ML052490134
| ML052490134 | |
| Person / Time | |
|---|---|
| Site: | Surry |
| Issue date: | 09/15/2005 |
| From: | Stephen Monarque NRC/NRR/DLPM/LPD2 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Monarque S | |
| Shared Package | |
| ML052490161 | List: |
| References | |
| TAC MC4412, TAC MC4413 | |
| Download: ML052490134 (16) | |
Text
September 15, 2005 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 - ISSUANCE OF AMENDMENTS TO REVISE THE ADMINISTRATIVE CONTROLS SECTION (TAC NOS.
Dear Mr. Christian:
The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 244 to Renewed Facility Operating License No. DPR-32 and Amendment No. 243 to Renewed Facility Operating License No. DPR-37 for the Surry Power Station, Units 1 and 2, respectively.
The amendments change the Technical Specifications (TS) in response to your application dated September 15, 2004, as supplemented by letter dated May 5, 2005.
These amendments revise the TS for Surry Power Station, Units 1 and 2 to support the implementation of the proposed Topical Report DOM-QA-1, Dominion Nuclear Facility Quality Assurance Program Description. The implementation of this topical report would create a common quality assurance program for North Anna, Surry, and Millstone Power Stations. The review of these proposed amendments was requested to be done in concert with the review of the Topical Report. The Topical Report was submitted to the NRC staff for review on August 24, 2004, and supplemented by letter dated May 5, 2005. By letter dated September 9, 2005, the NRC staff issued Topical Report DOM-QA-1.
A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Stephen Monarque, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosures:
- 1. Amendment No. 244 to DPR-32
- 2. Amendment No. 243 to DPR-37
- 3. Safety Evaluation cc w/encls: See next page
ML052940134 NRR-058 OFFICE PDII-1/PM PDII-2/LA SRXB/SC IPSB/IROB/SC IROB/SC OGC PDII-1/SC NAME SMonarque CHawes JNakoski DThatcher TBoyce JHull EMarinos DATE 09/12/2005 09/12/2005 08/19/2005 07/20 /2005 08/26/2005 08/13/2005 9/13/2005
SUBJECT:
SURRY POWER STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE THE ADMINISTRATIVE CONTROLS SECTION (TAC NOS.
DATED: September 15, 2005 DISTRIBUTION:
PUBLIC PDII-1 R/F RidsNrrDlpmLpdii (EHackett)
RidsNrrDlpmLpdii1 (EMarinos)
RidsNrrPMSMonarque (Hard Copy)
RidsNrrLACHawes (Hard Copy)
RidsOcgRp RidsAcrsAcnwMailCenter GHill (4 Hard Copies)
T. Boyce RidsRgn2MailCenter (KLandis)
RidsNrrDlpmDpr
VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-280 SURRY POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 244 Renewed License No. DPR-32 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Virginia Electric and Power Company (the licensee) dated September 15, 2004, as supplemented by letter dated May 5, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-32 is hereby amended to read as follows:
(B)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 244, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 6 months of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Evangelos C. Marinos, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: September 15, 2005
VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-281 SURRY POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 243 Renewed License No. DPR-37 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Virginia Electric and Power Company (the licensee) dated September 15, 2004, as supplemented by letter dated May 5, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-37 is hereby amended to read as follows:
(B)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 243, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 6 months of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Evangelos C. Marinos, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: September 15, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 244 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-32 LICENSE AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-37 DOCKET NOS. 50-280 AND 50-281 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages 2.1-2 2.1-2 2.2-1 2.2-1 6.1-1 6.1-1 6.1-2 6.1-2 6.1-3 6.1-3 6.2-1 6.2-1 6.3-1 6.3-1 6.4-3 6.4-3 6.4-4 6.4-4 6.8-1 6.8-1 6.8-2 6.8-2
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 244 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-32 AND AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281
1.0 INTRODUCTION
By letter dated September 15, 2004 (Reference 2), as supplemented by letter dated May 5, 2005, (Reference 3), Virginia Electric and Power Company (the licensee) submitted a request to revise the Administrative Controls Section technical specifications (TS) for the Surry Power Station, Units 1 and 2. These proposed TS changes are required to support the licensees implementation of Topical Report DOM-QA-1, Dominion Nuclear Facility Quality Assurance Program Description (NFQAPD). The NRC staff approved this Topical Report on September 9, 2005. In addition, the licensee has proposed to slightly reword the Administrative Controls TS for Surry Power Station to establish consistency with North Anna Power Station, to eliminate descriptions of the onsite and offsite safety review organizations, and to relocate the required actions for Safety Limit violations. The proposed changes are consistent with the intent of NUREG-1431, Standard Technical Specifications Westinghouse Plants.
