ML19209A677
| ML19209A677 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/24/1979 |
| From: | Brown S VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19209A670 | List: |
| References | |
| 674, NUDOCS 7910050171 | |
| Download: ML19209A677 (3) | |
Text
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P00R ORGIRL August 24, 1973 Mr. Harold R. Denton, Director Serial fio. 674 Office of tiuclear Reactor Regulation PSEaC/SNK:adw:me Attn: Mr. O. D. Parr, Chief Light '.later Reactors Branch No. 3 Docket Nos. 50-404 Division of Project Managenent
~50-405
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U. S. fluclear Regulatory Comission
!iashington, D. C.
20555
Dear Mr. Denton:
Cur letter Serial No. 039 of February 6,1979, advised you of our in-tention to inform you continually of company positions which are not in accordance with individual Regulatory Guides.
This letter advises you of the company position on Regulatory Guide 1.140, Revision 0, " Design, Test-ing, and Maintenance Criteria for Nomal Ventilation Exhaust System Air Filtration and Adsorption Units of Light 'Jater-Cooled fluclear Power Plants" for the fiorth Anna 3 and 4 units.
Company Position The horth Anna Unit.s 3 and 4 project will comply with the Regulatory Position (paragraph c) of this guide with the followimg clarifications or excep ticns:
c.1.a - The design of each atmosphere cleanup system is based on air flow rate and resident tice.
c.3.d - Scme filters are upstream access c.3.f - Exception is taken to Section 5.10.3.5 of A'4SI flSO9-1976; ductwork, as a structure, will have a resenant frequency above 25 Hz, but this may not be true for the unsupported plate of sheet sectior.
c.3.1 - System resistances will be detemined in accordance with-Section 5.7.1 of AflSI fiS09-1975 except that fan inlet and outlet losses will not be calculated in accordance with AMCA 201.
Exception is taken to Section 5.7.2 of ANSI N509-1976; copies of fan ratings or test reports are not necessary when certi-fied fan perfomance curves are furnished.
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7 Mr. Harold R. Denten 2
Exception is tuken to balancing techniques defined in Section 5.7.3 of ANSI H509-1976.
Dispiaceaant c"iteria following normal industry practice will Se used when maximum vibration velocity method imposes unrealistic requirements at certain operating speeds.
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Cocumentation will not ba furnished in accordance with' U
Section 5.7.5 where NiCA certification ratings are sub-mitted.
c.3.1 - Exception is taken to the provisions in Section 5.9 of MtSI N509-1976 of designing dampers to ANSI B31.1 and to using butterfly valves. Class B dampers may be de-signed and tested to meet the verification of strength and leaktightness necessary for use in a contaminated air stream.
(flote: This exception does not pertain to containment penetrations)
In addition, exception is taken to the following:
Class B leakage rates shall be detemined for one danper or each tyce instearf of every dam-per.
c.4.a - The desi;n of normal ventilation exhaust system air filtration and aosorption units minimizas the time tnat personnel are exposed to contaminated coraponents.
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sf The guicelines specified in this paragraph are consider-3.f ed to be general guices, and full compliance is not
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necessarj.
c.4.0 - Mounting frames in the filters are less than three feet apart. All filter assemblies are provided with acequate working space to permit tne maintenance personnel to re-place the filters.
This position will be placed on file and will be included in the Final
- Z, Safety Analysis Report for these units.
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!!r. Harold R. Denton 3
We would be pleased to discuss this position with you at your con-venience.
Should you wish to meet with us to discuss this position, or if you have any questions please contact us.
Very truly yours,
. Original Signed by F/.C. SPENCER Sam C. Brown, Jr.
t Senior Vice President-Power Station Engineering and Construction "tg i
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