ML18038B982
| ML18038B982 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/16/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18038B981 | List: |
| References | |
| NUDOCS 9711050020 | |
| Download: ML18038B982 (27) | |
Text
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RE UESTS FOR RELIEF 2-SPT-9 THROUGH 2-SPT-12 AND 2-ISI-7 TENNESSEE VAI LEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 2 DOCKET NUMBER 50-260
1.0 INTRODUCTION
The Technical Specifications (TS) for the Browns Ferry Nuclear Plant (BFN)
Unit 2, state that the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B8PV) Code and applicable addenda as required by 10 CFR 50.55a(g).
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficultlywithout a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4),
ASME Code Class 1, 2, and 3 components (including supports) shall meet the requi rements, except the design and access provisions and the pre-service examination requi rements, set forth in the ASME Code.Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design,
- geometry, and materials of construction of the components.
The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The applicable edition of Section XI of the ASME Code for BFN Unit 2 second 10-year inservice inspection (ISI) interval is the 1986 Edition.
Pursuant to 10 CFR 50.55a(g)(5). if the licensee determines that conformance with an examination requi rement of Section XI ot the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement.
After evaluation of the determination.
pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise ENCLOSURE 1
97ii050020 97i0i6 PDR ADQCK 05000260 P
qi in the public interest.
giving due consideration to the burden upon the licensee that could result if the requirements were imposed.
In a letter dated June 4, 1997, the Tennessee Valley Authority (the licensee),
submitted to the NRC its Second 10-Year Inservice Inspection Interval Program Plan Requests for Relief 2-SPT-9 through 2-SPT-12.
and 2-ISI-7 for the BFN Unit 2.
Additional information was provided by the licensee in its letter dated September 9,
1997.
2.0 EVALUATION The staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL). has'valuated the information provided by the licensee in support of its Second 10-Year Inservice Inspection Interval Program Plan Requests for Relief 2-SPT-9 through 2-SPT-12.
and 2-ISI-7 for BFN Unit 2.
Based on the information submitted, the staff adopts the contractor 's conclusions and recommendations presented in the Technical Letter Report (TLR) attached.
Request for Relief 2-SPT-9 (Revised):
The licensee requested the use of ASHE Code Case N-498-2 Alternative Requirements for 10-Year System Hydrostatic Testing for Class 2, Z, and 3 Systems,Section XI, Division 1.
Revised Request for Relief 2-SPT-9 was withdrawn by the licensee in the submittal dated September 9,
1997.
This Relief Request was a revision to 2-SPT-9 (invoking Code Case N-498-1) as previously submitted by TVA Harch 9,
- 1995, and subsequently accepted by NRC letter dated August 18, 1995 Request for Relief 2-SPT-10 (Revised 9/9/97):
ASHE Section XI, 1986 Edition, Subsection IWA-2300 requires that personnel performing VT-2 visual examinations be qualified and certified using a written program prepared in accordance with IWA-5240 and shall have comparable levels of competency as defined in ANSI N45.2.6.
Pursuant to 10 CFR 50.55a(a)(3)(i),
the licensee proposed an alternative to the qualification requi rements for VT-2 visual examiners.
The licensee stated:
As an alternative to the existing ASHE Section XI requirements, BFN will utilize the provisions of ASHE Code Case N-646 and additional criteria.
ASHE Code Case N-546 states:
Personnel must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and non-licensed plant operators.
local leak rate personnel, system engineers, and inspection and non-destructive examination personnel.
Individuals must have at least four hours of training in Section XI requirements and plant specific procedures for visual examinations.
Each person must meet (annual) vision test requirements in accordance with the 1995 Edition of the ASHE Section XI Code, Paragraph IWA-2321.
I J
JI In addition to the requi rements of ASME Code Case N-546, TVA wi11 also:
Develop procedural guidelines for obtaining consistent quality VT-2 visual examinations.
Document and maintain records to verify the qualifications of personnel selected to perform VT-2 visual examinations.
