ML053080307

Emergency Amd MC8818, TS 3.5.2 ECCS Operating Temporary 7-day Completion Time

ML053080307
Person / Time
Site:	North Anna
Issue date:	11/04/2005
From:	Stephen Monarque NRC/NRR/DLPM/LPD2
To:	Christian D Virginia Electric & Power Co (VEPCO)
Monarque, S R, NRR/DLPM, 415-1544
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ML053080310	List: ML053080307
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Download: ML053080307 (9)

Text

November 4, 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:

NORTH ANNA POWER STATION, UNIT NO. 1 (NORTH ANNA 1) - ISSUANCE OF AMENDMENT ON TEMPORARY EXTENSION OF THE COMPLETION TIME FOR THE LOW-HEAD SAFETY INJECTION TRAIN A (TAC NO.

MC8818)

Dear Mr. Christian:

The Commission has issued the enclosed Amendment No. 246 to Renewed Facility Operating License No. NPF-4 for the North Anna 1. The amendment changes the Technical Speci-fications (TSs) in response to your letter dated November 3, 2005, as supplemented by letter dated November 4, 2005.

This amendment revises TS 3.5.2, ECCS-Operating, to add a note to the Completion Time that allows a temporary 7-day Completion Time in order to repair a weld leak that was discovered on the A train of the low-head safety injection pump suction piping. This amendment is issued as an emergency license amendment to allow for the repair of this piping while preventing an unnecessary plant transient and unscheduled shutdown of North Anna 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 Plant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-338

Enclosures:

1. Amendment No. 246 to NPF-4

2. Safety Evaluation cc w/encls: See next page

ML053080307 NRR-058 OFFICE NRR/LPLC/PM NRR/LPLC/LA NRR/SPWB/BC NRR/APLA/BC OGC NRR/LPLC/BC NAME SMonarque MOBrien SSun(A) MStutzke(A) SBrock LOlshan for EMarinos DATE 11/4/2005 11/4/05 11/3/2005 11/3/2005 11/4/05 11/4/05

VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-338 NORTH ANNA POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 246 Renewed License No. NPF-4

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Virginia Electric and Power Company et al.,

(the licensee) dated November 3, 2005, as supplemented by letter dated November 4, 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 2.C.(2) of Renewed Facility Operating License No. NPF-4 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 246, are hereby incorporated in the 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 is applicable until the A train of the Unit 1 Low-Head Safety Injection system is returned to operable status or until November 9, 2005, at 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br />, whichever occurs first.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA LOlshan for/

Evangelos Marinos, Chief Plant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 4, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 246 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-4 DOCKET NO. 50-338 Replace the following page of the Appendix "A" Technical Specifications with the enclosed page as indicated. The revised page is identified by amendment number and contains a vertical line indicating the area of change.

Remove Page Insert Page 3.5.2-1 3.5.2-1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 246 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-4 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NO. 1 DOCKET NO. 50-338

1.0 INTRODUCTION

By letter dated November 3, 2005, as supplemented by letter dated November 4, 2005,Virginia Electric and Power Company (the licensee) submitted a request for an emergency amendment to the North Anna Power Station, Unit 1 (North Anna 1), Renewed Facility Operating License No. NPF-4. The amendment would revise Technical Specification (TS) 3.5.2, ECCS-Operating, by adding a note to the Completion Time that allows for a temporary 7-day allowed outage time when one or more emergency core cooling system (ECCS) trains are inoperable. The licensee had requested this emergency amendment in order to provide more time to repair a leak on the A train to the low-head safety injection (LHSI) pump suction piping.

On November 2, 2005, at 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br /> the licensee discovered a leak on the North Anna 1, LHSI pump suction piping. As such, LHSI pump 1-SI-P-1A was declared inoperable. Since TS 3.5.2 Condition A required the A train to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee had to either complete the repair work within this 72-hour time limit or shut down North Anna 1.

