Forwards hardship exemption request for accepting as is … · 2018-06-27 · Attachment Hardship Exemption Request For Acceptance As-Is of Certain Identified Meld Defects In The

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 AFFILIATIONBOUCHEYgG ~ DE Washington Public Power Supply System

REC IP ~ NAME, RECIPIENT AFFILIATIONYOUNGBLOODrB.J. Licensing Branch 1

SUBJECT: Forwards hardship exemption request for accepting as issacrificial sheield wall weld defects identified as being inviolation of ANS D1.1~Revisions 1-73 Code. Certificate'f Svcencl.

DISTRIBUTION CODE: 8006S COPIES RECEIVED:LTR " ENCL SIZE:rTITLE: Requests for Exemptions (Al l Types)

NOTES:PM: 2'opies of al l mater ial. 05000397

RECIPIENTID CODE/NAME

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Washington Public Power Supply System,A JOINT OPERATING AGENCY

P.O. BOX 968 3000 GEO. WASHINGTON WAY RICHLAND,WASHINGTON 99352 PHONE I509) 372.5000

February 20, 1981G02-81-29

Docket No. 50-397

U. S. Nuclear Regulatory CommissionOffice of Nuclear Reactor RegulationWashington, D. C. 20555

Attention: Mr. B. J. Youngblood, ChiefLicensing Branch No. 1

Division of Licensing

Dear Mr. Youngblood:

Subject: WPPSS NUCLEAR PROJECT NO. 2HARDSHIP EXEMPTION REQUESTWNP-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 "SacrificialShield Wall Repairs"

Attached herewith is a hardship exemption request for accepting as-issome specific SSW weld defects identified as being in violation of theAWS 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 thecode requirements. This was mentioned in the reference letter and„isper the a,greed upon understanding from the January 22nd meeting withyou concerning the open items remaining on your review of the WNP-2Sacriftcial 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 Wallwill have been resolved. Accordingly, we request your expedited 'reviewand approval of this request and associated release from the current

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Washington Public Power Supply SystemBJ Youngblood February 20, 1981Page 2 G02-81-29

technical hold on construction activities involving the SacrificialShield Wall. This will allow us to proceed with work activities onthe wall at the earliest possible times so as to minimize critical pathschedule impacts in the drywell.

In summary, out II) 156 AWS Dl.l defects identified, the following isthe disposition:>

(1) 115 defects will be repaired to meet AWS Dl.l,

(2) 20 defects upon reevaluation were found to be in 'conformancewith /5lS Dl.l,

(3) 5 defects are requested to be considered for hardship exemptionbased upon the original visual inspection criteria, and

(4) 16 subsurface or internal defects are requested to be consideredfor hardship exemption which were discovered during the ultra-sonic examinations associated with the SSW evaluation.

This number reflects 140 visually identified defects and 16 defects1/

identified by ultrasonic examination during the SSW evaluation bythe Supply System.

For all future work activities on the Sacrificial Shield Wall excludingthose discussed herein and in the previous SSW submittals to NRR, theSupply 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. . BoucheyDirector, Nuclear Safety

cc w/att: G. Georgiev - NRC, I8E HeadquartersD. Smith - NRC, NTEBHD Lynch - NRC, DOLAD Toth - NRC, Resident Inspector - WNP-2RH Engelken - Director, Region VJJ Verderber - Burns 5 Roe, N.Y.W. Wood - NUS CorporationND Lewis - EFSEC, Olympia, Wash.WS Chin - Bonneville Power Admin.WNP-2,Files

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SUBJECT: WNP-2 HARDSHIP EXEMPTION REQUESTWNP-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 actingfor the Director, Nuclear Safety, for the WASHINGTON PUBLIC POWER SUPPLYSYSTEM, the applicant herein; that I have full authority to execute thisoath; that I have reviewed the foregoing; and that to the best of myknowledge, 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 tobe the individual who executed the foregoing instrument and acknowledgedthat he signed the same as his free act and deed for the uses and purposestherein mentioned.

GIVEN under my hand and seal this ~9~ day of , 1981.

NOT RY PUBLIC in and fan the Stateof Washington, residing at:

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Attachment

Hardship Exemption RequestFor Acceptance As-Is of

Certain Identified Meld DefectsIn 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 accessibleportions of the wall which were in violation of the specifiedwelding code for the SSW, AWS Dl.l (Rev. 1-73). References (1)and (2) discussed in detail the implications of the defects andfound that, with incorporation of a replacement girth weld at the501'levation construction joint, the design margins in thestructure were adequately maintained considering the defects inthe wall remained. This was considered by the Supply System to bean adequate disposition of a code nonconformance as allowed byAWS 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 Codeshould be brought into conformance with the Code unless specificweld-by-weld hardship exemption was requested by the applicant andapproved by the NRC. Such hardship exemptions would have to be ona 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 Coderequirements, or

(2) Request a hardship exemption to the code with justificationon a weld-by-weld basis-

In item (2) below are listed the specific hardship exemptionrequests.

