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Category:Annual Operating Report
MONTHYEARL-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-22-037, 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2022-06-30030 June 2022 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-21-140, 2020 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2021-06-24024 June 2021 2020 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models ML21134A0702021-05-15015 May 2021 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2020 ML20142A3932020-05-0505 May 2020 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the 2019 L-20-119, Report of Facility Changes, Tests, and Experiments2020-05-0404 May 2020 Report of Facility Changes, Tests, and Experiments L-19-076, 2018 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models and 10 CFR 50.46 30-Day Report2019-07-0808 July 2019 2018 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models and 10 CFR 50.46 30-Day Report L-18-035, Report of Facility Changes, Tests, and Experiments2018-05-21021 May 2018 Report of Facility Changes, Tests, and Experiments L-17-041, Submittal of 2016 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2017-08-22022 August 2017 Submittal of 2016 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models ML17150A0922017-05-11011 May 2017 Transmittal of Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for 2016 ML17150A2742017-02-17017 February 2017 ATI Environmental Midwest Laboratory - Radiological Environmental Monitoring Program for Davis-Besse for 2016 Final Report L-15-153, Transmittal of 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2015-05-26026 May 2015 Transmittal of 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-15-109, ISFSI - Summary Report of Changes, Tests and Experiments for the Period of January 1, 2013 Through December 31, 20142015-04-0606 April 2015 ISFSI - Summary Report of Changes, Tests and Experiments for the Period of January 1, 2013 Through December 31, 2014 L-12-194, Report of Facility Changes, Tests, Experiments for Period Covering June 17, 2010 Through June 14, 20122012-06-27027 June 2012 Report of Facility Changes, Tests, Experiments for Period Covering June 17, 2010 Through June 14, 2012 L-12-166, Submittal of Annual Report of 10 CFR 50.46 of Changes to or Errors in ECCS Evaluation Models2012-05-18018 May 2012 Submittal of Annual Report of 10 CFR 50.46 of Changes to or Errors in ECCS Evaluation Models ML12174A0902012-05-15015 May 2012 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2011 L-11-167, CFR 50.46 Report of Changes or Errors in ECCS Evaluation Models, for the Period of January 1, 2010 to December 31, 20102011-05-27027 May 2011 CFR 50.46 Report of Changes or Errors in ECCS Evaluation Models, for the Period of January 1, 2010 to December 31, 2010 L-10-139, CFR 50.46 Report of Changes or Errors in ECCS Evaluation Models2010-05-27027 May 2010 CFR 50.46 Report of Changes or Errors in ECCS Evaluation Models L-09-125, Submittal of Annual Report of Changes to the Emergency Core Cooling System Evaluation Model and in the Application of the Model in Accordance with 10 CFR 50.46(a)(3)2009-05-28028 May 2009 Submittal of Annual Report of Changes to the Emergency Core Cooling System Evaluation Model and in the Application of the Model in Accordance with 10 CFR 50.46(a)(3) L-08-139, Submittal of Report of Facility Changes, Tests and Experiments for Period of May 19, 2006 Through February 14, 20082008-06-23023 June 2008 Submittal of Report of Facility Changes, Tests and Experiments for Period of May 19, 2006 Through February 14, 2008 L-08-168, Report of Changes to the Emergency Core Cooling System Evaluation Model in Accordance with 10 CFR 50.46(a)(3)2008-05-28028 May 2008 Report of Changes to the Emergency Core Cooling System Evaluation Model in Accordance with 10 CFR 50.46(a)(3) L-07-062, Units 1 and 2, 2006 Firstenergy Corp. Annual Report2007-04-0909 April 2007 Units 1 and 2, 2006 Firstenergy Corp. Annual Report ML0522902482005-08-16016 August 2005 TS Pages - Issuance of Amendment ML0504601972005-02-0303 February 2005 10 CFR 72.48 Report of Dry Fuel Storage Facility Changes, Tests and Experiments for January 2003 to December 2004 ML0314702122003-04-30030 April 2003 Annual Radiological Environmental Operating Report, January 1, 2002 Through December 31, 2002, Pages 68 Through 81 ML0314702092003-04-30030 April 2003 Annual Radiological Environmental Operating Report, January 1, 2002 Through December 31, 2002, Pages 60 Through 67 ML0314702072003-04-30030 April 2003 Annual Radiological Environmental Operating Report, January 1, 2002 Through December 31, 2002, Pages 46 Through 59 ML0314702042003-04-30030 April 2003 Annual Radiological Environmental Operating Report, January 1, 2002 Through December 31, 2002, Table of Contents Through Table 6 ML0314305042003-04-30030 April 2003 Annual Radiological Environmental Operating Report, Radioactive Effluent Release Report, January 1 Through December 31, 2002 L-03-039, Firstenergy - Retrospective Premium Guarantee2003-03-0606 March 2003 Firstenergy - Retrospective Premium Guarantee ML0530704932001-12-31031 December 2001 System Health Report 4th Quarter 2001 Reactor Coolant System 2023-06-13
