ML17275A843
| ML17275A843 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/20/1981 |
| From: | Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| GO2-81-29, NUDOCS 8103030613 | |
| Download: ML17275A843 (28) | |
Text
REGULATORY FORMATION DISTRIBUTION SY M (RIDS)
ACCESSION NBR o 8103030613 DOC ~ DATE: 81/02/20 NOTARIZED: YES'OCKET' FACIL:50-397 HPPSS Nuclear Projects Unit 2g 'llashjngton Public Powe 05000397 AUTH ~ NAME
'UTHOR AFFILIATION BOUCHEYgG ~ DE Washington Public Power Supply System REC IP ~ NAME, RECIPIENT AFFILIATION YOUNGBLOODrB.J.
Licensing Branch 1
SUBJECT:
Forwards hardship exemption request for accepting as is sacrificial sheield wall weld defects identified as being in violation of ANS D1.1~Revisions 1-73 Code. Certificate'f Svc encl.
DISTRIBUTION CODE:
8006S COPIES RECEIVED:LTR ENCL SIZE:
r TITLE: Requests for Exemptions (Al l Types)
NOTES:PM: 2'opies of al l mater ial.
05000397 RECIPIENT ID CODE/NAME
'ACTION:
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Washington Public Power Supply System, A JOINT OPERATING AGENCY P.O. BOX 968 3000 GEO. WASHINGTONWAY RICHLAND,WASHINGTON 99352 PHONE I509) 372.5000 February 20, 1981 G02-81-29 Docket No.
50-397 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.
C.
20555 Attention:
Mr. B. J.
Youngblood, Chief Licensing Branch No.
1 Division of Licensing
Dear Mr. Youngblood:
Subject:
WPPSS NUCLEAR PROJECT NO.
2 HARDSHIP EXEMPTION REQUEST WNP-2 SACRIFICIAL SHIELD WALL
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Reference:
Letter G02-81-25, dated February 17,
- 1981, GD Bouchey (WPPSS) to RL Tedesco (NRC), subject "Sacrificial Shield Wall Repairs" Attached herewith is a hardship exemption request for accepting as-is some specific SSW weld defects identified as being in violation of the AWS Dl.l (Rev.
1-73)
Code.
The balance of the SSW weld defects identi-fied as being in violation of the code will be repaired to meet the code requirements.
This was mentioned in the reference letter andis per the a,greed upon understanding from the January 22nd meeting with you concerning the open items remaining on your review of the WNP-2 Sacriftcial Shield Wall (SSW).
With your approval of this hardship exemption'request, it is our under-standing that all NRR concerns with the WNP-2 Sacrificial Shield Wall will have been resolved.
Accordingly, we request your expedited 'review and approval of this request and associated release from the current
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Washington Public Power Supply System BJ Youngblood February 20, 1981 Page 2
G02-81-29 technical hold on construction activities involving the Sacrificial Shield Wall.
This will allow us to proceed with work activities on the wall at the earliest possible times so as to minimize critical path schedule impacts in the drywell.
In summary, out II) 156 AWS Dl.l defects identified, the following is the disposition:>
(1) 115 defects will be repaired to meet AWS Dl.l, (2) 20 defects upon reevaluation were found to be in 'conformance with /5lS Dl.l, (3) 5 defects are requested to be considered for hardship exemption based upon the original visual inspection criteria, and (4) 16 subsurface or internal defects are requested to be considered for hardship exemption which were discovered during the ultra-sonic examinations associated with the SSW evaluation.
This number reflects 140 visually identified defects and 16 defects 1/
identified by ultrasonic examination during the SSW evaluation by the Supply System.
For all future work activities on the Sacrificial Shield Wall excluding those discussed herein and in the previous SSW submittals to NRR, the Supply System will implement normal Project technical controls (recog-nizing confirmed NRC Region V holds and interface requirements).
Very truly yours,
Attachment:
Hardship Exemption Request G.
. Bouchey Director, Nuclear Safety cc w/att:
G. Georgiev - NRC, I8E Headquarters D. Smith - NRC, NTEB HD Lynch - NRC, DOL AD Toth - NRC, Resident Inspector - WNP-2 RH Engelken - Director, Region V
JJ Verderber - Burns 5 Roe, N.Y.
W. Wood -
NUS Corporation ND Lewis - EFSEC, Olympia, Wash.
WS Chin - Bonneville Power Admin.
WNP-2,Files
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-g a
SUBJECT:
WNP-2 HARDSHIP EXEMPTION REQUEST WNP-2 SACRIFICIAL SHIELD WALL STATE OF WASHINGTON) ss COUNTY OF BENTON
)
I, G.
