ML20216C966

Requests That Proprietary CAA-97-234, Farley Unit 1 Cycle 15 Thimble Deletion Study, Be Withheld,Per 10CFR2.790(b)(4)

ML20216C966
Person / Time
Site:	Farley, 05200003
Issue date:	08/29/1997
From:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Collins S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19317C700	List: ML20216C923 ML20216C966 ML20216D003 ML20216D017
References
CAW-97-1160, NUDOCS 9709090181
Download: ML20216C966 (23)

Text

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[ CAW.971160 Document Control Desk U S. Nuclear Regulatory Commission Washington, DC 20555 Attention: hit. Samuel J. Collins APPLICATION FOR WITilHOLDING PROPRIETARY WEQBh1ATION FR0ht PUllLICEJECLQ1URE

Subject:

'Tarley Unit I Cycle 15 nimble Deletion Study", CAA 97 234 (Proprietary)

Dear hir. Collins,

The proprietary information for which withholding is being requested in the above referenced report is further identified in Affidavit C AW 97 1160 signed by the owr.er of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission's regulations.

Accordmgly, this letter authonzes the utilization of the accompanying Affidavit by the Southern Nuclear Operating Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse aflidavit should reference this letter, CAW 97 1160, and should be addressed to the undersigned.

Very truly yours, k

N. J. Liparuto, hianager Equipment Design and Regulatory Engineering Enclosures cc: Kevin Bohrer/NRC(12H5)

Ei493L Os17 97 9709090181 970903 PDR ADOCK 05000348 p PDR J

1 Proprietary Information Notice Transmitted herewith are proprieury and/or non-proprietary versions of documents furnished to the

- NRC in connection with requests for generic and/or plant specific review and approval, in order to conform to the requirements of 10CFR2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary vwslons is contained within brackets, and where the proprietary information has been deleted in the non proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary vwstons having been deleted). 'the justincation for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) contained within parenthesu located as a superscript immediately following the brackets enclosing each item of information being Ideritined as proprietary -

. or in the margin opposite such informatiori. *!hese lower case letters refer to the types of information Westinghouse customarily holds in conndence identined in Sections (4)(ll)(a) through (4)(ii)(f) of the amdavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. 'Ihe NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its v.ternal use in connection with generic and plant 4pecinc reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a licenu, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westlnshouse, copyright protection notwithsta. Ming. With respect to the non-proprietary versions of these reports, the NRC la permitted to make the nun,ber of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations it the number of copies submitted is insumclent for this' purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

• I l ,

CAW 97 Il60 AFFIDAVIT COMMONWEAL *EH OF PENNSYLVANIA:

ss COUNTY 0F ALLEGHENY:

Before me, the undersigned authority, perronally appeared Henry A. Sepp, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (' Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

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c Henry A.(Sepp, Manager c r Regulatory and Licensing Engineering Sworn to and subscribed before thi. A f day of L/>isi d ,1997 b

miw Jastet A kNeb Notary PubNe W ist afcI2k g,, ,g m.

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3 CA"' 97-l 160 l) I am Manager, Regulatory and Licensing Engineering, in the Nuclear Services Division, of the Westinghouse Electric Corporation and as such, I have been speci0cally delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.

(2) I am making this A10 davit in conformance with the ' provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Af0 davit.

(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit in derl i...ating informatk.a as a trade secret, privileged or as conudential commercial or unancial information, (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(1) The information sought to be withheld from public dischsure is owned and has been held in con 0dence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in con 0dence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse polley and provides the rational basis required.

Under that system, information is held in con 0dence if it falls in one or more of several types, the release of which might result in the loss of an existing er potential competitive advantage, as follows:

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'] 3 CAW.97 ll60 (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or imptove his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded deulopment plans and programs of potential commercial value to Westinghouse.

(0 It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position, (b) It is information which is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products ud services involving the use of the information, uncasaw

I 4- CAW 97 l160 (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may bis the key to the entire puzzle, thereby depriving Westinghouse of a competitive advartage.