Implement independent review and evaluation of leakage by persons other than those that performed the VT-2 visual examinations.
The Code requires that VT-2 visual examination personnel be qualified to comparable levels of competency as defined in ANSI N45.2.6.
The Code also requires that the examination personnel be qualified to near and far distance vision acuity.
The licensee proposed to implement the alternative contained in Code Case N-546 which requires that VT-2 visual examiners meet the following requirements:
~
Personnel must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and non-licensed operators, local leak rate personnel, system engineers, and inspection and non-destructive examination personnel.
~
Personnel must receive at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of training on Section XI requirements and plant-specific procedures for VT-2 visual examination.
~
Personnel must meet the vision test requi rements of IWA-2321,
'1995 Edition.
The qualification requi rements in Code Case N-546 are not significantly different from those for VT-2 visual examiner certification.
Licensed and nonlicensed operators, local leak rate personnel, system engineers.
and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts.
This knowledge makes them acceptable candidates for performing VT-2 visual examinations.
In addition to the requi rements in Code Case N-546, the licensee proposed to:
~
develop procedural guidelines for consistent, quality VT-2 visual examinations:
~
verify and maintain records of the qualifications of persons selected to perform VT-2 examinations:
and
~
perform independent reviews and evaluations of leakage by persons. other than those that performed the VT-2 visual examinations.
The staff requires these conditions to ensure consistent implementation of the
'ode Case.
4'
4 Based on the above.
the staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety.
Therefore, the licensee's proposed request to implement Code Case N-546 with the additional commitments stated by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
Use of Code Case N-546 is authorized for the current interval or until such time as the Code Case is published in Regulatory Guide
- 1. 147.
From that time, if the licensee intends to continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-546, if any.
Request for Relief 2-SPT-11:
The licensee requested to use ASHE Code Case N-566, Corrective Action for Leakage Identified at Bolted Connections as an alternative to the Code requi rements.
The licensee withdrew Request for Relief 2-SPT-ll in the submittal dated September 9.
1997.
Request for Relief 2-SPT-12:
The licensee requested the use of ASHE Code Case N-522, Pressure Testing of Containment Penetration Piping as an alternative to the Code requi rements.
The licensee withdrew Request for Relief 2-SPT-12 in the submittal dated September 9,
1997.
Request for Relief'-ISI-7 (Revised 9/9/97):
ASHE Section XI, Table IWB-2500-1, Examination Category 8-K-1. Item 810. 10, requires (as applicable) a volumetric or surface examination.
as defined by Figure IW8-2500-15, for integrally welded attachments with base material design thickness greater than or equal to 5/8 inch.
In accordance with 10 CFR 50.55a(g)(5)(iii). the licensee requested relief from performing the volumetric or surface examinations (as applicable) to the extent required by the Code f'r the following Class 1 integrally welded attachments in the Feedwater System:
':,.'-":,:;:,:::Suppa'r't:',':,':;:j9',"'j'-478415S0009 2-478415H0002 2-478415H0004 2-478415H0006 88K 88K (same as above)
(same as above) 63K Box shape (welded on both sides)
- interior weld not accessible 88K 4 welded lugs - examination limited by pipe clamp 2-478415H0008 88K (same as above) 2-478415H0010 2-478415H0012 2-478415S0023 88K 88K (same as above)
(same as above) 21K 4 welded lugs inside circular frame - limited by circular frame and shims 2-478415S0025 21K (same as above)
I The Code requires a
100K surface/volumetric examination (as applicable) of the nine subject welded attachments.
The licensee stated that portions of these integrally attached support welds are inaccessible.
For example, support number 2-478415S0009 is box-shaped and welded on both sides.
Access is limited to the exterior welds and areas of the interior welds near the opening of the box.
Additionally, support numbers 2-478415S0023 and 2-478415S0025 are integrally welded attachments consisting of four lugs inside a circular frame with shims adjacent to the lugs.
The examination of these two supports is
-limited by the structural frame and shims; therefore, an examination. to the extent required by the Code, is impractical based on geometric configurations.
