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{{#Wiki_filter:PVNGS License Renewal Application Metal Fatigue Topics April 1, 2010 Discussion Topics*Historical and general background*Metal Fatigue Monitoring Program
{{#Wiki_filter:PVNGS License Renewal Application Metal Fatigue Topics April 1, 2010
*Cycle Counting Questions
*Class 1 Fatigue TLAA Evaluation Process*Future actions
*NRC staff questions Historical and general background Initial development of PVNGS metal fatigue monitoring program*Program required by PVNGS Technical Specification 5.5.5*SYS80-PE-DE "Compilation of NSSS Responses to Design Bases Dynamic


Events for the System 80 Standard Design" established applicable design cycles and their 40-year expected accumulation*Class I metal fatigue analyses incorporated the SYS80-PE-DE limits and in some cases identified additional items of concern Initial development of PVNGS metal fatigue monitoring program*The initial Technical Specification program did not require all UFSAR
Discussion Topics
* Historical and general background
* Metal Fatigue Monitoring Program
* Cycle Counting Questions
* Class 1 Fatigue TLAA Evaluation Process
* Future actions
* NRC staff questions


transients to be monitored*The UFSAR does not incorporate all of the additional limits (e.g. RCP stud tensioning/de-tensioning) -to be
Historical and general background


discussed later in this presentation
Initial development of PVNGS metal fatigue monitoring program
*PV staff identified that not all UFSAR transients were being counted *Implemented expanded list of transients in January 1996*ITS upgrade in 1998 established current requirements*Not counted data between '85 and '95 was assumed to be an accumulation of 25% of the design allowed transients in all but a few casesProgram Review -1995
* Program required by PVNGS Technical Specification 5.5.5
*Actual event counting has been in place since January 1996*Unit 1, 2 and 3 records have now been reviewed for LRA support Performance of cycle counting since January 1996 Metal Fatigue Monitoring Program
* SYS80-PE-DE Compilation of NSSS Responses to Design Bases Dynamic Events for the System 80 Standard Design established applicable design cycles and their 40-year expected accumulation
*Current methodology:-Cycle counting to ensure design assumptions are not exceeded-Specific component locations are not specified-Exception: Partial cycle (CBF-PC) methodology is used to track spray nozzle
* Class I metal fatigue analyses incorporated the SYS80-PE-DE limits and in some cases identified additional items of concern


usage Current PVNGS Metal Fatigue Monitoring Program
Initial development of PVNGS metal fatigue monitoring program
*LRA development prompted PVNGS staff to revisit the assumptions for 1985 -1995*Recounts of all three units were reported in the response to RAI B3.1-4 (see RAI response Table 3.1-4)-Recount Methodology*Best source selected (logs, MORs, LERs, WOs, interviews)*Validated assumptions Addressing Cycle Count Assumptions
* The initial Technical Specification program did not require all UFSAR transients to be monitored
*Recount Methodology-Best source selected (logs, MORs, LERs, WOs, interviews)-Reviewed assumption of 25% accumulated cycles*Actual data*Comparison to '95 -'05 operating history Cycle Recount
* The UFSAR does not incorporate all of the additional limits (e.g. RCP stud tensioning/de-tensioning) - to be discussed later in this presentation
*Required by 10 CFR54.21 (c)(1)(iii)*Scope -All Class I components *Methodology:-Based on component locations-Adds SBF for  high usage locations (not discussed in this presentation)-Continues cycle counting for "Global"monitoring*Used for low 40-year design CUF*No new industry issues since original design*Industry experience indicates not a problem location-Expands CUF monitoring*CBF-C (CUF based on design cycle)*CBF-PC (CUF based on partial cycle)*CBF-EP (CUF based on event pairing)-Establishes appropriate action limits and corrective actions Enhanced Metal Fatigue Monitoring Program
*SBF methodology (to be determined)*FatiguePro is under evaluation for cycle counting and CBF monitoring*Current manual cycle counting will continue until a suitable software program has been