[Table view] Category:Letter type:L
MONTHYEARL-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage L-23-059, Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-0022023-03-0909 March 2023 Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-002 L-22-212, CFR 50.55a Request RP-5 Regarding Inservice Pump Testing2023-03-0606 March 2023 CFR 50.55a Request RP-5 Regarding Inservice Pump Testing L-23-048, Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2023-03-0101 March 2023 Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023 Energy Harbor Nuclear Corp Retrospective Premium Guarantee L-22-253, Submittal of Pressure and Temperature Limits Report, Revision 52023-01-10010 January 2023 Submittal of Pressure and Temperature Limits Report, Revision 5 L-22-284, Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS)2022-12-28028 December 2022 Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS) L-22-211, Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2022-09-29029 September 2022 Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-22-216, Submittal of Pressure and Temperature Limits Report. Revision 42022-09-27027 September 2022 Submittal of Pressure and Temperature Limits Report. Revision 4 L-22-213, Occupational Radiation Exposure Report for Year 2021 - Correction2022-09-23023 September 2022 Occupational Radiation Exposure Report for Year 2021 - Correction L-22-129, Submittal of the Updated Final Safety Analysis Report, Revision 342022-09-20020 September 2022 Submittal of the Updated Final Safety Analysis Report, Revision 34 L-22-194, Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events2022-09-19019 September 2022 Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events L-22-203, Submittal of Evacuation Time Estimates2022-09-12012 September 2022 Submittal of Evacuation Time Estimates L-22-050, Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual2022-08-0909 August 2022 Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual L-22-152, Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan2022-07-0505 July 2022 Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan L-22-068, Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report2022-06-30030 June 2022 Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report L-22-037, 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2022-06-30030 June 2022 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-22-149, Post Accident Monitoring Report2022-06-23023 June 2022 Post Accident Monitoring Report L-22-153, Readiness for NRC Supplemental Inspection Required for a White Finding2022-06-22022 June 2022 Readiness for NRC Supplemental Inspection Required for a White Finding L-22-098, Withdrawal of Proposed Inservice Inspection Alternative RR-A22022-06-22022 June 2022 Withdrawal of Proposed Inservice Inspection Alternative RR-A2 L-22-136, Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage2022-06-0707 June 2022 Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage L-22-102, Report of Facility Changes, Tests, and Experiments2022-05-16016 May 2022 Report of Facility Changes, Tests, and Experiments L-22-092, Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 20212022-05-16016 May 2022 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2021 L-22-124, Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building2022-05-12012 May 2022 Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building L-22-047, Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 12022-05-10010 May 2022 Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 1 L-22-127, Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding2022-05-0606 May 2022 Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding L-22-089, Occupational Radiation Exposure Report for Year 20212022-04-12012 April 2022 Occupational Radiation Exposure Report for Year 2021 L-22-056, Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage2022-03-22022 March 2022 Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage L-22-059, Response to Request for Additional Information on Proposed Inservice Test Alternative RP-32022-03-21021 March 2022 Response to Request for Additional Information on Proposed Inservice Test Alternative RP-3 L-22-074, Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-15015 March 2022 Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations L-22-061, Ile Post Exam Letter L-22-0612022-02-24024 February 2022 Ile Post Exam Letter L-22-061 L-22-023, Retrospective Premium Guarantee2022-02-17017 February 2022 Retrospective Premium Guarantee L-21-266, Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A22022-01-27027 January 2022 Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A2 L-20-289, Emergency Plan Amendment Request2022-01-19019 January 2022 Emergency Plan Amendment Request L-21-290, Response to NRC Inspection Report 05000346/2021091, EA-21-1762021-12-21021 December 2021 Response to NRC Inspection Report 05000346/2021091, EA-21-176 2023-09-12
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.a energy Energy Harbor Nuclear Corp.