(e) Unrestricted disclosure would.leopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining a' nd maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not beer. previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in *Farley Unit I Cycle 15 Thimble Deletion Study," CAA 97-234 (Proprietary), Aui;,.st,1997 for Farley Unit I, being transmitted by Southern Nuclear Operating Company letter and Application for Withholding Proprietary Information from Public Disclosure, Document Control Desk, Attention Mr. Samuel J.

Collins. The proprietary information as submitted for use by Southern Nuclear unemen

e 5 CAW 971160 Operating Company for Farley Unit I is erpeeted to be applicable in other lleensee submittals in response to certain NRC requirements for justification of reduction in the required number of movable detector thimbles.

This information is part of that which will enable Westinghouse to:

(a) Provide the NRC with technical evaluations on the proposed reduction in the number of available movable detector thlmtiles required for J. M. Farley Unit ! Cycle 15 operations.

(b) Assist Southern Nuclear Operating Company in obtaining NRC approval.

(c) Establish the applicable methodology for movable detector thimble reductions.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of justifying reduction in the number of available movable detector thimbles required.

(b) Westinghouse can sell support and defense of the product to its custoniers in the licensing process.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive positlen of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justi0 cations and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information, ucmau

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't 6- CAW 97.ll60 l

• Ihe development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money, in order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower etfort, having the requisite talent and esperience, would have to be expended for developing the enclosed improved core thermal performance methodology.

Further the deponent sayeth not.

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Enclosure i Discussion of Proposed Change

j I)iscussion of Proposed Change Backaround and Measons for Channes The Moveable incore Detector System consists of 50 incore flux thimbles which permit measurement of the axial and radial neutron flux distribution within the reactor core.

Moveable fission chamber detectors are available to scan the length of the 50 selected core locations. Specifleation 3.3.3.2.a currently requires at least 75% (38 thimbles) of the detector thimbles to be operable when performing a flux map to ensure compliance with i

the peaking factor requirements of Technical Specification 3.2.2. In accordance with the surveillance requirements in Specification 3.2.2, the peaking fcctors must be determined to l be within limits at least once per 31 effective full power days. If the moveable detector system is degraded to the extent that less than 75% of the detector thimbles are available, Technical Specification 3.3.3.2 requires that the system not be used for applicaHe monitoring or calibration functions.

During the Unit I founeenth refueling outage, the incore thimbles were inspected and cleaned, in addition, six incore thimbles were capped; the clutches on four drive units were replaced; and the detector / cable assembly for two drive units was replaced. Clutch

drag testing was .' iso performed in order to determine if excessive drag forces might bc

afTecting the ability of the detector to completely transit its assigned paths. Identified tubing sections between the drive units and the seal table that caused excessive losses were replaced.

During the start up process, numerous flux maps were run with nn ur,osual problems, liowever, a flux map attempt on July 8,1997 was unsimsiul because sixteen incore thimbles would not allow the detector to comp;cie its transit. This flux map was later

, successfully completed; however, the problems identified with the incore detector system have continued. The following table illustrates the actual number of successfully mapped thimblee to date for Unit 1 Cycle 15; Flux Map Date  % Power Successful Thimbles 366 6/5/97- 33 43' 372 6/10/97 100 43*

373 7/10/97 100 41*

374 8/5/97 100 38*

375 8/l4/97 100 38 376 8/27/97 100 39 "

• For these maps, one thimble, L-8, was not attempted due to historical problems. For map 374, one additional thimble,113, was inadvertently not attempted.

• For map 376, thimble, B 5, was not attempted due to recent sticking problems.

