel will be trained in the use of fuel handling equipment and will also be familiar with the operation procedures dealing with receiving, handling and storing new fuel assemblies. A dummy.'uel assembly will be utilized for testing and training. 2.2.4 An exemption is requested from the requirements of 10CFR370.24 as provided in 570.24(b). A criticality accident is not credible under the storage and handling conditions previously described. Additionally, two area radiation monitors located as show in Figure 1-2 will provide an audible and. visual alarm in both the area monitored and in the control room if the area rad-iation levels exceed a specified limit. The radiation-mon-itoring systems include ionization chamber detectors with a 0 measurement range of 1 to 10 mr/hr. 4 -

<m 2.3 Accident Anelynin 4 2.3.1 The potential for accidents affecting the safety of storage in the storage area is limited to the dropping of fuel assemblies over the storage area or at other places. The Seismic Class I design of the auxiliary building, bridges, cranes, racks, and pools preclude the credibility of more severe accidents. In the unlikely event of dropping a fuel assembly in the storage area, the consequences affecting safety would be minimal. Due to the spacing of the storage array, a criticality condition would not be possible under these conditions. The consequences of the accident would'be limited to the affect of possibly rupturing an undetermined number of fuel rods and releasing unirradiated low-enrichment uranium dioxide fuel. The Davis-Besse Nuclear Power Station Emergency Plan (refer to Appendix 13-D of the FSAR) adequately provides the necessary course of action to be followed as a result of such an incident. G 0,

r~s 3'.0 OTHER MATEP.IALS REQUIRING NRC LICENSE 3.1 Startup Sources -3.1.1 Authorization is requested to receive title to, own, receive, t-transfer and store one or more Americium-Berylliun-Curium (ABC) neutron sources or equivalent, the total amount not to exceed'one thousand (1000) curies, in addition to and at the same time as the fuel assemblies previously described in this Application. These sources will be sealed in leaktight metal containers and will contain Americium-241, Americium-242, 4 f Beryllium and Curium-242. The neutron sources will not be removed from their shielded casks at any time while in storage in the fuel storage and handling area. Since the neutron sources are stored in their shipping containers, there will be a negligible effect on the multiplication factor of the fuel array. 3.1.2 In addition to storage, authorization is requested for pro-visions to cover return shipping of the sources in their shipping containers to the supplier in case of damage to the sources or decay of sources because of other delays. Appropriate procedures .and precautions will be utilized should this need'arise. 3.1.3 In addition to the shielding provided for the sources, radiation ," protection provisions will include:

1) properly labeling of storage. location, 2)'radia, tion surveys of the area, and 3)' personnel radiation monitoring for individuals in the area. -

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n EXHIBIT A Proof of Financial Protection a E 3 r h e t%-

e .~ NUCLEAR ENERGY LIABILITY INSURANCE ASSOCIATION 127 John Street, New York, New York 10038 Nuclear Energy Liability Policy No. NF-- 236 (Facilary form) escLAaAvious, Item t. Named Inswid The Toledo Edison Company Ada,,,t 300 Madison Avenue,

Toledo, Ohio 43652 (No.

Street Town or Cary State) !aem 2. Policy Period: Begutning at 12:01 A.M. on the 1st day of November i, 75. and continuing through the criettave date of the cancelataors or termination of tha policy. standard time at he aJJress of the.4med ensured as stated herein ! tem). Dewraption of the Fudity: All of the premises including the land and all buildings and structures of Location Toledo Edison Company's Davis-Beese Nuclear Power Station located on a site consisting of approximately 954 acres on the southwestern shore of Lake Eri-approximately twenty (20) miles east southeast of the City of Toledo and twenty (20) miles west northwest of the City of Sandusky in Ottawa County, Ohio. Type Power Reactor The opentor of the facility is The Toledo Edison Company ! em 4. The limit of the companies habdity is : 1,000,000.00 subieci io sit the terms of ibis rainy havins refercixe thereto. Item 3. Advance Premium $ 100.00 Item & These declarations and the schedules formans a part hereof gne a complete description of the fudity insofar as : relates to the nuclest energy hatard estept as noted No exceptio_ns ,,, 75 _ coon,,,,igned by October 27 Date of Inve . This is to certify that this is a true copy of the opginal Declara1Tb3'd'%ffli"Rit8" Endorsement Numb rs 1 thru 9 belag made part of the Nuclear Energy, Liability {foli (Facility Form) as dccignated hereon. No Insurance is afforded hereunder Charles R. rdes, Ma ger iability Underwriting Nwleer Fnetsy !.aab.lity Policy (Fwility Form) 2/th? (Scrond Revisio. )Nucicar Eifergy Liability Property Insurance Assoc. T i l

r* () b 1 ~ UCLEIR EhihGi LIABilliY /:50PERTY li43Ui Ai!CE ASSOCIATi% NF-236 Re: Nuclear Energy Liability Policy No. ISSUED TO: The Toledo Edison Company Gentlemen: The nuclear energy hazard is a relatively new one to both the atomic indus try and the insurance business. Its nature is such that injury and claims may first become apparent long af ter exposure to nuclear materials. We call your attention to Condition 5 of your policy regarding Notice of Occurrence, Claim or Suit. The provisions of this Condition are a part of the contract of insurance and, as such, must be followed. Because it will be dif ficul t to assess accurately the full extent of

1. ') nuclear incident and especially to foretell whether claims will be made, we also urge you to report promptly any occurrence, incident, event or condition which may result in bodily injury or prope-ty damage even though it may appear that the policy does not apply thereto or that-no claims'may arise.

He feel sure that your cooperation in the above respect will enable us to work with you towards minimizing injury or damage from the nuclear energy ha za.-d and towards keeping the cost of nuclear ener gy liability insurance a!. low as possible. ours very traly, Burt C. Pro n G eneral Ma ni. g er 'BCP:H0'D (G ~ i 'o Is:h wg?. truiUni,1I ofI A S sita i.'i ' f arrm igten A.cn.y Iarnuncton. Con t ta.t OtW f ?Jh 61.' /N5 i Ensneering Dot. UCh U/ //15 ._I

o s NUCLEAR ENERGY LIABILITY INSURANCE ASSOCIAllON 127 John Street, flew York, New Yo'rk 10038 Nucles Energy Liabilsey Policy No. NF.-- 236 (Facility Form) DECLARATIONS The Toledo Edison Company I.em t. Named Insured 300 Madison Avenue.

Toledo, Ohio 43652 Add,,s, (No.