Because it needed additional time to complete the repairs beyond the 72-hour limit, the licensee requested that the Nuclear Regulatory Commission (NRC) staff process this submittal as an emergency amendment so as to avoid the risks from plant shutdown and startup evolutions.

2.0 REGULATORY EVALUATION

The NRC staff has identified the applicable regulatory requirements for which the NRC staff based its acceptance. The requirements that the NRC staff considered in its review are listed below:

Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR) requires that all operating licenses for nuclear reactors must include the TS for the subject plant. Limiting conditions for operation (LCOs) along with required Completion Times (CTs) are specified for each system that is included in the TS. The licensee submitted risk-informed information to support the proposed license amendment.

Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, and RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, were used since the licensee requested a limited temporary extension to the Required Action Completion Time for the A train of the LHSI.

The Maintenance Rule, 10 CFR 50.65(a)(4), requires licensees to perform assessments before conducting maintenance activities on structures, systems, and components (SSC) that are covered by the Maintenance Rule and to manage any increase in risk that may result from the proposed activities.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes The specific changes requested by the licensee would revise the CT of Required Action A.1 of TS 3.5.2, ECCS-Operating, from the current 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a temporary 7-day time period for the North Anna 1, A train of the LHSI system.

3.2 Risk Assessment Evaluation In evaluating the risk information submitted by the licensee, the NRC staff followed the three-tiered approach documented in RG 1.177.

The first tier addresses the assessment of the risk impact of the proposed change for comparison to acceptance guidelines consistent with the NRCs Safety Goal Policy Statement, as documented in RG 1.174. In addition, the first tier aims at ensuring that the plant risk does not increase unacceptably during the period when the equipment is taken out of service.

The second tier addresses the need to preclude potentially high-risk configurations that could result if equipment, in addition to that associated with the change, is taken out of service simultaneously.

The third tier addresses the establishment of an overall configuration risk management program for identifying risk-significant configurations resulting from maintenance or other operational activities and taking appropriate compensatory measures to avoid such configurations.

3.3 Basis and Quality of Risk Assessment The licensee used its Probabilistic Risk Assessment (PRA) model and appropriate conservative assumptions to assess the risk increase associated with operation at power for a period of 7 days without an operable LHSI pump train A. The risk considerations included maintaining defense-in-depth and quantifying the PRA to determine the change in core damage frequency (CDF) and large early release frequency (LERF) as a result of the proposed temporary 7-day allowed outage time (AOT) for the LHSI pump train A. Also, the licensee maintained the continuous online risk management program to control the performance of other risk-significant activities during the weld leak repair with consideration of specific compensatory measures to minimize risk.

The dominant accident sequences contributing to the assessed risk increase include the occurrence of conditions due to the unavailability of and demand for the use of the LHSI pump train A. The assumption of the accident analysis and design basis for North Anna 1, demands maintaining at least one train of the LHSI System operable during accident conditions in the event of an assumed loss-of-coolant accident (LOCA).

TS LCO 3.5.2 requires two ECCS trains to be operable such that the flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains. TS 3.5.2, Action A, states that with one or more ECCS trains inoperable, the inoperable ECCS train must be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Under the proposed change for a 7-day AOT, all design-basis accident ECCS requirements can be met with one operable LHSI pump train without a single failure.

The NRC staff evaluated the quality of the PRA model, major assumptions, and data used in the risk assessment. This evaluation compared the applicable findings from the NRC staffs review of the PRA (developed as part of the licensees individual plant evaluation) with the NRCs Standardized Plant Analysis Risk Model (SPAR), Version 3.0.1, for North Anna 1, as well as findings from similar evaluations of similar plants. The NRC staff found the quality of the PRA, its major assumptions, and data used in the risk assessment to be acceptable.

