Text

Application for Amend to License NPF-3,revising Tech Specs to Incorporate 24 H Time Limit to Complete Inadvertently Missed Surveillance
	ML20239A294
Person / Time
Site:	Davis Besse
Issue date:	09/10/1987
From:	Shelton D; TOLEDO EDISON CO.
To:	;
Shared Package
ML20239A287	List: ML20239A285; ML20239A294; ML20239A307;
References
	NUDOCS 8709170246
	Download: ML20239A294 (11)
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n-i' Dockat No. 50-346 License No. NPF-3 Serial No. 1416 Enclosure Page 1 l

APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 i

FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 l

Attached are the requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Facility Operating License No. NPF-3.

Also included are the Safety Evaluation and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1416) concern:

Technical Specification 4.0.3; and Bases Section 4.0.3.

By

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D. C. Shelton, Vice President, Nuclear Sworn and subscribed before me this 10th day of September, 1987.

Dadu kno$A Notary Public, State of Ohio My commission expires

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8709170246 870910 PDR ADOCK 05000346 p

PDR

Docket No. 501346 License No NPF-3 p:

i Serial No. 1416 Enclosure Page 2 The following information is provided to support issuance of the

. requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License No. NPF-3, Appendix A Technical Specification 4.0.3 and Bases Section 4.0.3.

A.

Time Rsquired to Implement: This change is to be effective upon NRC issuance of the license amendment.

B.

Reason for Change (FCR No. 87-0123): Revise Technical Specification 4.0.3 and Bases Section 4.0.3 in accordance with NRC Generic Letter 87-09 to include a specific, acceptable time limit of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an inadvertently missed surveillance before the provisions of the Action Requirements apply.

C.

Safety Evaluation: See attached Safety Evaluation (Attachment No. 1).

D.

Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment No. 2).

Dockst No. 50-346~

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License No. NPF-3

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Serial No.-1416'

. Page.1-l?

SAFETY EVALUATION DESCRIPTION OF THE PROPOSED ACTIVITY The purpose _of)this Safety Evaluation is to review a proposed change to the-Davis-Besse Nuclear Power Station, Unit No. 1.0perating License,-

Appendix.A Technical Specifications. The proposed changes involve revising

-Technical Specification 4.0.3.and Bases Section 4.0.3,. consistent with NRC Generic Letter 87-09 to:

1) include a specific, acceptable time limit (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to complete a missed. Surveillance Requirement before the Action i

Requirements apply; and'2) clarify when a missed surveillance constitutes a violation of.the operability requirements of a Limiting Condition for

-Operation.

EFFECTS ON SAFETY Surveillance Requirements are defined in 10CFR50.36(c)(3) as those requirements relating to test, calibration, or inspection to:

1). Assure that the necessary quality of systems and components is main-tained; 2)

Assure that facility operation will be within the safety limits; and 3)

Assure that the Limiting Conditions for Operation vill be met.

Consistent with this regulatory requirement, Specification 4.0.3, states that the failure'to perform a surveillance within the specified time interval (provided in Specification'4.0.2) constitutes failure to meet the

. operability requirements for a Limiting Condition for Operation. Thus, per the existing requirement, if a Surveillance Requirement is missed due to administrative 4 error, the system / component in question should be declared inoperable and the necessary actions as stipulated in the Action Statement should be followed.

Generally, the Action Requirements include a specified time-interval

before requiring plant shutdown.

This time interval permits corrective action to satisfy the Limiting Condition for Operation. Completion of a missed surveillance within this time interval satisfies Specification 4.0.3.

However, some Action Requirements allow only one or two hours, or require immediate shutdown and therefore do not establish a practical time limit for completing a missed surveillance. This may result in en unneces-sary plant shutdown. Even if the Action Requirements include remedial measures permitting continued operation, they may be stated in such a way that they could prevent performance of the required surveillance. A plant shutdown would also be required (under Specification 3.0.3) if the missed surveillance applies to more than the minimum number of systems / components required to be operable under the Action Requirements.

