ML20113G817

Application for Amend to License NPF-3,changing TS Definition 1.8, Containment Integrity, TS 3/4.6.1.1, Containment Integrity & Bases, TS 3/4.6.1.2, Containment Leakage & TS 3/4.6.1.3, Containment Air Locks

ML20113G817
Person / Time
Site:	Davis Besse
Issue date:	05/01/1992
From:	Myers T CENTERIOR ENERGY
To:
Shared Package
ML20113G815	List: ML20113G814 ML20113G817 ML20113G818
References
NUDOCS 9205120259
Download: ML20113G817 (10)

Text

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Docket Number 50-346-

-o License Number NPF-3 Serial Number 1971 Enc 40sure

'Page 1 APPLICATION FOR AMENDHENT TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR P9VER STATION UNIT NUMBER 1 Attached are requested changes to the Davis-Besse Nuclear Power Station, Unit Number 1 Facility Operating' License Number NPF-3. Also included is the Safety Assessment and Significant Hazards Consideration.

The proposed chant,es (submitted under cover letter Serial Number 1971) concern:

Appendix A, Technical Specification Definition 1.8, Containment Integrity Appendix A, Technical Specification-3/4.6.1.1, Containment Integrity Appendix A, Technical Specification 3/4.6.1.2, Containment Leakage Appendix A,; Technical Specification 3/4.C.1.3, Containment Air Lot.ks-1 Appendix'A, Technical Specification Bases 3/4.6.1.1, Containment Integrity For: D. C. Shelton Vice President, Nuclear By: Y T. J My4rs Dir tot - Technical Services Sworn and Subscribed before me this 1st day of May, 1992.

YtMf/A) if N6taryjt6birc', State of Ohio EVELYNLDRESS NOTARYPUSUC,STATEOFOHO hhGwinalEgimuy28.1994 9205120259 920501 PDR ADOCK 05000346 P ppg i

i Docket Number 50-346 License Number NPF-3 Serial Number 1971

. Enclosure Page 2 The fnllowing information is provided to support issuance of the requested changes to Davis-Besse Nuclear Power Station, Unit Number 1 Operating License Number NPF-3,- Appendix 4, Technical Specification (TS)~ Definition 1.8, Containment Integrity; TS 3/4.6.1.'1, Containment Integrity and its associated Bases: TS 3/4.6.1.2, Containment Leakage; and TS 3/4.6.1.3,_ Containment Air Locks.

A. Time Required to Implement: This change is to be implemented within 90 days after NRC issuance of the License Amendment.

B. Reason for Change (License Amendment Request Number 90-0048, Revision 1):

The revision to Definition 1.8c, changing ".. 0PERABLE pursuant to  ;

Specification 3.6.1.3," to "...in compliance with the requirenents of Specification 3.6.1.3," may prevent an unwarranted entry into the 1-hour Action statement of TS 3.6.1.1. As currently written, Definition 1.8c does not address the use of the allovable outage time of the TS 3.6.1.3 action. Deletion of the redundant Surveillance Requirements 4.6.1.lb and 4.6.1.2f eliminates a

-similar potential source of_ confusion.

Revision of the TS 3.6.1.3-Action Statement may prevent an unvarranted plant shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As currently written, the DBNPS TS vould require a plant shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if one containment air lock door becomes inoperable or if the air lock door interlock becomes inoperable. If a door in the same containment air lock is operable, closed and locked, then

-containment integrity is maintained and the plant should be allowed to continue to operate. In addition, TS Bases 3/4.6.1.1 is proposed to be revised to be consistent with the above revision.

Clarification of SR 4.6.1.3a, and addition of the footnote for SR 4.6.1.3a and SR 4.6.1.3b which states that the provisions of Specification 4.0.2 are not applicable, vill help prevent an

-inadvertent violation of the requirements of 10 CFR 50, Appendix J.

