ML19263D629

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Responds to Re Implementation of NRC Review Requirements.Clarifies Intent of .Further Response Not Appropriate Unless Serious Conflict Occurs
ML19263D629
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 03/21/1979
From: Vassallo D
Office of Nuclear Reactor Regulation
To: Proffitt W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 7904130081
Download: ML19263D629 (3)


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UNITED STA TES 3'W f' 4 NUCLEAR REGULATORY COMMISSION f,'k[.fl.[) j WASHINGTON, D. C. 20555 s t W 'f i gv j MAR 21 1979 Docket tios. 50-404 and 50-405 Mr. W. L. Proffitt Senior Vice President - Power Virginia Electric & Power Company P. O. Box 26666 Richmond, Virginia 23261

Dear Mr. Proffitt:

SUBJECT:

IMPLEMEflTATI0fl 0F STAFF REVIEW REQUIREMErlTS - fl0RTH AftflA POWER STATI0ft, UNITS 3 & 4 - OPERATIrlG LICEtlSE REVIEU In our letter of flovember 21, 1978, we provided a listing of new regulatory guides, branch technical positions, and modifications to previously existing staff positions. These items were classified as Category 1, 2, 3, or 4 matters.

In addition, our letter explained the definition of each category and how these matters would be reviewed on your operating license application for florth Anna 3 & 4.

Our letter was intended to bring you up-to-date on those changes in staff positions, along with their implementation schedule, so that you may consider them in your Final Safety Analysis Report (FSAR) preparation.

In your response of February 6,1979, you stated that you have instituted a program to review regulatory guides, assess the guides against the already approved design of florth Anna 3 & 4, and inform the staff continually of Company positions which are not in accordance with individual regulatory guides.

You further stated, that you intend to address in your FSAR all regulatory guides and those items identified as Category 1, 2, 3, or 4 matters.

You requested clarification of the implementation of Category 1 regulatory guides and a listing of any guides issued that are not applicable to florth Anna 3 & 4.

790413008/

s Mr. W. L. Proffitt MAR 21 1979 It was the intent of our November 21, 1978 letter to advise you, along with similar generic letters to other applicants, of changes in staff positions. We knew that some of the requirements were not applicable to all plants; i.e., BWR requirements would not apply to PWR plants and vice versa. Additionally, it was understood that the existing design of a given plant might already encompass some of the new staff requirements.

Applicants are in the best position to assess the applicability of individual staff requirements to a given plant design.

Therefore, we do not propose to respond further to your request for a listing of regulatory guides that are not applicable to the subject facility.

Regarding your question on the implementation of Category 1 items, we reiterate our statement in our Ucvember 21, 1978 letter that,

" Category 1 matters are those to be applied to applications in accordance with the implementation section of the published guide."

Our understanding of your February 6,1979 letter is that you are in the process of reviewing all regulatory guides and all Category 1, 2, 3, and 4 matters (most of which are regulatory guides) and assessing them against the North Anna 3 & 4 design and that it is your intention to address all regulatory guides and Category 1, 2, 3, and 4 matters in your FSAR. We feel that this is the best approach for you to take.

We, in turn, will evaluate your design in line with all of these matters during the operating license review of your application.

Because of staff resource problems, we do not propose to meet to discuss your interpretation of these items prior to the submittal of your FSAR unless, during your assessment, you conclude that the existing North Anna 3 & 4 design appears to be in serious conflict with stated positions, and that unless resolved prior to the submission of your FSAR, deferral of a resolution could significantly impact your construction schedule or lead to major engineering design changes.

I hope this letter is responsive to the concerns expressed in your February 6, 1979 letter.

Sincerely, AW Domenic B. Vassallo, Assistant Director for Light Water Reactors Division of Project Management cc:

See next page

s 79 Mr. W. L. Prof fitt cc: Mrs. James C. Arnold lahn J. Runzer, Esq.

Box 3951 Pepper, Hamilton and Scheetz Charlottesville, Virginia 229.3 123 South Broad Street Philadelphia, Pennsylvania 19109 Honorable Frederick S. Fisher Assistant Attorncv deneral Mr. Peter S. Hepp Commonwealth of Virginia Executive Vice President 1101 East Broad St reet Sun Shipbuiding & Dry Dock Co.

Richmond, Vi rginia 23219 P. O. Box 540 Chester, Pennsylvania 19013 Michael W. Maupin, Esquire Hunton, Williams, Gay & Gibson P. O. Box 1535 Richmond, Virginia 23212 Mrs. June Allen 412 Owens Drive Huntsville, Alabama 35801 Mr. James Torson 501 Leroy Socorro, New Mexico 87801 Mrs. Margaret Dietrich Route 2, Box 568 Gordonsville, Virginia 22942 William H. Rodgers Jr., Esquire Georgetown University Law Center 600 New Jersey Avenue, N. W.

Washington, D. C.

20001 Michael S. Kidd USNRC P. O. Box 128 Spotsivania, Virginia 22553 Clarence T. Kipps, Jr., Esquire 1700 Pennsylvania Avenue, N. W.

Washington, D. C.

20006 Carroll J. Savage, Esquire 1700 Pennsyvania Avenue, N. W.

Washington, D. C.

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