ML20054L185

Requests Exemption from 10CFR50.44(c)(3)(iii) Re Reactor Vessel Head Vent Installation.Unique Facility Design Allows Alternate Means of Addressing Intent of Hydrogen Rule

ML20054L185
Person / Time
Site:	Davis Besse
Issue date:	07/01/1982
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
835, TAC-48593, NUDOCS 8207070241
Download: ML20054L185 (1)

Text

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Docket No. 50-346 TOLEDO License No. NPF-3 EDISON Rcmmo P. CRoust Seria1 No. 835 v yt,-

July 1, 1982 m 9nsa om Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz Operating Reactors Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stolz:

This letter is being submitted in order to request an exemption from 10 CFR 50.44 (c)(3)(iii) " Standards for Combustible Gas Control Systems in Light-Water Cooled Power Reactors" for Davis-Besse Nuclear Power Station Unit No. 1. The relief from the requirement to install a Reactor Vessel Head Vent is being requested pursuant to 10 CFR 50.12(a).

Davis-Besse is a Babcock and Wilcox (B&W) raised loop, Once Through Steam Generator (OTSG) power plant. In a recent evaluation of the ability to ensure venting of non-condensible gases in accordance with Lessons Learned from Three Mile Island (Toledo Edison letter dated January 30, 1980, Serial No. 582), it was determined that a reactor vessel head vent provides no advantage for a B&W nuclear steam supply system beyond that achieved by the installed high point hot leg vents. Any accumulation of non-condensible gases that is sufficient to fill the reactor vessel head below the hot leg nozzles can be vented via the hot leg vents due to the free path available from the reactor vessel to these vents.

Based on the above, Toledo Edison has determined a reactor vessel head vent is not required to meet the intent of the hydrogen rule. The unique Davis-Besse plant design allows an alternate, equally satisfactory means of addressing the concerns raised in the subject rule. Therefore, Toledo Edison requests that relief from the reactor vessel head vent portion of 10 CFR 50.44 (c)(3)(iii) be granted.

Very truly yours,

. o RPC: GAB: lab cc: DB-1 NRC Resident Inspector pk 4p THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652

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8207070241 820701 PDR ADOCK 05000346 P PDR _ _ ._ _