3.4 Risk Impact of the Proposed Change (Tier 1)

An acceptable approach to risk-informed decision making is to show that the proposed change to the licensing basis meets several key principles. One of these principles is to show that the proposed change results in a small increase in risk in terms of CDF and LERF, and is consistent with the NRCs Safety Goal Policy Statement. Acceptance guidelines for meeting this principle are presented in RG 1.174. Therefore, in accordance with the RG 1.174 guidelines, the licensees proposed change to allow for a temporary AOT of 7 days for the LHSI pump train A results in an acceptable increase in risk, which is small and consistent with the NRCs Safety Goal Policy Statement.

The licensee used its PRA model for North Anna 1 to calculate risk increases due to the proposed temporary AOT of 7 days. Both the incremental conditional core damage probability (ICCDP) and the incremental conditional large early release probability (ICLERP) were assessed. These quantities are a measure of the increase in probability of core damage and large early release, respectively, during a single outage assumed to last for the entire duration allowed by the proposed TS change. Based on the proposed 7-day AOT, the results are:

ICCDP: 4.1E-7 with common cause vulnerability, and 1.9E-7 without common cause vulnerability.

ICLERP: 2.9E-9 with common cause vulnerability, and 2.7E-9 without common cause vulnerability.

The acceptance guidance criteria are 5.0E-7 for ICCDP and 5.0E-8 for ICLERP, respectively, as outlined in RG 1.177 and RG 1.174 for permanent changes. The guideline criteria were based on the baseline CDF being smaller than 1.0E-4/reactor-year. For a temporary change, the acceptance guidance criteria are higher than that of a permanent change. Thus, the ICCDP (4.1E-7) and ICLERP (1.9E-7) are within the acceptable values of temporary increases. The proposed 7-day AOT will avoid transitional risk associated with the plant shutdown.

The proposed 7-day AOT is temporary only. The increase in CDF is numerically equal (approximately) to the assessed ICCDP value. Similarly, the increase in LERF is numerically

equal (approximately) to the assessed ICLERP value. The baseline CDF will be changed for the 1-year period due to the proposed temporary 7-day AOT.

The mean CDF of North Anna 1 will increase by no more than 4.1E-7/year (during the 1-year period that the proposed change will be implemented).

The mean LERF of North Anna 1 will increase by no more than 2.9E-9/year (during the 1-year period that the proposed change will be implemented).

According to the guidelines of RG 1.174, the estimated increases in the mean values of CDF and LERF are small and of low risk significance.

The impact of external events was qualitatively considered in the analysis. For the proposed duration of 7 days, the probability of having earthquakes or other natural events is small. The risk of potential fire hazards can be minimized during this extended period under the proposed compensatory measures by reducing or even eliminating certain maintenance activities on SSCs that impact fire protection systems.

3.5 Avoidance of High-Risk Plant Configurations (Tier 2)

The licensee has a Maintenance Rule (a)(4) program for complying with 10 CFR 50.65(a)(4) that fully satisfies the guidance in RG 1.177 for avoidance of high-risk plant configurations. The licensees 10 CFR 50.65(a)(4) program requires the performance of full model PRA analyses of all planned maintenance configurations at power using a PC-based Safety Monitor tool. The PRA model in the Safety Monitor tool is a comprehensive, component level, core damage and large early release model.

The licensee also used its PRA to identify dominant contributing sequences and associated cutsets to the estimated increase in risk, as well as major contributing failures and human errors. Insights from the risk assessment were used in identifying the six compensatory measures to avoid plant configurations or conditions that may lead to significant risk increases during implementation of the proposed 7-day AOT. The NRC staff finds that the proposed measures, as well as their proposed implementation, are adequate for preventing plant configurations or conditions that may increase risk significantly.