The supplement dated May 5, 2005, provided clarifying information only and did not change the Nuclear Regulatory Commission staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 7, 2004 (69 FR 70723) or expand the scope of the original application.
2.0 REGULATORY EVALUATION
The Commissions regulatory requirements related to the content of TS are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.36. This regulation requires that the TS include items in five specific categories. These categories include 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation, 3) surveillance requirements, 4) design features, and 5) administrative controls.
Specifically, 10 CFR 50.36(c)(5) describes administrative controls as provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of each facility in a safe manner. The specific content of the administrative controls section of the TS is, therefore, that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the NRC staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from administrative controls.
The NRC staff used the following guide to evaluate the licensees request.
NUREG-1431, Standard Technical Specifications Westinghouse Plants Administrative Letter 95-06, Relocation of Technical Specification Administrative Controls Related to Quality Assurance,
3.0 TECHNICAL EVALUATION
In its letter dated August 24, 2004 (Reference 1), as supplemented by letter dated May 5, 2005, the licensee submitted Topical Report DOM-QA-1 for NRC staff review and approval in accordance with the provisions of 10 CFR 50.54(a)(4). By letter dated September 9, 2005, the NRC staff issued Topical Report DOM-QA-1. This quality assurance (QA) topical report would replace and consolidate the current site-specific quality assurance programs for North Anna, Surry, and Millstone Power Stations. As such, the licensee has proposed administrative TS changes to support implementation of the proposed NFQAPD at Surry Power Station.
Administrative (non-technical) modifications to TS are intended to incorporate human factors principles into the form and structure of the TS so plant operations personnel can more easily and effectively use them. These modifications are editorial in nature or involve the reorganization or reformatting of TS requirements without affecting technical content or operational restrictions.
The following table lists the proposed administrative changes associated with the proposed NFQAPD. The table provides a summary description of the administrative change.
Plant TS Section Summary Surry 1 and 2 6.0 Editorial changes and renumbered as discussed below.
Surry 1 and 2 6.1 Changes title of section from Organization, Safety, and Operation Review to Responsibility, Organization, and Qualifications.
Changes Specification to Responsibility and reformatted -
now 6.1.1.
Surry 1 and 2 6.1.A Reformatted and renumbered to 6.1.1.1. Replaces Site Vice President with plant manager. Adds unit to overall operation. This proposed change identifies the generic title of the person with the responsibility of overall unit operation and requires delegation of succession to this responsibility be performed in writing.
Plant TS Section Summary Surry 1 and 2 6.1.A Added 6.1.1.2. Adds identification of the Shift Manager as being responsible for the control room command function consistent with North Anna TS and NUREG-1431.
Surry 1 and 2 6.1.A Added titles 6.1.2, Organization and 6.1.2.1, Onsite and Offsite Organizations.
Added s to organization and changed facility to unit.
Surry 1 and 2 6.1.A.1 Renumbered to 6.1.2.1.a. The specified location of the organization requirements is changed to reference the QA Program rather than the Updated Final Safety Analysis Report.
Added requirement that plant-specific titles are to be documented in the appropriate administrative documents.
Surry 1 and 2 6.1.A.2 Renumbered to 6.1.2.1.b. Changed the specific title of Site Vice President to the generic title plant manager consistent with North Anna TS and NUREG-1431.
Surry 1 and 2 6.1.A.3 Renumbered to 6.1.2.1.c. Changed the specific title of Vice President - Nuclear Operations to the generic title a specified corporate officer consistent with North Anna TS and NUREG-1431.
Surry 1 and 2 6.1.A.4 6.1.A.5 Renumbered to 6.1.2.1.d. Combined and reworded the current TSs 6.1.A.4 and 6.1.A.5 into new TS 6.1.2.1.d which is consistent with NUREG-1431.
Surry 1 and 2 6.1.B Added title 6.1.2.2, Unit Staff.
Changed facility to unit staff and conform to to include.
Changes are consistent with NUREG-1431.