Strcet Town or City Sute) 1st day ofj!ovember 19 75 _.nd continuing throush Item 2. Policy Period: Beginning at 12.01 A.M. on the the efective date of the canelation or termination of this policy, standard time at the addrest of the named insured as stated herein. Item 3. Description of the Facility: All of the premises including the land and all buildings and structures of Location Toledo Edison Company's Davis-Besse Nuclear Power Station located on a sito consisting of approximately 954 acres on the southwestern shore of Lake Erie approximately twenty (20) miles east southeast of the City of Toledo and twenty (20) miles west northwest of the City of Sandusky in Ottava County, Chio. Type Power Reactor The Toledo Edison Conpany De Operator of the faciliry is 1,000,000.00 ,ubiect to ali the terms of this policy having reference thereto. . Jacm 4. The limit of the cornpanies' liability is $ 100.00 Item 5. Munce Premium $ Item 6. %cse declarations and the schedules forc2K a part hereof give a complete description of the facility, insofar as it relates to the nuc!ctr energy hasard. except as noted No exceptions Dste of Issue , ip 75 countersigned by October 27 Authorned Representative U""% Nucteer Energy Gability Policy (Facilitt Form) 2/1/57 (Second Revisioni) .W

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NUCGA" ENERGY LIAGluTY Pol'CY (FACILITY FORfM The under@ned members of Nuc! car Energy Liability insurance Assneistion, hereinafter called the " companies," cach for itself, several'y and not jointly, and in the ropntase proportions hereinafter set forth, agree with the insureJ, named in the declarations made a part hereof, m consideration of the premium and in reliance upon the statements irt the destara, ions and subject to the limit of liability, esclusions, conditions and other terms of this puhey: INSURING AGREEMENTS I COVERAGE A - 8CDILY INJURY AND PROPERTY DAMAGE byproduct material; LIClLITY To pay on belulf of the insured: "sourre m are,id," "speri.r! andrar material," and "bypraian ma:erid" (1) a!! sun which the insured sha'l bevorne legally obligated to pay have t!w recanings given them in the Atornie Energy Act cf 1954, or in as damages because of bodily injury or r operty damage caused any law amendatory thereof; by the nuclear energy haned, and tiu com anies shall e'efend anY "sprst prF means any fuel e!cment or fuel component, solid or liquid, suit against the insured allegmg such ily iabiry or property which tus been used or exposed to radiation in any nuclear reac9t; danuse and seding danuses whish are payable under t5e terms ,,,,,,,,,, sneans any waste material (t) containing byproduct material of this pohcy; but the companies m.sy nuke such investigation, and (2) rcsultmg from the operation by ar.y person or organintion of negotiane, and settle nent of any claim or suit as they deem anY nut! car facility incirded within the de5nition of nucicar facility orc 6ent, ,, der paragraph (1) or (2) thereof; (2) costs, taxed ag.iinit the insured in any such suit and interest on ,,3, j,,,jjj,y, means the facility described in the declarations and in-any judg nent therein; ciudes the location designated in item 3 of the declarations and all (3) premiums on arpe2l bonds and on bonds to release attachments prorerty and operations at such location; such suit, but without obligation to apply for or furnish ,,udm M#in** means "the facility" as desned in any Nuclear Energy ,m n Liability Policy' (Facility Form) issued by the companies or by Mutual (4) reasonable expenses, oth,er tiun loss of earnings, incurred by the Atomic Energy Liability Unde writers. The term " nuclear facility" also msured at the wrnp2nns request. means (1) any nuclear reactor, COVERAGE 8 - DAl.fAGE TO PROPERTY OF AN INSURED .(2) any equipment or device designed or

• sed for (a) separating the AWAY FacM THE FAclLITY isotopes of uranium or plutonium, (b) processing or utuuing With rortct to property damage caused by the nuclear energy luntd spent fuel, or (c) handling, processing or rackaging waste, to property of an insured which is away from the facility, to pay to (3) any equipment or device used for the processing, fabricating or such insured those sums which such insureJ would have been Ic :11Y s!!oying of special nuclear nuterial if at any time the total amount oblicated to pay as damascs therefor, lud such property belonge. to of such material in the custody of the insured at the premises where such equipment or device is located consists nf or centains

anomer, more than 23 grams of piutonium or uraniurn 23) or ani com-COVERAGE C - SUCn0GATION - CFF51TE EMPLOYEES bination thereof, or more than 250 grams of uranium 235, With respect to bodily intury sustained by any employee of an insured (4) any structure, basin, excavation, premises or place prepared or used for the storage or disposal of waste, and caused by the nudear energy h2zard, to pay to the workmen's com-and includes the site on which any of the foregoing is located, all pensation carrier of such insured all sums which such carrier would have been entitled to recover and retain as damages frorn another operations conducted on such site and all premises used for such person or organiution, had such person or organization alone been operations; Icgally responsible for such bodily injury, by reason of the rights "indemirifel endsar facillif' means acqsted by subrogation by the payment of the bene 6ts required of such (t) "the facility" as de6ned in any Nuc! ar Energy Liability Policy carrier under the apphcaole workrnen s compenspt:on or occupational (Facility Form) issued by the compan ies or by Mutual Atomie disease law. An eruployer who is a duly quahrted self-insurer under Energy Liability Underwriters, or such, law shall be deemed to be a workmen's compensation carrier (2) any cther nuc! car facility, withm the me2ning of this coserage. This Coverage C does not appt to if 6nancial protection is required pursuant to :he Atomic Energy Act of bodily injury sustained by any person who is employed at an in 1954, or any law amendatory thereof, with respect to any actmtaes or ronnection with the facihty.

operations conducted thereat; This Cuverage C shall not constitute workmen's compensation insurance ,,ndur remr me2ns any apparatus & signed or used to sustain as rtv;uired under the laws of any state, nuclear fission in a self supporting chain r< action or to contain a critical rnass of Essionable material; DE "sur/c.tr energy /uurt' means the radioactive, toxic, explosive or other II (a)FINITIM OF lHSURED The unqualified word " insured" includes hazardous properties of nuclear nuterial, but only if the namcd insured and (b) any other person or organiution with respect to his legal responubihty for danuges because of bodily injury (t) the nuclear material is at the facility or has been discharged or or property damage caused by the nudear energy hazard. dispersed therefrom without intent to relinquish possession or subdivision (b) above does not include as an insured the United custody thereof to any person or organization, or Swts of America or any of its agencies. (2) the nudear material is in an insured shioment which is (a) in the Subject to Condition 3 and the other provisions of this policy, the course of transportation, including handling and temporary storace insurave applies separately to'esch insured against whom claim is incidental thereto, within the territorial limits of the l'nited States nude or suit is brought. of America,its territories or possessions, Puerto Rico or the Canal Zone and (b) away from any other nuclear facility; %#"'.'l #N"'""~ "'*"8

• 8rnaterial, spent fuel or waste, herein called nuterial,,I'b

'I"Y" I*'"'*I'""'"'***' Wherever used in this policy: III ' DEFINITIONS' held; inrury" means bodily m.., iury, sakness or disease, includm.g ity from a nuc! car facility owned by the United States of America, but (1) to the racil-ueath resulting theretrom, susuined by any person; only if the transportation of the material is not by preJeterrmanan to aproperty Janug, mesns physical injury to or destruction or radio-be mterrupted by the terroval of the material from a tramportin;: con-active contamination of proper:y, and loss of use of property so injured, veyance for >ny purpose other than the continuation of its transNr 2 destrosed or contaminated. and loss of use vi preperty while evacuated tion, or (2) from the facility to any other location except an indemni-or withJeawn from use bnause possibly 50 contammated or because of 6ed nu; lear facility, but only untd the nuterial is ren oved from a knminent Janger of such contanunstion; transporting conveyance for any purpose other than the continuation of "enclar micri2' means source materia!, special nuclear material or its transportauon. Nuclear Energy Liability Policy (Facility Forrn) 2/1/37 (Saend Revision) NEF-toco : F m