3.6 Risk-Informed Configuration Risk Management (Tier 3)

The intent of the risk-informed configuration risk management is to ensure that plant safety is maintained and monitored during an extended outage. A formal commitment to maintain a configuration risk management program is required on the part of a utility prior to implementation of a risk-informed TS whenever such TS is entered and risk-significant components are taken out of service. The licensee has programs in place for North Anna 1 to comply with 10 CFR 50.65(a)(4) in order to assess and manage risk from proposed maintenance activities. These programs can support the licensees decision making regarding the appropriate actions to control risk whenever a risk-informed TS is entered.

3.7 Deterministic Evaluation In addition to the probability basis supporting the proposed North Anna 1 LHSI A-train pump emergency TS change, the North Anna 1 ECCS design provides further assurance that the LOCA consequences reported under the North Anna 1 LOCA design analyses would continue to bound those postulated to occur during the proposed allowed outage for the ECCS LHSI A train.

The design-basis LOCA analyses assume the operation of only one train of ECCS (with a single failure that would disable the other train). By regulatory precedent, the single failure of the redundant train is not assumed during the AOT. Therefore, the North Anna 1 design license basis LOCA analyses applies directly to the proposed AOT.

Even if a beyond-design-basis failure of the redundant LHSI pump were postulated, such that no trains of LHSI were available, it is highly likely that core damage would be arrested for most postulated large-break (LB)LOCA events for the following reasons:

a. The North Anna 1 LBLOCA analyses assume the operation of only one train of ECCS, including one LHSI and one high-head safety injection (HHSI). In reality, the HHSI pumps of both trains of ECCS can deliver approximately 40 percent as much ECCS flow as one LHSI pump would deliver in an LBLOCA scenario at low system pressures.

North Anna 1 has three HHSI pumps, but can only power two HHSI pumps concurrently because of EDG load limitations. In the event that the redundant LHSI pump fails, manual interlocks could be defeated to power the third HHSI pump, which would provide approximately another 20 percent of one LHSI pump flow. In addition, with further manual action, approximately another 60 percent of one LHSI pump flow can be delivered through a unit-to-unit cross-tie between North Anna 2 and North Anna 1 HHSI systems, and a swing HHSI that also can be started manually. This total flow rate approximately equals one LHSI pump and one HHSI pump at low system pressures existing during an LBLOCA. It is expected that the total flow rate from these pumps would be sufficient to arrest core damage for most postulated LBLOCA events.

b. North Anna 1 has a cross-tie from the recirculation spray pump system to the LHSI train that can provide flow to the LHSI system to provide long-term cooling.

c. The small-break LOCA analysis is not likely to be affected.

The NRC staff has confirmed that the recirculation spray pump discussed in b. above can provide flow to the suction of the HHSI system pump(s) during the ECCS recirculation mode.

None of the equipment mentioned above, or the diesels and other equipment necessary to support that equipment, may be taken out of service for maintenance during the allowed outage. The licensee committed to take these compensatory measures in its letter dated November 3, 2005.

3.8 Summary Based on the availability and reliability of the other ECCS train and the cross-tie capability of ECCS trains from North Anna 2, and the fact that the licensee has taken compensatory measures limiting activities that have the potential to result in a plant transient or adversely impact the availability of the other ECCS trains, the NRC staff finds that there is no undue risk to public health and safety associated with granting the temporary 7-day AOT.

The NRC staff has completed its review and has determined that the risk impact of the proposed 7-day CT for the Train A LHSI as estimated by ICCDP and ICLERP and changes to CDF and LERF is consistent with the acceptance guidelines specified in RG 1.174 and RG 1.177.

Additionally, the NRC staff determines that the licensees Tier 3 Risk-Informed Configuration Risk Management Program is capable of adequately assessing the activities being performed to ensure that high-risk plant configurations do not occur and/or compensatory measures are implemented if a high-risk plant configuration or condition should occur. As such, the licensees program meets RG 1.177.

The licensees configuration risk management program under 10 CFR 50.65(a)(4) manages plant risk when the Train A LHSI is out of service. The Train A LHSI availability will be monitored and assessed under the Maintenance Rule to confirm that performance continues to be consistent with the assumptions used in the analysis for extending the CT.