Inclusion of valves, blind flanges, or deactivated valves secured in their positions-located inside the Shield Building (including the annulus and_ containment) in~the asterisked note to SR 4.6.1.la.1 vill clarify that these compor.ents are exempt from position verification during plant operational Modes 1 - 4. Due to inaccessibility as a result of.high radiation inside the Shield Building, components should-be exempt from position verification in Modes 1 - 4. The proposed change vould clarify that the exemption includes valves, blind flanges, or deactivated automatic valves inside the Shield Building (including the annulus and containment).

C. Safety Assessment.and Significant Hazards Consideration: See Attachment

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Docket Number 50-346 i: . License Number:NPF-3

. ' Serial Number 1971

. Attachment Page 1:

SAFETY ASSESSMENT AND JNIFICANT HAZARDS CONSIDERATION

'FOR' LICENSE AMENDMENT kEQUEST NO. 90-0048, REVISION 1 TITLE:

Revision of Technical Specification (TS) Definition 1.8, TS 3/4.6.1.1 and its Associated Bases, TS 3/4.6.1.2, and TS 3/4.6.1.3, Addressing the' Verification of the Operability of the Containment Air Locks, Allovable Outage Times for the Cantainment Air Lock Doors and Interlocks, and Applicability of Containment Integrity Surveillance for Coaponents Located within the Shield Building.

DESCRIPTION:

The containment structure houses the nuclect steam supply system at the DBNPS. The containment consists of three basic structures: a steel containment vessel, a reinforced concrete shield building, and the internal structures'- The shield building encloses the steel containment vessel. An annular space (annulus) exists between the containment vessel and shield building. The containment structure and shield structure are provided with filtration, purge and spray systems which would contain and limit radioactive material released from the reactor coolant. system in the unlikely event of the design basis loss-of-coolant accident or another hypothetical accident postulated in DBNPS Updated Safety Analysis Report Chapter 15, Accident Analysis.

The containment design, along with the engineered safety features provid,3, ensure that the exposure to the public resulting from a hypothetical accident is below the guidelines established by 10CFR Part '

100.

Updated' Safety Analysis Report (USAR) Section 3.8.2.1, cescribes the two' air locks-which provide personnel access into containment: a personnel air lock and an emergency air lock. These are velded steel assemblies which are designed in accordance with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section VIII.

Each of these air locks have a door on the shield building vall side

-interlocked with-a door in the containment vessel vall side. Each door-is double gasketed and designed for testing by pressurizing the space between the gaskets._ The interlock mechanism is designed.to prevent the opening of one door before the other door in the air lock has sealed closed. Each door in an air lock is designed so that with-the other door in the same air lock open, the closed door can withstand and~

seal against the design pressures of the containment vessel.

The purpose for the proposed changes are to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical Specification (TS) Definition 1.8 (Containment Integrity), TS l- .3/4.6.1.1 (Containment Integrity) and its associated Bases, TS l

3/4.6.1.2 (Containment Leakage), and TS 3/4.6.1.3-(Containment tir l Locks).

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Dock. Number 50-340 4 Lic(nse %mber NPF-3  !

[' Set !al thimber 1971  ;

Attachment  !

,Page 2 '

l Terknical Specification Definition 1.8c cutrently states: "CONTAlHHEfJT  ;

INTEGRITi shall txist when ... each air lock is OPPhl.blE pursuant to i Specification 3.6.1.3." It is proposed that this definition be i ievoided to tead: "c0NTAINMENT INTEGRITY shall exist when ... each air  :

lock is in compliance with the requitements of Specification 3.6.1.3."  ;

The purpose of this proposed change is ta reflect that containment i 1.tegrity is satisfied ar long as the requirements of TS 3.6.1.3, including its Action statement, are satisfied. Technical Specification i 3.0.1.3 currently statis "Vith an air lock inoperable, restore the air lock to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ..." In 'he event that the i containment air lock beromes inoperable, this ch e.e vill clarify that it is appropriate to enter the TS 3.6.1.3 Action statement which allovs 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for air lock restoration rather than the TS 3.6.?.1 Action statement which allows only one hour for containment integrity {

restoration.

