ML11187A108

NRR E-mail Capture - NFPA 805 Commitment Letter from Kewaunee

ML11187A108
Person / Time
Site:	Kewaunee
Issue date:	07/01/2011
From:	Sly C Dominion Generation
To:	Feintuch K Plant Licensing Branch III
References
Download: ML11187A108 (9)

Text

NRR-PMDAPEm Resource From: Craig D Sly [craig.d.sly@dom.com]

Sent: Friday, July 01, 2011 3:06 PM To: Feintuch, Karl

Subject:

RE: NFPA 805 Commitment Letter from Kewaunee Attachments: 08-0451.pdf; ML082710001.pdf

Karl, Heres the story for Kewaunee.

Kewaunee submitted its Letter of Intent in July 2008 (attached) and our NRC enforcement discretion expires end of July 2011 (not end of June like most other plants) (see attached ML082710001).

Our internal project schedule indicates we will submit by July 29, 2011, but there is absolutely no float in the schedule and its going to be very tight. We have known that we have a tight schedule to meet July 29, and some weeks ago I developed a letter that would change our current commitment from July 29 to August or September. This letter has been reviewed and approved and is currently sitting on the desk of my VP-Engineering for final signature (its considered a contingency at this point).

Senior management is pushing the project to meet the July 29 date, but they also realize that we may need some extra time for internal review and approval of this large document.

Now, as to your e-mail. It sounds like Staff is expecting a commitment letter from everyone who is not going to submit before July 1, 2011. If this is so, then I have mis-interpreted the SECY 11-061 document. I read the document to mean submit before your enforcement discretion runs out.

Maybe I was overly focused on the underlined sentence below and the fact that Kewaunee enforcement discretion expires end of July 2011. I have led my management to the conclusion that either we will submit the LAR by the end of July or we will send in a commitment letter sometime near the middle of July stating that we will submit the 805 LAR at the end of August or September (depending on how much additional time we will need).

If I have not met the intention of SECY, please let me know. If I need to submit the commitment letter on my VPs desk ASAP, let me know that too.

Regards, Craig Sly Dominion Resources Services, Inc.

Nuclear Licensing and Operations Support W: 8042732784 C: 8042412473 SECY 11-0061 Cover doc: Pg. 3 para 4.

An industry working group is currently generating a list of transitioning licensees with suggested corresponding LAR submittal dates necessary to support this staggered submittal approach.

Once the working group completes this list, the staff will review and decide whether to approve it. The approved sequencing will also include submittal dates for licensees who are currently 1

scheduled to submit sometime after June 29, 2011. Each licensee will be required to submit a letter to the NRC acknowledging the agreed-upon commitment date with the exception of the first group of licensees that are scheduled to submit around July 1, 2011. The NRC expects that all commitment letters will be submitted before the current enforcement discretion expires on June 29, 2011. Enforcement discretion will continue while the staff processes and responds to the commitment letters.

Enclosure Pg 4: bottom pg. 4/pg. 5 top An industry working group is currently generating a list of transitioning licensees with suggested corresponding LAR submittal dates necessary to support this staggered submittal approach. Once the working group completes the list, the staff will review and decide whether to approve it. The NRC expects the sequencing of the submittals to result in approximately 7 LARs by July 1, 2011; 10 additional LARs by July 1, 2012; another 10 LARs by July 1, 2013; and the remainder by July 1, 2014. The NRC will require licensees, with the exception of the first group of licensees scheduled to submit around July 1, 2011, to submit a letter by June 29, 2011, that acknowledges their new commitment date. Enforcement discretion will continue while the staff is processing and responding to the commitment letters.

From: Feintuch, Karl [1]

Sent: Friday, July 01, 2011 1:34 PM To: Craig D Sly (Generation - 6)

Subject:

NFPA 805 Commitment Letter from Kewaunee

Craig, Doug Pickett contacted me concerning a commitment letter pertaining to NFPA-805. Currently, the NRC staff expects a submittal by July 29 and is concerned that Dominion Energy Kewaunee (DEK) may be under the impression that it does not need to submit a commitment letter. However, since DEK did not meet the June 29 date, NRC staff was expecting a commitment letter.

Over the past few days I noted some increased submittal traffic (the commitment letter not among them), and you and I encountered one EIE submittal problem at our end. Please let me know the status of the NFPA commitment letter.

Karl Feintuch 301-415-3079 CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and/or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

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Hearing Identifier: NRR_PMDA Email Number: 92 Mail Envelope Properties (DECB54B0BB23DC4E8E8C1B7C4741C45023EB0AAEF2)

Subject:

RE: NFPA 805 Commitment Letter from Kewaunee Sent Date: 7/1/2011 3:05:30 PM Received Date: 7/1/2011 3:05:37 PM From: Craig D Sly Created By: craig.d.sly@dom.com Recipients:

"Feintuch, Karl" <Karl.Feintuch@nrc.gov>

Tracking Status: None Post Office: DOM-MBX01.mbu.ad.dominionnet.com Files Size Date & Time MESSAGE 5446 7/1/2011 3:05:37 PM 08-0451.pdf 122891 ML082710001.pdf 104672 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: