ML19269C806
| ML19269C806 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/06/1979 |
| From: | Brown S VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Parr O Office of Nuclear Reactor Regulation |
| References | |
| 039, 39, NUDOCS 7902120210 | |
| Download: ML19269C806 (2) | |
Text
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V VIRGINI A ELECTRIC AND POWER COMP ANY, RICHMOND, VIRGINI A 23261 FEB e my Mr. Harold R. Denton, Director Serial No. 039 Office of Nuclear Reactor Regulation PSE&C/DPB/EAB:bep/mc Attn: Mr. O. D. Parr, Chief Light Water Reactors Branch No. 3 Docket Nos. 50-404 Division of Project Management 50-405 U. S. Nuclear Regulatory Cormiission Washington, D. C.
20555
Dear Mr. Denton:
We have received your latter of November 21, 1978 concerning the cate-gorization of Regulatory Guides by the Regulatory Rea':f rements Review Commit-tee (RRRC).
We have instituted a program to review Regulatory Guides, and it is our intention to inform you continually of Company positions which are not in accordance with individual Regulatory Guides. We will be prepared to discuss these positions with you as nect sary. However, to assist us in the implementation of this program there are several areas for which clarification is needed.
These areas were discussed in general with your Messrs. Vassallo, Parr and Capra on January 25, 1979, but we request that you address them specifically in writing.
The North Anna 3 and 4 PSAR addresses the first twenty-nine Regulatory Guides. We will also address those items listed under Categories 1, 2, 3 and 4 in the FSAR. Your letter indicates that Category 1 items are forward fit only, however during the North Anna 1 and 2 Operating License review we were required to address Regulatory Guide 1.XX, Thermat Overload Protection For Motors On Motor-0perated Valvec, which has been considered as Category 1.
For this reason, we are unclear as to the implementation of Category 1 Regu-latory Guides.
While we recognize the difficulty in categorizing Regulatory Guides on a case-by-case basis, we nevertheless are confronted with uncertanity regarding the final design description for the operating license applica-tion. With a construction permit dated July 1974 and the dynamic nature of the regulatory guide process, that is, new guices being issued as well as revisions to existing guides being made, it is against this background that we are continuing our assessment of the already approved design and the potential economic consequences that the changing requirements of coalply;ng with these regulatory guides present. lie therefore intend to address all regulatory guides.
When we decide it is unreasonable or im-prudent to meet a guide, or if it is questionable that we do not meet the intent of a regulatory guide, we will advise the staff. Also, should there Q
990212 MO
~,o VIRGINIA JLECTRIC AND POWER COMPANY TO be any regulatory guides issued that are not applicable to North Anna Units 3 & 4, we would appreciate that listing in order to minimize our review
- schedule, f
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M y,druf' rs, h
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/tM SW a u C. Brown, Jr.
(Power Station Enginee /
n nd Construction