C.
- SORENSEN, being duly sworn, subscribe to and say that I am acting for the Director, Nuclear Safety, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information and belief the statements in it are true.
DATED aP-
, 1981 G.
C.
SO ENSEN On this day personally appeared before me G.
C.
SORENSEN to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mentioned.
GIVEN under my hand and seal this ~9~ day of
, 1981.
NOT RY PUBLIC in and fan the State of Washington, residing at:
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, lb V
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Attachment Hardship Exemption Request For Acceptance As-Is of Certain Identified Meld Defects In The WNP-2 Sacrificial Shield Mall in Violation of AWS Dl.l Rev.
1-'73 l.
'Summar During the reinspection of the WNP-2 Sacrificial Shield Wall (SSW), weld defects were found and identified in the accessible portions of the wall which were in violation of the specified welding code for the
- SSW, AWS Dl.l (Rev. 1-73).
References (1) and (2) discussed in detail the implications of the defects and found that, with incorporation of a replacement girth weld at the 501'levation construction joint, the design margins in the structure were adequately maintained considering the defects in the wall remained.
This was considered by the Supply System to be an adequate disposition of a code nonconformance as allowed by AWS Dl.l, paragraph 3.7.6.
The Office of Nuclear Reactor Regula-tion, U. S. Nuclear Regulatory Commission, maintained the policy, however, that all identified weld defects in violation of the Code should be brought into conformance with the Code unless specific weld-by-weld hardship exemption was requested by the applicant and approved by the NRC.
Such hardship exemptions would have to be on a weld-by-weld basis and have adequate justification to be approved.
Accordingly, after a meeting with the NRC on January 22, 1981, Where the policy was stated, the Supply System agreed to:
(1)
Repair the identified weld defects to meet the AWS Dl.l Code requirements, or (2)
Request a hardship exemption to the code with justification on a weld-by-weld basis-In item (2) below are listed the specific hardship exemption requests.
2.
Hardshi Exem tion'Re uests A.
Requests for Exemption from Visually Discovered Defects Below are listed five (5) requests for hardship exemption on weld defects in violation of AWS Dl.l visual inspection criteria.
In summary, the requests are made since the
1 Attachment Page 2 of 14 defects are, for the most part, of a cosmetic nature and are located in areas of high restraint, where repair could possibly induce more serious defects.
It should also be noted that these defects were considered in the engineering assessment of Reference 1, Sections III C and III D.
(1)
Weld No.'W130-'197 Weld Type: 0:H.'illet; 3/8" Weld Location:
EL:559'Z 318 Type Inspection:
'VT
Defect
Description:
Underfill 1/16" deep for entire weld (30")
Justification for Hardship:
Defective area is highly restrained per criteria of Table 1.
It is less than 7" from pipe whip restraint PWS 28-1B.
The thickness of material at the location of the defects is 2-1/2".
(2)
Weld No.: W3-'92'eld Type:
'Electrosla Weld Weld Location:
El:'520'Z'.170 Type Inspection:'T''''
Defect
Description:
Porosity - See figure 2 for detail.
Justification for Hardship:
Defective area is highly restrained per criteria of Table 1..Defective area is adjacent to skin plate fillet weld and is approximately 6-1/2" from a pipe whip restraint fillet weld.
The thickness of the material at the location of the defect is
, 1-1/2".
~
Attachment Page 3 of 14 (3)
Weld No.;
WF 23-87 Weld Type:
OH II VERT 5 8" Fillet Weld Location: EL'30'z 100 Type Inspection:
VT Defect
Description:
Crater fill - one area 1/4" L8ng x 1/4" wide x 3/32" deep at 100 Az, one area 1/2" long x 1/8" wide k%
1/8" deep at 2" to right of 110 Az.
Excessive reinforcement - 1/8" height x 4" long at vertical portion of weld.
Justification for Hardship:
Hardship exemption requested on 2 parts of this weld:
1.
Zone containing crater fill defect is 1-1/2" from toe of 1-1/2" fillet attaching a pipe whip restraint support.
Thickness of material at location of defect is 3/4". It is highly restrained per Table l.
2.
There is no access to a 5" portion of this weld where it passes behind a support member.
(4}
Weld No.
'WF-130-'119 Meld Type:'OR:'3 8" Fillet Weld Location:'l 560'Az'52 Type Inspection:VT Defect
Description:
Overlap - 1/16" height intermittent for entire weld length.
Justification for Hardship:
Hardship exemption requested as contingency if grinding of fillet weld produces unders'ize condition.
Over part of length of weld the toe of W131-238 overlaps buttered area under a pipe whip support column and is within 2" of the butt weld attaching the column to the wall.