validated*Enhanced program will be implemented no later than two years prior to the PEO (LRA commitment #39 as revised in Amendment 9)Enhanced Program Status Cycle Counting NRC Questions Cycle Counting RAIs and Amendments*Amendment 3 (annual update)-Added Unit 3 record review results and revised one transient total to replace an  
Program Review - 1995
* PV staff identified that not all UFSAR transients were being counted
* Implemented expanded list of transients in January 1996
* ITS upgrade in 1998 established current requirements
* Not counted data between 85 and 95 was assumed to be an accumulation of 25% of the design allowed transients in all but a few cases


estimate with data-Revised current program action limit discussion to avoid confusion with the
Performance of cycle counting since January 1996
* Actual event counting has been in place since January 1996
* Unit 1, 2 and 3 records have now been reviewed for LRA support


enhanced program limits-Minor clarifications were included in the AMP OE discussion Cycle Counting RAIs and Amendments (continued)*Amendment 9 (result of RAI B3.1-1 thru 8)-RAI B3.1-4 response provided the individual unit cycle totals from best available sources-Corrected typographical errors
Metal Fatigue Monitoring Program
-Included enhanced monitoring implementation schedule-Committed to selection of a suitable SBF methodology-Clarified cycle projection methodology Cycle Counting RAIs and Amendments (continued)
Most recent cycle count related DRAI set (DRAI 4.3-1 thru 9-DRAI 4.3-1 Transients projected to exceed 40-year limits*Projections are conservative and may not be reached*10CFR54.21(c)(1)(iii) permits aging management for TLAAs that are not  validated or projected for the PEO*NUREG 1800 paragraph 4.3.3.1.1.
3 permits the use of GALL programs for aging management*NUREG 1801 Vol2 AMP X.M1 allo ws use of this program to manage aging and recommends "no further evaluation"if this program is selected to satisfy 10CFR54.21(c)(1)(iii)*PVNGS took no exceptions to X.M1 and concludes fatigue reanalyses are not required bas ed on projections . Corrective action will be initiated if needed based on program action limits Cycle Counting RAIs and Amendments (continued)*DRAI 4.3-1 LRA Transient projection methodology-Presented for information only -Concept of a worst case bounding unit
-Conservative Assumptions*Highest unit total was used for '85-'95 and for '95-'05*Lowest operating years was used for accumulation rate*42 years were used for projecting and added to above*'Zero accumulation'assumed to be linear times 22/40-If not expected still assumed 1 event Cycle Counting RAIs and Amendments (continued)*DRAI 4.3-2 Global monitoring criteria does not seem consistent-Exceptions are explained in LRA table notes*DRAI 4.3-3 Clarify the CBF-PC method
*DRAI 4.3-4 Program action limits (see commitment #39)
*DRAI 4.3-5 Some cycles do not agree with the UFSAR-Some are derived from UFSAR sections other than 3.9.1-Some come from specific analyses (e.g. RCP studs)-Addition of cycles to the UFSAR is under consideration Cycle Counting RAIs and Amendments (continued)*DRAI 4.3-6 25% cycle assumption-Review of best source data was presented in the response to RAI B3.1-4-Compared assumption to actual data from recount efforts or data from '95-'05-Result:*Four assumptions of 25% cycle accumulation are being reviewed: Rx Trip, Load Reject, Turbine Trip w/o Rx


Trip and Depressurization by MSSV at 100% power*Remaining 25 % assumptions are conservative Cycle Counting RAIs and Amendments (continued)*DRAI 4.3-7 Not all cycles were recounted-Some had accurate data and did not require recount-Some were not significant (e.g. plant loading at 5%/min)-Some could not be recovered so the 25%
Current PVNGS Metal Fatigue Monitoring Program
assumption was used and validated from '95-
* Current methodology:
  - Cycle counting to ensure design assumptions are not exceeded
  - Specific component locations are not specified
  - Exception: Partial cycle (CBF-PC) methodology is used to track spray nozzle usage


'05 data Cycle Counting RAIs and Amendments (continued)*DRAI 4.3-8 Questioned an incorrect table note (had been corrected in Amendment
Addressing Cycle Count Assumptions
* LRA development prompted PVNGS staff to revisit the assumptions for 1985 - 1995
* Recounts of all three units were reported in the response to RAI B3.1-4 (see RAI response Table 3.1-4)
  - Recount Methodology
* Best source selected (logs, MORs, LERs, WOs, interviews)
* Validated assumptions


