ML092600288

Errata to Supplement 1 to License Renewal Application

ML092600288
Person / Time
Site:	Palo Verde
Issue date:	05/08/2009
From:	Mims D Arizona Public Service Co, Pinnacle West Capital Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Regner L M, NRR/DLR, 415-1906
References
102-06005-DCM/GAM
Download: ML092600288 (8)

Text

.9 10 CFR 54.17 A subsidiariy of'Pinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-06005-DCM/GAM May 08, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Errata to Supplement I to License Renewal Application By letter no. 102-05989, dated April 14, 2009, Arizona Public Service Company (APS) submitted Supplement 1 to the license renewal application (LRA) for PVNGS Units 1, 2, and 3. Supplement 1 to PVNGS LRA provided valve fatigue analysis information in response to NRC letter to APS dated February 13, 2009, and also included changes to reflect completed commitments, make minor corrections and enhancements, and clarify information previously provided.

In Supplement 1, additional references were added to the Environmental Report. This caused repagination of the reference pages with information rolling onto page 4-35.

However, page 4-35 was not provided in the April 14, 2009, submittal. In addition, footnotes 3 and 4 on Supplement 1 page 4.3-54 contained editorial errors. This letter transmits an errata to Supplement 1 to the PVNGS LRA to provide the corrected pages 4.3-54 and 4-35 (Environmental Report).

In addition, Supplement 1 identified that one element of Commitment No. 14 (Table A4-1) was completed, but the procedure change implementation was delayed and not implemented until April 26, 2009. This has been entered into the PVNGS corrective action program as Palo Verde Action Request (PVAR) 3318172.

No commitments are being made to the NRC by this letter. Should you have questions regarding this submittal or if additional information is needed, please contact Angela K.

Krainik, License Renewal Department Leader, at 623-393-5045.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon 0 Palo Verde 0 San Onofre 0 South Texas

• Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Errata to Supplement 1 to License Renewal Application Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on .5/ /

(Date)

Sincerely, DCM/SAB/GAM/gat

Enclosure:

Replacement Pages and Insertion Instructions, Errata to Supplement 1 to License Renewal Application, Palo Verde Nuclear Generating Station Units 1,2, and 3 cc: E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector B. E. Holian NRC License Renewal Director J. G. Rowley NRC License Renewal Project Manager L. M. Regner NRC License Renewal Environmental Project Manager A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

T. Morales Arizona Radiation Regulatory Agency (ARRA)

Enclosure Replacement Pages and Insertion Instructions, Errata to Supplement 1 to License Renewal Application, Palo Verde Nuclear Generating Station Units 1, 2, and 3

Insertion Instructions Errata to Supplement I to License Renewal Application, Palo Verde Nuclear Generating Station Units 1, 2, and 3 Remove page: Insert pacqe:

4.3-54/4.3-55 4.3-54/4.3-55 Appendix E Environmental Report Remove page: Insert page:

4-35/blank 4-35/blank 1

Section 4 TIME-LIMITED AGING ANALYSES OJr-r1 VU-U) dIlU OdJkrlDrlVU-U0 VdIUUI IVIUUUI V -O-U3O I0-, 4 Isolation Valves between the Unit 3 Regenerative Heat Exchanger and Auxiliary Spray Line 0.151 A fatigue analysis of the crotch of the body used Subparagraph 10,000 (Crotch)

NB-3545.3 for the section in thermal cycles when the temperature change rate is 100 °F/hr. Pipe and seismic load stresses are treated as cyclic loads in the fatilue analysis.

1/2/3JRCEPSV0200/2011202/203 Dresser Model 6-31709NAX > 106 <0.002 XNC045 Pressurizer Pressure Safety Valves (6" Inlet) 1/2/3JCHEPDVO240 FisherModel 667-DBQ/ 50B0617/ 54A6460, 2" 0.7656 Isolation Valves for the Charging Line 6,000 (Valve This analysis used Subparagraph NB-3545.3, "Fatigue 600Vv Requirements," 1983 Body) 1,2,3JSIBPSV0169 and 1,2,3JSIAPSV0469 Crosby Model JMAK- 0.075 3/4X1, 3/4" Safety Injection Line Thermal Relief Valves (Valve The analysis confirms that these valves will withstand the > 2,000 Bod specified number of each of three thermal transients from the Inlet)'G) valve specification as reported in UFSAR 5.2.2.4.4.2.

1 NA and It were calculated for the design basis number of loading events applicable to the component that were originally intended to encompass a 40-year design life.

2 The fatigue evaluations of the valve components are performed in accordance with ASME Code,Section III, Subparagraph NB-3222.4, hence a calculated NA for NB-3545.3 normal duty operations is not applicable.

3 "Crotch" is the region in the valve between the body and the neck, a stress concentration region and a required analysis location under ASME Ill, Subarticle NB-3500 design rules for Class 1 valves, Subparagraph NB-3545.1.

4 A range of 40-year CUFs has been calculated. The higher value was arrived at by conservative interpretation of the Code for combination of cycles that exceed 100 °F/hr, whereas the lower value uses the actual 116 °F/hr rate.