2. Hardshi Exem tion'Re uests

A. Requests for Exemption from Visually Discovered Defects

Below are listed five (5) requests for hardship exemptionon weld defects in violation of AWS Dl.l visual inspectioncriteria. In summary, the requests are made since the

1AttachmentPage 2 of 14

defects are, for the most part, of a cosmetic nature andare located in areas of high restraint, where repair couldpossibly induce more serious defects. It should also benoted that these defects were considered in the engineeringassessment 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 entireweld (30")

Justification for Hardship:

Defective area is highly restrained per criteria ofTable 1. It is less than 7" from pipe whip restraintPWS 28-1B. The thickness of material at the locationof the defects is 2-1/2".

(2) Weld No.: W3-'92'eld Type: 'Electrosla Weld

Weld Location: El:'520'Z'.170Type Inspection:'T'''''''''Defect Description: Porosity - See figure 2 for detail.


Defective area is highly restrained per criteriaof Table 1. .Defective area is adjacent to skinplate fillet weld and is approximately 6-1/2" froma pipe whip restraint fillet weld. The thicknessof the material at the location of the defect is

, 1-1/2".

~ AttachmentPage 3 of 14

(3) Weld No.; WF 23-87 Weld Type: OH II VERT 5 8" FilletWeld Location: EL'30'z 100

Type Inspection: VT

Defect Description: Crater fill - one area 1/4" L8ng x1/4" wide x 3/32" deep at 100 Az,one area 1/2" long x 1/8" wide

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1/8" deep at 2" to right of 110 Az.Excessive reinforcement - 1/8"height x 4" long at vertical portionof weld.


Hardship exemption requested on 2 parts of this weld:

1. Zone containing crater fill defect is 1-1/2" fromtoe of 1-1/2" fillet attaching a pipe whip restraintsupport. Thickness of material at location of defectis 3/4". It is highly restrained per Table l.

2. There is no access to a 5" portion of this weldwhere it passes behind a support member.

(4} Weld No. 'WF-130-'119 Meld Type:'OR:'3 8" FilletWeld Location:'l 560'''Az'52

Type Inspection:''VTDefect Description: Overlap - 1/16" height intermittent

for entire weld length.


Hardship exemption requested as contingency if grindingof fillet weld produces unders'ize condition. Over partof length of weld the toe of W131-238 overlaps butteredarea under a pipe whip support column and is within 2"

of the butt weld attaching the column to the wall. Thethickness 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, thecondition would be enveloped by the engineering assess-ment of Reference 1.

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~ AttachmentPage 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 throughthickness of el ectros 1 ag wel d to remove poros i ty .

Thi s wi 1 1 requ ire chipping of concrete , fitting ofbacking plate and rewel di ng . Also if pores extend along1 ength of weld , skin plates will have to be r emoved andweld excavated .

The nature of this defect does not war r ant repair s incethe extens ive nature of thi s repai r increases risk ofgenerating more ser ious defects .

r

B. Requests for Exemption from Defects discovered throughUltra-'onic

(UT) Examination

Listed below are ten (10) requests for hardship exemption onsixteen (16) individually numbered welds which were discoverddby UT examination of the Sacrificial Shield Wall during theSupply System's investigation of the wall. The defects,

'eingfor the most part inaccessible, were subsequently evaluatedand considered acceptable based on-the justification presentedin Reference (1).

l AttachmentPage 5 of 14

SHAW


l. Only 12" of weld is accessible - remainder of weld's

behind attachments or behind skin'plates.

2. Repair would require removing attachments and skinplates, cutting through wall, chipping concrete,installing backing plate and rewelding.

3. Nature of defect does not warrant such extensiverework with potential for creating serious defects.

(1) Weld No. W4-65 Weld Type:

Weld Location: El 528'z 330

Type Inspection: VT, UT

Defect Description: Incomplete penetration in Type C

weld. (Figure 1)

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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 Aweld joint. (Figure 1)

Justification. for Hardship:

1. Ot total weld length of 2'7",only 1'5" isaccessible. The remainder is behind a pipe whiprestraint.

2. To repair the accessible part it would be necessaryto excavate through the wall into the stiffener plate.

3. Nature of the defect does not warrant suchextensive rework with a potential for creatingserious defects.

4. Access is limited by a main steam line which is 15"from the $ SW.

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AttachmentPage 6 of 14

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W113-123) Weld No. W113-14 Weld Type:

Weld Location: El 552'z 247


FCAW

Defect Description: Incomplete penetration inType A weld joint (figure 1)


l. Of total weld length 2'7" only 1'5"is accessible. The remainder is behind a pipewhip restraint.