AP' PLICATION OF POUCY This policy arplice ontatz bodily inirty written claim is rnsJe spinst the instred, not later tham tw years aftrr Ty or property damage (1) shich D caissd dxring tl< slicy l criod by the end of the policy period. - A. the.nus! car energy hazard ar.d (2) which is diaovtand f: which EXCLUSIONS This policy does not apply: tions, in time of peace or war, of any nuc! car weapon or other (a) to any obligation for which the insured or any carrier as his in, instrurnent of war utdiams spuial nuclest material or byproduct rnaterial; surer may be held Isable under any workmen's compensation, un. employment compensation or disabdity benefits law, or under anY (e) to bodily injury or property damage due to war, whether or not samalar law; declared, civil war, insurrection, rebellion or revolution, or to any (b) except with respect to liability of another assumed by the insured act or condition incident to any of the foregoing; under contract, to bodde iniury to any employee of the insured (f) to property damage to any property st the location designated in arising out of and m, the course of his emriloyment,by the in-Item 3 of the declarations, other than aircraft, wattrcraft or ve. sured; but this exclusion does not apply to b,od !y insury to any hicles licensed for highway use,' provided such aircraft, watercraft person who is not emptnyed at and in connect:on with the facility or vehicles are not used in connection with the operation of the si the insured has complied with the requirements of the applicable g,,jg 'I.' vorkmen's compensation or occupational disease law respecting the securing of compensation benetits thereunder to his employees; (g) to propert-damage to nuclear rnaterial in the course of transporta tion to os Irom the facility including handling or storage incidental (c) to liability assumed by the insured under contract, other than an assumption in a contract with another of the liabdity of any person thereto; or organization which would be imposed by law on such person or (h) under Coverage D. tn property damage due to negfect of the in-organnation in the absence of an express assumption of liability; suced to use all reasonable means to save and preserve the prop. (d) to bodily injury or property damage due to the manufacturing, erty after knowledge of the occurrence resulting in such property handling or use at the location designated in item 3 of the declara. damage. CONDITIONS 1 PREMlUM De named insured shall pay the companies the advanceerty damage caused during the policy period by the nuc!est energy premium stated in the declarations, for the period from the eticctive harard, the limit of the companies' liability stated in the declarations as date of this policy through Dxember !! following. Thereafter, at ne the total liability of the corepanies for their obligations under this beginning of each calendar year while this policy is in force, the named policy and the expenses incurred by the companies an connection with insured shall pay the advance premium for sucli ye.tr to the companies. such obligations, including The adunce premium fur each calendar year shall be stated in a (a) payments in settlernent of claims and in satisfaction of judgments written notice given by the companies to the named insured as soon as against the insureds for damages because of bodily injury or prep. Coverage A andments made unJrr parts (2), (3) and (!) practicable prms tc or after the besmning of ?uch year. erty damage, pa - payments made in settlement of claims under Sach adv'nce premiu*5 ne estimated p,remiums only. As soon as practicable after each December 31 and atter the termination cf this Coverages B and C; policy, the earned preraium for the preceding premium period shall be (b) paym'nts for expenses incurred in the investigation, negotiation, e computed in accordance with the cornpanies' rules, rates, rating plans, settlement and defense of any claim or suit, including, but not prermums and minimum premiums applicable to this insurance. If the limited to, the cost of such services by salaried employrcs of the for any pienuum period exceeds the companies, fees and expenses of independent adjusters, attorneys' . carned premium thus computed,d for such period, the rumed insured advance premium previously g fees and disbursements, expenses for expert testimony, inspection shall pay the excess to the compames; il less, the companies shall re-and appraisal of property, examination, X ray or autopsy or snedi-turn to the named insured the unesmed portion paid by such msured-cat expenses of any kind; ne named insured shall maintain records of the inforrnation neces. (c) payments for expenses incurred by the comranies in investigating sary for premium compttation and shall send copics of such records to an occurrence resulting in bodily mjury or property Januge or in the companies as directed, at the end of each calendar year, at the end minimizing its erkets. of the policy period and at such other times during the policy period Each payment made by the companies in discharge of their obligations as the compan:es rnay dirnt. under this policy or for expenses incurred in connection with such obligations shall reduce by the amount of such payment the limit of the INSPECTION SU5 PENSION The comp *nics shall be permitted to companies' lubility under this policy. 2 inspcet the facility and to examine the insured's books and records at If, during the policy period or subsequent ther'eto, the toul cf such any time, as far as th,y relate to the subject matter of this ms,arance. payments made by the companies shall exhaust the limit of the com. If a representative of the companics discovers a condition which he panies' liability under this policy, all liability and obliptions of the ticlieves to be unduly dangerous with respect to the nu! car enercy companies under this policy shall thereupon terminate and shall be hazard, a representatise of the companies may request that such condi. conclusively presumed to have been discharged. This policy, if not tion be cerrected without delay. In the event of non-compliance with theretofore canceled, shall thereupon automatically terminate. such request, s. representative of the cempanies may, by notice to the Regardless of the number of years this policy shall continue in force named insured, to any other person or organn4 tion considered by the and the nurnber of premiums which shall be rayable or paid, the limit companies to be responsible for the conunuance et such dangerous of the ompanies' liability suted in the declarations shall not be condation, and to the United States Atornic Energy Commission, sus-cumulative from year to year. pend the insurance with respect to the named insured and such other person er organization eilective 12:00 midnight of the next business day of such Commission fnllowing the date' that such Crmmission LIMITATION OF LlACILITY: COMMON OCCURRENCE Any occur. A receives such notice. The period at such suspension shall terminate as rence or series of occurrences resultmg in boddy injury or property v of the time stated in a written notice from the con,* antes to the named danuge arising out of the radioactive, toxic, explosive or other iuastd-insured and to each such person or organization that such condition has ous properties of been corrected. (a) nuclear rnaterial discharged or dispersed from the facility over a period of days, weeks, months or longer end also arising out of LIMlf OF LIAtlLITY: TERMINATION CE POLICY UPON EX. s ach properties of other nuc!cor rnaterut, so dischargni or dis. 3 HAUSTION OF LIMIT Reprdless of the number of persons and persed from one or more other nuclear tacdities insurcd by the orpnizations who are msureds under this policy, and regardless of the (ompanics under a Nuc! car Energy Liabdity Policy (Dcility nun her of claims made and suits brought apmst any or all insureds Form), or because of one or more oscurrences cciutting in boddy injury or prop-(b) source material, srceis! nuclear material, spent fuel or waste in the a ene so we t e

