Request for Extension to Answer the November 5, 2004, Order Imposing Requirements for the Protection of Certain Safeguards Information (EA-04-190)| ML043350396 |
| Person / Time |
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| Site: |
Indian Point, Pilgrim, Vermont Yankee, FitzPatrick  |
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| Issue date: |
11/23/2004 |
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| From: |
Kansler M
Entergy Nuclear Northeast, Entergy Nuclear Operations |
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| To: |
Dyer J
Office of Nuclear Reactor Regulation |
|---|
| References |
|---|
| 2.04.113, BVY-04-125, EA-04-190, JPN-04-017, NL-04-146 |
| Download: ML043350396 (3) |
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Category:Letter type:JPN
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2005-06-15
[Table view] |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
-a En tergy 440 Hamilton Avenue White Plains, NY 10601 Tel 9142723200 Fax 914 272 3205 Michael R. Kansler President November 23, 2004 NL-04-146 BVY-04-125 ENO Itr. 2.04.113 JPN-04-017 Mr. J. E. Dyer Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Units Nos. 2 and 3 Docket Nos. 50-247, and 50-286 Vermont Yankee Nuclear Power Station Docket No. 50-271 Pilgrim Nuclear Power Station Docket No. 50-293 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for Extension to Answer the November 5, 2004, Order Imposing Requirements for the Protection of Certain Safeguards Information (EA-04-190)
REFERENCE:
NRC letter from J. E. Dyer to holders of licenses for power and research and test reactors as listed in Attachment 1 to Enclosure 1, dated November 5, 2004 regarding order imposing requirements for the protection of certain safeguards information.
Dear Sir:
Section IV of the November 5, 2004, Order Imposing Requirements for the Protection of Certain Safeguards Information (EA-04-190) ("Order") states that, in accordance with 10 CFR
§2.202, the recipient of the Order must submit an answer to the Order, and may request a hearing on the Order, within 20 days of the date of the Order. Attachment 2 to the Order, Modified Handling Requirements for the Protections of Certain Safeguards Information (SGI-M),
which is incorporated by reference with the Order, contains detailed requirements which recipients of the Order must meet.
Pursuant to the provisions of Section IV, of the Order, the above captioned licensees (hereinafter "Entergy Nuclear Operations, Inc." or "ENO") hereby request an extension of time in which to submit an answer to or request a hearing with respect to one or more provisions of the Order. The implications of the Order to licensees who have a program for controlling Safeguards Information that meets all current regulatory requirements is not clear, and the granting of time to interact with the NRC to ensure that the Commission's intent in issuing the Order and how it is to be implemented is clear, is both necessary and appropriate.
ENO requests an extension of time to answer the Order not to exceed twenty (20) days after clarification of the following issues:
- 1. Clarify that an existing Safeguards Information program can be used and how it can be used to satisfy the Order (i.e., a separate SGI-M program is not required), and that no changes to that Safeguards Information program are required by the Order.
- 2. Attachment 2 establishes different, and in some cases, more restrictive requirements than our existing Safeguards Information program.
- 3. Resolution of potential programmatic compliance issues arising when a licensee uses its existing Safeguards Information program but must interface with an entity using an SGI-M program where the requirements are different (e.g., double versus single envelopes; differing requirements on telecommunications).
The need for clarity regarding these and related issues constitutes good cause for the requested extension to be granted. During this period, ENO will control all material designated SGI-M under its Safeguards Information program. ENO also requests that the Commission exercise enforcement discretion during this period.
If you have any questions, or require additlL al information, please contact Ms. Charlene Faison at 914-272-3378. This letter includes ,,new commitments.
In accordance with 10 CFR § 2.202(b), the following~ffirmation is provided:
I declare under penalty of perjury that the foregoing is trueand correct.
Executed on Sincerely, Date cc: Next page.
2
cc:
Mr. Samuel J. Collins Resident Inspector's Office Regional Administrator, Region I James A. FitzPatrick U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 475 Allendale Road P.O. Box 136 King of Prussia, PA 19406-1415 Lycoming, NY 13093-0136 Mr. Patrick D. Milano, Sr. Project Manager Senior Resident Inspector Project Directorate I Pilgrim Nuclear Power Station Division of Licensing Project Management U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 600 Rocky Hill Road U. S. Nuclear Regulatory Commission Mail Stop 66 Mail Stop 0-8-C2 Plymouth, MA 02360 Washington, DC 20555-0001 USNRC Resident Inspector Mr. Robert Fretz, Project Manager Vermont Yankee Nuclear Power Station License Project Directorate I 320 Governor Hunt Road Division of Licensing Project Management P. O. Box 157 Office of Nuclear Reactor Regulation Vernon, VT 05354 U. S. Nuclear Regulatory Commission Mail Stop 0-8-B2 Mr. David O'Brien Washington, DC 20555-0001 Commissioner Department of Public Service Mr. Richard B. Ennis, Project Manager 112 State Street, Drawer 20 License Project Directorate I Montpelier, VT 05620-2601 Division of Licensing Project Management Office of Nuclear Reactor Regulation Director U. S. Nuclear Regulatory Commission Office of Nuclear Materials and Safeguards Mail Stop 0-8-Bl U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Resident Inspector's Office Assistant General Counsel for Materials Indian Point Unit 3 Litigation and Enforcement U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission P. 0. Box 337 Washington, DC 20555-0001 Buchanan, NY 10511-0337 Mr. Paul Eddy Senior Resident Inspector's Office New York State Department of Public Indian Point Unit 2 Service U. S. Nuclear Regulatory Commission 3 Empire State Plaza P. O. Box 59 Albany, NY 12223-6399 Buchanan, NY 10511-0059 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 3