If a plant shutdown is required before a missed surveillance is completed, it is likely that the missed surveillance would be conducted when the

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'Dockst1No.U50-346; License No.'NPF-3)

Serial No. 1416 J

-Page 2-plant'is being shutdown because; completion of the surveillance would_.

terminate'the shutdown requirement. This is; undesirable'for'two1 reasons.

First, the plant would be.placed in a transient state where there is-greater potential for a, plant unset.

In this state, the system / component could.likely be needed; however,cbecause the system / component is being.

tested, it may be out-of-service'and therefore unavailable.- It_is_usually.

l preferable.to restore the system / component to operable status before

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making major. changes'in operating plant conditions. Secondly, a shutdown could intensify demands on'the plant staff to expeditiously. complete the surveillance and return the plant to power operation. Shutting down the plant and performing the surveillance while in the process.of shutting' I

down further increases the potential for a plant upset.

-It_is_ overly conservative to assume that systems / components are inoperable:

without due cause when a surveillance has not been performed because the vast majority of surveillance demonstrate that systems / components are operable. Therefore, it can be concluded that a 24-hour time limit would be an acceptable amount of time to complete a missed surveillance when the time limit of the Action Requirement is less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance against'the risks associated with the potential for a plant upset and challenge to safety systems when a shutdown is necessary to comply with the Action Requirements. Although most surveil-lances could be completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the~24-hour time limit allows sufficient time to conduct the surveillance in a safe manner. Also, the

-provision of a 24-hour time limit would provide adequate time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of_ plant conditions.

PROPOSED AMENDMENT REQUEST DISCUSSION Technical. Specification 4.0.3 sets forth the criteria for determining compliance with the operability requirements of the Limiting Conditions for Operation. _Under this criteria, equipment, systems or components are considered operable if the Surveillance Requirements have been satis-factorily performed within the specified time interval (provided in Specification 4.0.2).

Likewise, equipment, systems or components are considered not operable if the Surveillance Requirements have not been performed, or have not been performed satisfactorily within the specified 1

time interval. However, nothing in this provision is to be construed as l

l implying that systems or components are operable when they are found or J

.known to be inoperable even though they meet the Surveillance Requirement.

j If a surveillance is missed due to administrative error, the Limiting l

Condition for Operation would not be met and the Action Requirements

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would apply. However, some Action Requirements do not provide an appropriate time to perform a missed surveillance. Therefore, Technical Specification 4.0.3 should be modified to include an appropriate time I

limit that allows a delay of the Action Requirements to permit performance l

of the missed surveillance.

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Docket No.150-346 License No. NPF 1 Serial No. 1416 4 Page 3 Toledo Edison proposes adopting the NRC recommendations proposed in Generic Letter 87-09 for Technical Specification 4.0.3 and Bases Section 4.0.3.

The guidance provides a grace period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , after discovery of _ a missed surveillance (due to administrative error), to complete the surveillance before the Action. Requirements apply. This grace period only applies when Action Requirements are required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or when i

shutdown Action Requirements apply. This provides an adequate. time limit to complete Surveillance Requirements that have not.been performed. The purpose of'this allowance is to permit the completion of a surveillance

'before a shutdown is required (to comply with Action Requirements) or before_other remedial measures would be required that may preclude completion of a surveillance. 1he basis for this allowance includes-considerations i

of plant' conditions,' adequate planning, availability of personnel, the time required to perform the surveillance, and the safety' significance of theLdelay in completing the' required surveillance. This provision also provides-an appropriate amount of time to complete Surveillance Requirements that become applicable as a consequence of mode changes imposed by Action Requirements, and to complete Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed.

If a surveillance is-not completed within the 24-hour allowance, the time limits of the Action Requirements are applicable at that time. When a surveillance is' performed within the 24-hour allowance and the Surveillance Requirements are not met,- the time limits of the Action Requirements are applicable at the time the surveillance is terminated.

Completion of the Surveillance Requirement within the allowable time limits of the Action Requirements restores compliance with the require-ments of 4.0.3.

