ML19256A146

Responds to 780925 Ltr Requesting Statement of Intent Re Compliance W/Nrc Position on Emergency Diesel Generator Air Start Manual Isolation Valves.Util Does Not Intend to Place These Valves Under Any Addl Controls for Stated Reasons

ML19256A146
Person / Time
Site:	North Anna
Issue date:	10/31/1978
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Parr O Office of Nuclear Reactor Regulation
References
NUDOCS 7811030160
Download: ML19256A146 (2)

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VIHOINIA ELecTurc ann POWER COMPANY H I C II M O N D . VI H O I N I A 2 3 2 G1 October 31, 1978 Mr. Olan D. Parr, Chief Serial No. 556/092578 Light Water Reactors Branch No. 3 PO/IBF:jps Division of Project Management Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 Washington, D. C. 20555 License Nos. NPF-4 CPPR-78

Dear Mr. Parr:

This is in response to your letter of September 25, 1978 which requested a statement of tr intent regarding compliance with your position on emergency diesel generator air start manual isolation valves. In that letter you concluded that existing administrative procedures for control of the diesel " air start manual isolation valves" should be replaced with design provisions to kev-lock these valves to their open position with the key to be administratively controlled, Before commenting on your position, we would like to clarify statements in response to item (d) in our letter dated July 7, 1978.

In the July 7, 1978 letter response to QUESTION (d), we stated that the air start manual isolation valves and the control room selector switch are checked every four (4) hours and recorded in the Diesel Log by an operator. Also, the status of the above items are reviewed by the shift supervisors at the change of each shift. We would like to restate the response to QUESTION (d) as follows: The control room selector switch is checked every four (4) hours and recorded in the Diesel Log by an operator. Also, the status of the control room selector switch is reviewed by the shift supervisors at the change of each shift.

With regard to your position on air start manual isolation.

valves, we do not intend to place these valves under any additional controls for the following reasons. In the Unit's Technical Speci-fications concerning Electrical Power Systems (T.5.3.8.1.1), there is a surveillance requirement on the diesels which state that each diesel generator shall be demonstrated OPERABLE at least once per 31 days. This implies that the air start valve line-up to the diesels are verilied. If these valves are not in their intended position the diesel will not start which will put the unit in the ACTION statements.

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im,ma Etr.cTaic aso rowra comsv To Mr. Olan D. Parr 2.

1 We find the 31 day surveillance requirement on the Diesel sufficient to insure that the isolation valves are in their in-tended positions. This reasoning is consistent with the surveillance requirements placed on other safety related systems (i.e. ECCS subsystems) which require that the valve line-ups be checked every 31 days.

Very truly yours,

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C. M. Stallings Vice President-Power Supply "h

and Production Operations

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