ML23312A198
| ML23312A198 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/2023 |
| From: | Jennifer Golder NRC/OCFO |
| To: | Palm N Electric Power Research Institute |
| Shared Package | |
| ML23312A207 | List: |
| References | |
| OCFO-23-00206 | |
| Download: ML23312A198 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 5, 2023 Nathan Palm BWRVIP Program Manager Electric Power Research Institute 1300 West W.T. Harris Blvd Charlotte, NC 28262-8550
SUBJECT:
FEE EXEMPTION REQUEST FOR NRC REVIEW FEES FOR BWRVIP-138, REVISION 2, A: BOILING WATER REACTOR VESSEL AND INTERNALS PROJECT, UPDATED JET PUMP BEAM INSPECTION AND FLAW EVALUATION GUIDELINES
Dear Nathan Palm:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated October 25, 2023 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML23299A114), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) for NRC fees associated with reviewing the document, Boiling Water Reactor Vessel and Internals Project (BWRVIP)-Revision 2, A: BWR Vessel and Internals Project, Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines.
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) 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-138 was identified in NUREG-2191, Generic Aging Lessons Learned (GALL) Report for Subsequent License Renewal (SLR), part of the aging management program for jet pump assemblies (ML17187A031 and ML17187A204). In addition, you state that as part of the safety evaluation (SE) for BWRVIP-138, Revision 1 (ML12080A146), the NRC recognized that the BWRVIP had a project underway to conduct
N. Palm testing of crack growth rates (CGRs) on Alloy X-750, which is the material the jet pump beams are fabricated from. You also state that, in the SE for BWRVIP-138, Revision 1, the NRC stated that if the results of the testing do not confirm the CGRs used in the development of the current inspection intervals, the BWRVIP is expected to re-evaluate the inspection intervals using the new CGR results. Finally, you state that the purpose of Revision 2 to BWRVIP-138 is to re-evaluate the new CGR results and to update the inspection intervals.
The NRC acknowledges that the SE for BWRVIP-138, Revision 1, recognized that the BWRVIP had a project underway to measure CGRs on a representative heat of Alloy X-750 material and that BWRVIP planned to communicate those results to the NRC when available. Further, the NRC acknowledges that the SE for BWRVIP-138, Revision 1, also stated that:
If the results of the supplemental CGR testing on a representative heat of Alloy X-750 that the BWRVIP is currently conducting do not confirm the assumed X-750 CGRs, then the BWRVIP should re-evaluate the proposed re-inspection intervals using the results of the supplemental testing.
Further, BWRVIP-138 is identified in NUREG-2191 as a staff-approved BWRVIP guideline for inspection and evaluation of jet pump assemblies 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-138, and review and approval of Revision 2 to BWRVIP-138 would directly impact every applicant for subsequent license renewal.
I conclude that the Electric Power Research Institutes request for NRC review of BWRVIP-138, Revision 2, including the NRC staff time spent on any pre-submittal activities, 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, Signed by Golder, Jennifer on 12/05/23 Jennifer M. Golder Acting Chief Financial Officer cc: Martin Bonifanti
N. Palm
SUBJECT:
FEE EXEMPTION REQUEST FOR NRC REVIEW FEES FOR BWRVIP-138, REVISION 2, A: BOILING WATER REACTOR VESSEL AND INTERNALS PROJECT, UPDATED JET PUMP BEAM INSPECTION AND FLAW EVALUATION GUIDELINES, DATED: DECEMBER 5, 2023 DISTRIBUTION: OCFO-23-00206 NAridi, OCFO MVelasquez, OCFO LJames, NRR RidsNrrOd Resource ADAMS Accession Number: ML23312A207 Package; ML23312A198 Letter OFFICE OCFO/DOB NRR/DORL NRR/DORL OGC NAME BBlaney GGeorge VCusumano EAnderson*NLO DATE 11/08/2023 11/08/2023 11/09/2023 11/22/2023 OFFICE OCFO/DOC OCFO/DOB OCFO/DOB OCFO/DOB NAME RRevinzon ARossi LYee MSchofer DATE 11/22/2023 11/28/2023 11/30/2023 11/28/2023 OFFICE CFO CFO NAME DDAbate JGolder DATE 12/05/2023 12/05/2023 OFFICIAL RECORD COPY