ML043280082

ML043280082
Person / Time
Site:	Millstone, Surry, North Anna
Issue date:	11/22/2004
From:	Matthews W Dominion Nuclear Connecticut, Virginia Electric & Power Co (VEPCO)
To:	Dyer J Office of Nuclear Reactor Regulation
References
04-701
Download: ML043280082 (5)

Text

1 Dominion November 22,2004 Re:

10 CFR 2.202 10 CFR 50.4 Mr. J. E. Dyer Serial No.:

04-70 1 Director, Office of Nuclear Reactor Regulation NL&OS/MAE:

F12 U. S. Nuclear Regulatory Commission Docket Nos.:

50-336/423 Washington, D. C. 20555 50- 3 3 8/3 3 9 50-280/281 License Nos.:

DPR-65 N PF-49 N P F-4/7 DPR-32/37 DOMINION NUCLEAR CONNECTICUT, INC.

VIRGINIA ELECTRIC AND POWER COMPANY MILLSTONE POWER STATION UNITS 2 AND 3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 REQUEST FOR EXTENSION TO RESPOND TO THE NOVEMBER 5.2004. ORDER IMPOSING REQUIREMENTS FOR THE PROTECTION OF CERTAIN SAFEGUARDS INFORMATION (EA-04-1901 Section IV of the November 5, 2004, Order Imposing Requirements for the Protection of Certain Safeguards Information (EA-04-190) (Order) states that, in accolrdance with 10 CFR s2.202, 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. to the Order, Modified Handling Requirements for the Protection of Certain Safeguards lnformation (SGI-M), which is incorporated by reference into the Order, contains detailed requirements which recipients of the Order must meet.

This letter constitutes the response of Dominion Nuclear Connecticut, Inc. (DNC) and Virginia Electric and Power Company (Dominion) to the Order.

Pursiuant to the provisions of Section IV of the Order, DNC and Dominion 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 lnformation that meets all current regulatory requirements is not clear. The granting of time to interact with the NRC is both necessary and appropriate to ensure that the Commissions intent of the Order and how it is to be implemented is clear.

DNC and Dominion request an extension of time to respond to the Order not to exceed twenty (20) days after clarification of the following issues:

Serial No.04-701 Req. for Extension Order EA 04-190 Page 2 of 5

1.

2.

3.

Applicability of the existing Safeguards Information program 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. establishes different, and in some cases, more restrictive requirements than the existing Safeguards Information program.

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, DNC and Dominion will control all material designated SGI-M under its Safeguards Information program. DNC and Dominion also request that the Commission exercise enforcement discretion during this period.

If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Very truly yours,

- - L A William R. Matthews Senior Vice President - Nuclear Operations Dominion Nuclear Connecticut, Inc.

Virginia Electric and Power Company Commitments made by this letter: None

Serial No.04-701 Req. for Extension Order EA 04-190 Page 3 of 5 Docket Nos. : 50-336/423 50-3 3 8/3 3 9 50-280/281 COMMONWEALTH OF VIRGINIA

)

1 COUNTY OF HENRICO 1

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by William R. Matthews who is Senior Vice President - Nuclear Operations of Dominion Nuclear Connecticut, Inc. and Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

, 2004.

Acknowledged before me this&?Cdday of xflkm6h My Commission Expires:

Y J

-, I -

422 a

Notary Public (SEAL)

Serial No.04-701 Req. for Extension Order EA 04-1 90 Page 4 of 5 cc:

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Secretary, Office of the Secretary of the Commission U. S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff Washington, D. C. 20555 Director, Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington] D. C. 20555 Assistant General Counsel for Materials Litigation and Enforcement U. S. Nuclear Regulatory Commission Washington] D. C. 20555 U. S. Nuclear Regulatory Commission Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1 41 5 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-8931 Mr. S. R. Monarque NRC Project Manager North Anna and Surry U. S. Nuclear Regulatory Commission, Mail Stop 8 H12 Washington, D. C. 20555 Mr. V. Nerses NRC Senior Project Manager Millstone Unit 2 U. S. Nuclear Regulatory Commission, Mail Stop 8 C2 Washington, D. C. 20555 Mr. G. F. Wunder NRC Senior Project Manager Millstone Unit 3 U. S. Nuclear Regulatory Commission, Mail Stop 8-B-1 A Washington, D. C. 20555

Serial No.04-701 Req. for Extension Order EA 04-190 Page 5 of 5 Mr. R. J. Prince N RC Inspector 475 Allendale Road King of Prussia, PA 19406-1 41 5 Mr. M. T. Widmann NRC Senior Resident Inspector North Anna Power Station Mr. N. P. Garrett NRC Senior Resident Inspector Surry Power Station Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station