The thickness of material at the defect location is 1-1/2".
This meets criterion for severe restraint in Table l.
In addition, if the undersize situation results, the condition would be enveloped by the engineering assess-ment of Reference 1.
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Attachment Page 4 of 1 4
( 5 )
Wel d No. :
W23-24 Wel d Type :
Yertical El ectros 1 a Weld Location : 'l 533'z 1 60 Type Inspection :
VT Defect Des cripti on :
Poros ity - See Fi gure 3 for deta i 1.
Justification for Hardship :
Repair wi 1 1 possibly "require excavati on through thickness of el ectros 1 ag wel d to remove poros ity.
This wi 1 1 requ ire chipping of concrete, fitting of backing plate and rewel ding.
Also if pores extend along 1 ength of weld, skin plates will have to be r emoved and weld excavated.
The nature of this defect does not war r ant repair s ince the extens ive nature of thi s repai r increases risk of generating more ser ious defects.
r B.
Requests for Exemption from Defects discovered through Ultra-'onic (UT) Examination Listed below are ten (10) requests for hardship exemption on sixteen (16) individually numbered welds which were discoverdd by UT examination of the Sacrificial Shield Wall during the Supply System's investigation of the wall.
The defects,
'eing for the most part inaccessible, were subsequently evaluated and considered acceptable based on-the justification presented in Reference (1).
l Attachment Page 5 of 14 SHAW Justification for Hardship:
l.
Only 12" of weld is accessible
- remainder of weld
's behind attachments or behind skin'plates.
2.
Repair would require removing attachments and skin plates, cutting through wall, chipping concrete, installing backing plate and rewelding.
3.
Nature of defect does not warrant such extensive rework with potential for creating serious defects.
(1)
Weld No.
W4-65 Weld Type:
Weld Location:
El 528'z 330 Type Inspection:
Description:
Incomplete penetration in Type C
weld.
(Figure 1) 5j W113-4 (2)
Me1d Mo.M113-6 Meld Type:
FCAW Weld Location:El'552'Az'112 Type Inspection:
YT;'UT'efect
==
Description:==
Incomplete penetration in Type A
weld joint.
(Figure 1)
Justification. for Hardship:
1.
Ot total weld length of 2'7",only 1'5" is accessible.
The remainder is behind a pipe whip restraint.
2.
To repair the accessible part it would be necessary to excavate through the wall into the stiffener plate.
3.
Nature of the defect does not warrant such extensive rework with a potential for creating serious defects.
4.
Access is limited by a main steam line which is 15" from the
$SW.
t W
Attachment Page 6 of 14 Gg8 W113-12 3)
Weld No.
W113-14 Weld Type:
Weld Location:
El 552'z 247 Type Inspection:
Description:
Incomplete penetration in Type A weld joint (figure 1)
Justification for Hardship:
l.
Of total weld length 2'7" only 1'5" is accessible.
The remainder is behind a pipe whip restraint.
2.
To repair the accessible part it would be necessary to excavate through the wall into the stiffener
~
plate.
3.
Nature of the defect does not warrant such extensive rework with a potential for creating serious defects.
4.
Access is limited by a main steam line which is 15" from the SSW.
(4)
Weld Location:
El 551'Az 253 Type Inspection:
Description:
Defect is 15" long with a DB rating of +3 which makes it a large reflector per AWS Dl.l for electroslag welds.
Defect is located at" 1-5/8" from the outside s'urface of the SSW.
See weld type D (Figure~1).
Justification for Hardship:
1.
Of 20" total length of weld, 16" is accessible.
Remainder lies behind skin plates.
2.
Defect apparently not in weld but in backing bar.
3 Removal would require cutting through wall and removing skin plates.
4.
Nature of defect does not warrant such extensive repair with potential for creating serious defects.
5.
Access is limited by main steam line which is 15" from the'wall.
W114-6 (5)
Weld No.
W114-4 Weld Type:
Weld Location:
EL. 552 Az 84 Type Inspection:
VT, UT Attachment Page 7 of 14 5/S 5j FCAW Defect Descr iption:
Incomplete penetration in Type A weld joint. (Figure 1)
Justification for Hardship:
1.
Weld is 2'8-1/2" long.
Only 12" are accessible.
Remainder is behind a pipe whip restraint.
2.
To repair the accessible part it would be necessary to excavate through the wall into the stiffener plate.
3.
Nature of defect does not warrant such extensive rework with a potential for creating serious defects.
'~a W114-12 (6)
Weld No.
W114-14 Weld Type:
Weld Location:EL552'z 285 J
Type Inspection; YT, UT FCAW Defect Inspection:
Incomplete penetration in Type A weld joint (Figure 1)
Justification for Hardship:
1.
