NORTH ANNA POWER STATION RESTART ACTION PLAN (PUBLIC)* 

Initial Action Plan: 10/7/2011 

Lead Division: DORL 

Supporting Divisions: DE, DSS, DLR, DIRS, DPR, and DRA 

Supporting Offices: Region II, NMSS, NRO, RES, and OGC 

Docket Nos. 50-338 and 50-339 

TAC Nos. ME7254 and ME7255 

GOAL

The goal of this action plan is to identify and coordinate the agency’s ongoing initiatives related 

to the North Anna Power Station (NAPS) restart decision as a result of the recent seismic event 

on August 23, 2011. 

BACKGROUND

On August 23, 2011, with NAPS Units 1 and 2 operating at 100 percent, the site experienced a 

seismic event (from a Magnitude 5.8 earthquake reported at the epicenter by the U.S. 

Geological Survey) in Mineral, Virginia, approximately 10 miles from NAPS. The earthquake 

caused a series of reactor trip signals to both the Unit 1 and Unit 2 reactors, as well as a loss of 

offsite power to the station. Four emergency diesel generators and one alternate AC diesel 

generator were activated to provide onsite power. Separately, the 2H Emergency Diesel 

Generator developed a coolant leak and was subsequently manually secured. A Root Cause 

Evaluation of the leak was performed. Subsequent analysis indicated that the spectral and 

peak ground accelerations for the Operating Basis and Design Basis Earthquakes (OBE and 

DBE, respectively) for NAPS were exceeded. 

Both NAPS units are currently shutdown. Unit 1 currently has fuel in the reactor, whereas Unit 2 

entered a refueling outage which was planned to begin in mid-September. At the time this plan 

was being developed, no significant equipment damage to safety-related systems (including 

Class 1 structures) has been identified through site walkdowns nor has equipment degradation 

been detected through plant performance and surveillance testing following the earthquake. 

REGULATORY CONSIDERATIONS

In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Appendix A to 

Part 100, Paragraph V(a)(2), a nuclear power plant is required to be shutdown when the 

vibratory ground motion exceeds that of the Operating Basis Earthquake. In addition, the 

regulations state that “prior to resuming operations, the licensee will be required to demonstrate 

to the Commission that no functional damage occurred to those features necessary for 

continued operation without undue risk to the health and safety of the public.” It is also noted 

that the NAPS Updated Final Safety Analysis Report (UFSAR), Section 3.7.4.6 commits to 

demonstrate to the NRC that no functional damage has occurred to those features necessary 

for continued operation without undue risk to the health and safety of the public. 

*Updated November 21, 2013, only to reflect completion dates noted in the table. 
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Licensee actions are underway to inspect, evaluate, test, and repair if necessary, the systems, 

and components to ensure they are capable of performing their required functions. The 

licensee is performing plant walkdowns in accordance with Regulatory Guide (RG) 1.167, 

“Restart of a Nuclear Power Plant Shutdown by a Seismic Event,” which endorses the Electric 

Power Research Institute’s (EPRI’s) NP-6695, “Guidelines for Nuclear Plant Response to an 

Earthquake,” with conditions. 

The staff’s assessment will utilize the guidance provided in NRC’s RG 1.167, which endorses 

the EPRI guidelines. In addition, the staff will utilize the International Atomic Energy Agency 

(IAEA) Safety Report No. 66, “Earthquake Preparedness and Response for Nuclear Power 

Plants,” inform its reviews. It should be noted that the IAEA safety report acknowledges the 

prospect that hidden damage (especially after an SSE) is a possibility. In addition, the staff will 

utilize its expertise and knowledge to review areas beyond the RG 1.167 and EPRI guideline. 

Since the August 23, 2011, earthquake produced ground motion that exceeded the plant’s SSE, 

the staff will review the licensee’s activities, as documented in its September 17, 2011, submittal 

as well as any supplemental information, in accordance with 10 CFR Part 100, Appendix A. 

