ML19289D092

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Letter to Ken Schrader Response to Fee Waiver WCAP-17096-NP, Revision 3, Reactor Internals Acceptance Criteria Methodology and Data Requirements
ML19289D092
Person / Time
Issue date: 11/06/2019
From: Maureen Wylie
NRC/OCFO
To: Schrader K
PWR Owners Group
Jo Jacobs, NRC/OCFO, 301-415-8388
Shared Package
ML19289D090 List:
References
WCAP-17096-NP
Download: ML19289D092 (3)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 6, 2019 Mr. Ken Schrader Chief Operating Officer and Chairman PWR Owners Group 100 Westinghouse Drive, Suite 172 Cranberry Township, PA 16066

Dear Mr. Schrader:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated September 27, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19274B205), requesting a fee waiver under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) for NRC review of WCAP-17096-NP, Revision 3, Reactor Internals Acceptance Criteria Methodology and Data Requirements.

The NRC has established regulations for the granting of fee exemptions under 10 CFR 170.11, Exemptions, which may be applied for in accordance with 10 CFR 170.5, Communications.

The NRC staff has reviewed your request based on the following regulations, 10 CFR 170.11(a)(1)(ii) and 10 CFR 170.11(a)(13):

10 CFR 170.11(a) No application fees, license fees, renewal fees, inspection fees, or special project fees shall be required for: (1) A special project that is a request/report submitted to the NRC... (ii) When the NRC, at the time the request/report is submitted, plans to use the information in response to an NRC request from the Office Director level or above to resolve an identified safety, safeguards, or environmental issue, or to assist the NRC in generic regulatory improvements or efforts (e.g. rules, regulatory guides, regulations, policy statements, generic letters, or bulletins).

10 CFR 170.11(a)(13) All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.51, and the Chief Financial Officer will grant or deny such requests in writing.

In your letter you state that WCAP-17096-NP, Revision 3, contains the methodology and data requirements necessary to evaluate the potential degradation of reactor vessel internals structural components during MRP-227, Revision 1, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, inspections. WCAP-17096-NP, Revision 3 includes changes related to updates made to MRP-227, Revision 1, and in response to lessons learned from operating experience from MRP-227 inspections conducted to date.

1 10 CFR 170.5 provides that All communications concerning the regulations in this part should be addressed to the NRC's Chief Financial Officer, either by mail to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; by hand delivery to the NRC's offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD-ROM.

WCAP-17096-NP, Revision 3 is also applicable to all Babcock and Wilcox (B&W), Combustion Engineering (CE), and Westinghouse Nuclear Steam Supply System (NSSS) plants. WCAP-17096-NP, Revision 3, also provides a means of exchanging information supporting generic regulatory improvements associated with potential degradation of reactor vessel internals structural components identified during MRP-227, Revision 1, inspections for the life of the plant, including the first license renewal. WCAP-17096-NP, Revision 3 contains a methodology providing a consistent basis for evaluation of reactor internal degradation identified during MRP-227, Revision 1, inspections. If accepted for use by the NRC, WCAP-17096-NP, Revision 3 will reduce the burden on both licensee and NRC staff resources for the disposition of plant specific MRP-227 inspection results.

The NRC staff has reviewed the waiver request and agrees with the PWR Owners Group that NRCs review and approval of WCAP-17096-NP, Revision 3, Reactor Internals Acceptance Criteria Methodology and Data Requirements, will further assist the NRC in generic regulatory improvements or efforts as described within the waiver request. Therefore, the waiver request meets the criteria within 10 CFR 170.11(a)(1)(ii) and is approved.

If you have any technical questions regarding this matter, please contact Ms. Leslie Fields 301-415-1186. Please contact Ms. Jo Jacobs, of my staff, at 301-415-8388 for any fee-related questions.

Sincerely,

/RA/

Maureen E. Wylie Chief Financial Officer

ML19289D090 (pkg) ML19274B205 (incoming)

ML19289D092 (letter)

  • via e-mail OFFICE OCFO/DOB/LFPT OCFO/DOB/LFPT NRR/DORL/LLPB:PM NRR/DORL/LLPB:BC NAME JJacobs WBlaney LFields*

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DATE 10/17/2019 10/17/2019 10/17/2019 10/17/2019 OFFICE OGC OCFO/DOC/LAFBB OCFO/DOC/LAFBB OCFO/DOB/LFPT NAME EMichel*

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ARossi DATE 10/29/2019 10/30/2019 10/29/2019 10/30/2019 OFFICE OCFO/DOB OCFO/DOB DCFO CFO NAME MSampson SCoffin BFicks MEWylie DATE 10/31/2019 10/31/2019 11/6/19