9)*DRAI 4.3-9 Some cycles are not included in the UFSAR (similar to DRAI 4.3-5)-Some come from specific analyses (e.g. RCP studs)-Addition of cycles to the UFSAR is under consideration Class 1 Fatigue TLAA Evaluation Process -LRA Section 4.3.2
Cycle Recount
*Identify TLAAs and Affected Components-SRP Guidance, Industry Experience, CLB Search*Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)*Evaluate and Summarize CDB TLAAs-Analysis Results -Analyzed Locations, CUFs, etc.
* Recount Methodology
-Effects of Modification, Analysis, and Op. History
  - Best source selected (logs, MORs, LERs, WOs, interviews)
-Effects of Differences in Analysis Methods-Identify Disposition Class 1 Fatigue TLAA Evaluation Process
  - Reviewed assumption of 25% accumulated cycles
*SRP Guidance-NUREG-1800 Sect. 4.3 and Tables for Class 1-Based on ASME III Subsection NB and NG and Industry Experience*Industry Experience-Examples:-Other LRAs-NRC and NSSS vendor Bulletins, Notices, etc.*CLB Search-Word Search of CLB (FSAR, Docketed Reports, Letters, etc.)-Confirm applicability to Palo Verde-Identify other plant-specific TLAAs Identify TLAAs and Affected Component s
* Actual data
*Research and Summarize History of CLB-Confirm Current Licensing Basis*Research Design and Analysis History-Confirm Current Design Basis-TLAAs are analyses , are therefore part of the CDB-TLAAs are usually bases of the CLB ("incorporated by reference") rather than included verbatim Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)
* Comparison to 95 - 05 operating history
*Analysis Results-All TLAA Results (e.g., all reported fatigue summaries)-All Analyzed Locations
-Tabulated for Complex Components*Effects of Modification, Analysis, and Operating History -
Examples:-Instrument Nozzle Half-Nozzle and MNSA Repairs (Several LRA Sections)-Pressurizer Surge Line Thermal Stratification (LRA Section 4.3.2.9)-Unit 2 Head Vent Repair -high part-life CUF, head replaced Fall 2009 (LRA p. 4.3-34)
Evaluate and Summarize CDB TLAAs
*Identify Disposition-Based on Analysis History, Results, and Methods*10 CFR 54.21(c)(1)(i) -If simple design life or cycle ratios, etc., confirm adequate margin at 60 years*10 CFR 54.21(c)(1)(iii) -Used in most other cases-Requires Aging Management*10 CFR 54.21(c)(1)(ii) -Reanalysis performed Evaluate and Summarize CDB TLAAs (Continued)
*Identify Disposition (Continued)-10 CFR 54.21(c)(1)(iii) monitoring methods are described in LRA 4.3.1, summarized by monitored


location in Table 4.3-4-Details of 10 CFR 54.21(c)(1)(iii) monitoring methods are location and analysis-specific.
Enhanced Metal Fatigue Monitoring Program
Examples:*Global -monitor transients *Cycle-based fatigue (CBF) -moni tor transients, possible CUF impacts*Stress-based fatigue (SBF) -i mpact of transients require reevaluation of CUF Evaluate and Summarize CDB TLAAs (Continued)
* Required by 10 CFR54.21 (c)(1)(iii)
NRC Staff Questions*Have we answered the questions and issues stated in this presentation?*Does the staff have additional questions with respect to cycle counting or the
* Scope - All Class I components
* Methodology:
  - Based on component locations
  - Adds SBF for high usage locations (not discussed in this presentation)
  - Continues cycle counting for Global monitoring
* Used for low 40-year design CUF
* No new industry issues since original design
* Industry experience indicates not a problem location
  - Expands CUF monitoring
* CBF-C (CUF based on design cycle)
* CBF-PC (CUF based on partial cycle)
* CBF-EP (CUF based on event pairing)
  - Establishes appropriate action limits and corrective actions