Specific actions are identified in the table below, entitled, “North Anna Power Station Restart 

Action Plan Milestones.” 

The licensee may use a variety of approaches to demonstrate that no functional damage 

occurred as a result of the earthquake. For example, the licensee may analyze and evaluate 

the actual earthquake to show that structures, systems, and components (SSCs) were not 

adversely affected. In lieu of analyses/evaluations or in combination with them, the licensee 

may inspect and/or test various SSCs to demonstrate that there was no functional damage. 

The licensee’s submittals for demonstrating no functional damage will be reviewed by the NRC 

staff to confirm that the licensee’s analyses, evaluations, inspections, or tests, are in 

accordance with RG 1.167, which endorses the EPRI NP-6695 guidelines, are adequate for 

demonstrating that no functional damage has occurred to those features necessary for 

continued operation, without undue risk to the health and safety of the public as a result of the 

earthquake (as required by Appendix A to Part 100). 

The following actions must be completed before the NRC approves restart of NAPS: 

1. visual walkdowns by the licensee in accordance with the EPRI guidelines by 

personnel trained and qualified in accordance with ASME and ACI Codes, 

2. confirmatory inspections by the NRC inspectors, and 

3. review and acceptance by the staff of short term evaluations performed by licensee 

prior to restart. 

Subsequent to restart, the staff will review long term evaluations by the licensee that 

demonstrate long term operability. 

The staff will evaluate the adequacy of the scope of the licensee’s inspections, tests and 

analyses, which are intended to demonstrate that no functional damage resulted from the 

earthquake to systems, subsystems, trains, components and devices (i.e., SSCs) (1) that are 

required to be operable by technical specifications (TSs); (2) that perform required support 

functions to maintain a TS-required system operable; (3) that are risk significant or 

safety-related; and (4) SSCs that are not described in TSs, but which warrant programmatic 
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controls to ensure that SSC availability and reliability are maintained (e.g., nonsafety-related 

SSCs that are risk significant). 

NRC Inspection Manual Part 9900, “Operability Determinations and Functionality Assessments 

for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety,” 

provides more detailed guidance for determinations of operability and resolution of degraded or 

nonconforming conditions. The NRC staff will evaluate the adequacy of the licensee’s plan, 

that details the methods used to search for nonconforming conditions, and the resulting 

evaluation method if non-conforming conditions are found. The staff will also confirm that the 

licensee’s plan includes a determination of an adequate search for nonconforming conditions. 

In ensuring that the licensee has adequately identified the long-term actions, the staff will 

assess the need for a regulatory vehicle to ensure that the long-term actions are completed 

following plant restart. The staff will also assess whether there is a sufficient technical basis to 

require the licensee, following plant restart, to update its seismic licensing basis related to the 

SSE for NAPS, and, if so, the appropriate regulatory tool(s) to bring this about. 

MILESTONES, UPDATE FREQUENCY, AND SCHEDULED DATES FOR COMPLETION: 

Noted in Table 

Current Status: Noted in table 

Potential Problems: N/A 

Closeout Criteria: N/A 

CONTACTS: 

DORL: M. Evans, A. Howe, M. Khanna, R. Martin, P. Boyle, and P. Bamford 

DE: P. Hiland, K. Manoly, K. Karwoski, G. Wilson, R. Matthew, M. Murphy, 

T. McMurtray, T. Lupold, H. Gonzalez, and V. Cusumano 

DSS: G. Casto, R. Dennig, A. Ulses, and A. Mendiola 

DLR: A. Hiser, R. Auluck, and B. Pham 

DIRS: T. Tate and D. Harrison 

NRO: C. Munson, R. Karas, C. Cook, and N. Chokshi 

NMSS: E. Love and E. Benner 

RES: R. Hogan 

OGC: E. Williamson, C. Scott, D. Roth, and M. Lemoncelli 

OPA: S. Burnell 

OCA: E. Dicus 

Region I: R. Conte 

Region II: R. Croteau, L. Wert, G. McCoy, and M. Franke 

Region III: A. Shaihk 

Region IV: G. Werner 

 
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REFERENCES: 

1. 10 CFR Part 100, Appendix A, Seismic and Geologic Siting for Nuclear Power Plants. 