In order to perform a
100K examination, the three supports described above would require redesign and replacement.
Considering the large percent of integral attachments receiving 100K coverage, and the partial coverage being obtained for these three integrally welded attachments, the staff concluded that a pattern of degradation, if present. will be detected.
As a result, reasonable assurance of structural integrity is provided.
Therefore.
pursuant to 10 CFR 50.55a(g)(6)(i) for Supports 2-478415S0009, 2-478415S0023, and 2-478415S0025.
the licensee's request for relief is granted as requested except as noted below.
To'xamine 100K of the Code-required area/volume of support numbers 2-47815H0002, 2-47815H0004, 2-47815H0006, 2-47815H0008, 2-47815H0010, and 2-47815H0012, the licensee would only be required to remove a pipe clamp.
The licensee has not provided supporting documentation to show that removal of the pipe clamp to perform the Code-required examination is impractical per 10CFR50.55a(g)(6)(i).
Based on incomplete supporting documentation, the staff concluded that for support numbers 2-47815H0002.
2-47815H0004.
2-47815H0006, 2-47815H0008, 2-47815H0010.
and 2-47815H0012, relief is denied.
3.
CONCLUSIONS In response to an NRC request for additional information dated September 9.
1997. the licensee withdrew Requests for Relief 2-SPT-9, 2-SPT-ll, and 2-SPT-12.
The staff concluded that the licensee's proposed alternative contained in Request for Relief 2-SPT-10 (as revised September
- 9. 1997), provides an acceptable level of quality and safety.
Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
The staff has concluded that for Supports 2-478415S009, 2-478415S023, and 2-478415S025 as listed in Request for Relief 2-ISI-7 (as revised September 9,
1997), the licensee has demonstrated that the specific Section XI requirement is impractical.
Therefore.
the staff concluded that pursuant to 10 CFR 50.55a(g)(6)(i) relief is granted.
Furthermore.
the granting of relief will not endanger life, property.
or the common defense and security and is otherwise in the public interest.
giving due consideration to the burden upon the licensee that could result if the requirement were imposed on the facility.
For Supports 2-47815H0002.
2-47815H0004, 2-47815H0006.
2-47815H0008.
2-47815H0010, and 2-47815H0012.
as listed in Request for Relief 2-ISI-7 (Revised 9/9/97), the staff has concluded that relief is denied because the licensee did not demonstrate that the specific Section XI requirements were impractical.
Principal Contributor:
T. HcLellan Dated:
October 16, 1997
TECHNICAL LETTER REPORT SECOND 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUESTS 2-SPT-9 THROUGH 2-SPT-12 AND 2-ISI-7 FOR TENNESSEE VALLEYAUTHORITY BROWNS FERRY NUCLEAR'PLANT UNIT 2 DOCKET NUMBER 50-260
1.0 INTRODUCTION
By letter dated June 4, 1997, the licensee, Tennessee Valley Authority (TVA),
submitted Relief Requests 2-SPT-9 (Revised), 2-SPT-10, 2-SPT-11, 2-SPT 12, and 2-ISI-7 (Revised) for the second 10-year inservice inspection interval.
In a September 9, 1997, response to an NRC request for additional information, TVA submitted additional revisions to Relief Requests 2-SPT-10 and 2-ISI-7, and withdrew Relief Requests 2-SPT-9, 2-SPT-11, and 2-SPT-12.
The Idaho National Engineering and Environmental Laboratory (INEEL) staff has evaluated the licensee's submittals in the following section.
2.0 EVALUATION The second 10-year inservice inspection (ISI) interval for Browns Ferry Nuclear Plant, Unit 2, started May 24, 1992.
The Code of record for the second 10-year interval is the 1986 Edition of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.
The information provided by the licensee in support of the requests for relief has been evaluated and the bases for disposition are documented below.