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Discussion of Proposed Change Page 2 Attachments 2,3, and 4 show the thimble locations inaccessible during the performance of flux maps 374,375, and 376 for Unit i Cycle 15. As can be seen from the data above, during the flux maps performed on August 5,1997 and August 14,1997, only 75% (38 of

50) of the incore thimbles were successfully mapped. For map 374, two additional thimbles were not attempted, and thus may or may not have been accessible. For map 375, all unplugged thimbles were attempted, and only 38 were accessible. For map 376, one thimble was not at:empted, and 39 thimbles were successibily mapped As evidenced by the data above and by Attachments 2,3, and 4, the locatmui detector thimbles which were unavailable has changed throughout Unit 1 Cy& 15. Ilowever, as can be seen in Attachments 2 through 4, for flux maps 374. 2, and 376 the available detectors were well distributed throughout the com .md the thimble verage was adequate.

Until conective actione =. be taken, in view of the recent decline in the number of detector thimb!:, available, Southern Nuclear is concerned about meeting the 75%

erite'% called for in Technical Specification 3.3.3.2 for future required moveable incore detection system monitoring / calibration uses. Southern Nuclear believes that this problem has the potential to worsen throughout Unit 1 Cycle 15. Failure to have at least 75% of the thimbles (38 thimbles) accessible could eventually result in a forced Unit I shutdown due to the inability to satisfy the peaking factors per the requirements of the Technical Specifications.

Pronosed Chances The proposed change will allow Farley Unit I a reduction in the number of required available movable detector thimbles (flux map paths) for Cycle 15. Currently, Unit i Technical Specification 3.3.3.2, requires at least 75% of the 50 movable detector thimbles (38 flux map paths) available with 2 per quadrant. The proposed change will allow a reduction in the available paths to a minimum of 25 with 3 per quadrant. As a result of this reduction, an additional incremental uncertainty associated with the peaking factor measurements is required. This incremental uncertainty will be a linear assessment that is applied due to the reduction of available flux map paths from 38 to 25. The total additional uncertainty associated with the thimble reduction is a maximum of 2% for F N and 1.5% for F"m Evaluation _and Justificathm of Chanm TI,e moveable incore detector system is used for confirmatory information and is not required for the day to day safe operation of the reactor (daily core power performance is monitored by the excore detectors). The measured power distribution is affected by the "true" power distribution that exists in the core, the predicted power distribution in the core, and the instrument thimble pattern. The thimbles are distributed nearly uniformly over the core with approximately the same number of thimbles in each quadrant. The number and location of these thimbles allows measurement of F"m to within 4% and F"o to within 5% with at least 75% (38 thimbles) of the detector thimble locations available.

Discussion of Propaed Change Page 3 The seguirement for maintainig,75% (38 thimbles) of the detector thimbles available provides for a reasonable amount of failures of the incore detectors while encouraging licensees to strive for maintaining the system as near to 100% available as possible. As shown by the attached evaluation, the reduction of available detector thimbles to 50% (25 thimbles), as proposed by this amendment request, does not significantly degrade the ability of the detector system to measure core power distributions. Ilowever, use of the moveable incore detector system with less than 75% (38 thimbles) of the detector thimbles available requires the core peaking factor measurement uncenainties specified in the Technical Specifications be increased to compensate for the reduction in the number of available detector thimble locations.

The attached Westinghouse evaluation concludes that with the inclusion of the additional peaking factor uncertainties, operation of the moveable incore detector system with a minimum of 50% (25 thimbles) of the thimbles available is acceptable with the above provisions on the number of detector thimbles per quadrant.

As of the last flux mnp conducted on August 27,1997, the burnup on Unit 1 Cycle 15 was

r. bout 3,175 htWD/MTU of a 19,350 MWD /MTU cycle. At this point in cycle operation, the core characteristics have been well established and, specifically, core power distribution is well behaved. All power distribution surveillance parameters (F*ai and F"o) currently have suflicient margin to their limits after the current Technical Specification required uncertainties are applied. From the flux map taken on August 27,1997,it is calculated that there is approximately 10.1% margin to the F"ailimit (i.e., measured F"ai plus its measurement uncertainty compared to its Technical Specification limit) and approximately 5.7% margin to the F"q transient limit. See Attachment I for a summary of the results of the flux maps taken to date during Unit i Cycle 15. The predicted peaks provide 5% to 12% margin to the Technical Specification limits through the remainder of the cycle. Attachment 5 demonstrates that low power physics testing results were well within expected criteria. It is also expected that the core will continue to behave as designed. Therefore, adequate margin exists for implementation of the additional measurement uncertainties resulting from the Westinghouse evaluation.