2. RG 1.167, “Restart of a Nuclear Power Plant Shut Down By a Seismic Event.” 

3. EPRI NP-6695 Guideline, “Guidelines for Nuclear Power Plant Response to an Earthquake.” 

4. IAEA Safety Report No. 66, “Earthquake Preparedness and Response for Nuclear Power 

Plants.” 

5. NUREG-1407, “Procedural and Submittal Guidance for the Individual Plant Examination of 

External Events (IPEEE) for Severe Accident Vulnerabilities, June 1991. 

6. Augmented Inspection Team Charter to Evaluate Total Loss of Offsite Power, Dual Unit 

Reactor Trips and Plant Equipment Issues Following a Seismic Event at North Anna 

(ADAMS Accession No. ML11243A021). 

7. Dominion Presentation Slides, September 8, 2011 (ADAMS Accession No. ML11252A006). 

8. Virginia Electric and Power Company (Dominion) North Anna Power Station Units 1 and 2, 

North Anna Independent Spent Fuel Storage Installation Summary Report of August 23, 

2011 Earthquake Response and Restart Readiness Determination Plan, dated 

September 17, 2011 (ADAMS Accession No. ML11262A151). 

9. Virginia Electric and Power Company North Anna Power Station Units 1 and 2, Post 

Earthquake Restart Readiness Determination Plan Status Update, dated September 27, 

2011. 

10. Virginia Electric and Power Company North Anna Power Station Units 1 and 2, Response to 

Request for Additional Information Regarding the Earthquake on August 23, 2011 and 

Restart Readiness Determination Plan, dated September 27, 2011 (Fuels and Reactor 

Systems). 

11. Virginia Electric and Power Company (Dominion) North Anna Power Station Units 1 and 2, 

Response to Request for Additional Information Regarding the Earthquake on August 23, 

2011 and Restart Readiness Determination Plan, dated October 3, 2011 (Fuels and Reactor 

Systems). 

12. Virginia Electric and Power Company (Dominion) North Anna Power Station Units 1 and 2, 

Response to Request for Additional Information Regarding the Earthquake on August 23, 

2011 and Restart Readiness Determination Plan, dated October 3, 2011 (HVAC, 

Containment, Electrical, I&C, Fire Protection, PRA, Steam Generators, Snubbers, and 

Reactor Vessel Internals). 
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13. Virginia Electric and Power Company (Dominion) North Anna Power Station Units 1 and 2 

Response to Request for Additional Information Restart Readiness Determination Plan, 

dated October 10, 2011 (Electrical, Steam Generators, Snubbers, and Reactor Vessel 

Internals). 

14. Virginia Electric and Power Company (Dominion) North Anna Power Station Units 1 and 2 

Response to Request for Additional Information Restart Readiness Determination Plan, 

dated October 10, 2011 (Piping, EMCB, and License Renewal). 

 
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NORTH ANNA POWER STATION RESTART ACTION PLAN MILESTONES 

Item

#

Milestone Completion Date Lead

1 Conduct daily conference calls with the licensee to 

obtain status of activities.

11/11/11 (C) DORL

2 Conduct audit on the effects of the earthquake on the 

nuclear fuel.

9/19/11-9/22/11 

(C)

SNPB

3 Prepare acceptance criteria for reviewers. 9/20/11 (C) DORL

4 Issue Communications Plan, and update as 

necessary.

9/20/11 (C) DE

5 Brief NRR OD of regulatory basis for restart and 

review process.

9/22/11 (C) DORL

6 Provide briefing books to EDO (VEPCO Drop-ins with 

Chairman and Commissioners - 9/29 and 9/30.