Weld is 2'8-1/2" long'.
Only 12" are accessible.
Remainder is behind a pipe whip; restraint.
2.
To repair the accessible part it would be necessary to excavate through the wall into the stiffener plate.
3.
Nature of defect does not warrant such extensive rework with a potential for creating serious defects.
Attachment Page 8 of 14 jl
)
I FCAW (7)
Weld No.
W145-29 Wel d Type:
Groove flat Weld Location: 'EL554'z 240 Type Inspection:
Description:
Incomplete penetration in Type B weld joint. (Figure 1) 2.
Half of the weld is highly restrained being only, 2-1/2" from large pipe whip restraints.
3.
Nature of defect does not warrant such extensive repair with potential for creating serious defects.
jt FCAW (8)
Wel d No.
W145-23 Wel d Type:
Weld Location:El'554
Az'120 Type Inspection:VT; UT Defect
Description:
Incomplete penetration in Type B
weld joint (Figure 1)
Justification for Hardship:
Justification for Hardship:
1.
Repair would require extensive gouging and grinding with potential for cutting through wall.
Rewelding would require extensive preheating of a highly restrained area (per criteria of Table 1).
l.
Repair would require extensive gouging and grinding with potential for. cutting through wall.
Rewelding would require extensive preheating of a highly 1"estr ained area (per criteria of Table 1).
2.
Half of the weld is highly restrained being only 2-1/2" from large pipe whip restraints.
3.
Nature of defect does not warrant such extensive repair with potential for creating serious defects.
t Attachment "
Page 9 of 14 5p FCAvl 5'ustification for Hardship:
l.
Of 2'6" total length of weld only 1'3" are accessible.
The remainder is behind a pipe whip restraint.
2.
To repair the accessible part it would be necessary to excavate through the wall into the stiffener plate.
3.
Nature of defect does not warrant such extensive rework with a potential for creating serious defects.
W113-28 (9)
Weld No.
W113-30 Weld Type'eld Location:
El 552'z 264 Type Inspection:
Description:
Incomplete penetration in Type A
weld joint (Figure 1)
W113-20 (10)
Weld Location:
El'552'z 96 Type Inspection:'T; UT" 5~
FcAw 5g Defect
Description:
Incomplete penetration in Type A
weld joint (Figure 1)
Justification for Hardship:
l.
Of 2'7" total length of weld, only 1-'4" are accessible.
The remainder is behind a pipe whip restraint.
,2.
To repair the accessible part, it would be necessary to,excavate through the wall into the stiffener plate.
3.
Nature of defect does not warrant such extensive rework with'a potential for creating serious defects.
4.
In addition repair access is limited by a 13" OD vertical pipe running 15" from the SSW.
Attachment Page 30 of 14 3.
References (1)
"Engineering Evaluation of the HNP-2 Sacrificial Shield Wall", a report transmitted by letter, D. L. Renberger (WPPSS) to B. J.
Youngblood (NRC),'ubject "Engineering Evaluation of the Sacrificial Shield Wall", letter number C~02-80-167, dated August 1, 1980 (2)
"Engineering Evaluation of the WNP-2 Sacrificial Shield Wall, Supplement No. 1", a supplement to Reference (1),
transmitted by letter D. L. Renberger (WPPSS) to B. J.
Youngblood (NRC), subject "Engineering Evaluation of the Sacrificial Shield Wall (SSW)", letter number G02-80-182, dated August 19, 1980
Attachment Page ll of 14 Table 1
Criteria for'Hardshi Exem tion Based U on Restraint o
Where severe restraint exists, there is a significant risk that repair of the workmanship defects will lead to additional, more damaging defects such as cracks.
o The whole SSW is in a condition of some restraint.
Severe restraint exists where additional heavy members are welded to the wall.
o If the workmanship defect lies within a distance of 5T (where T
is the thickness of the underlying SSW material) from the toe of an attachment weld,.then it is considered to lie in a region of high restraint provided the attachment weld is greater than 1" (leg length for fillet; throat for butt weld).
o The distance of 5T was judged to define a zone within which the residual stresses from the attachment will have a potential for affecting the integIity of the repair.
FIGURE 1
Attachment Page 12 of 14 CATEGORIES OF MELD JOINTS WHICH CONTAIN BURIED DEFECTS, DETECTED BY UT TYPE A TYPE B
ROOT INDICATIONS
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~:o' NOTE'TRUCTURAL ACCEPTABILITY OF THESE DEFECTS WAS DETERt1INED AND REPORTED IN REFERENCE 81.
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