At Beaver Valley the operable incore detector physical inventory is demonstrated through the fact that the detectors provide a signal. For used detectors in the wall "storage" area we note that these will be inventoried during the next refueling. We usually attempt to remove the used incore detectors during each refueling outage and transfer them to a barrel with a TID for better control and inventory. No exemption was pursued and the NRC. I believe this was discussed with the NRC during industry meetings back in 2005 and the NRC did not object to this approach. Also, during the NRC audit of SNM in 2005 at BV, the NRC did not identify this as an issue, etc.

Anthony (A.R.) Burger Supervisor, Reactor Engineering FENOC - Beaver Valley Power Station Phone: (724) 682-4108 Cell: (724) 601-3224 FAX: (724) 682-4250 Email: aburger@firstenergycorp.com

From: Rosanne.Carmean@exeloncorp.com To: pwrrm@retaqs.com Date: 05/26/2011 02:43 PM Subject: [Pwrrm] PWR In-Core detector Physical Inventories Sent by: pwrrm@retaqs.com

Has any one ever pursued an NRC exemption for 10CFR74.19(c) physical inventory of in-core detectors in efforts to eliminate risk of going into containment and reduce dose?

Thanks in advance for responding. Rosanne Carmean Exelon Nuclear Spent Fuel and Decommissioning Phone: (630) 657-2166 Fax: (630) 657- 4331 mailto:Rosanne.Carmean@exeloncorp.com

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