A similar license mmendment was approsed by the NRC and issued on July 1, 1991 1or the Baltimore Gas and Electrie Company Calvert Clifis t

Nuclear Power Plant Unit No. 1 (Docket No. 50-317, Amendment Nc. 156 (TAC No. 80112) to License No. DPR-53) and Unit No. 2 (Docket No.

50-318, Amendment No. 136 (TAC No. 00113) to License Nn. DPR-69). In addition, NUREG-0452, Revision 5. Standard Technical Specifications for '

Vestinghouse Pressutized Vater Reactors, ham modified standardized wording regarding these Technical Specifications similar to that being proposed i this License Amendment Request. The Technical ^

Specifica s issued by the NRC for the following plants also use similar A ngt Palo Verde Nuclear Cenerating Station (NUREG-1287),  !

V.C. Summet luclear Station (NUREG-0932), Seabrook Station (NUREG-1386), and Vaterford Steam Electric Station (NUREG-lll7).

For additional clarification, it is proposed that Surveillance Requirements (SR) 4.6.1.lb and 4.6.1.2f be deleted. These SRs a:e redundant-to the requirements of TS 3/4.6.1.3, and therefore this change is considered to be administrative in nature.

An additional change to TS 3/4.6.1.1 is proposed which affects-the asterisked note for SR 4.6.1.la.l. The proposed change vould clarify the excep han to include components located in the Shield Building (including the annulus and containment). The exception is presently vorded to exempt from position vetification those " valves, blind flanges, and deactivated automatic valves which are located inside the containment ..." USAR 3.8.2 states: "The containment for the station ,

consists of three basic structures: a steel con'ainment vessel, a reinforced concrete Shield Bui.1 ding, and the internal a'.ructures."

Thus-the prcsent wording "inside thc containment" includes the Shield Building, and-the proposed revording is a clarification. Access to the Shield Duilding is restricted during Modes 1 through 4 due to high radiation. Inspection of valves and other components located in the annolus between the containment vessel and the Shield Building would result in unnecessary personnel radiation exposure and conflict with the goals of the As-Low-As-Reasonably-Achievable (!.LARA) program, in ,

addition, since access is restricted, tne probability of misalighment is lov. This change is considered to be administrative in nature.

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Docket thimber 50 346 License !Jumber !JPP-3 Set ial !Jumbet 1971 Attachment Page 3 The pi npnsed change en TS 3.6.1.3 (Cnntainment Ait Locks) expands the Action statement to allow continued operation with an inoperable containment alt lock door ot with an inopetable air loth door interlock methanism, pt ovidt d an oper able containment ait lock door is closed and locked. A footnote is included to allov entry and exit through the operable door if necessaiy to petform tepairs of the affected air lock components. Aftot each ently and exit, the opetable doot must be closed without delay. As cuttently viitten, the DBtJPS TS tequires that a plant shutdown be initiated after 24 houts if a containment alt lock is inoperable for any reason. This includes th* situation of theto being two opeteble, closed doots in the same containment ait lock, but the interlocking mechanism is inopetable undet s arveillance Requir ement 4.6.1.3c. This situation, in particulat, does %t vattant putting the plant through a shutdovn evolution. 1he containment ait lock is "

provided for transit into and out of containment when containment integtity is required. During plant operational Modes 1 (Operation), 2 (Stattup), 3 (Hot Standby), and 4 (llot Shutdovn), when one containment air lock door is open, the other door is requited by TS 3.0.1.3 to be closed. This iequit ement , in conjunction with the containment air lock Icakage limits, ensures that containment integrity is maintained during entry and exit thtouch the conte nment air lock. Since containment i

integrity is maintained with on+ door in the same containment air lock closed, operation t hould be allowed with one operable containment air ,

lock door being mdntained closed (except when entry and exit is necessary to pertotm repairs). A related change is proposed for TS Bases 3/4.6.1.1 consistent vith the above change. This portion of the License Amendment Request is proposed considering the vording of NUREG-0103, Revision 4 (page 3/4 6-6L), Standard Technical Specifications for Babcock and Vilcox Pretsurized Vatet Reactors.

