ML042730453
| ML042730453 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/28/2004 |
| From: | Ross-Lee M NRC/NRR/DLPM/LPD2 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Monarques, S R, NRR/DLPM, 415-1544 | |
| References | |
| TAC MC4251, TAC MC4252 | |
| Download: ML042730453 (12) | |
Text
September 28, 2004 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060-6711
SUBJECT:
SURRY POWER STATION, UNITS 1 AND 2 - AMERICAN SOCIETY OF MECHANICAL ENGINEERS INSERVICE TESTING PROGRAM, REVISED RELIEF REQUESTS P-2 (TAC NOS. MC4251 AND MC4252)
Dear Mr. Christian:
By letter dated September 1, 2004, Virginia Electric and Power Company (VEPCO) requested approval for Unit 1 Revised Relief Request P-2 and Unit 2 Revised Relief Request P-2 for Surry Power Station, Units 1 and 2, and to withdraw NRC staff-approved Relief Requests P-2 for these same units. By letter dated July 2, 2004, the NRC staff had conditionally approved Relief Requests P-2 for the fourth 10-year inservice testing (IST) program at Surry Power Station, Units 1 and 2. In its letter, the NRC staff imposed three conditions on Relief Requests P-2:
Condition 1: During either refueling outages or cold shutdowns, pumps 1-RH-P-1A, 1-RH-P-1B, 2-RH-P-1A, and 2-RH-P-1B shall be tested prior to being put into service and declared operable. This test will remain valid for a period of 3 months.
Condition 2: During refueling outages or cold shutdowns that extend beyond a 3-month period, the licensee shall test these pumps once every 3 months.
Condition 3: During back-to-back refueling outages or cold shutdowns that occur beyond any 3-month test period, the licensee shall test these pumps once every 3 months.
During a conference call conducted on August 11, 2004, VEPCO and the NRC staff agreed that condition 1 was impractical to implement because this condition conflicted with the requirements of the Technical Specifications. In order to resolve this issue, VEPCO agreed to submit revised relief requests and to withdraw Unit 1 Relief Request P-2 and Unit 2 Relief Request P-2. The revised relief requests were to incorporate conditions 2 and 3 and state that the residual heat removal pumps would be tested as soon as practical after containment subatmospheric pressure is relieved.
Our evaluations and conclusions are contained in the enclosed Safety Evaluation. The NRC staff has determined that imposing certain American Society of Mechanical Engineers Code requirements is impractical. In addition, the licensees proposed alternative provides reasonable assurance that the component is operationally ready. Therefore, the licensees request for relief, as described in Revised Relief Requests P-2, is granted pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(f)(6)(i) for the fourth 10-year IST
interval at Surry Power Station, Units 1 and 2. The granting of relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
This completes the NRC staffs activities associated with TAC Nos. MC4151 and MC4152.
Sincerely,
/RA/
Mary Jane Ross-Lee, Acting Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
As stated cc w/enclosure:
See next page
September 28, 2004 interval at Surry Power Station, Units 1 and 2. The granting of relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
This completes the NRC staffs activities associated with TAC Nos. MC4151 and MC4152.
Sincerely,
/RA/
Mary Jane Ross-Lee, Acting Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
As stated cc w/enclosure:
See next page Distribution PUBLIC MJRoss-Lee EDunnington RidsRgn2MailCenter RidsNrrDlpmLpdii GHill SMonarque PDII-1 R/F RidsOgcRp ACRS DTerao WPoertner G:\\DLPM\\PDII-1\\surry\\relief requests\\IST\\surryrevisedP2.wpd ADAMS ACCESSION NO. ML042730453 NRR-028 OFFICE PM/PDII-1 LA/PDII-2 SC/EMEB OGC SC/PDII-1 NAME SMonarque EDunnington DTerao DReddick MJRoss-Lee DATE 09/15/2004 09/15/2004 09/15/2004 09/23/2004 09/28/2004 OFFICIAL RECORD
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FOURTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM SURRY POWER STATION, UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NOS. 50-280 AND 50-281
1.0 INTRODUCTION
By letter dated September 1, 2004, Virginia Electric and Power Company (the licensee) submitted Unit 1 Revised Relief Request P-2 and Unit 2 Revised Relief Request P-2 for the fourth 10-year inservice testing (IST) interval at Surry Power Station, Units 1 and 2. In addition, as part of this submittal, the licensee withdrew Relief Requests P-2 for these same units.
