ML22161A482
| ML22161A482 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/2022 |
| From: | Clay Johnson NRC/OCFO |
| To: | Mcgill R Electric Power Research Institute |
| Jacobs J - 301-415-8388 | |
| Shared Package | |
| ML22161A484 | List: |
| References | |
| Download: ML22161A482 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 25, 2022 Robert O. McGill MRP Program Manager Electric Power Research Institute 3420 Hillview Avenue Palo Alto, CA 94304
SUBJECT:
LETTER TO ROBERT O. MCGILL IN RESPONSE TO A REQUEST FOR A FEE EXEMPTION FOR MATERIALS RELIABILITY PROGRAM-227, REVISION 2
Dear Robert McGill:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated May 9, 2022 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML22129A139), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR), Section 170.11(a)(1)(ii) for NRC review and endorsement of Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation (I&E) Guidelines (MRP-227, Revision 2).
The NRC has established regulations for the granting of fee exemptions under 10 CFR 170.11 Exemptions. An interested person may apply for an exemption under 10 CFR 170.11 in accordance with 10 CFR 170.5, Communications.1 The NRC staff reviewed your request based on the regulations in 10 CFR 170.11(a)(1)(ii) and 10 CFR 170.11(a)(13). Section 170.11(a)(1)(ii) states:
(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).
Section 170.11(a)(13) states:
All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.5, and the Chief Financial Officer will grant or deny such requests in writing.
1 10 CFR 170.5 provides that All communications concerning the regulations in this part should be addressed to the NRCs Chief Financial Officer, either by mail to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; by hand delivery to the NRCs offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD-ROM.
R. McGill In your letter, you state that MRP-227, Revision 2, was provided as a means of exchanging information with the NRC for the purpose of supporting generic regulatory improvements related to methodologies for demonstrating pressurized water reactor (PWR) safety-related internals integrity throughout the life of the plant, including the extended period authorized by license renewal in accordance with 10 CFR Part 54. In addition, you indicate that many licensees have made commitments as part of power up-rate and license renewal submittals to incorporate the applicable program elements of an industry reactor vessel internals inspection program.
Your letter further states that the guidelines in MRP-227, Revision 2, serve as an effective means to address the aging of reactor internals components and meet or exceed NRC guidance provided in the Generic Aging Lessons Learned (GALL) Reports, both NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, and NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. The subject inspection and evaluation guideline is applicable to reactor internal structural components for Babcock & Wilcox, Combustion Engineering, and Westinghouse designed PWRs.
Finally, your letter states that the major intent of MRP-227, Revision 2, is to incorporate lessons learned and to address subsequent license renewal periods of extended operation (beyond 60-calendar years of PWR operation) concerns related to managing the aging effects of PWR reactor internals.
The NRC staffs review of MRP-227, Revision 2, meets the criteria under 10 CFR 170.11(a)(1)(ii) because the review and potential endorsement of MRP-227, Revision 2, will improve subsequent license renewal applications submitted to the NRC, which will improve the efficiency of the staffs review, and the guidelines will ultimately be incorporated into an update to NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. Thus, the NRC staff concludes that MRP-227, Revision 2, if endorsed, would assist the NRC in generic regulatory improvements or efforts related to PWR operating power reactors; therefore, the fee exemption request is approved.
If you have any technical questions regarding this matter, please contact Brian Yip at 301-415-3154. Please contact Jo Jacobs, of my staff, at 301-415-8388 for any fee-related questions.
Sincerely, Signed by Johnson,Cherish on 07/25/22 Cherish K. Johnson Chief Financial Officer
R. McGill
SUBJECT:
LETTER TO ROBERT O. MCGILL IN RESPONSE TO A REQUEST FOR A FEE EXEMPTION FOR MATERIALS RELIABILITY PROGRAM-227, REVISION 2, DATED: JULY 25, 2022 DISTRIBUTION:
NAridi, OCFO RidsNrrOd Resource BFicks, OCFO ADAMS Accession Number: ML22161A484 (Package); ML22129A139 (Incoming Letter);
ML22161A482 (Response Letter)
OFFICE OCFO/DOB OCFO/DOB NRR/DORL NRR/DORL NRR/DORL NAME WBlaney JJacobs LJames RChang BPham DATE 06/10/2022 06/10/2022 06/10/2022 06/10/2022 06/16/2022 OFFICE OGC OCFO/DOC OCFO/DOC OCFO/DOB OCFO/DOB NAME CMcCann MHerrera MBlair ACRossi RCAllwein DATE 07/22/2022 06/21/2022 06/21/2022 07/25/2022 07/25/2022 OFFICE OCFO/DOB CFO NAME JEShay CKJohnson (RAllwein for)
DATE 07/25/2022 07/25/2022 OFFICIAL RECORD ONLY