PVNGS approach to metal fatigue?*Review action items
Enhanced Program Status
*Future topics Thank you for your participation}}
* SBF methodology (to be determined)
* FatiguePro is under evaluation for cycle counting and CBF monitoring
* Current manual cycle counting will continue until a suitable software program has been validated
* Enhanced program will be implemented no later than two years prior to the PEO (LRA commitment #39 as revised in Amendment 9)
 
Cycle Counting NRC Questions Cycle Counting RAIs and Amendments
* Amendment 3 (annual update)
  - Added Unit 3 record review results and revised one transient total to replace an estimate with data
  - Revised current program action limit discussion to avoid confusion with the enhanced program limits
  - Minor clarifications were included in the AMP OE discussion
 
Cycle Counting RAIs and Amendments (continued)
* Amendment 9 (result of RAI B3.1-1 thru 8)
  - RAI B3.1-4 response provided the individual unit cycle totals from best available sources
  - Corrected typographical errors
  - Included enhanced monitoring implementation schedule
  - Committed to selection of a suitable SBF methodology
  - Clarified cycle projection methodology
 
Cycle Counting RAIs and Amendments (continued)
Most recent cycle count related DRAI set (DRAI 4.3-1 thru 9
  - DRAI 4.3-1 Transients projected to exceed 40-year limits
* Projections are conservative and may not be reached
* 10CFR54.21(c)(1)(iii) permits aging management for TLAAs that are not validated or projected for the PEO
* NUREG 1800 paragraph 4.3.3.1.1.3 permits the use of GALL programs for aging management
* NUREG 1801 Vol 2 AMP X.M1 allows use of this program to manage aging and recommends no further evaluation if this program is selected to satisfy 10CFR54.21(c)(1)(iii)
* PVNGS took no exceptions to X.M1 and concludes fatigue reanalyses are not required based on projections . Corrective action will be initiated if needed based on program action limits
 
Cycle Counting RAIs and Amendments (continued)
* DRAI 4.3-1 LRA Transient projection methodology
  - Presented for information only
  - Concept of a worst case bounding unit
  - Conservative Assumptions
* Highest unit total was used for 85-95 and for 95-05
* Lowest operating years was used for accumulation rate
* 42 years were used for projecting and added to above
* Zero accumulation assumed to be linear times 22/40
        - If not expected still assumed 1 event
 
Cycle Counting RAIs and Amendments (continued)
* DRAI 4.3-2 Global monitoring criteria does not seem consistent
  - Exceptions are explained in LRA table notes
* DRAI 4.3-3 Clarify the CBF-PC method
* DRAI 4.3-4 Program action limits (see commitment #39)
* DRAI 4.3-5 Some cycles do not agree with the UFSAR
  - Some are derived from UFSAR sections other than 3.9.1
  - Some come from specific analyses (e.g. RCP studs)
  - Addition of cycles to the UFSAR is under consideration
 
Cycle Counting RAIs and Amendments (continued)
* DRAI 4.3-6 25% cycle assumption
  - Review of best source data was presented in the response to RAI B3.1-4
  - Compared assumption to actual data from recount efforts or data from 95-05
  - Result:
* Four assumptions of 25% cycle accumulation are being reviewed: Rx Trip, Load Reject, Turbine Trip w/o Rx Trip and Depressurization by MSSV at 100% power
* Remaining 25 % assumptions are conservative
 
Cycle Counting RAIs and Amendments (continued)
* DRAI 4.3-7 Not all cycles were recounted
  - Some had accurate data and did not require recount
  - Some were not significant (e.g. plant loading at 5%/min)
  - Some could not be recovered so the 25%
assumption was used and validated from 95-05 data
 
Cycle Counting RAIs and Amendments (continued)
* DRAI 4.3-8 Questioned an incorrect table note (had been corrected in Amendment 9)
* DRAI 4.3-9 Some cycles are not included in the UFSAR (similar to DRAI 4.3-5)
  - Some come from specific analyses (e.g. RCP studs)
  - Addition of cycles to the UFSAR is under consideration
 