By letter dated July 2, 2004, the NRC staff approved several relief requests associated with the fourth 10-year IST program at Surry, Units 1 and 2, including Unit 1 Relief Request P-2 and Unit 2 Relief Request P-2. Relief Requests P-2 address the testing requirements for Residual Heat Removal (RHR) pumps 1-RH-P-1A, 1-RH-P-1B, 2-RH-P-1A, and 2-RH-P-1B. In its conditional approval of Relief Requests P-2, the NRC staff imposed the following three conditions:
Condition 1: During either refueling outages or cold shutdowns, pumps 1-RH-P-1A, 1-RH-P-1B, 2-RH-P-1A, and 2-RH-P-1B shall be tested prior to being put into service and declared operable. This test will remain valid for a period of 3 months.
Condition 2: During refueling outages or cold shutdowns that extend beyond a 3-month period, the licensee shall test these pumps once every 3 months.
Condition 3: During back-to-back refueling outages or cold shutdowns that occur beyond any 3-month test period, the licensee shall test these pumps once every 3 months.
During a conference call conducted on August 11, 2004, the licensee and the NRC staff agreed that condition (1) was impractical to implement because it conflicted with the requirements of the Technical Specifications (TS). However, the licensee understood the NRC staffs concerns about the necessity of testing the RHR pumps during refueling outages and cold shutdowns, as well as complying with conditions (2) and (3). As a result, the licensee agreed to revise the relief requests in order to address the NRC staffs concerns, described above, and to withdraw Unit 1 and Unit 2 Relief Request P-2.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(f)(4) requires that IST of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves be performed in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission.
Section 50.55a of 10 CFR authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the Code requirements that are acceptable to the NRC staff.
Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.
The Code of record for the fourth 10-year IST interval at Surry, Units 1 and 2, is the 1998 Edition up to and including the 2000 Addenda of the ASME OM Code. The Surry fourth 10-year IST interval began on May 10, 2004, and ends on May 9, 2014.
3.0 TECHNICAL EVALUATION
3.1 Surry, Unit 1, Revised Relief Request P-2 3.1.1 The Components for which Relief Is Requested The components affected by this relief request are RHR Pumps 1-RH-P-1A and 1-RH-P-1B for Surry, Unit 1. These RHR pumps are classified as Class 2, Group A pumps in the IST Program and function to remove decay heat from the reactor core and the reactor coolant system (RCS) during plant cool down.
3.1.2 Code Requirements The licensee has requested relief from OM Code Table ISTB-3400-1. Table ISTB-3400-1 requires an inservice test be run on each Group A pump nominally every 3 months.
3.1.3 Licensees Basis for Requesting Relief The RHR pumps are located inside containment. These pumps are low pressure (600 psig design pressure) pumps that take suction from and discharge to the RCS. The RCS is maintained at 2235 psig and the containment atmosphere is maintained at subatmospheric pressure during normal operation. The RHR motor-operated suction and discharge isolation valves are interlocked with an output signal from RCS pressure transmitters that prevent the valves from being opened when the RCS pressure exceeds 460 psig. Therefore, it is not possible to test the RHR pumps during normal operation.
As the plant goes through the process of shutting down to the cold shutdown condition, the RHR pumps must be placed in service and be operable as required by the Surry TS and the RCS cooldown sequence before it is practical to test the pumps. According to Surry TS 3.1.A.1.d:
When the average reactor coolant loop temperature is less than or equal to 3500 F, the following conditions shall be met:
1.
A minimum of two non-isolated loops, consisting of any combination of reactor coolant loops or residual heat removal loops, shall be OPERABLE except as specified below:
(a) One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is OPERABLE and in operation.
(b) During REFUELING OPERATIONS the residual heat removal loop may be removed from operation as specified in TS 3.10.A.4.
2.
At least one reactor coolant loop or one residual heat removal loop shall be in operation, except as specified in Specification 3.10.A.4.
(TS 3.10.A.4 applies to operation limitations during refueling operations or irradiated fuel movement in the fuel building.)
At the beginning of the RCS cooldown sequence, heat is extracted from the RCS using the RCS loops and the steam generators. As the RCS temperature falls below 3500 F, the steam generators became less effective at removing heat.
Between the RCS temperatures of 3500 F and approximately 2500 F, the RHR system must be placed in service to continue the cooldown process.
