ML23215A062
| ML23215A062 | |
| Person / Time | |
|---|---|
| Site: | 99902016 |
| Issue date: | 08/30/2023 |
| From: | Osborne H NRC/OCFO |
| To: | Palm N Electric Power Research Institute |
| Shared Package | |
| ML23215A056 | List: |
| References | |
| BWRVIP-100, Rev 2, 2023-055 | |
| Download: ML23215A062 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Nathan Palm BWRVIP Program Manager Electric Power Research Institute 1300 West W.T. Harris Blvd Charlotte, NC 28262-8550
SUBJECT:
RESPONSE TO REQUEST FOR A FEE EXEMPTION FOR NRC REVIEW OF BWRVIP-100, REVISION 2
Dear Mr. Palm:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated July 19, 2023, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML23200A181), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) for NRC review and approval of BWRVIP-100, Revision 2: BWR Vessel and Internals Project, Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Internal Components. BWRVIP-100, Revision 2, was submitted by letter dated July 11, 2023 (ML23198A334).1 NRC regulations pertaining to fee exemption requests are set forth in 10 CFR 170.11 Exemptions. The NRC staff reviewed your request consistent with the provisions in 10 CFR 170.11(a)(1)(ii) and 170.11(d). Section 170.11(a)(1)(ii) states:
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 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(d) 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.
In your letter, you state that BWRVIP-100 was identified in NUREG-2191, Generic Aging Lessons Learned (GALL) Report for Subsequent License Renewal (SLR), as part of the aging management program for BWR vessel internals. In addition, you state that as part of the safety evaluation (SE) for BWRVIP-100, Revision 1 (ML040650779), the NRC recommended that the 1 EPRI submitted a proprietary version and a non-proprietary version of BWRVIP-100, Revision 2. The non-proprietary version is publicly available (ML23198A335).
August 30, 2023
N. Palm BWRVIP continue to seek additional austenitic stainless steel weld materials to better characterize the toughness of weld materials affected by both irradiation and thermal aging. In response to that recommendation, the BWRVIP obtained and tested irradiated austenitic stainless steel weld materials from two different sources. The results of that testing necessitated Revision 2 to BWRVIP-100. An initial evaluation of the test data from harvested reactor internals materials showed lower than anticipated fracture toughness for weld metal, indicating a potential non-conservatism in BWRVIP-100, Revision 1-A. You state that Revision 2 incorporates the newly acquired test data to reassess the relationship between fracture toughness and fluence.
The NRC acknowledges that the SE for BWRVIP-100, Revision 1, provided several recommendations, including that BWRVIP revise its model for fracture toughness as needed based on the results of testing additional specimens. Further, BWRVIP-100 is identified in NUREG-2191 as a staff-approved BWRVIP guideline for flaw evaluation methodologies and fracture toughness data for SS core shroud exposed to neutron irradiation in Aging Management Program (AMP) XI.M9, BWR Vessel Internals. The staff issued Revision 1 of NUREG-2191 for public comment on July 11, 2023. Revision 1 advises that subsequent license renewal applicants should account for the latest data from BWRVIP research programs in their vessel internals inspection program. This latest data is the basis for Revision 2 to BWRVIP-100, and review and approval of Revision 2 to BWRVIP-100 would impact every applicant for subsequent license renewal.
Therefore, I conclude that the Electric Power Research Institutes request for NRC review of BWRVIP-100, Revision 2, including the NRC staff time spent on the pre-submittal meeting that was held on February 27, 2023, meets the criteria under 10 CFR 170.11(a)(1)(ii) because the guidance will assist the NRC in generic regulatory improvements or efforts; therefore, the fee exemption request is approved.
If you have any technical questions regarding this matter, please contact Ms. Lois James at 301-415-3306. Please contact Mr. Billy Blaney, of my staff, at 301-415-5092 for any fee-related questions.
Sincerely, Howard K. Osborne Chief Financial Officer Signed by Osborne, Howard on 08/30/23
N. Palm
SUBJECT:
RESPONSE TO REQUEST FOR A FEE EXEMPTION FOR NRC REVIEW OF BWRVIP-100, REVISION 2, DATED: AUGUST 30, 2023 DISTRIBUTION: OCFO-023-00135 NAridi, OCFO MVelasquez, OCFO LJames, NRR RidsNrrOd Resource ADAMS Accession Number: ML23215A056 Package; ML23215A062 Letter OFFICE OCFO/DOB NRR/DORL NRR/DORL OGC NAME BBlaney GGeorge GSuber CMcCannNLO DATE 08/03/2023 08/07/2023 08/07/2023 08/24/2023 OFFICE OCFO/DOC OCFO/DOC OCFO/DOB OCFO/DOB NAME RRevinson MBlair ARossi RAllwein DATE 08/24/2023 08/24/2023 08/24/2023 08/28/2023 OFFICE OCFO/DOB CFO CFO NAME JShay JCorbett HOsborne DATE 08/29/2023 08/30/2023 08/30/2023 OFFICIAL RECORD COPY