Davis-Besse Nuclear Power Station
~ harbor 5501 N. State Route 2 Oak Harbor, Ohio 43449 Mark B. Bezilla 419-321-7676 Site Vice President, Davis-Besse Nuclear May 4, 2020 L-20-119 10 CFR 50.59(d)(2)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Report of Facility Changes, Tests, and Experiments In accordance with 10 CFR 50.59(d)(2), Energy Harbor Nuclear Corp. hereby submits the Report of Facility Changes, Tests, and Experiments for the Davis-Besse Nuclear Power Station, Unit No. 1. The attached report covers the period of May 12, 2018 through May 4, 2020.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A.
sµ/4.~
Lentz, Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6810.
Mark B. Bezilla /
Attachment:
Davis-Besse Nuclear Power Station, Unit No. 1 Report of Facility Changes, Tests, and Experiments cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Utility Radiological Safety Board
Attachment L-20-119 Davis-Besse Nuclear Power Station, Unit No. 1 Report of Facility Changes, Tests, and Experiments Page 1 of 5
Title:
Component Cooling Water System Procedure Activity
Description:
This activity involved identifying a slight increase trend in oil leakage from the inboard bearing of the component cooling water (CCW) 1 pump. Operational oil leakage from the inboard sleeve bearing adaptor of the CCW 1 pump increased to an amount that requires oil addition during the 30-day mission time. With the recent leakage trend, this condition has the potential to affect pump performance during its required mission time if actions are not taken to ensure oil level is maintained at an adequate level.
A similar oil leakage trend was identified that was associated with the inboard bearing of the CCW 3 pump. CCW 2 pump is known to have bearing oil leaks. These issues have been documented in the corrective action program. All three CCW pumps are the same model and have the same bearing configurations.
The CCW pump leakage from all three pumps, inboard and outboard bearings, was evaluated in a Prompt Operability Determination (POD). The POD requires compensatory actions to support CCW pump operability for its mission time with the identified leakage.
The CCW system procedure was updated to implement the following compensatory actions.
- 1. During normal operations, at least once per shift, operators shall verify the oil levels for all six CCW pump bearing oil sight glasses are above the halfway point of the operating band identified in the CCW pump lubrication data sheets. If, at any time, oil level of any of the CCW pump bearings is identified to be at or below the halfway point of the operating band marked on the sight glass, then oil shall be added to refill that bearing's reservoir to the high mark on the sight glass. Oil addition shall be completed within one shift of identification.
- 2. During post-accident conditions, Operations shall monitor pump bearing oil levels at 24-hours intervals and request maintenance to add oil as needed to maintain oil level at or above the halfway point of the operating band identified in the CCW pump lubrication data sheets.
Attachment L-20-119 Page 2 of 5 Summary of Evaluation:
All design basis functions of the CCW pumps were met during, and remain met after, implementation of this activity. No accident initiators are altered. The likelihood of equipment malfunction is not increased. The consequences of accidents or malfunction of systems, structures, or components are unchanged. No new or different accidents or malfunctions of systems, structures or components are created. No fission product barrier limits are changed or challenged. No new methods of analysis have been used in the safety analyses performed to assess the change. In conclusion, the proposed revision of the procedure does not meet any of the 10 CFR 50.59(c)(2) criteria; therefore, a license amendment is not required.
Title:
Control Rod Survivability Analysis During a Loss-of-Coolant Accident (LOCA)
Activity
Description:
This activity involved evaluation and implementation of a revision to the site calculation for control rod survivability during a LOCA. Specifically, this involved the evaluation of the potential for control rod melt with absorber expulsion during a LOCA. The calculation revision added a detailed evaluation of the potential for control rod melt during a small break loss-of-coolant accident (SBLOCA). An update to the Updated Final Safety Analysis Report (UFSAR) was completed along wi~h the calculation revision.
During the initial licensing of the Davis-Besse Nuclear Power Station (DBNPS), the NRC staff requested a description of the analytical methods and uncertainties associated with the calculations performed to evaluate the potential for control rod melt. The original analysis described in the UFSAR determined temperatures throughout the control rod structures by modeling conductivity, gap conduction, convection, and thermal radiation heat transfer as well as internal heat generation. The new analysis described in the revised calculation used the same basic methodology as the original but revised multiple elements to address identified non-conservatisms in the original methodology. The revised analysis used the RELAP5/MOD2-B&W code.
Summary of Evaluation:
The use of an alternate method rather than the method originally described in the UFSAR that was used in establishing the safety analyses and establishing the design bases meets the definition of an adverse change that must be evaluated under 10 CFR 50.59(c)(2)(viii). The screening determined that the proposed activity involved only a change to a method of evaluation, and the criteria of 10 CFR 50.59(c)(2)(i-vii) are not applicable.