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NUCLEAR ENERDY LIACILITY POLICY (FACILITY FCPJ,1) n AMENDMENT OF TRANSPORTATION COVERAGE (Indemnified Nuclear Facility) s It is agreed that the de6aition of " insured shipment" in Insuring Agreement III is amended to read: "losered shipmees" mesns a shipment' of source material, special nuclear material, spent fuel or waste, herein es!!cd " material," (1) to the facility from any location except an indemni6cd nuclear faci _lity, but only if the transportation of the snarerial is not by predetermination to be internapted , by removal of the material from a transporting conveyarice for any purpose other than the continuation of its transportation, or (2) from the facility to any other location, but only until the material is removed from a transporting conveyance for any purpose other than the continuation of in transportation."- D Effective Date of NF-236 this Endorsemea, November 1,1975 To form a part of Psy N'o Issued to The Toledo Edison Company p,,, og ;,,,, October 27, 1975 For she Subscribing Cornpanies /% O-3 .l 3 A(t e i 7 %.--. ~ By_ 1 { h General Manager ? ' m:: :.t No Countersis by e.6w-eme as me O e-pe

4 Nucl3 Ensrgy Lirbility insuranca NUCLEAR ENERGY LIABILITY INSURANCE ASSOCIATION O ABIENDATORY ENDORSE 31ENT (Facility Form) It is agreed that: L The first sentence of the defmition of nuclear facility is amended to read: " nuclear facility" means "the facility" as defined in any Nuclear Energy Liability Policy (Facility Form) issued by Nuclear Energy Liability Insurance Association or by 21utual Atomic Energy Liability Underwriters. IL The definition of " indemnified nuclear facility" is repirced by the following: " indemnified nuc! car facility" means (1) "the facility" as defined in any Nuc! car Energy Lia:. 'ity Policy (Facility Form) issued by Nuclear Energy Liability Insurance Association or by SIutual Atomic Energy Liability Underwriters, or (2) any other nuclear facility, O if financiai protection is reautred pursuant to the Atomic Enerer Act of 1954, or any law amendatory thereof, with respect to any activities or operations conducted thereat; IIL Condition 4 is replaced by the following: LDIITATION OF LIABILITY; CO3DION OCCURRENCE Any occur-rence or series of occurrences resulting in bodily injury or property damage arising out of the radioactive, toxic, explosive or other hasardous properties of (a) nuclear material discharged or dispersed from the facility over a period of days, weeks, months or longer and also arising out cf such properties of other nuclear material so discharged or dis-persed from one or more other nuclear facilities insured under any Nuclear Energy Liability Policy (Facility Form) issued by . Nuclear Energy Liability Insurance Association, or (b) source material, special nuclear material, spent fuel or waste in the course of transportation for which insurance is afforded under this policy and also arising out of such properties of other source material, special nuc! car material,' spent fuel or waste in the course of transportation for wMeh insurance is afTorded under one or' more other Nuclear Energy Liability Policies (Facility ~ Form) issued by Nucicar Energy Liability Insurance Association, shall be deemed to be a common occurrence resulting in bodily injury .O. or prevertr a# m =ce causca ur the # ucte=r e=crcr n azera. With respect to such bodily injury and property da. mage (1) the total aggsegat'c liability of the members of Nucl ir Energy Liability lusurance Association under all' Nuc! car Enerr - Liability Policies , (Facility Form), including this policy, applical b to such conimon .... me i

_ occurrersaunmCmdeanun9-

wuaae,

' the limit cf liabilityef each such policy being as determined)y Condi-ti:n 3 thircof, but no event shall auch total'aggregatc .bility of such members exceed 04G,50',000; (2) the total liability ot the com-0 panics under this policy shall not exceed that proportion of the total aggregate liability. of the members of Nuclear Energy 1.iability Insurance Association, as stated in clause (1) above, which (a) the limit of liability of this policy, as determined by Condition.'i, bears to (b) the sum of the limit.s of liability of all such policies issued by such members, the limit of liability of each such policy being as determined by Condition 3 thereof. The provisions of this condition shall not operate to increase the limit of the companics' liability under this policy. IV. The second paragraph of Condition 12 "Other Insurance" is amended to read: "If the insured has other valid and collectible !nsurance (other than such concurrent insurance or any other nuc! ear energy liability insurance issued by Nuclear Energy Liability Insurance. Associa-tion or Mutual Atomic Energy Liability Underwriters to any person or organization) applicable to loss or expense covered by this policy, the insurance atTorded by this policy shall be execsa insur-ance over such other insurance; provided, with respect to any . person who is not employed at and in cotmeetion with the facility, such insurance as is arTarded by this policy for bodily injury to an employee of the insured arising out of and in the course of his employment shall be primary insurance under such other insurance." 'O ~ 1 -236 November 1, 1975 ro form a part of PoIIcy No this do e, IL0t A.M. SoaJarJ Tinie The Toledo Edison Company ,j October 27, 1975 For the subscribing cornpanies 1 By i OMW- / General Manager Countersignet by_ _._ Emlorsemear No fxiliry Form 1161 8s8 64 Phat S ' * ~

Nuct:sr En:rgy Liabi!Dy Inctt nace NUCLEAR ENERG LIA31 LIT't IN5URANCE ASSf ^ !ATION ^ INDUSTRY CREDIT RATING PLAN g PREMIUM ENDDRSEMENT It is agreed that Condition 1 of the policy is replaced by the fo!!owing: CONDITION 1. PREhflUhi (1) Definitions: With reference to the premium for this policy: " advance premium", for any calendar ycar, is the estimated standard premium for that calendar year; " standard premium", for any calendar year, is the premiam for that calendar year computed in accordance with the companies' rules, rates, mting plans (other than the Industry Credit Rating Plan), premiums and minimum premiums applicab!c to this insurance; " reserve premium" means that portion of the standard premium paid to the companics and specifically allocated under the Industry Credit Rating Plan for incurred losscs. The amount of the "rcscrve premium" for this policy for any calendar year during which this policy is in force is the amount designated as such in the Standard Premium Endorst.nent for that calendar year; " industry reserve premium", for any calendar year, is the sum of the reserve premiums for that calendar year for all Nuclear Energy Liability Policies issued by Nuc! car Energy Liability Insurance Association and 51utual Atomic Energy Liability Underwriters and subject to the Industry Credit Rating Plan; " policy refund ratio", for any calendar year, is the ratio of the named insured's reserve pre-mium for that calcadar year to the industry reserve premium for that calendar year; " incurred losses" means the sum of: (1) a!!!csses and exp:nses paid b Nuc!:ar En:rgy Liability Insurance Association and Liu-y tual Atorai Energy Lic,bility Underwriters, and (2) all reserves for unpaid losses and expe:nes as estimated by Nuclear Energy Liability In-surance Association and 51utual Atomic Energy Liability Underwriters because of obligations assumed and the expenres incurred in connection with such obli"ations by members of Nucl:ar Energy Liability Insurance Association and hiutual Atomic Energy Liability Underwriters under all Nuclear Energy Liability Policies issued by Nuclear Energy Liability Insurance Association and hfutual A:omic Energy Liability Underwriters and sub- . ject to the Industry Credit Rating Plan; " reserve for refunds", at the end of any calendar year, is the amount by which (1) the sum of allindustry reserve premiums for the period from January 1,1957 through the cud of such calendar year execeds (2) the total for the same period of (a) allincurred losses, valued as of the ner.t following July 1, and (b) all reserve premium refunds made under the Industry Credit Rating Plan by members of Nuc! car Energy Liability Insurance Association and hiutual Atomic Energy Liability Underwriters; " industry reserve premium refund", for any calendar year, is determined by multiplying the reserve for refunds at the end of the ninth calendar year thereafter by the ratio of the indus-try rese,vc premium for the ca'endar year for which the premium refund is being determined to the sum of such amount and the total indmtry reserve premiums for the next nine calendar years thereafter, provided that the industry reacrve premium reftmd for any calendar year shall in no cvent be greater than the industry reserve premium for such calendar year. (2) Payment of Advance andStandctd 6;.siums The nam:d insured shall pay the companies the advance pmmium stated in the declarations, for 15e period from the efTective date of this policy through December 31 following. Thereafter, at the beginning of each calendar year while this policy is in force, the named insured shall pay the advance premium for such year to the companies. The advance premiu.n for each calendar year shall be stated in the Advance Pre- .mium Endorsement for such calcadar year issued to the named insured as soon as practicable -- O - erier io or =rict ia= *=st=#1=a er==ca