Conclusion This proposed change to the Farley Technical Specifications would allow an increase in plant operating flexibility for the remainder of Unit 1 Cycle 15, while maintaining sutlicient data collection capability to ensure that the operation of the core remains within licensed limits. This change would be utilized only if funher failures of the Unit I detector thimbles occur during the remainder of Cycle 15.13ased upon the preceding justification, Southern Nuclear concludes that the proposed amendments are necessary to avoid an unnecessary potential shutdown of Farley Unit I which has real benefits in terms of availability, component lifetime (avoiding an unnecessary thermal cycle on the reactor and associated systems), and safety (the potential for plant upset and challenges to safety systems is increased during a plant shutdown).

Discussion of Proposed Change Page 4 Attachment 1 Farley Nuclear Plant Unit 1 Cycle 15 Summary of Flux hlap Peaking Factors Fo Alargin Fu blargin ilurnup Fm to to Flux hlap (h1WD/h1TU)  % Power hlargin to Steady State Transient I.imit I.imit I.imita 366 approx.15 33 22.3 % 57,5% 48.8 %

372 151 100 10.9 % 23.0 % 8.2%

373 1304 100 10.1% 20.8 % 6.2%

374 2299 100 9.8% 20.1 % 5.4%

375 2662 100 10.4 % 20.2 % 6.0%

376 3175 100 10.1% 20.8 % 5.7%

• Additional uncer1ainty applied for increasing Fq.

I Discussion of Proposed Cicoge Page5 Attachment 2 Farley Nuclear Plant Unit I Cycle 15 Instrument Thimble locations (Map 374)

R P N M L K J H 0 F E D C B A 1 50 2 19 3 14 34 2" 30 4 27 40 Sh*

m 5 37 42 20 32 '9'i 44 6 7 46 15 7 49 1 4 26_ _ 8 8 2B* 31 17 " 35 12 39 9 47 $b 18 h 10 6 M* EN 24 11 13 Ih 28_ /$

12 43 48 45 38 13 22 16 14 S *:t 33 15 29 Inaccessible Thimble

• These thimbles are plugged. " These thimbles were not attempted,

Discussion of Proposed Change Page 6 Attachment 3 Farley Nuclear Plant Unit I Cycle 15 lustrument Thimble Locations I (Map 375)

R P N M L K J H G F E D C B A 1 50 2 19 3 h 34 2 30 4 27 40 NE 5 37 42 20 32 9 M 6 7 46 15 7 49 1- 4 26 8 8 M* 31 171 35 12 39 9 47 41

• 18 hii 10 6 as'* 21 24 11 13 10 28 N 12 43 48 45 38 13 22 E 14 S' 33 -

15 29 Inaccessible Thimble

• These thimbles are plugged, i

Discussion ofl'roposed Change Page 7 Attachment 4 Farley Nuclear I'lant Unit 1 Cycle 15 lustrument Thimble Locations (Map 376)

R P N M L K J H G_ _F E D C B A 1 50 2 19 3 14 34 2 30 4 27 40 23

• 5 37 42 20 32 9 44 "

6 7 46 15 7 49 1 4 26 8 8 26

• 31 -17~ 35 12 39 9 47 41? 18 11 :

10 6 36

• 21

• 24 11 13 10 28  ! 3' __

12 43 48 46 sis 13 22 't' i

14 '5*' 33 15 _29 inaccessible Thimble

• These thimbles are plugged. " This thimble was not attempted.

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Discussion of Proposed Change Page 8 Attachment 5 Farley Nuclear Plant Unit I Cycle 15 IA>w Power Physics Testing Initial Criticality at 04:37 on Jt'ne 3,1997.