Attachment L-20-119 Page 3 of 5 Nuclear Energy Institute (NEI) 96-07, Revision 1, Guidelines for 10 CFR 50.59 Evaluations, identifies that the use of a methodology revision that is documented as providing results that are essentially the same as, or more conservative than, the previous revision of the same methodology is not considered a departure from a method of evaluation described in the UFSAR. This evaluation demonstrated that the revised analysis methodology for evaluating control rod survivability during a LOCA provides more conservative results than the methodology described in the original DBNPS Final Safety Analysis Report.
Title:
UFSAR Section 18 - Leak Chase Monitoring Program changes necessary following commencement of the Period of Extended Operation.
Activity
Description:
The Leak Chase Monitoring Program is a condition monitoring program, consisting of observations and activities to detect leakage from the spent fuel pool, the fuel transfer pit, and the cask pit liners due to age-related degradation. The Leak Chase Monitoring Program includes periodic monitoring of the spent fuel pool, the fuel transfer pit, and the cask pit liners leak chase system.
Loss of intended function of the spent fuel pool, the fuel transfer pit, and the cask pit liners, that is gross leakage, would not occur at values at or just above the original selected acceptance criteria of 15 milliliters per minute (ml/min). Gross leakage is leakage in excess of makeup capacity. The UFSAR provides a value of makeup from the decay heat removal system to the spent fuel pool from the borated water storage tank by pumped or gravity-fill methods on the order of 70 gallons per minute. The magnitude of leakage being discussed herein is 25 ml/min through the leak chase monitoring lines. Assuming all 21 leak chases were leaking at this acceptance criteria rate, it would only result in a leak rate of 200 gallons per day or 0.14 gallons per minute. The increase in leak rate from the original acceptance criteria of 15 ml/min to the new acceptance criteria being evaluated of 25 ml/min is only 80 gallons per day or 0.06 gallons per minute. This loss is minimal when compared with evaporative losses that are still bounded by the makeup rate on the order of 70 gallons per minute.
The DBNPS UFSAR was revised to change the Leak Chase Monitoring Program criteria for documentation in the corrective action program of measurement of leakage from any leak chase monitoring line from 15 ml/min to 25 ml/min.
Attachment L-20-119 Page 4 of 5 Summary of Evaluation:
The 10 CFR 50.59 Evaluation determined that all design bases functions are met. No accident initiators are altered. The likelihood of equipment malfunction is not increased.
The consequences of accidents or malfunctions of systems, structures, or components are unchanged. No new or different accidents or malfunctions of systems, structures, or components are created. No fission product barrier limits are changed or altered. No methods of evaluation have been changed. Therefore, the proposed revision of the procedure does not meet the criteria of 10 CFR 50.59(c)(2) and prior approval is not required to implement this change.
Title:
Extension of Steam Turbine Valve Test Intervals Activity Description :
This activity implemented the extension of the steam turbine valve test intervals for the stop valves, control valves, and combined intermediate valves. The test interval was extended from quarterly to a maximum of six months. The test interval extension is based on a calculation from MPR Associates Inc., which determined the effect on the turbine missile generation probability. Valve testing is performed using periodic tests (main turbine stop valve test, main turbine control valve test, and the main turbine combined intermediate valve test). This activity only extends the test interval and no other changes were made to the periodic valve test procedures. The UFSAR section for turbine steam flow control was updated to indicate valves are tested closed within a 6-month interval.
Summary of Evaluation:
The 10 CFR 50.59 Evaluation concluded the design function of the overspeed protection system (OPS) was adversely affected by changing the turbine valve testing interval.
Changing to a greater than quarterly test frequency increases the probability of an overspeed event and therefore decreases the reliability of the OPS. Per NEI 96-07, a change that decreases the reliability of a function that could initiate an accident is considered an adverse effect to a design function.
The turbine missile generation probability was calculated as a function of the valve test interval. An analysis was completed which determined DBNPS will remain below the NRC approved value of 4x10-5 per year.
There are no new malfunctions or accidents introduced by this change in test frequency.
In addition, there are no consequences of previously evaluated events affected. All design basis limits for fission products are unaffected because there is no change to any
Attachment L-20-119 Page 5 of 5 assumed failures of mitigating systems. The turbine missile generation description in the UFSAR does not describe a methodology, therefore, the activity does not result in a departure from a method of evaluation described in the UFSAR.