==r. r IeS-I? PA44 I r e

Nuebsr En:rgy thbility in:uranca NUCLEAR ENER I LIADILITY INSU!!ANCE AS:,sCIATION rw As soon as practicable after each December 31 and after the termination of this policy, the standard premium for the preceding calendar year shall be ftnally determined and stated in the Standard Premium Endorsement for that calcadar year, if the standard premium so determined exceeds the advance premium previously paid for such calendar year, the named insured sha!! pay the excess to the companies; if less, the companies shall return to the named insured the excess portion paid by such insured. De named insured shall maintain records of the information necessary for premium computa-tiort and shall send copies of such records to the companies as directed, at the end of each cal-endar year, at the end of the policy period and at such other times during the policy period as the company may direct. (3) Use of Reserve Premiums All reserve premiums paid or payabic for this policy may be used by the members of Nuc! car Energy Liability insurance Association to discharge their obligations with respect to incurred losses whdcr such losses' are incurred under this policy or under any other policy issued by Nuclear Energy Liability Insurance Association or Mutual Atomic Energy Liability Underwriters. (4) Reserve Premium Refunds A pattion of the reserve premium for this policy for the first cal-endar year of any group of ten consecutive calendar years shall be reurnable to the named in-sured provided there is a reserve for refunds at the end of the tenth calendar year. (5). Computation of Reserve

• Premium Refunds ne reserve premium refund due the name insured for any calendar year shall be determined by multiplying any industry reserve premium refund for such calendar year by the policy refund ratio for such calendar year. The reserve pre-mium refund for any calendar year shall be finally deterrnined as soon as practicabic after July I of the tenth calendar year thereafter.

(6) Final Premium De final premium for this policy shall be the sum of the standard premiums for each calendar year, or portion thereof, duri::g which this policy remains in force less the sum of all refunds of reserve premiums due tha. named insured under the provisions of M this Condition 1. V ("l) Reserve Premium Refund A.ercement Each member of Nuclear Energy Liability Insurance Association subscribing this policy for any calendar year, or portion thereof thereby agrees for itself, severally and not jointly, and m the respective proportion.of its liability assumed under this policy for that calendar year, to return to the named insured that portion of any reserve premium refund due the named insured for that calendar year, determined in accord-acce with the provisions of this Condition 1. Effective Date of this Endorsement November 1, 1975 NF-236 To form a part of Poh.ey No. 12:C1 A.M. Standard Time Issued to The Toledo Edison Company Date of Issue October 27, 1975 gg,r the subscribing companies b By i a f General Manager ndorsement No. Counecrn n ed by ..., em a

• • • "-W8"*

Nucig r En rgy Linbility Insurancs NUCLEAR ENE.k.,( LIASILITY INSURANCE ASSOCIA..ON O AMENDATORY C:DORSE:4E;T (Application of Policy)_ It is agreed that Insuring Agreement IV of the policy captioned, '" Application of Policy. is amended to read as follows: APPLICATION OF POLICY This policy applies only to bcdily injury or property damage (1) which is caused during the policy period by the nuclear energy hazard and (2) which is discovered'and for which written claim is made against the insured, not later than ten years after the end of the policy period. ft v Effect:ve Date of NF-236 November 1, 1975 ro form a part of Poug No th.'s En donemer., 12:01 A.M. stacM Time The Toledo Edison Company Issued r For 6e SdurMng Cogads October 27, 1975 Date of hiue r' yy _ f ) Oh ['/ General N2 nase: 4 - Endorsemmt No Countersoned br ~ NE-32 (12/30/68)

Nucle-r En:rgy 1.fobility insurenco NUCLEAR ENERL i LIABILITY INSURANCE ASSOCI, .O N Waiver of Defenses Endorsement (Extrcordincry Nuclear Occurrence) (FACillTY FORM) The named insured, acting for himself and every other insured under the policy, and the members of Nuclear Energy Liability insurance Association egree es follows:

1. With respect to any extraordinary nuclear occ'urrence to which the plicy applies as proof of financial protection and which (a) Arises out of or results from or occurs in the course of the construction, pssession, or operation of the facility, or (b) Arises out of or results from or occurs in the course of the transportation of nuclear material to or from the fccility, the insureds and the companies cg ree to waive (1) any issue or defense as to the conduct of the cIciment or the fault of the insureds, including,.but not limited to:

(i) negligence, . (ii) contributory negligence, ()~ (iii) assumption of risk, and (iv) unforeseechle intervening causes, whether involving the conduct of a third person, or an act of God, (2) any issue or defense as to charitable or governmental immunity, and (3) anf ssue or defense based on any statute of limitations if suit is instituted within i inree years ? rom the date on which the claimant first knew, or reasonably could have known, of his bodily injury or property demoge and the cause thereof, but in no event.aore than ten years after the d te of the nuclear incident. The waiver of any such issue or defense shall be effective regardless of whether such issue or defense may otherwise be deemed jurisdictional or relating to an etcment in the cause of cction. 2. The waivers set forth in paragrcph 1. above do not apply to (a) Bodily injury or property demcge which is intentionally sustained by the claimant or which results from a nuclecr incident intentionally and wrongfully caused by the claimant; Bodily njury sustained byany claiment who is employed at the site of and in (b) i connection with the activity where the extraordinary nuclear occurrence takes place if berefits therefor are either payable or required to be provided under any workmen's com-pensorion or occupationc! disecsc law; (over) dF

, f f r wrongful d:cth undar any Stets Icw which prcvidas fer c'emagas only punitiva in nature, . this gxclusion d:cs not apply 1 ho cxtsnt that thn claimant has su Ined actual demogss, mcasured by the pecunicry injuries rssulting frem such decth but not to excced tha maximum omo'unt otherwise recoverable under such law.

