ML110350035
| ML110350035 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/26/2011 |
| From: | Hesser J Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06313-JHH/GAM | |
| Download: ML110350035 (6) | |
Text
Z A f A subsidiary of Pinnacle West Capital Corporation John H. Hesser Mail Station 7605 Palo Verde Nuclear Vice President Tel: 623-393-5553 PO Box 52034 Generating Station Nuclear Engineering Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-06313-JHH/GAM January 26, 2011 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529 and 50-530 Update to License Renewal Application (LRA) Section A3.2.1.5, LRA Amendment No. 29 By letter no. 102-06234, dated August 12, 2010, Arizona Public Service Company (APS) submitted Amendment No. 22 to the PVNGS license renewal application (LRA).
Amendment No. 22 included a revision to LRA Section 4.3.2.5 to identify the steam generator tube fatigue analysis as a time-limited aging analysis, as described in Response 1 to RAI 4.3-13 in the August 12, 2010 letter. It was recently discovered that the steam generator tube fatigue analysis discussion in LRA Section A3.2.1.5 had not been updated to be consistent with the changes made to Section 4.3.2.5 in Amendment No. 22. I contains LRA Amendment No. 29 with the updated Section A3.2.1.5 shown as markups. Enclosure 2 contains LRA Amendment No. 29 with the updated Section A3.2.1.5 shown retyped.
Should you need further information regarding this submittal, please contact Glenn Michael, Licensing Engineer for License Renewal, at (623) 393-5750.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on I/Z- (,/It I (date)
Sincerely, JHH/GAM/
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- San Onofre
- South Texas
- Wolf Creek g (1-.
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Update to License Renewal Application (LRA) Section A3.2.1.5, LRA Amendment No. 29 Page 2
Enclosures:
- 1. Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 29, Section A3.2.1.5 Markup
- 2. Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 29, Section A3.2.1.5 Retype cc:
E. E. Collins Jr.
J. R. Hall L. K. Gibson M. A. Brown L. M. Regner G. A. Pick NRC Region IV Regional Administrator NRC NRR Senior Project Manager NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS NRC License Renewal Project Manager NRC Region IV (electronic)
ENCLOSURE 1 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 29 Section A3.2.1.5 Markup (New text underlined; deleted text shown with strikethrough)
Appendix A Updated Final Safety Analysis Report Supplement A3.2.1.5 Steam Generator ASME Section III Class 1, Class 2 Secondary Side, and Feedwater Nozzle Fatigue Analyses The replacement steam generators (RSGs) are designed to ASME Ill, Subsection NB (Class 1) and NC (Class 2), 1989 Edition with no addendum. The design reports included design for a concurrent power uprate. Although the secondary side is Class 2, all pressure retaining parts of the steam generator satisfy the Class 1 criteria, including a Division 1,Section III fatigue analysis.
The design of the PVNGS steam generators includes a code fatigue analysis of the steam generator tubes. However, the cyclic stress range for the steam generator tubes is less than the endurance limit allowing an infinite number of cycles, so the CUF was determined to be zero. Since the steam generator tube CUF is zero, the analysis of record will remain valid throuah the period of extended operation for all three PVNGS units.
Although the team genepriator t have a Claas.qn 1 fatigue aNalyGS th chosntod upagy fagto i, zero, and-tho safoty dUerMnatit n fo rofnd 3
team geonrators te thues- '- At' now depen onO managing aging effocts by a poriodic inpcio4rg am.-.ahotan On the fatigue analysis.
Although the team generator tbe fatigue analyFigu isRe n
Ct c
one ant Pres e
SAuteam G
erator Tube Integrity prgram (Al2.8) will betseds to maanro age steam generator tubes.
The fatigue analyses of the Uinit is and replachemeAnt steami generaters Ae fco a period sufforiient to conbeor their intaed life, and reain valid-for then rio f extended opefratio.
H
- twever, With the exception of the steam generator tubes. PVNGS has chosen to apply aging management to all the Unit 1, 2 and 3 steam generators to achieve uniformnity in aging mnanagement practices. The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program (A2.1) will track events to ensure that appropriate reevaluation or other corrective action will be initiated if an action limit is reached.
Action limits will permit completion of corrective actions before the design basis number of events is exceeded, and before the cumulative usage factor exceeds the code limit of 1.0.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 29 Page A-31
ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 29 Section A3.2.1.5 Retyped
Appendix A Updated Final Safety Analysis Report Supplement A3.2.1.5 Steam Generator ASME Section III Class 1, Class 2 Secondary Side, and Feedwater Nozzle Fatigue Analyses The replacement steam generators (RSGs) are designed to ASME Ill, Subsection NB (Class 1) and NC (Class 2), 1989 Edition with no addendum. The design reports included design for a concurrent power uprate. Although the secondary side is Class 2, all pressure retaining parts of the steam generator satisfy the Class 1 criteria, including a Division 1,Section III fatigue analysis.
The design of the PVNGS steam generators includes a code fatigue analysis of the steam generator tubes. However, the cyclic stress range for the steam generator tubes is less than the endurance limit allowing an infinite number of cycles, so the CUF was determined to be zero. Since the steam generator tube CUF is zero, the analysis of record will remain valid through the period of extended operation for all three PVNGS units.
With the exception of the steam generator tubes, PVNGS has chosen to apply aging management to all the Unit 1, 2 and 3 steam generators. The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program (A2.1) will track events to ensure that appropriate reevaluation or other corrective action will be initiated if an action limit is reached. Action limits will permit completion of corrective actions before the design basis number of events is exceeded, and before the cumulative usage factor exceeds the code limit of 1.0.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 29 Page A-31