Measured Predicted Review DifTerence Parameter Value Value Criteria (M P)

ARO Critical lloron Concentration 1655 1677 i 50 -22 (ppm)

ARO ITC (pem/"F) +0. 5 40.33 i2 +0.17 Control Rod by Dynamic Rod Worth Controlllank A (pem) 317 314 i 75 pcm +3 pcm (1.0%)

Control llank 11 (pcm) 1506 1446 i 10 % +4.1%

Control llank C (pcm) 914 857 i 10 % 46.7%

Control llank D (pcm) 990 970 i 10 % +2.1 %

Shutdown llank A (pcm) 974 972 i 10 % +0.3 %

Shutdown llank II (pem) 1058 1004 i 10 % +5.4%

Total of Allitanks 5760 5563 i 8% +3.5%

1

Enclosure 2 Significant llazards Evaluation

Significant liarards F. valuation Pursuant to 10 CFR 50.02, each application for amendment to an operating license must be reviewed to determine if the proposed change involves a Significant llazards Consideration. The amendment, as defined below, describing the Technical Specification change associated with the change has been reviewed and deemed not to involve Signifiant flazards Considerations. The basis for this determination follows.

Proposed Change The proposed change will allow Farley Unit I a reduction in the number of required

] available movable detector thimbles (flux map paths) for Cycle 15. Currently, Unit 1 Technical Specification 3.3.3.2, requires at least 75% of the 50 movable detector thimbles (38 flux map paths) available with 2 per quadrant. The proposed change will allow a reduction in the available paths to a minimum of 25 with 3 per quadrant. As a result of this reduction an additional incremental uncertainty associated with the peaking factor 5 measurements is required. This incremental uncenainty will be a linear assessment that is applied due to the reduction of available flux map paths from 38 to 25. The total

]" additional uncertainty associated with the thimble reduction is a maximum of 2% for F N and 1.5% for F*an.

This application for amendment to the operating license for Farley Unit I is intended to be applicable for Cycle 15 only. For subsequent operation, Farley Unit I will revert to the original Technical Specifications.

Ilackground An engineering study,"Farley Unit i Cycle 15 Thimble Deletion Study", CAA 97-234, which used Farley specific flux maps has been performed to assess incremental peaking factor uncertainties associated with the reduction to a minimum of 25 paths. The review of the current flux maps indicate the core is behaving as predicted.11ased on this, it is not anticipated that the additional uneenainties on the peaking factors will result in any violation of the limits. Even with the increased measurement uncertainty applied as a result of the thimble reduction, the Farley Unit 1 Cycle 15 peaking factor surveillance Technical Specifications will provide the necessary protection.

The purpose of this evaluation is to assess the impact on the licensing basis and demonstrate that the movable detector thimble reduction identified will not adversely afTect the subsequent safe operation of the plant. This evaluation supports the conclusion that implementation does not represent a significant hazards consideration as defined in 10CFR50.92.

I

[ Significant flazards Evaluation Page3 Evaluation i

There are no changes to eny plant accident analysis input or assumption (i.e. peaking factors, etc.) as a result of this modification. The Technical Specifications requirements for verification of the core peaking factors will still be accomplished and the plant will be operated within the appropriate peaking factor limits. With this as a basis, the following evaluations were perfcimed.

LOCA and LOCA Related Evaluations The following LOCA related analyses are not adversely affected by the proposed actisity; large and small break LOCA, reactor vessel and loop LOCA blow down forces, post-LOCA long term core cooling suberiticality, post-LOCA long term core cooling minimum flow and hot leg switch over to prevent boron precipitation. The proposed activity does not affect the nomial plant operating parameters, the safeguards systems actuations or accident mitigation capabilities important to a LOCA, the assumptions used in the LOCA-related accidents, or create conditions more limiting than those assumed in these analyses.

Non LOCA Related Evaluation The non-LOCA safety analyses are not adversely affected by the proposed activity. This activity does not affect the assumptions used in the non-LOCA transients, or create conditions more limiting than those enveloped by the current non LOCA analyses.