ENCLOSURE 2
2.1 Re uest for Relief 2-SPT-9 Revised Use of ASME Code Case N-498-2 Alternative Re uirements for 10-Year S stem H drostatic Testin for Class 1 2 and 3 S stemsSection XI Division 1
Revised Request for Relief 2-SPT-9 was withdrawn by the licensee in the
, submittal dated September 9, 1997.
This Relief Request was a revision to 2-SPT-9 (invoking Code Case N-498-1) as previously submitted by TVA March 9, 1995, and subsequently accepted by NRC letter dated August 18, 1995.
2.2 Re vest for Relief 2-SPT-10 Revised 9 9 97 Use of ASME Code Case N-546 Alternative Re uirements for Qualification of VT-2 Examination Personnel Code Re uirement: ASME Section XI, 1986 Edition, Subsection IWA-2300 requires that personnel performing VT-2 visual examinations be qualified and certified using a written program prepared in accordance with IWA-5240 and shall have comparable levels of competency as defined in ANSI N45.2.6.
Licensee's Pro osed Alternative: Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the qualification requirements for VT-2 visual examiners.
The licensee stated:
"As an alternative to the existing ASME Section XI requirements, BFN will utilize the provisions of ASME Code Case N-546 and additional criteria. ASME Code Case N-546 states:
Personnel m'ust have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and non-licensed plant operators, local leak rate personnel, system engineers, and inspection and non-destructive examination personnel.
Individuals must have at least four hours of training in Section XI requirements and plant specific procedures for visual examinations.
I
Each person must meet (annual) vision test requirements in accordance with the 1995 Edition of the ASME Section XI Code, Paragraph IWA-2321
~
"In addition to the requirements of ASME Code Case N-546, TVAwill also.
Develop procedural guidelines for obtaining consistent quality VT-2 visual examinations.
Document and maintain records to verify the qualification of personnel selected to perform VT-2 visual examinations.
Implement independent review and evaluation of leakage by persons other than those that performed the VT-2 visual examinations.'icensee's Basis for the Pro osed Alternative: (as stated)
"The use of Code'Case N-546, 'Alternative Requirements for Qualification of VT-2 Examination Personnel,'ill allow experienced plant personnel to perform VT-2 visual examinations during the performance of system pressure tests and provide an acceptable level of quality and safety.
"Experienced plant personnel are knowledgeable of the plant systems and routinely perform walkdowns of plant systems looking for abnormalities such as leaks in piping systems.
They are more familiar with the location of piping systems and can therefore perform VT-2 examinations in a more timely manner.
Using experienced plant personnel will also eliminate the need for hiring additional personnel fully certified to IWA-2300. This is especially pertinent during refueling outages when pressure tests are performed and the number of IWA-2300 certified personnel are limited.
"Since the VT-2 examination is a check for the evidence of leakage, the use of plant personnel qualified to the N-546 alternative requirements, and who typically perform this type of examination during their daily activities, will not compromise the quality or safety of the systems examined.
"Compliance with the specified ASME Code requirements would result in an undue hardship without a compensating increase in the level of quality and safety.
TVA considers the ASME Code Case N-546 requirements to be an acceptable alternative to the qualification of VT-2 (visual examination personnel) using a written, approved procedure prepared in accordance with SNT-TC-1A and the additional requirements of ASME Section XI, Division 1."
Evaluation: The Code requires that VT-2 visual examination personnel be qualified to comparable levels of competency as defined in ANSI N45.2.6.
The
l
Code also requires that the examination personnel be qualified to near and far distance vision acuity.
The licensee proposed to implement the alternative contained in Code Case N-546 which requires that VT-2 visual examiners meet the following requirements:
~
Personnel must have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.
~
Personnel must receive at least four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examination.
~
Personnel must meet the vision test requirements of IWA-2321, 1995 Edition.
The qualification requirements in Code Case N-546 are not significantly different from those for VT-2 visual examiner certification.
Licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts.
This knowledge makes them acceptable candidates for performing VT-2 visual examinations.