Surry 1 and 2 6.1.B.1 6.1.B.2 Combined the current TS 6.1.B.1 and 6.1.B.2 into new TS 6.1.3.1.
Changed facility to unit and replaces except for: with Exceptions to this requirement are specified in the Quality Assurance Program. Replaced Shift Supervisor with Shift Manager, replaced Assistant Shift with Unit, deleted Nuclear from Control Room Operator Nuclear, and changed the specific title Shift Technical Advisor to the generic title the individual providing advisory technical support to the unit operations shift crew.
Plant TS Section Summary Surry 1 and 2 6.1.B.1 Added TS 6.1.3.2 that states: For the purposes of 10 CFR 55.4, a licensed Senior Reactor Operator and a licensed Reactor Operator are those individuals who, in addition to meeting the requirements of TS 6.1.3.1 perform the functions described in 10 CFR 50.54(m). This change clarifies the relationship between individuals referenced in 10 CFR 55.4 and 10 CFR 50.54(m) and is consistent with NUREG-1431.
Surry 1 and 2 6.1.B.1.b 6.1.B.1.c Combined 6.1.B.1.b and 6.1.B.1.c into new TS 6.1.2.2.d.
Changed specific title Superintendent Operations to operations manager and Supervisor Shift Operations to Supervisor Nuclear Shift Operations.
Surry 1 and 2 6.1.B.1.a 6.1.B.3 Deleted the statements that The Superintendent -
Radiological Protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and Also, a retraining and replacement training program for non-licensed facility staff shall meet or exceed the recommendations of Section 5 of ANS 3.1 (12/79 Draft)*. The associated footnote is also deleted. These requirements are covered by the statement Exceptions to this requirement are specified in the QA Program.
Deleted the statement that The Manager - Nuclear Training is responsible for ensuring that retraining and replacement training programs for the licensed facility staff meet or exceed the requirements of 10 CFR 55.59(c) and 55.31(a)(4). This requirement is covered by the existing regulations. These changes are consistent with NUREG-1431.
Surry 1 and 2 6.1.B.4 Renumbered to 6.1.2.2.a.
Surry 1 and 2 6.1.B.5 Renumbered to 6.1.2.2.b. Changed health physics technician to radiation protection technician. Added the sentence The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the position. This change is consistent with NUREG-1431.
Surry 1 and 2 6.1.B.6 Renumbered to 6.1.2.2.c.
Surry 1 and 2 6.1.B.7 6.1.B.8 Reformatted. Deleted sections deleted.
Surry 1 and 2 6.1.B.9 The radiation protection technician requirement is being deleted and incorporated into the new TS 6.1.2.2.b.
Surry 1 and 2 6.1.B.10 Renumbered to 6.1.2.2.e.
Plant TS Section Summary Surry 1 and 2 Table 6.1-1 Changed SS to SM, combined table and table information continuation onto one page, replaced Shift Supervisor with Shift Manager, and changed the specific title Shift Technical Advisor to the generic title the individual providing advisory technical support to the unit operations shift crew.
In the last paragraph of table information, changed Shift Technical Advisor to technical advisor and added SRO or to RO license.
The NRC staff reviewed the administrative and editorial changes proposed by the licensee.
The NRC staff confirmed that the appropriate information, discussed above, was captured correctly in the proposed QA Program. The NRC staff concludes that the proposed TS changes satisfy the guidance with regard to the content of TS and conform to the model provided in NUREG-1431, do not result in any change in operating requirements, and are consistent with the Commission's regulations.
3.2 Administrative Changes Associated with Violation of the Safety Limit The Surry TS are custom TS that are not consistent with NUREG-1431 content and format. As such, the safety limits for Surry, required by 10 CFR 50.36(c)(1)(i)(A), are listed in Section 2 of the TS, while the required action if a safety limit is violated is located in Section 6.3 of the TS.
The licensee has proposed to relocate the required action for when a safety limit is violated from TS 6.3, Action to be Taken if a Safety Limit is Exceeded to TS 2.1, Safety Limit, Reactor Core and TS 2.2, Safety Limit, Reactor Coolant System Pressure. Specifically, the licensee proposed to add the statement In the event the Safety Limit is violated, the facility shall be placed in at least HOT SHUTDOWN within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to TS 2.1.B and TS 2.2.B and delete the required action from TS 6.3. The proposed administrative change relocates the required action to the safety limits in TS 2.1 and 2.2 and is consistent with the requirement to shutdown the reactor if a safety limit is exceeded stated in 10 CFR 50.36(c)(1)(i)(A). Therefore, the NRC staff finds the proposed change to be acceptable. In addition, the proposed relocation of the required action is consistent with the intent of NUREG-1431.