However, the addition of the 24-hour grace period does not waive compliance with Technical Specification 4.0.2.

If a surveil-lance is inadvertently missed, Specification 4.0.3 allows the Action Requirements to be delayed up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; failure.to perform the surveillance within the maximum allowable extension (provided in Specification 4.0.2) constitutes a reportable event under 10CFR50.73 (a) (2) (1) (B).

(10CFR50.73(a)(2)(1)(B) states that any operation or condition prohibited by the plant's Technical Specifications shall be reported in a License Event Report (LER) within 30 days after discovery.)

Specification 4.0.3 has further been clarified by defining the allowed surveillance interval as the surveillance interval defined by Specification 4.0.2.

This clarification is also consistent with NRC Ceneric Letter 87-09.

Specification 4.0.3 previously included the statement that exceptions to it are stated in the individual specifications. This statement is deleted because Technical Specification 4.0.3 always applies.

There are l

no exceptions to Specification 4.0.3 identified in any Davis-Besse Technical l

Specification.

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Docket No. 50-346 License No. NPF-3 Serial No. 1416

-Attachment 1 Page 4 DISCUSSION OF UNREVIEWED SAFETY QUESTION The proposed changes involve revising Technical Specification 4.0.3 and Bases Section'4.0.3 to include an acceptable time limit, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , to complete a missed surveillance and clarify when a missed surveillance constitutes violation of the operability requirements in accordance with Generic Letter 87-09.

The implementation of these changes would not:

1.

Increase the probability of occurrence of an accident previously evaluated in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes.

It is overly conservative to assume that systems / components are inoperable when the vast majority of surveillance demonstrate operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant transients (required by Action Requirements) and consequently potential plant upsets that could lead to a demand for the system /

component being tested would be reduced. Thus, the probability of an accident previously evaluated in the USAR is actually expected to decrease. The proposed changes to Technical Specification 4.0.3 are also consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59 (a) (2) (1)).

2.

Increase the. consequences of an accident previously evaluated la the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes.

It is overly l

conservative to assume that systems / components are inoperable when the vast majority of surveillance demonstrate operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant transients (required by Action Requirements) and consequently potential plant upsets would be reduced. Thus, the probability of an accident previously evaluated in the USAR is actually expected to decrease. The proposed changes to Technical Specification 4.0.3 are also consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59 (a) (2) (1)).

3, Increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the USAR because the accident conditions and assumptions are not affected by the proposed Technical Specification changes.

It is overly conservative to assume that systems / components are inoperable when the vast majority of surveillance demonstrate operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant transients (required by Action Requirements) and consequently potential plant upsets would be reduced, thus offsetting any increase in the probability of a malfunction of equipment important to safety. The increased time has l

a negligible impact on mean time between failures. The proposed changes to Technical Specification 4.0.3 are also consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59(a)(2)(1).

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Dockat No.'50-346 ELicense No. NPF-3 Serial No. 1416 Page 5 4.

Increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because the accident condi-tions and assumptions are not affected by the proposed Technical Specification changes.

It is overly conservative to assume that' I

systems / components are inoperable when the vast majority of sur-veillances demonstrate operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed. surveillance, unnecessary plant transients (required

.by Action Requirements) and consequently potential plant upsets would be reduced, thus offsetting any increase in the probability of a malfunction of equipment important to safety..The proposed changes to Technical Specification 4.0.3 are also consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59(a)(2)(1))..

5.

Create the possibility for an accident of a different type than any evaluated previously in the USAR because the Surveillance Require-ments will still be performed at their required frequencies. By allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant

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transients (required by Action Requirements) and consequently potential plant upsets would be reduced. The proposed changes to Technical Specification 4.0.3 are consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59(a)(2)(11)).

5.

Create the possibility for a malfunction of a different type than any evaluated in the USAR because no station equipment is being modified by the proposed Technical Specification changes. It is overly conservative to assume that system / components are inoperable when the vast majority of surveillance demonstrate operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant

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transients (required by Action Requirements) and consequently potential j

plant upsets would be reduced. The proposed changes to Technical Specification 4.0.3 are also consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59(a)(2) (ii)).