Based on the above, the NRC staff has concluded that the proposed temporary extension of the AOT for the A train of the LHSI System is acceptable.

4.0 STATEMENT OF EMERGENCY CIRCUMSTANCES Section 50.91 of 10 CFR Part 50 provides special exceptions for the issuance of amendments when the usual 30-day public notice cannot be met. One type of special exception is an emergency. Specifically, 10 CFR 50.91(a)(5) provides that where the NRC finds that an emergency situation exists, in that failure to act in a timely way would result in a shutdown of a nuclear power plant, it may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or public comment. In this situation, the NRC will publish a notice of issuance under 10 CFR 2.106, providing for opportunity of a hearing and for public comment after issuance.

The licensee requested that the NRC issue this amendment on an emergency basis to allow North Anna 1 to continue to operate at full power. On November 2, 2005, at 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br />, the licensee discovered a boric acid substance on the Train A LHSI pump suction piping. During a subsequent inspection of the piping, the licensee identified an active leak. The licensee then declared LHSI pump 1-SI-P-1A to be inoperable on November 2, 2005, at 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br />.

Because the equipment failure was unexpected, the licensee could not have anticipated the need for a license amendment that would allow for a 30-day comment period. Additionally, the proposed amendment involves no significant hazards as specified in 10 CFR 50.92.

On the basis of the above discussion, the NRC staff has determined that emergency circumstances exist and that the licensee used its best efforts to make a timely application and could not avoid the emergency situation.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commissions regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from any previously evaluated; or, (3) Involve a significant reduction in a margin of safety.

The following analysis was provided by the licensee in its November 3, 2005, letter.

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes do not alter any plant equipment or operating practices in such a manner that the probability of an accident is increased. The proposed changes will not alter assumptions relative to the mitigation of an accident or transient event.

The ICCDP with and without potential common cause vulnerability is 4.14E-7 and 1.92E-7 respectively. The ICLERP with and without potential common cause vulnerability is 2.88E-9 and 2.68E-9, respectively. These results are well below the RG 1.174 limits of 1E-6 for ICCDP and 1E-7 for ICLERP. They are also below the RG 1.177 single event limits of 5E-7 for ICCDP and 5E-8 for ICLERP.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

The impact on safety margins is discussed in section 5.3 of this license amendment request. The systems design and operation are not affected by the proposed changes. The safety analysis acceptance criteria are not altered by the proposed changes.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

The NRC staff has reviewed the licensees analysis and, based on this review, it appears that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff determines that the proposed amendment involves no significant hazards consideration.

6.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Virginia State official was notified of the proposed issuance of the amendment. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 amendment involves 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 made a final no significant hazards finding with respect to this amendment.

Accordingly, the amendment meets 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 amendment.

8.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that (1) the amendment does not (a) involve significant increase in the probability or consequences of an accident previously evaluated or, (b) create the possibility of a new or different kind of accident from any previously evaluated or, (c) involve a significant reduction in a margin of safety and therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commissions regulations, and (4) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: S. Monarque Date: November 4, 2005

North Anna Power Station, Unit 1 cc:

Mr. C. Lee Lintecum Mr. Jack M. Davis County Administrator Site Vice President Louisa County North Anna Power Station Post Office Box 160 Virginia Electric and Power Company Louisa, Virginia 23093 Post Office Box 402 Mineral, Virginia 23117-0402 Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dr. Robert B. Stroube, MD, MPH Dominion Resources Services, Inc. State Health Commissioner Building 475, 5 th floor Office of the Commissioner Rope Ferry Road Virginia Department of Health Waterford, Connecticut 06385 Post Office Box 2448 Richmond, Virginia 23218 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Old Dominion Electric Cooperative 4201 Dominion Blvd.

Glen Allen, Virginia 23060 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, Virginia 23117