ML19269D613

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Details Positions Re Reg Guide 1.11 Revision 0,& Reg Guide 1.120,Revision 1.Will Comply W/Reg Guide 1.11 W/Exception of Containment Pressure Instrument Lines.Reg Guide 1.120 Not Applicable
ML19269D613
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 05/30/1979
From: Brown S
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 7906050280
Download: ML19269D613 (2)


Text

ny VIRGINI A ELECTRIC AND POWER COMP ANY, RICHMOND. vtRGINia 2M61 May 30, 1979 Mr. Harold R. Denton, Director Serial No. 251 Office of Nuclear Reactor Regulation PSE&C/LTW/LCK:mac: wang 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 Commission Washington, D. C. 20555

Dear Mr. Denton:

Our letter Serial No. 039 of February 6,1979 advised you of our intention to inform you continually of Company positions which are not in accordance with individual Regulatory Guides. This letter advises you of the Company positions on Regulatory Guide 1.11, " Instrument Lines Penetrating Primary Reactor Containment," dated March,1971; and Regulatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants," Revision 1, dated November, 1977. The North Anna Units 3 and 4 plant design is such that full compliance with these Regulatory Guides cannot be achieved. The Company positions on the Regulatory Guides are as follows:

Regulatory Guide 1.11, Revision 0 North Anna Units 3 and 4 will comply with Regulatory Guide 1.11, Revision 0 with the exception of the containment pressure instrument lines which penetrate the containment and are open to the containment atmosphere. The transmitters located outside the containment provide containment pressure signals for the Engineered Safeguards Actuation System and Post-Accident Monitoring. The containment isolation valves on these lines are remote-manual operated with position indication in the control room. These valves are air operated and f ail open to ensure continued operability of the transmitters.

In addition, each transmitter installation has a manual isolation valve for maintenance purposes.

Regulatory Guide 1.120, Revision 1 The requirements of Regulatory Guide 1.120 are an extension of the requirements of Appendix A to Branch Technical Position 9.5-1 which has been required on North Anna Units 3 and 4 in connection with an evaluation of the fire protection systems of the station, as directed by Mr. R. S. Boyd's letter of September 30, 1976. Resolution of this fire protection evaluation will satisfy all requirements for upgrading of fire protection systems on North Anna 3 and 4. Therefore, we believe Regulatory Guide 1.120 is not applicable to North Anna 3 and 4 2262 106 p

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Mr. Harold R. Denton, Director 2 These positions will be placed on file and will be included in the Final Safety Analysis Report for these units.

We would be pleased to discuss these positions with you at your con-venience. Should you wish to meet with us to discuss these positions, or if you have any questions, please contact us.

Very truly yours, Sam C. Brown, Jr.

Senior Vice President - Power Station Engineering & Construction 2262 107