3. Tho waivers set forth in peregraph 1. cbove shall be effective only with respect to bodily

. Injury or property domoge to which the policy applies under its terms other than this endorsement. Such waivers shall not apply to, or prejudice the prosecution or defense of any claim or portion of claim which is not within the protection offorded under (1) Tne Fovisions of the policy applicable to the financial protection required of the named insured, (2) The cgreement of indemnificction between the named insured and the Atomic Energy Commission made pursuant to section 170 of the Atomic Energy Act of 1954, as amended, and (3) The limit of liability p: visions of subsection 170 e. of the Atomic Energy Act of 1954, as amended. Such waivers shall not preclude a defense based upon the failure of the claimant to take reasonable steps to mitigate demages. 4. Subject to all of the limitations stated in this endorsement and in the Atomic Energy Act of 1954, os emended, the waivers set forth in paragraph 1. above shall be judicially enforceable (("i in accordance with their terms against any insured in on action to recove' demoges because of r bodily injury or proparty demcse to which the policy applies as proof of fincncial protection.

5. As used herein:

"Exticordinary nuclecr occurrence" means on event which the Atomic Energy Commission has de-termined to be on extraordinary nuclear occurrence os defined in the Atomic Energy Act of 1954, cs amended. " Financial protection" and " nuclear incident"'have the meanings given them in the Atomic Energy Act of 1954, as cmended. "Claiment" means'the person or organization actually sustaining the bodily injury or property demage and also includes his cssignees, legal representatives and other persons or vrganizations entified to bring on cetion for damages on cccount of such injury or demoge. Efective Date of -NF-236 this Endonem, Nove=ber 1, 1975 7, go,,, p,, og p,g;,7 g, 12:01 A.M. Standard Thr.e Issued - The Tolddo Edison Company For the Suburibing Companies Date of Innue October 27. 1975 ~ O ~ -o By ( C General Manager Zadorwment No 5 countenian d by .NE-33 (11/30/66)_

Nccher Er.ergy LI bil!!y ! :umnce P(UCLEAR C4:%. LIA' ail!YY INSUP.ANCE ASSOCIA..JN s 8 Address of Nucient Encrev Liabilf tv Insurance Association Endorsement It is agreed that the address of the Nuclear Energy Liability Insurance Association appearing in the " Company Representation" condition of the policy is amended to read: The Exchange Farmington Avenue Farmington, Connecticut 06032 /' %./ 3 U-236 November 1, 1975 7, g,,,,,,, og p,gy, y, 12:01' AM. S:me!.ud T.cs The Toledo Edison Cocpany October 27, 1975 For & S M % ~ W - db l. / C B_ CWh $ b Y / Ger.erci Manager 0 Ph IL Co minusned by NE 373 (4/1/74) F

Nucicar En rcy L!:bility Imurance NUCLEIJ! IN5PM LIA"!LITY INSU::ANCE ASSOCIAWN SUPPLEMENTARY ENDORSEMENT WAIVER OF DEFENSES RFACTOR CONSTRUCTION AT TIIE FACILITY It is agreed that in construing the application of paragraph 2(b) of the Waiver of Defenses Endorsement (NE-33) with respect to an extra-ordinary nuclear occurrence occurring at the facili~y, a claimant who is employed at the facility in connection with the construction of a nucicar reactor with respect to which no operating license has been issued by the Atomic Energy Commission shall not be considered as employed in connection with the activity where the extraordinary nuclear occurrence takes place if: (1) the claimant is employed exclusively in connection with the construction of a nuclear reactor, including all_ related equipment and installations at the facility, and (2). no operating license has been issued by the Atomic Energy Commission with respect to the nuclear reactor, and (3) the claimant is not employed in connection with the possession, storage, use or transfer of nuclear material at the facility. () NF-236 Effcctive Date of Nove=ber 1, 1975 To forin a pre of Potky No this Endonemco, 12:01 A.M. St:acad Time The Toledo Edison Company ggr ror the subur&g co:: pates October 27, 1975 % of w b L > O b- ~ By I V Cencral Manager 7 Endorsement No Guntersigned h h2ff4/71) _._ m... _ _.

[ourse cf trar:sportation far which insurano is a% Qed under this property. 'Ile instred shall larlude in the pronf #f loss a crpy c' 311 policy as,d aho arising tut gf sush pmpertics ' ther source descriptions and schedules in ti! "icies. Upon the cen: panics rte;:e::, restern!, srecial nuclear in2 trial, spent fuel < r wa a thJ courst the insured shall furnish ser% !ans and snr&ations of ent n5 prnpetty. The insured, as nften as nuy be ressor.aMy reuired, s!.d! tv. of transportanon for which insurance is siforded undJr one er habit ta any person doignated by tha cornpanies any ol such pmp my, rnore other Nudear Energy J.iabihty Policies (l'acility form) is-and submit to cuminstwns under cath by any person named !w ee sueJ by the companies, shall be deerned to be a iommon occurrence tes,iting in bodily injury or companies and sulwcribe the sanu; an f, as often as rr.ay be reasS.My required, shdl produce for examination all books of account, rc:nJs, property damage uused by the nuctor energy hazard. bius, invoices and other souchers, or certified coisics thereof if o ign_Is With respect to such bodily it.iury and property dama:te ( t) the total be lost. at such reasonable time and place as may be designat d tw tne aggregate liability of the companies under all Nuclear Energy Liability companies or their representatises, and shall permit extracts and copes mon occurrence shall be the sum of the limits o[licable to such com-Policies (Facility Form), including this policy, arm thereof to be made, liabdity of all such policies, the imut of liabdity of uch such policy being as deterrrined AFFRAISAL - Coverage 8 In care the insured and the companies Q by Condition 5 thereof, but in no event shall such total aggregate lia, shall fail to agree as to the amount of property dam.*ge, then, en the bdity of the compan:cs eacced $MJ00,000; (2) the total hatadity of the companies under tms pohey shall not exceed that proportion of the written demand of either, each sh.Il select a corentsnt and disintercsted total eggregate habili:y of the companies, as stated in clause (1) above, appraiser and notify the other of the appraiser se!ccted within t.vry which (a) the limit of liability ct this policy, as determined by Conds-d2ys of such demand. The appraisers shall first se!cct a competent and tion 5, bears to (b) the sum ot the hmits of liabit;ty of all such pohcies disinterested umpire and, fading for fifteen days to agree upcn such umpire, then on request ot' the insured or the companies, such umrire issued by the companies, the limit of li2bdity of each such policy being as determined by Condition 5, thereof. shall be sek<ted by a judge of a sount of record in the state in which The provisions of this condition shall not operate to increase the limit the property is located. The appraisers shall then appraise cach iten of property d2 mace and, failing to agree, shall sahmit their di6eences of the companies