2. To repair the accessible part it would be necessaryto excavate through the wall into the stiffener ~

plate.

3. Nature of the defect does not warrant such extensiverework with a potential for creating serious defects.

4. Access is limited by a main steam line which is15" from the SSW.

(4) Weld No.'102-117 Weld Type:Weld Location: El 551'Az 253

Type Inspection: 'VT; UT

Defect Description: Defect is 15" long with a DB ratingof +3 which makes it a large reflectorper AWS Dl.l for electroslag welds.Defect is located at" 1-5/8" from theoutside s'urface of the SSW. Seeweld type D (Figure~1).


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 andremoving skin plates.

4. Nature of defect does not warrant such extensiverepair with potential for creating serious defects.

5. Access is limited by main steam line which is15" from the'wall.

W114-6(5) Weld No. W114-4 Weld Type:

Weld Location: EL. 552 Az 84



5/S

5jFCAW

Defect Descr iption: Incomplete penetration inType A weld joint. (Figure 1)


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 necessaryto excavate through the wall into the stiffenerplate.

3. Nature of defect does not warrant such extensiverework with a potential for creating seriousdefects.

'~a

W114-12(6) Weld No. W114-14 Weld Type:

Weld Location:''EL''552'z 285J

Type Inspection; YT, UT

FCAW

Defect Inspection: Incomplete penetration in Type Aweld joint (Figure 1)


1. Weld is 2'8-1/2" long'. Only 12" are accessible.Remainder is behind a pipe whip; restraint.


3. Nature of defect does not warrant such extensiverework with a potential for creating seriousdefects.


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IFCAW

(7) Weld No. W145-29 Wel d Type: Groove flatWeld Location: 'EL''554'z 240


Defect Description: Incomplete penetration inType B weld joint. (Figure 1)

2. Half of the weld is highly restrained being only,2-1/2" from large pipe whip restraints.


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)



1. Repair would require extensive gouging and grindingwith potential for cutting through wall. Reweldingwould require extensive preheating of a highlyrestrained area (per criteria of Table 1).

l. Repair would require extensive gouging and grindingwith potential for. cutting through wall. Reweldingwould require extensive preheating of a highly1"estr ained area (per criteria of Table 1).

2. Half of the weld is highly restrained being only2-1/2" from large pipe whip restraints.


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.


3. Nature of defect does not warrant such extensiverework with a potential for creating serious defects.

W113-28(9) Weld No. W113-30 Weld

Type'eld

Location: El 552'z 264

Type Inspection: VT UT

Defect Description: Incomplete penetration in Type Aweld joint (Figure 1)

W113-20(10) Weld No.'113-'22 Weld Type:

Weld Location: El'552'z 96

Type Inspection:'T; UT"

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Defect Description: Incomplete penetration in Type Aweld joint (Figure 1)


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 necessaryto,excavate through the wall into the stiffenerplate.

3. Nature of defect does not warrant such extensiverework 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.


3. References

(1) "Engineering Evaluation of the HNP-2 Sacrificial ShieldWall", a report transmitted by letter, D. L. Renberger(WPPSS) to B. J. Youngblood (NRC),'ubject "EngineeringEvaluation of the Sacrificial Shield Wall", letter numberC~02-80-167, dated August 1, 1980

(2) "Engineering Evaluation of the WNP-2 Sacrificial ShieldWall, Supplement No. 1", a supplement to Reference (1),transmitted by letter D. L. Renberger (WPPSS) to B. J.Youngblood (NRC), subject "Engineering Evaluation of theSacrificial Shield Wall (SSW)", letter number G02-80-182,dated August 19, 1980

AttachmentPage ll of 14

Table 1

Criteria for'Hardshi Exem tion Based U on Restraint

o Where severe restraint exists, there is a significant riskthat 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. Severerestraint exists where additional heavy members are welded tothe wall.

o If the workmanship defect lies within a distance of 5T (where Tis the thickness of the underlying SSW material) from the toe ofan attachment weld, .then it is considered to lie in a region ofhigh restraint provided the attachment weld is greater than 1" (leglength for fillet; throat for butt weld).

o The distance of 5T was judged to define a zone within which theresidual stresses from the attachment will have a potential foraffecting the integIity of the repair.

FIGURE 1


CATEGORIES OF MELD JOINTS WHICH

CONTAIN BURIED DEFECTS, DETECTED BY UT

TYPE A TYPE B

ROOT INDICATIONS

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NOTE'TRUCTURAL ACCEPTABILITY OF THESE DEFECTS WAS DETERt1INED AND REPORTED

IN REFERENCE 81.

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Documents

Forwards hardship exemption request for accepting as is … · 2018-06-27 · Attachment Hardship Exemption Request For Acceptance As-Is of Certain Identified Meld Defects In The