Mechanical Components and Systems Evaluation The plant activity as described "ould not afTect tne RCS component integ ity or the ability of the system to perform its into.ded safety function. The plant activity as described would not affect the integrity of a plant auxiliary fluid system or the ability of the auxiliary system to perform its intended safety function. The proposed modification to surveillance requirements does not result in a condition where the material and construction standards which were applicable prior to the change are at:ered. System integrity is maintained.

Containment Integrity Evaluation (Short Term /Long Term LOCA Release)

The identified change does not adversely affect the short and long term LOCA mass and energy releases or the containtnent analyses. The change does not affect the systera actuations, accident mitigating capabilities or assumptions important to the containment analyses.

k.

Signific:nt llazards Evaluation Page 3 hiain Steamline Break (hiSLB) hiass and Energy Release The identified change neither adversely afTects the main steamline break (htSLB) mass and energy releases, either inside or outside containment, nor adversely afTects the calculations

for the steam mass release used as input to the radiological dose evaluation.

t Radiological Consequences Evaluation The movable detector thimble reduction would not affect radiological consequences or post-LOCA hydrogen production. Those areas of concern for radiological impac: are reactor core and coolant fission product activity, performance of ESF systems used to mitigate the release of radioactivity to the environment such as containment sprays and filtration systems, and the mass of steam released to the environment, as appropriate for the various FS AR accidents. None of these are affected by the proposed change.

Steam Generator Tube Rupture Evaluation The movable detector thimble reduction does not afTect the normal plant operating parameters, input assumptions, results, or conclusions of the SGTR thermal and hydraulic analyses. Also, conditions are not created which are more limiting than those enveloped by the current analysis break flow / steam release.

Determination of No Significant llazards Consideration The movable detector thimble reduction has been evaluated for significant hazards consideration, in accordance with the three factor test of 10CFR50.92. Based on the evaluations presented, the proposed Technical Specification license amendment does not involve a significant hazards consideration as defined in 10CFR50.92,

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The movable detector thimble reduction does not significantly increase the probability or consequences of an accident previously evaluated in the FSAR. This modification does not directly initiate an accident. The consequences of accidents previously evaluated in the FS AR are unafTected by this proposed change because no change to any equipment response or accident mitigation scenaria has resulted.

There are no additional cha.lenges to fission product barrier integrity.

Significant llazards Evaluation Page 4

2. Does the proposed amendment create the possibility of a new or difTerent kind of l accident from any accident previously evaluated?

No. The movable detector thimble reduction does not create the possibility of a new or different kind of accident than any accident already evaluated in the FSAR, No new accident scenarios, failure mechanisms, or limiting single failures are irtroduced as a result of this proposed change. The proposed Technical Specification modification does not challenge the performance or integrity of any safety-related systems. Therefore, the possibility of a new or different kind of accident is not created.

3. Does the proposed amendment involve a significant reduction in a margin of safety.

No. The proposed change to the technical specifications does not involve a significant reduction in a margin of safety. The margin of safety associated with the acceptance criteria for any accident is unchanged.

The movable thimble reduction will have no affect on the availability, operability or performance of the safety-related systems and components. The movable detector thimble number reduction does require a change to the Technical Specifications but does not reduce the number or frequency of inspections or surveillances required by the Technical Specifications. Therefore, the movable detector thimble reduction will not reduce the margin of safety, as described in the Bases to any Technical Specification.

The Bases of the Technical Specifications are founded on the ability of the regulatory criteria being satisfied assuming the limiting conditions for operation for various systems. Confonnance to the regulatory criteria for operation with the movable detector thimble reduction is demonstrated, and the regulatory limits are not exceeded, the margin of safety as defined in the Technical Specifications is not reduced.

Conclusion Based on the preceding information, it has been determined that this proposed change does not involve a Significant Hazards Consideration as defined in 10CFR50.92(c) for Farley Unit 1 Cycle 15.

_ - _ _ _