ML19276G893

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Advises of Position Re Reg Guide 1.52,Revision 2, Design, Testing & Maint Criteria for Post-Accident Engineered Safety Feature Atmosphere Cleanup Sys Air Filtration & Absorption Units of Light Water Cooled Nuclear Power Plants.
ML19276G893
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/24/1979
From: Brown S
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Parr O
Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.052, RTR-REGGD-1.052 NUDOCS 7908280560
Download: ML19276G893 (3)


Text

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Vepco _ _ _ _

August 24, 1979 Mr. Harold R. Denton, Director Serial No. 675 Office of Nuclear Reactor Regulation PSE&C/SNK:adw:mc Attn: Mr. O. D. Parr, Chief Light Water Reactors Branch No. ? Docket Nos. 50-404 Division of Project Management 50-405 U. S. Nuclear Regulatory Comission 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 position on Regulatory Guide 1.52, Revision 2, "De-sign, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants", for the North Anna 3 and 4 Units.

Company Position The engineered-safety-feature atmosphere cleanup system air filtra-tion and adsorption units for North Anna 3 and 4 are as follows:

a. Auxiliary Building Comon Exhaust Filtration System
b. Control Room Emergency Filtration System The North Anna Units 3 and 4 project will comply with the Regulatory Position (paragraph c) of this Guide with the following clarifications or exceptions:

c.1.c The systems are designed based on air flow rate and resident time.

c.2.b Vepco complies for the control room emergency filter system. The common exhaust filter system is not pro-tected from missiles generated by natural phenomena.

The top floor of Auxiliary Building is not designed for missile protection.

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viRaiNiA suCTRIC AND POWER COMPANY TO Mr. Harold R. Denton 2 Exception is taken to balancing techniques defined in Section 5.7.3 of ANL N509-1976. Displacement criteria following nonnal industry practice will be used when maximum vibration velocity method imposes unrealistic requirements at certain operating speeds.

Documentation will not be furnished in accordance with Section 5.7.5 where AMCA certification ratings are sub-mitted.

c.3.1 - Exception is taken to the provisions in Section 5.9 of ANSI 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. (Note: This exception does not pertain to containment penetrations)

In addition, exception is taken to the following:

Class B leakage rates shall be determined for one damper or each type instead of every dam-per.

c.4.a - The design of normal ventilation exhaust system air filtration and adsorption units minimizes the time that personnel are exposed to contaminated components.

The guidelines specified in this paragraph are consider-ed to be general guides, and full compliance is not necessary.

c.4.b - Mounting frames in the filters are less than three feet apart. All filter assemblies are provided with adequate working space to permit the maintenance personnel to re-place the filters.

This position will be placed on file and will be included in the Final Safety Analysis Report for these units.

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waaima etecrnic Ano powan COMPANY TO Mr. Harold R. Denton 3 We would be pleased to discuss 1.his 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 ruly yours,

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S C. rown, Jr.

Senior Vice) President-Power Station Engineering and Construction 204i 106