In addition to the requirements in Code Case N-546, the licensee proposed to:
~
Develop procedural guidelines for consistent, quality VT-2 visual examinations;
~
Verify and maintain records of the qualification of persons selected to perform VT-2 examinations;
- and,
~
Perform independent reviews and evaluations of leakage by persons other than those that performed the VT-2 visual examinations.
The staff requires these conditions to ensure consistent implementation of the Code Case.
Based on the above, the INEEL staff believes that the licensee's proposed alternative will provide an acceptable level of quality and safety.
Therefore, it is recommended that the licensee's request to implement Code Case N-546 with the additional commitments stated by the licensee be authorized pursuant to
Use of Code Case N-546 should be authorized for the current interval or until such time. as the Code Case is published in Regulatory Guide 1.147.
From that time, if the licensee intends to continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-546, if any.
2.3 Re uest for Relief 2-SPT-11 Use of ASME Code Case N-566 Corrective Action for Leaka e Identified at Bolted Connections The licensee withdrew Request for Relief 2-SPT-11 in the submittal dated September 9, 1997.
2.4 Re uest for Relief 2-SPT-12 Use of ASME Code Case N-522 Pressure Testin of Containment Penetration Pi in The licensee withdrew Request for Relief 2-SPT-12 in the submittal dated September 9, 1997.
2.5 Re uest for Relief 2-ISI-7 Revised 9 9 97 ASME Section XI Examination Cate or 8-K-1 Item 810.10 Inte rail Welded Attachments to Class 1 Pi in Code Re uirement:
Table IWB-2500-1, Examination Category B-K-1, Item 810.10, requires (as applicable) a volumetric or surface examination, as defined by Figure IWB-2500-15, for integrally-welded attachments with base material design thickness greater than or equal to 5/8 inch.
Licensee's Code Relief Re uest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from performing the volumetric or surface examinations (as applicable) to the extent required by the Code for the following Class 1
integrally welded attachments in the Feedwater System:
s 4
l i1
,,'4 I
1
'I
,P 0
- .':Exam",::
2-47B41 5S0009 63%
2-47B41 5H0002 88%
2-47B41 5H0004 88%
2-47B41 5H0006 88%
2-47B41 5H0008 88%
2-47B41 5H0010 88%
2-47B41 5H001 2 88%
2"'47B41 5S0023 21 %
2-47B41 5S0025 21 %
':':;::::.':;',';:,: ~i:;.":;:::::;i,';',::::;::.;::,':::.::::::."kntecrfec'r'e'r'ice)-':';':-',it!::...':::~",."-':.-,'::,j'~"':;:
Box shape (welded on both sides)-
interior weld not accessible 4 welded lugs - examination limited by pipe clamp (same as above)
(same as above)
(same as above)
(same as above)
(same as above) 4 welded lugs inside circular frame-limited by circular frame and shims (same as above)
Licensee's Basis for Re uestin Relief (as stated):
"In accordance with 10 CFR 50.55a(g)(5)(iii), TVA has determined that the above Code inspection requirements are impractical for certain integrally welded supports.
For those supports, (see attached list) TVA is requesting relief from the ASME Section XI, 1986 Edition (no addenda),
Table IWB-2500-1, Examination Category B-K-1, Item B10.10, requirements to perform a volumetric or surface examination, as applicable, of essentially 100 percent of the examination volume/area.
"In some cases this examination would require the removal of support members to achieve the coverage required by the ASME Code.
Estimates for the duration and costs for activities associated with the temporary removal, examination, and reinstallation of these ASME Class 1 supports are listed below:
~Activit Engineering evaluation of temporary support Duration (man-hrs) 20 Craft time for support member removal, installation of temporary support, and support reinstallation 100 Quality Control verification of activity 5
~,
"Examination of the accessible areas of the integral attachment welds for the nine supports without removal of support members would result in an estimated savings of approximately
$40,000 for personn'el and materials, and approximately 55 man-rems of exposure, which equates to $ 550,000 during the remaining BFN Unit 2 inservice inspection intervals.
This equates to a total savings of $ 590,000 for the nine supports.