The licensee has proposed to delete TS 6.3.A.2 through 6.3.A.4 reporting requirements, which provide additional required actions regarding reporting the violation of a safety limit. 10 CFR 50.36(c)(1)(i)(A) states if a safety limit is exceeded the licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for the corrective action taken to preclude recurrence. In addition, 10 CFR 50.72 and 50.73 provide further requirements for Commission notification and licensee event reports when any plant shutdown is required by TS. Therefore, the NRC staff concludes that the proposed deletion of the TS 6.3.A.2 through 6.3.A.4 is acceptable because the required actions are captured in existing regulations.
3.3 Administrative Changes Associated with Safety Committees The licensee has proposed to delete TS 6.1.C which provides the function, composition, use of alternatives, meeting frequency, quorum, responsibilities, authority, and record requirements for the Station Nuclear Safety and Operating Committee (SNSOC) and the Management Safety Review Committee (MSRC). The licensee has also proposed to delete 6.2.A.2, 6.4.C, and 6.4.G which provides additional responsibilities for SNSOC regarding review of reportable events, procedures, and changes to procedures in cases of emergency. The specific details of how the SNSOC and MSRC are organized and conduct their functions are contained in Appendix B of the proposed NFQAPD. Relocation of SNSOC and MSRC requirements to the NFQAPD allows these requirements to be controlled by the 10 CFR 50.54(a) and 10 CFR 50.59 change process rather than the TS amendment process. Consistent with the guidance provided in Administrative Letter 95-06, the NRC staff concludes that sufficient regulatory controls exist under 10 CFR Part 50, Appendix B for the implementation of the functions specified in the NFQAPD, and sufficient controls exist under 10 CFR 50.54(a) for subsequent changes to the NFQAPD such that moving these requirements to the NFQAPD is acceptable.
The licensee has also proposed to delete the SNSOC review function from TS 6.8.A.2 and 6.8.B.2. In addition, the Site Vice President is changed to plant manager in TS 6.8.A.2 and 6.8.B.2. These administrative changes are also acceptable.
In conclusion, the above relocated requirements for SNSOC and MSRC related to administrative controls are not required to be in TS under 10 CFR 50.36 and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. Accordingly, the NRC staff has concluded that these requirements may be relocated from the TS to the NFQAPD.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of the amendments. The State official had no comment.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 70723). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
1.
David A. Christian, DNC and Dominion, to the U.S. NRC, Virginia Electric and Power Company, Dominion Nuclear Connecticut, Inc., Surry Power Station Units 1 and 2 and ISFSI, North Anna Power Station Units 1 and 2 and ISFSI, Millstone Power Station Units 1, 2 and 3 and ISFSI, Associated Radioactive Material Packages, Nuclear Facility Quality Assurance Program Description, Topical Report DOM-QA-1, Revision 0," August 24, 2004. ADAMS Accession Nos. ML042470015, ML042470017 through ML042470021 2.
Hartz, L. N., Virginia Electric and Power Company (Dominion), to USNRC, Virginia Electric and Power Company Surry Power Station Units 1 and 2 North Anna Power Station Units 1 and 2 Proposed Technical Specification Change Administrative Controls Changes, September 15, 2004. ADAMS Accession No. ML042600290 3.
Grecheck, E. S., DNC and Dominion, to the U.S. NRC, Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone Power Station Units 1, 2, and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, Response to Requests for Additional Information on Nuclear Facility Quality Assurance Program Description and Associated Proposed Technical Specifications Changes, May 5, 2005.
ADAMS Accession Nos. ML051300513, ML051300539, ML051300544, ML051300548, ML051300556, and ML051300559 Principal Contributors:
R. Pelton K. Kavanagh Date: September 15, 2005
Surry Power Station, Units 1 & 2 cc:
Ms. Lillian M. Cuoco, Esq.
Senior Counsel Dominion Resources Services, Inc.
Building 475, 5th Floor Rope Ferry Road Waterford, Connecticut 06385 Mr. Donald E. Jernigan 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 Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 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