5 The CUF is not explicitly calculated in the Design Report, but the CUF presented here is derived from the statement in the Design Report that the allowable number of cycles from the ASME Code analysis is greater than 106, compared to the specification allowable value of 2,000 cycles (CUF =

2,000/>106 < 0.002).

6 Highest CUF calculated for the three analyzed locations; the inlet nozzle, valve inlet and valve outlet.

Palo Verde Nuclear Generating Station Supplement 1 Errata Page 4.3-54 License Renewal Application, April 16, 2009

Section 4 TIME-LIMITED AGING ANALYSES For the valves modeled with an NB-3545.3 normal duty operating cycle evaluation, the allowed NB-3545.3 NA normal duty operations is much greater than the required minimum of 2000 cycles. The calculated cumulative usage factors It for NB-3550 cyclic loads are less than the code limit of 1.0.

Effect of Combustion Engineering Infobulletin 88-09 "Nonconservative Calculation of Cumulative Fatigue Usage" The CE Owner's Group review of Combustion Engineering Infobulletin 88-09 did not identify any effects on the fatigue analyses of Class 1 valves.

Disposition: Validation, 10 CFR 54.21(c)(1)(i); and Aging Management, 10 CFR 54.21(c)(1)(iii)

Validation - Valves with large margin The calculated worst-case usage factors for the 16" Shutdown Cooling Suction Containment Isolation Valves, the 14" Safety Injection Tank Injection Discharge Isolation Gate Valves, the 14" Safety Injection Tank Injection Discharge Check Valves, the 12" HPSI/LPSI check valves, the 3/4" Safety Injection Line Thermal Relief Valves, the pressurizer safety valves, and the 2" isolation valves for the auxiliary spray indicate that the designs have large margins, and therefore that the pressure boundaries would withstand fatigue effects for at least 1.5 times the original design lifetimes. The design of these valves for fatigue effects is therefore valid for the period of extended operation, in accordance with 10 CFR 54.21 (c)(1)(i).

Aging Management - Shutdown Cooling Suction Isolation Valve, and ChargingLine Isolation The calculated worst-case usage factor in these valves is 0.7656. However, fatigue usage factors in these valves do not depend on effects that are time-dependent at steady-state conditions, but depend only on effects of operational, abnormal, and upset transient events.

The Metal Fatigue of Reactor Coolant Pressure Boundary program will track events to ensure that appropriate reevaluation or other corrective action is initiated if an action limit is reached. Action limits will permit completion of corrective actions before the design basis number of events is exceeded. The charging line isolation valves are subject to similar but less-severe cyclic effects than the charging nozzles, whose fatigue usage is tracked by the stress-based method. The shutdown cooling suction isolation valve is the limiting location on the shutdown cooling line, and will be tracked by the cycle-based fatigue method. Effects of fatigue in Class 1 valve pressure boundaries will thereby be managed for the period of extended operation, in accordance with 10 CFR 54.21 (c)(1)(iii).

The Metal Fatigue of Reactor Coolant Pressure Boundary program is described in Section 4.3.1; and is summarized in Appendix B, Section B3.1. See Table 4.3-4 for details of the program, and Section 4.3.1.5 for a description of its action limits and corrective actions.

Palo Verde Nuclear Generating Station Supplement 1 Page 4.3-55 License Renewal Application April 10, 2009

Section 4.22 References Section 4.13 IEEE (Institute of Electrical and Electronics Engineers) 1997. National Electrical Safety Code, 1997 Edition, New York, New York.

TtNUS (Tetra Tech NUS) 2007a. "Calculation Package for Palo Verde Transmission Lines Induced Current Analysis." Aiken, South Carolina. July.

TtNUS (Tetra Tech NUS) 2007b. "Calculation Package Addendum - Palo Verde Nuclear Generating Station Induced Current Calculation for PVNGS-DEVERS Crossing of Chuckwalla Road." Aiken, South Carolina. September 4.

Section 4.14 NRC (U.S. Nuclear Regulatory Commission) 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GElS), Volumes 1 and 2. NUREG-1437, Washington, D.C. May.

Section 4.15 NRC (U.S. Nuclear Regulatory Commission) 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), Volumes 1 and 2, NUREG-1437, Washington, D.C., May.

Section 4.16 NRC (U.S. Nuclear Regulatory Commission) 1996. Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants (GELS), Volumes 1 and 2, NUREG-1437, Washington, D.C.,

May.

Section 4.17 NRC (U.S. Nuclear Regulatory Commission) 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), Volumes 1 and 2, NUREG-1437, Washington, D.C., May.

Section 4.18 NRC (U.S. Nuclear Regulatory Commission) 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), Volumes 1 and 2, NUREG-1437. Washington, D.C. May.

Section 4.19 NRC (U.S. Nuclear Regulatory Commission) 1982. Final Environmental Statement related to the operation of Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Docket Nos. STN 50-528, STN 50-529 and STN 50-530. NUREG-75/078. Arizona Public Service Company, et al. February.

NRC (U.S. Nuclear Regulatory Commission) 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), Volumes I and 2, NUREG-1437. Washington, D.C. May.

Palo Verde Nuclear Generating Station Supplement 1 Errata Environmental Report for License Renewal April 16, 2009 Page 4-35

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