Class 1 Fatigue TLAA Evaluation Process - LRA Section 4.3.2
 
Class 1 Fatigue TLAA Evaluation Process
* Identify TLAAs and Affected Components
  - SRP Guidance, Industry Experience, CLB Search
* Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)
* Evaluate and Summarize CDB TLAAs
  - Analysis Results - Analyzed Locations, CUFs, etc.
  - Effects of Modification, Analysis, and Op. History
  - Effects of Differences in Analysis Methods
  - Identify Disposition
 
Identify TLAAs and Affected Components
* SRP Guidance
  - NUREG-1800 Sect. 4.3 and Tables for Class 1
  - Based on ASME III Subsection NB and NG and Industry Experience
* Industry Experience - Examples:
  - Other LRAs
  - NRC and NSSS vendor Bulletins, Notices, etc.
* CLB Search
  - Word Search of CLB (FSAR, Docketed Reports, Letters, etc.)
  - Confirm applicability to Palo Verde
  - Identify other plant-specific TLAAs
 
Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)
* Research and Summarize History of CLB
  - Confirm Current Licensing Basis
* Research Design and Analysis History
  - Confirm Current Design Basis
  - TLAAs are analyses, are therefore part of the CDB
  - TLAAs are usually bases of the CLB (incorporated by reference) rather than included verbatim
 
Evaluate and Summarize CDB TLAAs
* Analysis Results
  - All TLAA Results (e.g., all reported fatigue summaries)
  - All Analyzed Locations
  - Tabulated for Complex Components
* Effects of Modification, Analysis, and Operating History - Examples:
  - Instrument Nozzle Half-Nozzle and MNSA Repairs                (Several LRA Sections)
  - Pressurizer Surge Line Thermal Stratification  (LRA Section 4.3.2.9)
  - Unit 2 Head Vent Repair - high part-life CUF, head replaced Fall 2009 (LRA p. 4.3-34)
 
Evaluate and Summarize CDB TLAAs (Continued)
* Identify Disposition
  - Based on Analysis History, Results, and Methods
* 10 CFR 54.21(c)(1)(i) - If simple design life or cycle ratios, etc.,
confirm adequate margin at 60 years
* 10 CFR 54.21(c)(1)(iii) - Used in most other cases
          - Requires Aging Management
* 10 CFR 54.21(c)(1)(ii) - Reanalysis performed
 
Evaluate and Summarize CDB TLAAs (Continued)
* Identify Disposition (Continued)
  - 10 CFR 54.21(c)(1)(iii) monitoring methods are described in LRA 4.3.1, summarized by monitored location in Table 4.3-4
  - Details of 10 CFR 54.21(c)(1)(iii) monitoring methods are location and analysis-specific. Examples:
* Global - monitor transients
* Cycle-based fatigue (CBF) - monitor transients, possible CUF impacts
* Stress-based fatigue (SBF) - impact of transients require reevaluation of CUF
 
NRC Staff Questions
* Have we answered the questions and issues stated in this presentation?
* Does the staff have additional questions with respect to cycle counting or the PVNGS approach to metal fatigue?
* Review action items
* Future topics Thank you for your participation}}

Latest revision as of 18:03, 13 November 2019

License Renewal - April 1 Webinar on Metal Fatigue Arizona Public Service Company Presentation Slides
ML101380215
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/01/2010
From:
Arizona Public Service Co
To:
Division of License Renewal
Regner L M, NRR/DLR, 415-1906
References
TAC ME0254, TAC ME0255, TAC ME0256
Download: ML101380215 (30)


Text

PVNGS License Renewal Application Metal Fatigue Topics April 1, 2010

Discussion Topics

  • Historical and general background
  • Metal Fatigue Monitoring Program
  • Cycle Counting Questions
  • Class 1 Fatigue TLAA Evaluation Process
  • Future actions
  • NRC staff questions

Historical and general background

Initial development of PVNGS metal fatigue monitoring program

  • SYS80-PE-DE Compilation of NSSS Responses to Design Bases Dynamic Events for the System 80 Standard Design established applicable design cycles and their 40-year expected accumulation
  • Class I metal fatigue analyses incorporated the SYS80-PE-DE limits and in some cases identified additional items of concern