6.

Reduce the margin of safety as defined in the basis for any Technical Specification because the Surveillance Requirements will still be performed at their required frequencies.

By allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance, unnecessary plant trensients (required by Action Requirements) and consequently potential plant upsets would be reduced. The proposed changes to Technical Specification 4.0 3

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are consistent with the guidance provided in Generic Letter 87-09 (10CFR50.59(a) (2) (iii)).

CONCLUSION Based on the above, it is concluded that the proposed Technical Specification changes do not constitute an unreviewed safety question.

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Dockat.No. 50-346 License No. NPF-3 Serial No. 1416 Page 1 SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF THE PROPOSED ACTIVITY The purpose of this. License Amendment Request is to review a proposed change to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A Technical Specifications. The proposed changes involve revising Technical Specification 4.0.3 and Bases Section 4.0.3, consistent with NRC Generic Letter 87-09, to:

1) include a specific, acceptable time limit (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to complete a missed Surveillance Requirement before the Action Requirements apply; and 2) clarify when a missed surveillance constitutes a violation of the operability requirements of a Limiting Condition for Operation.

EFFECTS ON SAFETY Surveillance Requirements are defined in 10CFR50.36(c)(3) as those requirements relating to test, calibration, or inspection to:

1)

Assure that the necessary quality of systems and components is main-tained; 2)

Assure that facility operation will be within the safety limits; and 3)

Assure that the Limiting Conditions for Operation will be met.

Consistent with.this regulatory requirement, Specification 4.0.3, states that the failure to' perform a surveillance within the specified time interval (provided in Specification 4.0.2) constitutes failure to meet the operability requirements for a Limiting Condition for Operation. Thus, per the existing requirement, if a Surveillance Requirement is missed due to administrative error, the system / component in question should be declared inoperable and the necessary actions as stipulated in the Action Statement should be followed.

Generally, the Action Requirements include a specified time interval before requiring plant. shutdown. This time interval permits corrective action to satisfy the Limiting Condition for Operation. Completion of a missed surveillance within this time interval satisfies Specification 4.0.3.

However, some Action Requirements allow only one or two hours, or require immediate shutdown and therefore do not establish a practical time l

limit for completing a missed surveillance. This may result in an unneces-sary plant shutdown. Even if the Action Requirements include remedial measures permitting continued operation, they may be stated in such a way that they could prevent performance of the required surveillance. A plant shutdown would also be required (under Specification 3.0.3) if the missed surveillance applies to more than the minimum number of systems / components 1

required to be operable under the Action Requirements.

If a plar.t shutdown is required before a missed surveillance is completed, it is likely that the missed surveillance would be conducted when the I

Docket No. 50-346 '

DLicense'No'.NPF-3 Serial No. 1416 '

Page 2

. plant is being shutdown because completion of the surveillance would terminate the shutdown requirement.

This is undesirable for two reasons.

First, the plant would be-placed in a transient state where there is I

greater potentia 1'for a plant. upset. In this state, the system / component could likely.be needed; however, because the system / component is being tested, it may be out-of-service.and therefore unavailable.

It is usually

. preferable.to restore the system / component to operable status before making major changes in operating plant conditions. Secondly, a shutdown could intensify demands on the plant staff to expeditiously complete the surveillance and return the plant to power operation.

Shutting down the plant and performing the surveillance while'in the process of shutting down further increases the potential for a plant upset.

It is overly conservative to aesume that systems / components are inoperable without due cause when a surveillance has not been performed because the vast majority of surveillance demonstrate that systems / components are operable. 'Therefore, it can be concluded that a 24-hour time limit would be an acceptable amount of time to couplete a missed surveillance uhen the time limit of the Action Requirement is less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .. The 24-hour time limit would balance the risks associated with an allowance for completing'the surveillance against the risks associated with the potential for a plant upset and challenge to safety systems when a shutdown is necessary to comply with the Action Requirements. Although most surveil-lances could be completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the 24-hour time limit allows sufficient time'to conduct the surveillance in a safe manner. Also, the provision of a 24-hour time limit would provide adequate time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of plant conditions.