• lbbihty under this policy.

only to the urnpire. An award in writing, so iremized, of acy t=co when filed with the companies sha:1 determine the amount of prorer*y 5 H3TICE OF OCCURRENCE, CLAIM OR SUIT In the event of damage. Each appraiser shall be paid by she party se:etting him anc the bodily injury or preferty dwage to which this policy applies or,of expenses of the appraisal and umpire shall be paid by the parties am occurrence shtch may gise rise to claims tnerefor, written nonce equally. The companies shall not,be held to have waived any ot their containing particulars sudicient to identify the insured and also reason-rights by any act reisting to appraisal. ably obtainable information with respect to the time, piace and circum-staraces thereof, and the names and addresses of the iniured and of SUDROGATION In the event of any payment under this policy, the 1{ arailable witnesses, shall be given by or for the msured to Nuclear companies sha!! be subrogated to sit the insurefs rights of r cose:y 1 Energy Liability insurance Association or the comp 2nies as soon as therefor against any person or org2nization, and the insured sh211 ex-practicable. If claim is made or suit is brought against the insured, he ecute and deliver instruments and papers and do whatecer else is shall immedia:ely forward to Nuc! car Energy Li2bdity Insurance Asso-necessary to secure such rights. prior to knowledge of boddy lniury er ciation or the companies every demand, notice, summons or other pro-property damage caused by the nuclear energy h2urd the insured.2y cess received by him or his representative. waive in writing any right of recovery apinst any person or organiw ti n, but after such know!cdge the insured shall not waive or otherecise The in. f ASSISTANCE AND COOPERATION OF THE INSUREDsured shall cooperate with the companies and, upon the The companies hereby yatre any rights of subrogation acquired prejudice any such right of recovery. request, attend heatings and trials and asust m nuling settlements. ag2 inst the Un;ted States of America or any of its ager.cies by ressan of securing and giving evidence, obtaining the attendance of witnesses and any payment under this policy. in the ccadect of any leg 21 proceedings in connection with the subject . The companies do not relinquish, by the foregoing provisions, :ny restter of this insurance. The insured shall not, except at his own cost. risht to restitut:en from the insured o :t of any rportries nade by se anale any payment, assume any obligation or mcur any expense. insured on account of a loss covered by this policy or any amounts to which the companies would be entitled had such provisions, or any of 7 ACTION AGAINST COMPANIES - Coverages A and C No them, not heen included in this policy. action shall lie spinst the compames or any of thern unless, as a con-dition preedent thereto, the insured shall have fully complied with all OTHER INSURANCE If the insurance aHorded by this policy for ! css 1Q the tere..s of this policy, not until the amount of the insured's obligation or expense is concurrent with insurance adorded for such loss or ex-la to pay shall have been finally determined either by judgment aesinst the pense by a Nuclear Energy Liability Policy (Facility Fcrm) issued ta insured after actual trial or by written agreement of the iniured, the the named insured by Alutual Atomic Energy Liablity Underwri:ers, claimant and the corepanies. hereinafter called " concurrent insurance," the companies shall net be Any person or organiution or the leg 21 representative thereof who liable under this pohey for a greater proportion of such loss or c:: pense has secured such judgment or written agreement shall thereafter be than the iam of Qih,ty stated in,the declarations of th,is pc'.cy bears entitled to recover under this policy to the extent of the insurance to the surn of such hmst and the hmat of liabihty stated . e dec.ar2-aforded by this policy. No person or orgniaation shall have any right U ns of such concunent poucy. under this po! icy to join the companies cr any cf them as parties to any If the ii.sured has other valid and collectible insurara tother than action against the insured to determine the insured's liability, nor shall such concurrent insurance or any other nuclear energyliability in?urance the companies or any of them be impleaded by the insured or his le. cal issued by the companies or >!utual Atomic Energy Liabinty Undetwrit.. representative. Bankruptcy or insolveng of the insured or of the in. ers to any person or organia2 tion) appocable to loss ut expense covered s: red's estate shall not relieve the companies of any of their obligations by this pobey, the msurance 26orded by this polier shall be exccts in-hereunder. surance over such other insurancet provided, with resrct to any pe:sen such insur-who is not employed at and in connection with the facility'empicyte cf ance as is aHorded by this policy for bodily iniury to an ACTION AGAINST COMPANIES-Coverage B No suit or action 8 on this policy for the recovery ci any claim for property damage to the insured arising out of and in the course of his empforment sha!I be which Coverage B apphes shall be sustainable in any court of law or primary insurance under such other insurance. equity unless all the requirements of this pohcy snail have been com-plied with and unless commenced within two years after the occurrence CHANGES Notice to any agent or knowledge possessed by any a. cent 1* d resulting in such property damage. br by any other person shall not efect a waiver or a change in any part on' this policy or estop the companies from assertin,; any richt un&r 'he INSURED'S DUTIES WHEN. LOS$ CCCURS - Coverage, B terms of this rohey; not shair the terms of this poiicy be waimi or h in the esent of property darnage to which Coverage 3 2pphes, the m* changed. except by endorsenwnt usued to form a p2rt of this pMicy sured shall furnph a complete inventory of the property damage executed by Nuclear Energy Liabihty Insurance Association on behalf claimed, showing m derad the anmunt thereof. Within ninsty-cne d2)s of the companies. efter the occurrence resulting in such property damage, unless such time is extended in writing by the companies, the insured shall render ASSIGNMENT Assignment of interest by the narned insured shat; not bf d 4 to the companics a proof of lois, signed and sworn to by tne insuied. bind the companies unut their consent is endorsed hereon; if, howem, stating the knowledge and belief of the ensured as to the following: the named insured shall die or be Jetlared bankrupt or insolvent, this identaticat:an ef saca occurrencet the intere:t of the insured in the policy shall coser such insured's legal representame. receiver or r:ustee property destro3cd er damaged, and tre amount of each : tem of proc-erty damage claimedt 2;l encumbrances on such property; and all other as an insured under this pu&y, but only with rcs;wt to his lind;:y as contracts of insonnce, whether valid or nor, coverms any of such such, and then only provided written notice of his appointment as !rgal 9 0 se 90 0 9' g e

' representative, receiver or trustee $3 given to the compaDes within ten (b) In any action ce suit assinst_the companies, service cf process m2r 4 . days after such appointment. be rnade on any cne of tt and such servics sh211 be deemed valid and bndmg service. all comr2nies-(c) Nuclear Encrev Liability Insurance Association is the agent of f g' CANCELATION Th.n poh.ey may be canceled by the named insured by the cornpanici'with respect to all rnatters pertaininst to this insur.