However, the containment subatmospheric pressure must be maintained until the RCS temperature is below 2000 F. According to Surry TS 3.8.A.2:
The inside and outside isolation valves in the Containment Ventilation Purge System shall be locked, sealed, or otherwise secured closed whenever the Reactor Coolant System temperature exceeds 2000 F.
The containment ventilation purge system is used to relieve the containment subatmospheric condition.
Testing the RHR pumps requires a containment entry because the instrumentation used to measure flow and pressure must be monitored at the pump location. Also, vibration must be measured at the pump. Entering the containment to perform RHR pump testing when the containment is at subatmospheric pressure requires the test personnel to wear a self-contained breathing apparatus (SCBA). The SCBA comes with a full-face mask and an air tank. The
mask restricts communication and vision, making readings difficult to obtain. The tank restricts range of motion and movement, making placement of the vibration probes more difficult and hazardous because the test personnel must climb up onto the pump housing to place the vibration probes. Also, personnel are under time constraints due to the limited air supply in the SCBA units, thus creating additional stress.
Being in close proximity to rotating equipment while wearing a SCBA is in itself hazardous due to the restricted field of vision, and the straps and hoses of the SCBA that may become entangled by the pump. Therefore, testing the RHR pumps while test personnel are wearing SCBAs is considered difficult, hazardous, and thus not practical. Testing should only be performed when containment is not at subatmospheric pressure.
3.1.4 Licensees Proposed Alternate Testing The licensee proposes to test these pumps during every cold shutdown outage and reactor refueling outage at the first practical opportunity after containment subatmospheric pressure is relieved, unless the pump has been tested within the previous 3 months. (During back-to-back cold shutdown or refueling outages, the test period remains valid for 3 months following each test, and no additional periodic testing needs to be performed within this 3-month test period.)
For a cold shutdown or reactor refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with ISTB 3400-1.
3.1.5 Staff Evaluation RHR pumps 1-RH-P-1A, and 1-RH-P-1B are located inside the containment and are classified as Group A pumps in the IST Program. These pumps are low-pressure (600 psig design pressure) pumps that take suction from the RCS hot leg, pass flow through the RHR heat exchangers, and discharge to the RCS cold leg. These pumps are in a standby condition during power operation and only activate when the RCS is at a low pressure and the RHR system is needed. The RHR system is a low-pressure system controlled by two motor-operated valves that are interlocked with RCS pressure transmitters to prevent the motor-operated valves from being opened whenever the RCS system pressure exceeds 460 psig (Surry Updated Final Safety Analysis Report Section 9.3.3.2). This prevents testing of the RHR pumps during normal operations.
TS 3.8.A.2 requires the containment to be in a subatmospheric condition when the RCS temperature exceeds 2000 F. As such, personnel who enter the containment to perform RHR pump testing when the containment is at subatmospheric pressure are required to wear a SCBA. The SCBA restricts personnel movement and field of vision. This creates a difficult and hazardous environment for personnel conducting vibration testing of the RHR pumps.
The ASME OM Code, Table ISTB-3400-1, requires that a Group A test be performed quarterly on each Group A pump. The NRC staff has reviewed the Table ISTB-3400-1 requirements and has determined that due to the difficulty of wearing a SCBA when performing pump testing, the standby condition of the RHR pumps, and the isolation of the RHR system during power operation, compliance with the quarterly testing requirements is not practical. Major plant and
system modifications would be needed in order to implement the Code-required quarterly testing of the RHR pumps. These modifications would be costly and burdensome for the licensee.
As an alternative to the Table ISTB-3400-1 requirements, in its submittal dated September 1, 2004, the licensee has proposed to test RHR pumps 1-RH-P-1A and 1-RH-P-1B every cold shutdown outage and reactor refueling outage at the first practical opportunity after containment subatmospheric pressure is relieved, unless the pump has been tested within the previous 3 months. (During back-to-back cold shutdown or refueling outages, the test period remains valid for 3 months following each test, and no additional periodic testing needs to be performed within this 3-month test period.) For a cold shutdown or reactor refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with ISTB 3400-1. The NRC staff finds that the licensees proposed testing will ensure that the RHR pumps are performing adequately.
The NRC staff finds that the licensees alternative testing will provide reasonable assurance that the pumps are operationally ready. Therefore, in accordance with 10 CFR 50.55a(f)(6)(i) and for the fourth 10-year IST interval, relief is granted from the requested ASME Code requirements.