"The limitations encountered during the performance of surface examinations are caused by component configuration, Based on a construction permit date prior to January 1, 1971, and the requirements of 10 CFR 50,55a(g)(1) and 10 CFR 50.55a(g)(4),
BFN components (including supports) must meet the requirements of ASME Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
BFN Unit 2 was not designed to provide access for ASME Section XI examinations of this type.
"The surface examination of the subject integral attachments (for the accessible surfaces only) provides an effective assessment of the structural integrity of the integral attachments."
Licensee's Pro osed Alternative Examination (as stated):
"Perform the required examination method from Table IWB-2500-1, Examination Category B-K-1, Item Number B10.10, for the accessible examination volume/area only, of the support integral attachments without removal of support members.
"Note:
The examination of the accessible areas of integral attachments without removal of support members was approved for a future Code revision by the ASME Section XI committee during their March 1995 meeting and incorporated into the 1995 ASME Section XI Addenda."
Evaluation:
The Code requires a 100/o surface/volumetric examination (as applicable) of the nine subject welded attachments.
The licensee stated that portions of these integrally attached support welds are inaccessible.
For example, support number 2-47B415S0009 is box-shaped and welded on both sides.
Access is limited to the exterior welds and areas of the interior welds near the opening of the box. Additionally, support numbers 2-47B415S0023 and 2-47B415S0025 are integrally welded attachments consisting of 4 lugs inside a circular frame with shims adjacent to the lugs.
The examination of these two supports is limited by the structural frame and shims, therefore an
I X )
J
examination, to the extent required by the Code, is impractical based on geometric configurations.
In order to perform a 100% examination, the three supports described above would require redesign and replacement.
Considering the large percent of integral attachments receiving 100% coverage, and the partial coverage being obtained for these three integrally welded attachments, it can be concluded that a pattern of degradation, if present, will be detected.
As a result, reasonable assurance of structural integrity is provided.
Therefore, for Supports 2-47B415S0009, 2-47B415S0023, and 2-47B415S0025, it is recommended that relief be granted as requested, pursuant to 10 CFR 50.55a(g)(6)(i).
However, to examine 100% of the Code-required area/volume of support numbers 2-47B15H0002, 2-47B15H0004, 2-47815H0006, 2-47B15H0008, 2-47815H0010, and 2-47B15H0012, the licensee would only be required to remove a pipe clamp.
The licensee has not provided supporting documentation to show that removal of the pipe clamp to perform the Code-required examination is impractical, therefore, relief cannot be granted in accordance with 10 CFR 50.55a(g)(6)(i).
Based on the lack of supporting documentation, it is recommended that for support numbers 2-47B15H0002, 2-47B15H0004, 2-47B15H0006, 2-47B15H0008, 2-47B15H0010, and 2-47B15H0012, relief be denied.
3.0 CONCLUSION
The licensee'withdrew Requests for Relief 2-SPT-9 (Revised), 2-SPT-11, and 2-SPT-12, in a September 9, 1997, response to an NRC request for additional information.
Pursuant to 10 CFR 50.55a(a)(3)(i), it has been concluded that for Request for Relief 2-SPT-10 (Revised 9/9/97), the licensee's proposed alternative will provide an
acceptable level of quality and safety.
Therefore, it is recommended that the licensee's proposed alternative be authorized.
Pursuant to 10 CFR 50.55a(g)(6)(i), it has been concluded that for Supports 2-47B415S009, 2-47B415S023, and 2-47B415S025 as listed in Request for Relief 2-ISI-7 (Revised 9/9/97), the licensee has demonstrated that the specific Section XI requirement is impractical and it is recommended that relief be granted.
The granting of relief will not endanger life, property, or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirement were imposed on the facility.
For Supports 2-47B15H0002, 2-47B15H0004, 2-47B15H0006, 2-47B15H0008, 2-47B15H0010, and 2-47B15H0012, as listed in Request for Relief 2-ISI-7 (Revised 9/9/97), the licensee has not demonstrated that the specific Section XI requirement is impractical and it is therefore recommended that relief be denied.
E.
4