, 'ivo additional changes ate proposed to TS 3/4.6.1.3. The first proposed change is to add a clarification that each containment air lock shall be demonstrated opetable vithin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> aftet each opening. ~

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The prescat vording states "After each opening", with no time limit specified. Testing vithin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each opening is consistent with 10CFR50, Appendix J requirements. In addition, the present voiding "... except . hen the air lock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ... " becomes redundant assuming the ptoposei vording is adopted, and cc. therefore be deleted.

The second proposed change is to add a footnote for SR 4.6.1.3a and SR 4.6.1.3b which statest "The provisions of Spec 4fication 4.0.2 are not applicable." These fRs are also 10 CFR 50, Appendix J, III.D.2(b) requirements. Speellicatica 4.0.2 allows a 25% surveillance interval extension for petformance of TS SRs. However, 10 CFR 50, Appendly. J does not provide an extension to the testing period, and the TS 4.0.2 provision cannot be allowed for these SRs. These changes vill help prevent an inadvertent violation of the requirements of 10 CFR 50, Appendix J. These changes ate considered to be administrative in nature.

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Docket Number 50-346 License Numbet NPF-3

- Settal Numbet 1971 Attachment i Pye 4 I

SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:

Containment Integrity Containment Leakage Containment Air Locks SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMP 0NENTS, AND ACTIVITIES:

The TS 3.6.1.1 (Containment Integrity). TS 3.6.1.2 (Containment Leakage), and TS 3.6.1.3 (Containmen' Air Locks) Limiting Conditions for Operation (LCO) are based on requirements related to the control of offsite radiation doses resulting from major accidents. Compliance with these LCOs ensures a containment configuration that vill limit leakage to those paths and associated leakage rates assumed in the ~

safety analysis. The containment air locks are 10CFR Part 50, Appendix J Type B penetrations. TS 3.6.1.2 limits the combined Icocage through Type B and C penetrations and valve; o 60 percent of the allovable leakage rate. Each containment air lock la further restricted by TS 3.6.1.3 to 0.2 percent of the allovable leakage rate. Each air lock door double gasket is tested by pressurizing the space between the two ,

gaskets and measuring the leakage. As a result, radiation exposures at the site boundaty vill be maintained within the regulatory limits of 10CFR Part 100 following the most limiting design basis accident.

The containment personnel air lock is provided for routine transit . .. t o and out of containment when contair ment integrity is required. The containment emergency air lock is provided for emergency access and exit. During Modes 1, 2, 3, and 4, when one containment air lock door is epen, 'he other door in the same alt: lock is requited to be closed in accordance with TS 3.6.1.3a. This requirement, in conjunction sith the containment air lock leakage limits, ensures that containment integrity is maintained auring entry and exit through the containment air lock.

The air lock door interlock mechanism ensures that only one air lock doot can be opened at a tir , thereby ensuring containment integrity.

EFFECTS CN 5AFETY:

Containment air lock opetability consists of two separate aspects which are 1) the physical integrity of the doors, addressed by TS 3.6.1.3a, and 2) the overall containment air lock leakage, addressed by TS 3.6.1.3b. Addit.onal requirements for overall containment penetration leakage are provided in TS 3.6.1.2b and TS 3.6.1.2c. USAR 3.8.2.1.10 states: 'Each door is designed so that with the other door open, it can withstand and seal against design and testing pressures of the containment vessel." Thus, inoperability of one contninment air lock door or inoperability of the air lock door intctlock mechanism does not result in a significant adverse impact on contr.inment integrity as long as one operable door in the same air lock is closed and the containment air lock leakage requirements are met. The proposed changes to the TS 3.6.1.3 Action statement expands the Action statement to address continued operation with an inoperable containment air lock door or an inoperable air lock door interlock mechanism, pro.2ded an operable door

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Docket Number 50-346

. License Numbet Npf-3

- Serial Number 1971 Attachment Page 5 in the same contp % ont air inck is closed and locked. This proposed change vould p;e' ', en unvarranted plant shutdown evolution. A note is included to ' " ' < he ability to open the operable air lock doot for the purpose of r ang the necessary access required to perform repairs on afIceted air lock components. The note tequitas that the operable door be closed without delay after each entry and exit.

l t!!th the current TS vording, while in the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time, '

opening an operable air lock door is permitted. The proposed TS wording plees additional restrictions on operation in this situation, requiring that the operable door remain closed and locked except when  !

s access is necessary to perform repairs of the affected air lock components. Therefore, the proposed TS change does not impose an increase in consequences beyond that which r:xists with the present is '

wording.