Initial development of PVNGS metal fatigue monitoring program

  • The initial Technical Specification program did not require all UFSAR transients to be monitored
  • The UFSAR does not incorporate all of the additional limits (e.g. RCP stud tensioning/de-tensioning) - to be discussed later in this presentation

Program Review - 1995

  • Implemented expanded list of transients in January 1996
  • ITS upgrade in 1998 established current requirements
  • Not counted data between 85 and 95 was assumed to be an accumulation of 25% of the design allowed transients in all but a few cases

Performance of cycle counting since January 1996

  • Actual event counting has been in place since January 1996
  • Unit 1, 2 and 3 records have now been reviewed for LRA support

Metal Fatigue Monitoring Program

Current PVNGS Metal Fatigue Monitoring Program

  • Current methodology:

- Cycle counting to ensure design assumptions are not exceeded

- Specific component locations are not specified

- Exception: Partial cycle (CBF-PC) methodology is used to track spray nozzle usage

Addressing Cycle Count Assumptions

  • LRA development prompted PVNGS staff to revisit the assumptions for 1985 - 1995
  • Recounts of all three units were reported in the response to RAI B3.1-4 (see RAI response Table 3.1-4)

- Recount Methodology

  • Best source selected (logs, MORs, LERs, WOs, interviews)
  • Validated assumptions

Cycle Recount

  • Recount Methodology

- Best source selected (logs, MORs, LERs, WOs, interviews)

- Reviewed assumption of 25% accumulated cycles

  • Actual data
  • Comparison to 95 - 05 operating history

Enhanced Metal Fatigue Monitoring Program

  • Scope - All Class I components
  • Methodology:

- Based on component locations

- Adds SBF for high usage locations (not discussed in this presentation)

- Continues cycle counting for Global monitoring

  • Used for low 40-year design CUF
  • No new industry issues since original design
  • Industry experience indicates not a problem location

- Expands CUF monitoring

  • CBF-C (CUF based on design cycle)
  • CBF-PC (CUF based on partial cycle)
  • CBF-EP (CUF based on event pairing)

- Establishes appropriate action limits and corrective actions

Enhanced Program Status

  • SBF methodology (to be determined)
  • FatiguePro is under evaluation for cycle counting and CBF monitoring
  • Current manual cycle counting will continue until a suitable software program has been validated
  • Enhanced program will be implemented no later than two years prior to the PEO (LRA commitment #39 as revised in Amendment 9)

Cycle Counting NRC Questions Cycle Counting RAIs and Amendments

  • Amendment 3 (annual update)

- Added Unit 3 record review results and revised one transient total to replace an estimate with data

- Revised current program action limit discussion to avoid confusion with the enhanced program limits

- Minor clarifications were included in the AMP OE discussion

Cycle Counting RAIs and Amendments (continued)

  • Amendment 9 (result of RAI B3.1-1 thru 8)

- RAI B3.1-4 response provided the individual unit cycle totals from best available sources

- Corrected typographical errors

- Included enhanced monitoring implementation schedule

- Committed to selection of a suitable SBF methodology

- Clarified cycle projection methodology

Cycle Counting RAIs and Amendments (continued)

Most recent cycle count related DRAI set (DRAI 4.3-1 thru 9

- DRAI 4.3-1 Transients projected to exceed 40-year limits

  • Projections are conservative and may not be reached
  • PVNGS took no exceptions to X.M1 and concludes fatigue reanalyses are not required based on projections . Corrective action will be initiated if needed based on program action limits

Cycle Counting RAIs and Amendments (continued)

- Presented for information only

- Concept of a worst case bounding unit

- Conservative Assumptions

  • Highest unit total was used for 85-95 and for 95-05
  • Lowest operating years was used for accumulation rate
  • 42 years were used for projecting and added to above
  • Zero accumulation assumed to be linear times 22/40

- If not expected still assumed 1 event

Cycle Counting RAIs and Amendments (continued)

  • DRAI 4.3-2 Global monitoring criteria does not seem consistent

- Exceptions are explained in LRA table notes

  • DRAI 4.3-3 Clarify the CBF-PC method
  • DRAI 4.3-4 Program action limits (see commitment #39)
  • DRAI 4.3-5 Some cycles do not agree with the UFSAR

