ML033600026

Withdrawal of 10CFR50, Appendix R, Subsection Iii.L.I, Exemption Regarding Time to Reach Cold Shutdown

ML033600026
Person / Time
Site:	Davis Besse
Issue date:	12/17/2003
From:	Myers L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3008
Download: ML033600026 (3)

Text

FENOC FENOC 5501 North State Route 2 FnrstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 LewW MYerS 419-321-7599 Chief Operating Officer Fax: 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 3008 December 17, 2003 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555-0001

Subject:

Withdrawal of 10 CFR 50, Appendix R, Subsection III.L. 1, Exemption Regarding Time to Reach Cold Shutdown Ladies and Gentlemen:

This letter transmits a FirstEnergy Nuclear Operating Company (FENOC) request for withdrawal of an exemption from Title 10 of the Code of Federal Regulations (CFR), Section 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," Subsection III.L. 1 for the Davis-Besse Nuclear Power Station, Unit I (DBNPS).

Subsection 1I1.L. I of 10 CFR 50, Appendix R, states, in part, that the alternative shutdown capability shall be able to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Further, Subsection III.L.3 of 10 CFR 50, Appendix R, states that the alternative shutdown capability must accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Thus, the alternative shutdown capability must be able to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, independent of offsite power.

In the request for exemption dated September 30, 1983 (DBNPS letter Serial number 991), the DBNPS staff cited two issues that prevented the DBNPS from complying with the requirements of 10 CFR 50, Appendix R, Subsection III.L. 1. Specifically, with a loss of offsite power the driving force for the pressurizer spray (the Reactor Coolant Pumps) is lost, limiting the ability to depressurize the Reactor Coolant System (RCS) to a rate controlled by heat loss from the pressurizer to the Containment Vessel environment. In addition, the cooldown rate was limited to no more than 1.50 F/hr under natural circulation conditions to prevent the formation of voids in the upper reactor vessel head. This exemption was approved by the Nuclear Regulatory Commission (NRC) by letter dated August 20, 1984 (DBNPS letter Log number 1586).

Docket Number 50-346 License Number NPF-3 Serial Number 3008 Page 2 An evaluation consisting of short-term transient analyses, the plant simulator, and plant empirical data was recently performed to determine the time required for the DBNPS to achieve cold shutdown conditions. The issue related to the ability to depressurize the RCS due to a loss of driving force for the pressurizer spray was resolved by using alternate pressurizer spray from the High Pressure Injection (HPI) pumps. In addition, subsequent analysis and the RCS continuous vent line permit a maximum RCS cooldown rate of 50'F/hr. The evaluation showed that the DBNPS alternative shutdown capability is able to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, independent of offsite power. Therefore, the exemption is no longer required and the FENOC requests that it be withdrawn.

If you have any questions or require further information, please contact Mr. Kevin L. Ostrowski, Manager - Regulatory Affairs, at (419) 321-8450.

Very truly yours, CWS Enclosure cc: Regional Administrator, NRC Region III J. B. Hopkins, DB-1 NRC/NRR Senior Project Manager C. S. Thomas, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

- a Docket Number 50-346 License Number NPF-3 Serial Number 3008 Enclosure Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station, Unit Number 1, (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please notify the Manager -

Regulatory Affairs (419-321-8450) at the DBNPS of any questions regarding this document or associated regulatory commitments.

COMMITMENTS DUE DATE None N/A