Opening of the operable door, even if it wana the containment boundaty +

is temporarily not intact, is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the opetable door is expected to be open. Also, it is desirable to have both air lock doors operable. Thus the benefits resulting from being able to tepair an inoperable tir lock door outweigh the slight

• risk associated with opening the operable door for entry and exit. It should also be noted that no er.ception is taken to TS 3.0.4, therefore.  ;

plant startup could not occur while in an Action Statement of TS 3.6.1.3. Therefore. these changes to the TS 3.6.1.3 Action statement have a negligible adverse impact on safety.

The pr oposed change to the containment integrity definitic 1.8c clarifles the requirements for containment air lock inupeinbility for the cases where an inoperable containment air lock door or overall

• containment air lock leakage does not'present a containment ir:tegrity concern. Since the proposed change does not affect the overall ,

containment integrity / leakage requirements imposed through TSs 3.6.1.1 l and 3.6.1.2, there is no adverse effect on plant safety.

The remaining proposed changes of deleting TS 4.6.1.lb tad 4.6.1.2f, clarifying the asterisked footnote to TS 4.6.1 la, clarifying TS 4.6.1.3a, adding a footnote to TS 4.6.1.3a and TS 4.6.1.3b, and clarifying TS Bases 3/4.6.1.1 are considered to be administrative in natute and have_nw adverse effect on plant safety.

SIGNIFICANT HAZARDS CONSIDERATION:

The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c)-for determining whether a significant hazard exists due to a '

proposed. amendment to an Operating License for a facility. A proposed amendment involves no significant hazards 11 operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increa;e in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind'of. accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has revieved the proposed change and determined that a

Docket Number 50-346

. License Number NpF-3 Serial Number 1971 Attachment <

Page 6 significant harards consideration does not exist because operation of the Davis-Desse Nuclear power Station, tJnit Number 1, in accordance vit! these changes vould la. Not involve a significant incr ease in the probability of an s,ccident previously evaluated because no accident conditions and assumptions are significantly affected by the proposed changes.

The proposed change to TS Definition 1.8c reflects that containment integrity is satisfied as 19ag as the requirements of TS 3/4.6.1.3, including its Action statement are satisfied. The proposed change to expand the TS 3/4.6.1.3 Action statement allows continued operation vith an inoperable air lock door or with an inoperable air lock doot interlock mechanism, provided an operable door in the same containment air lock is closed and locked. This vould prevent an unvarranted plant shutdovn evolution. Each air '

lock door is designed to provide the containment barrier and is periodically tested to ensure leakage is not excessive. The ability to open the operable air lock door for the purpose of  !

providing the necessary access required to perform repairs on the affected air lock components, provided that the operable door is closed without delay following each entry and exit, has a negligible adverse impact on safety. Containment integrity and containment leakage rates are not significantly impacted by any of the proposed changes. Therefore, none of these proposed changes are associated vith the initiation of any design basis accident.

The other proposed changes are considered to be administrative in nature.