• AJ gui!ing ta the con pan:es and the (*natd Sta,tes Atomic Energy Com-ance. All noticcs or other communications required by this policy mission written not:ce s:atsnq shen, not Isss trun thirty days therufter.

to be given to the companies nur be given to such a: tent, at its ha Strect. New York 38, New York with the rarne such canatation shall be ettettae. This lecy nuy be oncued or the odice at 60 pct as if given directly to the compames. Any rem.:ests, companics by mathnat to the named insord at the address shown m this force and e e . pohcy and to the l'nated States Atornic Energy Commisstun u ntien notice demands or agreements made by such agent shall be deemed to stating when, not less than ninety days thereatter, such cancelation shall have been made directly by th.e companies. be eftective; provided m the event of non-p23 ment of prem:um or if the operator of the facihty, as designated in ene dularations, is replaced by another person or organization, this policy may be canceled by the AUTHORIZATION OF NAMED INSURED Except with respect to fm/ J. companies by m2 ding to the n2med insured at the address shown in compliance with the obligations imposed on the insured by Conditions this policy and to the.L*nited States Atomic Energy Commission written

5. 6, 7,8,9, to and 11 of this policy, the named insured is authori:ed notice stating when not less than thirty days thereafter, such cancela-to act for every other insured in all matters pertaining to this insurance.

tion shall be e:Tective. The m2 ding of netice as aforesaid shall be suficient proof of notice. The e6ective date and hour of cancelation CHANGES IN SUBSCR18tNG COMPAN!ES,AND IN THEIR jQ stated in the notice sh2;l become the end of the policy period. Delisery PROPORTIONATE LIACILITY By acceptance of this poh,ey the named O of such written notice either by the named insured or by the cornpanies insured agrees that the rnembers of Nuclear Energy L2b:aty Insurs::ce shall be equivalent to nuihng. Association liable under this pohq, and tae proportionate liability of Upon termination or cancelation of this policy, other than as of the each such member, may change from year to year, and further agrees end of December 31 in any year, the earned premium for the renod that regardless of such changest this policy has been in force since the preceding December 31 shall be (1) each company subscribm.g this policy upon.its issuance shall be computed in accordance with the following provisicos: Jiable only for its stated proportion of any oblig2 ten assumed or (t) if this policy is termauted, pursuant to Cono,stion 3, by reason of expense mcurred under this policy because ci boddy injury or the exhaustion of the limit of the companies' liabdity, all premium property damage caused, during the period from the efective date theretofore paid or ruysbla siull be ful!y earned; of this policy to the close of December 31 next following, by tne nuclear energy h.tzard; for each subsequent calendar, year.,cegi,n. (b) if the named insured cancels, the earned premium for such period nmg January i next followmg the enective dare of tms pohey, tne shall be computed in accordance with the sustomary annual short subxt bing companies and the proportionate liability ci cach such rate table and procedure, provided if the narned insured cancels company shall be stated m an endorsement issued to form a part after knowledge of bodily injury or proper'y damage caused by the of this pohcy, duly executed and attested by the General Enager ruclear energy hazard, all premiums theretofore paid or payable of Nuclear Energy I.iability Insurance Association on behalf of shall be fully e2rned; cach such company, and mailed or delivered to the named insured; if the companies cancel, the earned premium for such pen d shall o (c) be computed pro rata. date stated in the declarations until termiruted in accordance with (2) this poh.cy shall remain continuously m. e6cct from the e6ective Prernium adjustment, if any, may be made either at the tarne cancelation Condition 3 or Condition 13; is effected or as soen as practicable after cancelation becomes eiective. but payment or tender of unearned premium is not a condition of (3) neither the liability of any company nor the limit of liability stated in the declarations shall be cumulative from year to year. canceistion. DECLARATIONS By acceptance of this policy the named insured agrees .g n that the statements in tne declarations are the agreemcnts and repre. Ay 16 COMPANY'RWkESEMYAliON (s') Any notice, sworn statement or proof of loss which may be re-sentations cf the named insured, that this policy is issued in reliance upon the truth of such representations and that this policy embodies all quared by the provisions of this policy may be given to any one agreements between the named insured and the companics or any of of the companies, and such notice, statement or proof of loss so given sha!! be valid and binding as to all companies. their agents relating to this insurance. IN WmEss WHEREOF, each of the subscribing companies has caused thir policy to be crecuted and attested on its behalf by the General mnager (f Nuclear Energy Liabdity Insurance Association and duly countersigned on the declarations page by an authorized representative. For the Subscribing Companies e ed By N General Wruger 9 9 4 e 4 em y9.** 6 e meme D e**

Nutb" Et=cy US.~.;y Ec:un:nco NUCLCl2 CCGY IE"*?.lTI !ZC'J.NCE AS30CIATION 9 ADVANCE PRD11LH AND STANCARD PRD1IUM EhDORSEMENT Calendar Year 1975 It is agreed that Item 5 of the Declarations " Advance Premium: is amended to read: ADVANCE PRDiILH: It is agreed that the Advance Premium due the companies for the period desigr.oted above is: $ 100.00 STANDARD PREMIUM AND RESERVE PRDiILH: In the absence of a change in the Advance Premium indicated above, it is agreed that, subject to the provisions of the Industry Credit Rating Pla.", the Standard Premium is said Advance Premium and the Reserve Premium. is: $ 67.00 O November 1,1975 m, ro,:,, p.,e d Po!kr h4 12:01 M1 C.arcard Tmme w. The Toledo Edison Company Mdh October 27, 1975 Totdd30*ch%:Ccm:*aics C' ( / By C 1 N General Manager "" M 0 Countersigned by NE-41

Ned:sr Cr.:.y U=bi!!ty fr.su.cnce NUCLEAC C?EIGY U/T.iUTY INSU".N!CE ASSOCIAT!cN C AMENDMENT OF CONDITI0ft 4 Ei!DORSEMENT_ It is agreed that with respect to bodily injury or property damage caused after the effective date of this endorsement by the nuclear energy hazard the figure $46,500,000 sta ted in Condition 4 of the policy is amended to read $96,875,000. O v 1sses Dam d November 1, 1975 NF-236 n " ' '=' .ro fa a p of Pt&y No 22 01 A.M. M d L a* The Toledo Edison Company October 27, 1975 For 6e Shh Co= ses hdb By _ 6Rq ,1 lW / Genorci Monoger o hF Couab.itoeJby NE 43C (1/1/75)

"P#DiTLWR@'dR%if1MN = 3,bEDINSURED N Toleda Editon Comprny ' POLICY NO. NF-236 LIMIT OF LIABILITY $1 MILLION PREPARED BY Kathy %ephen DATE PREPARED 10/27/75 ENDORSEMENT N0. NEL-PIA INVOICE N0. PERIOD LIMIT STATUS PRDiIUM 11/1-12/31/75 SIM Standby $100.00 COMMISSION $100.00 0 10 = $10.00 RESERVE PRD!IUM Standard Premium: $100.00 Lisa Commission: 10.00 90.00 Luc 23% of S.P.: 23.00 Rossrve Premium: $ 67.00 GROSS COMMISSION NET 1975 Original Premium: $100.00 $10.00. $90.00 e 9 0 e S

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