3.2 Surry, Unit 2, Revised Relief Request P-2 3.2.1 The Components for which Relief Is Requested The components affected by this relief request are RHR Pumps 2-RH-P-1A and 2-RH-P-1B for Surry, Unit 2. These RHR pumps are classified as Class 2, Group A pumps in the IST Program and function to remove decay heat from the reactor core and the RCS during plant cool down.
3.2.2 Code Requirements The licensee has requested relief from OM Code Table ISTB-3400-1. Table ISTB-3400-1 requires an inservice test be run on each Group A pump nominally every 3 months.
3.2.3 Licensees Basis for Requesting Relief The RHR pumps are located inside containment. These pumps are low pressure (600 psig design pressure) pumps that take suction from and discharge to the RCS. The RCS is maintained at 2235 psig and the containment atmosphere is maintained at subatmospheric pressure during normal operation. The RHR motor-operated suction and discharge isolation valves are interlocked with an output signal from RCS pressure transmitters that prevent the valves from being opened when the RCS pressure exceeds 460 psig. Therefore, it is not possible to test the RHR pumps during normal operation.
As the plant goes through the process of shutting down to the cold shutdown condition, the RHR pumps must be placed in service and be operable as required by the Surry TS and the RCS cooldown sequence before it is practical to test the pumps. According to Surry TS 3.1.A.1.d:
When the average reactor coolant loop temperature is less than or equal to 3500 F, the following conditions shall be met:
- 1. A minimum of two non-isolated loops, consisting of any combination of reactor coolant loops or residual heat removal loops, shall be OPERABLE except as specified below:
(a) One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is OPERABLE and in operation.
(b) During REFUELING OPERATIONS the residual heat removal loop may be removed from operation as specified in TS 3.10.A.4.
- 2. At least one reactor coolant loop or one residual heat removal loop shall be in operation, except as specified in Specification 3.10.A.4.
(TS 3.10.A.4 applies to operation limitations during refueling operations or irradiated fuel movement in the fuel building.)
At the beginning of the RCS cooldown sequence, heat is extracted from the RCS using the RCS loops and the steam generators. As the RCS temperature falls below 3500 F, the steam generators became less effective at removing heat.
Between the RCS temperatures of 3500 F and approximately 2500 F, the RHR system must be placed in service to continue the cooldown process.
However, the containment subatmospheric pressure must be maintained until the RCS temperature is below 2000 F. According to Surry TS 3.8.A.2:
The inside and outside isolation valves in the Containment Ventilation Purge System shall be locked, sealed, or otherwise secured closed whenever the Reactor Coolant System temperature exceeds 2000 F.
The containment ventilation purge system is used to relieve the containment subatmospheric condition.
Testing the RHR pumps requires a containment entry because the instrumentation used to measure flow and pressure must be monitored at the pump location. Also, vibration must be measured at the pump. Entering the containment to perform RHR pump testing when the containment is at subatmospheric pressure requires the test personnel to wear a SCBA. The SCBA comes with a full-face mask and an air tank. The mask restricts communication and vision, making readings difficult to obtain. The tank restricts range of motion and movement, making placement of the vibration probes more difficult and hazardous because the test personnel must climb up onto the pump housing to place the vibration probes. Also, personnel are under time constraints due to the limited air supply in the SCBA units, thus creating additional stress.
Being in close proximity to rotating equipment while wearing a SCBA is in itself hazardous due to the restricted field of vision, and the straps and hoses of the SCBA that may become entangled by the pump. Therefore, testing the RHR pumps while test personnel are wearing SCBAs is considered difficult, hazardous, and thus not practical. Testing should only be performed when containment is not at subatmospheric pressure. 3.2.4 Licensees Proposed Alternate Testing The licensee proposes to test these pumps during every cold shutdown outage and reactor refueling outage at the first practical opportunity after containment subatmospheric pressure is relieved, unless the pump has been tested within the previous 3 months. (During back-to-back cold shutdown or refueling outages, the test period remains valid for 3 months following each test, and no additional periodic testing needs to be performed within this 3-month test period.)
For a cold shutdown or reactor refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with ISTB 3400-1.
3.2.5 Staff Evaluation RHR pumps 2-RH-P-1A and 2-RH-P-1B are located inside the containment and are classified as Group A pumps in the IST Program. These pumps are low-pressure (600 psig design pressure) pumps that take suction from the RCS hot leg, pass flow through the RHR heat exchangers, and discharge to the RCS cold leg. These pumps are in a standby condition during power operation and only activate when the RCS is at a low pressure and the RHR system is needed. The RHR system is a low-pressure system controlled by two motor-operated valves that are interlocked with RCS pressure transmitters to prevent the motor-operated valves from being opened whenever the RCS system pressure exceeds 460 psig (Surry Updated Final Safety Analysis Report Section 9.3.3.2). This prevents testing of the RHR pumps during normal operations.