Ib.- Not involve a significant increase in the consequences of an accident previously evaluated because no iccident conditions a.id assumptions are affected by the proposed changes. As discussed in item la above, the proposed change to TS Definition 1.8c reflects '

that containment integrity is satisfied-as long as the requirements of TS 3/4.6.1.3, including the Action statement, are satisfied. The proposed change to expani the TS 3/4.6.1.3 Action statement allows cont _inued operation with an inoperable air lock door or with an inoperable air lock door interlock mechanism, e provided an operable door in the same contcinment air lock is closed and locked. This vould prevent an unwarranted plant shutdown evolution. Since each cir lock door is designed to provide the containment barrier and is periodically tested to ensure leakage is not excessive, the change vill not significantly increase the radiological consequences of an accident. The ability to open the operable air lock door for the purpose of providing the necessary access required to perform repairs on the

-affected air lock components, provided that-the operable-door-is closed without' delay following each entry end exit, has a negligible adverse impact on safety. As described in the discussion of Effects on Safety, this proposed TS change does not involve an incr ease- in consequences beyond that which exists with the present TS vording. The other proposed changes are considered to be administrative in nature. Since containment integrity and containment leakag- rates are not significantly impacted by any of l

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Docket Number 50-346 1.icense Number NPF-3 Serial Number 1971 Attachment

. Page 7 the proposed changes, the rartiological consequences of a previously evaluated accident are not significantly increased.

2a. Not create the possibility of a new kind of accident frem any accident previously evaluated because no new accident conditions or assumptions are created by the proposed changes. As discussed in item la above, the proposed change to TS Definition 1.8c reflects that containment integtity is satisfied as long as the requirements of TS 3/4.6.1.3, including the Action statement, are

[ satisfied. The proposed change to expand the TS 3/4.6.1.3 Action statement allows continued operation with an inoperable alt lock j

door or with an inoperable air lock door interlock mechanism, '

provided an operable door in the same containment alc lock is I closed and locked. This vould prevent an unvarranted plant i thutdova evolution. Each air lock door is designed to provide the I containment barrier and tested to ensurg excessive leakage vill not occur. The ability to open the operable air lock door for the purpose of providing the necessary access required to perform repairs on the affected air lock components, provided that the operable door is closed without delay following each entry and exit, has a negligible adverse impact on safety. The other proposed changes are considered to be administrative in nature.

Containment integrity and containment leakage rates are not significantly impacted by any of the proposed changes. There is no new failure modes or mechanism associated with the proposed changes. Therefore, none of the proposed changes creates the possibility of a new kind of accident from any accident previously evaluated.

2b. Not create the possibility of a different kind of accident from any accident previously evaluated because no different accident 1 conditions or assumptions are created by the proposed changes. As discussed in item la above, the proposed change to TS Definition ,

1.8c reflects that containment integrity is satisfied as long as the requirements of TS 3/4.6.1.3, including the Action statement, are satisfied. The proposed change to_ expand the TS 3/4.6.1.3  ;

Action statement allows continued operation with an inoperable air -

lock door or with an. inoperable air lock door interlock., provided an operable-door in the same containment air lock is closed and locked. This vould prevent an unwarranted plant shutdown evolution. Each air lock door is designed to provide the containment barrier and tested to ensure excessive leakage vill not occur.- The ability to open the operable air lock door for the purpose of providing the necessary access required to perform repairs on the affected air lock components, provided that the operable door is closed without delay follevinr- each entry and exlt, has a negligible adverse impact on safety. The other proposed changes are considered to be administrative in nature.

Containment integrity and containment leakage. rates are not significantly adversely impacted by any of the proposed changes.

The proposed cha,ces do not involve any physical changes to the plant. Therefore, none of the proposed changes creates the possibility of a different kind of accident from any accident previously evaluated.

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Docket Number 50-346

-' License Number NPl%3 Serial Number 1971 Attachment l' age 8

> 3. Not involve a significant reduction in a margin of safety because each air lock door is designed to provide the containment barrier. 1 Containment integrity is maintained except for the short period of time allowed for necessaty access through an operable air lock i door (as described above), and containment-leakage rates and containment air lock leakage rates are not significantly eri"erstly  ;

affected by any of the proposed changes.

CONCLUSION:

On the basis of the above, Toledo Edison has determined that the License Amendment Request does not involve a significant hazards consideration. - As this License Amendment Request concerns a proposed change to the Technical Specifications that must be reviewed by the-Nuclear Regulatory Commission, this License Amendment Request dotA '10 t constitute an unreviewed safety question.

ATTACllHENT: f Attached are the proposed mark-up changes to the Operating License. -

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