- Some are derived from UFSAR sections other than 3.9.1

- Some come from specific analyses (e.g. RCP studs)

- Addition of cycles to the UFSAR is under consideration

Cycle Counting RAIs and Amendments (continued)

  • DRAI 4.3-6 25% cycle assumption

- Review of best source data was presented in the response to RAI B3.1-4

- Compared assumption to actual data from recount efforts or data from 95-05

- Result:

  • Four assumptions of 25% cycle accumulation are being reviewed: Rx Trip, Load Reject, Turbine Trip w/o Rx Trip and Depressurization by MSSV at 100% power
  • Remaining 25 % assumptions are conservative

Cycle Counting RAIs and Amendments (continued)

  • DRAI 4.3-7 Not all cycles were recounted

- Some had accurate data and did not require recount

- Some were not significant (e.g. plant loading at 5%/min)

- Some could not be recovered so the 25%

assumption was used and validated from 95-05 data

Cycle Counting RAIs and Amendments (continued)

  • DRAI 4.3-8 Questioned an incorrect table note (had been corrected in Amendment 9)
  • DRAI 4.3-9 Some cycles are not included in the UFSAR (similar to DRAI 4.3-5)

- Some come from specific analyses (e.g. RCP studs)

- Addition of cycles to the UFSAR is under consideration

Class 1 Fatigue TLAA Evaluation Process - LRA Section 4.3.2

Class 1 Fatigue TLAA Evaluation Process

  • Identify TLAAs and Affected Components

- SRP Guidance, Industry Experience, CLB Search

  • Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)
  • Evaluate and Summarize CDB TLAAs

- Analysis Results - Analyzed Locations, CUFs, etc.

- Effects of Modification, Analysis, and Op. History

- Effects of Differences in Analysis Methods

- Identify Disposition

Identify TLAAs and Affected Components

- NUREG-1800 Sect. 4.3 and Tables for Class 1

- Based on ASME III Subsection NB and NG and Industry Experience

  • Industry Experience - Examples:

- Other LRAs

- NRC and NSSS vendor Bulletins, Notices, etc.

- Word Search of CLB (FSAR, Docketed Reports, Letters, etc.)

- Confirm applicability to Palo Verde

- Identify other plant-specific TLAAs

Retrieve Component Current Licensing and Design Basis Documents (CLB and CDB)

  • Research and Summarize History of CLB

- Confirm Current Licensing Basis

  • Research Design and Analysis History

- Confirm Current Design Basis

- TLAAs are analyses, are therefore part of the CDB

- TLAAs are usually bases of the CLB (incorporated by reference) rather than included verbatim

Evaluate and Summarize CDB TLAAs

  • Analysis Results

- All TLAA Results (e.g., all reported fatigue summaries)

- All Analyzed Locations

- Tabulated for Complex Components

  • Effects of Modification, Analysis, and Operating History - Examples:

- Instrument Nozzle Half-Nozzle and MNSA Repairs (Several LRA Sections)

- Pressurizer Surge Line Thermal Stratification (LRA Section 4.3.2.9)

- Unit 2 Head Vent Repair - high part-life CUF, head replaced Fall 2009 (LRA p. 4.3-34)

Evaluate and Summarize CDB TLAAs (Continued)

  • Identify Disposition

- Based on Analysis History, Results, and Methods

confirm adequate margin at 60 years

- Requires Aging Management

Evaluate and Summarize CDB TLAAs (Continued)

  • Identify Disposition (Continued)

- 10 CFR 54.21(c)(1)(iii) monitoring methods are described in LRA 4.3.1, summarized by monitored location in Table 4.3-4

- Details of 10 CFR 54.21(c)(1)(iii) monitoring methods are location and analysis-specific. Examples:

  • Cycle-based fatigue (CBF) - monitor transients, possible CUF impacts
  • Stress-based fatigue (SBF) - impact of transients require reevaluation of CUF

NRC Staff Questions

  • Have we answered the questions and issues stated in this presentation?
  • Does the staff have additional questions with respect to cycle counting or the PVNGS approach to metal fatigue?
  • Review action items
  • Future topics Thank you for your participation