9/23/11 (C) DORL

7 Provide response to GT–IAEA one pager. 9/23/11(C) DORL

8 Develop SE template for reviewers. 9/28/11 (C) DORL

9 Conduct Commissioner’s TA briefing. 9/28/11 (C) DORL

10 Applicable technical branches within DE, DSS, DCI, 

DIRS, DRA, and DLR identify questions and issues 

that the licensee should address in the short term 

(prior to restart) and long term initiatives (post 

restart), and provide to DORL. 

11/11/13 (O)

(Ongoing)

All

11 Meeting with Chairman to address regulatory process 

for restart and licensing process.

9/29/11 (C) NRR/OGC

12 Dominion drop-in with Chairman and Commissioners. 9/29/11 and 

9/30/11 (C)

EDO

13 Issue Confirmatory Action Letter to licensee (after 

communicating CAL language to VEPCO).

9/30/11 (C) Region II

14 Issue formal requests for additional information to 

licensee.

9/30/2011 (C) DORL

15 NRR OD and Region 2 RA to tour site prior to AIT 

exit meeting.

10/3/11 (C) NRR and 

Region II

16 Identify issues for regional follow-up (walkdowns and 

inspections).

10/3/11 (C) All

17 Conduct AIT public exit briefing and provide insights 

to DORL for their review of the restart submittal.

10/3/11 (C) Region II

18 Restart Readiness Inspection 10/5/11 - 

10/14/11 (C)

Region II

19 Prebrief with NRR OD regarding 10/21 Comm. Mtg. 10/11/11 (C) DORL/DE

 
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NORTH ANNA POWER STATION RESTART ACTION PLAN MILESTONES, CONT. 

Item# Milestone Completion 

Date

Lead

20 Obtain acceptance from FEMA National regarding 

infrastructure to support restart prior to restart.

10/11/11 (C) NSIR

21 EDO alignment/prebrief for 10/21/11 Commissioner 

Meeting.

10/12/11 (C) DORL/DE

22 Receive draft safety evaluation input from reviewers. 10/13/11 (C) All

23 Determine regulatory vehicle, as necessary, to 

address long-term actions

9/30/11(C) DORL

24 Develop the language for appropriate regulatory 

vehicle to address long-term actions if necessary.

9/30/11(C) DORL/DE

25 Conduct Commissioner TA briefing. 10/18/11 (C) DORL

26 Conduct Public Commission Meeting regarding North 

Anna Restart Initiative.

10/21/11 (C) DORL

27 Obtain facilitator and contractor support for AV needs 

for the public meeting in Louisa, Virginia.

10/26/11 (C) DORL/

Region II

28 Receive final safety evaluation input from reviewers. 10/31/11 (C) DORL

29 Conduct Public Meeting in Louisa, VA, to discuss the 

Restart Readiness Inspection and technical review.

11/1/11 (C) Region II

NRR

30 Issue letter to VEPCO on restart decision (reference 

inspection activities and attach NRC SE).

11/11/11(C) NRR

31 Update 1-pager for Commissioners. Completed DORL

32 Address GT 20110668 regarding 2.206 petition. 4/26/12 (C) DORL/DPR

33 Address any potential generic issues (e.g., seismic 

instrumentation power supplies, seismic monitor 

locations on structures as well as in the “free field,” 

and seismic monitors on ISFSI pads).

Ongoing Region II 

NMSS/DE/DPR

34 Continue to respond to routine communications 

between the resident inspectors and local officials 

based on public interest. See Communications Plan.

Completed DORL

35 Address issues for resolution. Completed DORL/DIRS

36 Conduct ACRS briefings, as needed. NA DORL and 

Technical 

Branches

37 Conduct EDO and Commissioner briefings, as 

needed.

Completed DORL and DE

38 Develop SharePoint site. C DORL

T = Target 

C = Complete 

O = Ongoing