TS 3.8.A.2 requires the containment to be in a subatmospheric condition when the RCS temperature exceeds 2000 F. As such, personnel who enter the containment to perform RHR pump testing when the containment is at subatmospheric pressure are required to wear a SCBA. The SCBA restricts personnel movement and field of vision. This creates a difficult and hazardous environment for personnel conducting vibration testing of the RHR pumps.
The ASME OM Code, Table ISTB-3400-1, requires that a Group A test be performed quarterly on each Group A pump. The NRC staff has reviewed the Table ISTB-3400-1 requirements and has determined that due to the difficulty of wearing a SCBA when performing pump testing, the standby condition of the RHR pumps, and the isolation of the RHR system during power operation, compliance with the quarterly testing requirements is not practical. Major plant and system modifications would be needed in order to implement the Code-required quarterly testing of the RHR pumps. These modifications would be costly and burdensome for the licensee.
As an alternative to the Table ISTB-3400-1 requirements, in its submittal dated September 1, 2004, the licensee has proposed to test RHR pumps 2-RH-P-1A and 2-RH-P-1B every cold shutdown outage and reactor refueling outage at the first practical opportunity after containment subatmospheric pressure is relieved, unless the pump has been tested within the previous 3 months. (During back-to-back cold shutdown or refueling outages, the test period remains valid for 3 months following each test, and no additional periodic testing needs to be performed within this 3-month test period.) For a cold shutdown or reactor refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with ISTB 3400-1. The NRC staff finds that the licensees proposed testing will ensure that the RHR pumps are performing adequately. The NRC staff finds that the licensees alternative testing will provide reasonable assurance that the pumps are operationally ready. Therefore, in accordance with 10 CFR 50.55a(f)(6)(i) and for the fourth 10-year IST interval, relief is granted from the requested ASME Code requirements.
4.0 CONCLUSION
The NRC staff has determined that imposing certain ASME Code requirements is impractical.
In addition, the licensees proposed alternative provides reasonable assurance that the component is operationally ready. Therefore, the licensees request for relief, as described in Unit 1 Revised Relief Request P-2 and Unit 2 Revised Relief Request P-2, is granted pursuant to 10 CFR 50.55a(f)(6)(i) for the fourth 10-year IST interval at Surry, Units 1 and 2. The granting of relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
5.0 REFERENCES
1.
U.S. Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy, paragraph 50.55a(f)(6)(i).
2.
American Society of Mechanical Engineers, ASME Code for Operation and Maintenance of Nuclear Power Plants, 1998 Edition through 2000 Addenda, New York, NY.
3.
U.S. Nuclear Regulatory Commission, Guidance on Developing Acceptable Inservice Testing Programs, Generic Letter 89-04, through Supplement 1, April 4, 1995.
4.
U.S. Nuclear Regulatory Commission, Guidelines for Inservice Testing at Nuclear Power Plants, NUREG-1482, April 1995.
5.
U.S. Nuclear Regulatory Commission, Relief Request Reviews, NRR Office Instruction LIC-102, July 18, 2002.
6.
Letter, L.N. Hartz, Virginia Electric and Power Company, to the NRC, Fourth Interval Inservice Testing Program Revised Relief Requests P-2, dated September 1, 2004.
Principal Contributor:
S. Monarque Date: September 28, 2004
Mr. David A. Christian Virginia Electric and Power Company cc:
Ms. Lillian M. Cuoco, Esq.
Senior Counsel Dominion Resources Services, Inc.
Building 475, 5th Floor Rope Ferry Road Rt. 156 Waterford, Connecticut 06385 Mr. Richard H. Blount, II Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. O. Box 1197 Richmond, Virginia 23218 Robert B. Strobe, M.D., M.P.H.
State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 2448 Richmond, Virginia 23218 Surry Power Station Units 1 and 2 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.
Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060-6711 Mr. Jack M. Davis Site Vice President North Anna Power Station Virginia Electric and Power Company P. O. Box 402 Mineral, Virginia 23117-0402 Mr. William R. Matthews Vice President - Nuclear Operations Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060-6711