PR0p0 SED AMENDMENT REQUEST DISCUSSION Technical Specification 4.0.3 setr forth the criteria for determining compliance with the operability requirements of the Limiting Conditions for Operation. Under this criteria, equipment, systems or components are considered. operable if the Surveillance Requirements have been satis-factor 11y performed within the specified time interval (provided in Specification 4.0.2).

Likewise, equipment, systems or components are considered not operable if the Surveillance Requirements have not been performed, or have not been performed satisfactorily within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are operable when they are found or known to be inoperable even though they meet the Surveillance Requirement.

If a surveillance is missed due to administrative error, the Limiting Condition for Operation would not be met and the Action Requirements would apply. However, some Action Requirements do not provide an appropriate time to perform a missed surveillance. Therefore, Technical Specification 4.0.3 should be modified to include an appropriate time limit that allows a delay of the Action Requirements to permit performance of the missed surveillance.

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1 Docket No. 50-346 l-License No. NPF-3 Serial No. 1416 Page 3 Toledo Edison proposes adopting the NRC recommendations proposed in l

Generic Letter 87-09 for Technical Specification 4.0.3 and Bases Section l

4.0.3.

The guidance provides a grace period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , after discovery l

of a missed surveillance (due to administrative error), to complete the i

surveillance befcre the Action Requirements apply. This grace period only l

applies when Action Requirements are required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or when L

shutdown Action Requirements apply. This provides an adequate time limit l

to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required (to comply with Action Requirements) or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides an appropriate amount of time to complete Surveillance Requirements that become applicable as a consequence of mode changes imposed by Action Requirements, and to complete Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed.

If a surveillance is not completed within the 24-hour allowance, the time limits of the Action Requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the Action Requirements are applicable at the time the surveillance is terminated.

Completion of the Surveillance Requirement within the allowable time limits of the Action Requirements restores compliance with the require-ments of 4.0.3.

However, the addition of the 24-hour grace period does not waive compliance with Technical Specification 4.0.2.

If a surveil-3ance is inadvertently missed, Specification 4.0.3 allows the Action Requirements to be delayed up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; failure to perform the surveillance within the maximum allowable extension (provided in Specification 4.0.2) constitutes a reportable event under 10CFR50.73 (n) (2) (1) (B).

(10CFR50.73(a)(2)(1)(B) states that any operation or condition prohibited by the plant's Technical Specifications shall be reported in a License Event Report (LER) within 30 days after discovery.)

Specification 4.0.3 has further been clarified by defining the allowed surveillance interval as the surveillance interval defined by Specification 4.0.2.

This clarification is also consistent with NRC Generic Letter 87-09.

Specification 4.0.3 previously included the statement that exceptions to it are stated in the individual specifications. This statement is deleted because Technica1' Specification 4.0.3 always applies. There are no exceptions to Specification 4.0.3 identified in any Davis-Besse Technical Specification.

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Dockat No. 50-346 License No. NPF-31 Serial No.-1416 Atta'chmento2 Page 4 L

SIGNIFICANT HAZARDS CONSIDERATION The proposed changes.do not involve a significant hazards consideration L

because.the operation of.the Davis-Besse Nuclear Power Station, Unit No. 1, L

in accordance with these changes would.not:

1.

Involve'a.significant increase in the probability or consequences of L

an accident previously evaluated because the accident conditions and assumptions are.notfaffected by the proposed' Technical Specification changes.

It is overly conservative to assume that systems / components

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.are inoperable when the vast majority of surveillance demonstrate j

operability. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveil-lance,~ unnecessary plant transients (required.by Action' Requirements),

and consequently potential plant upsets that would lead to a demand for the system / component being tested, would be reduced. Thus, the probability of an accident previously evaluated in the USAR is actually expected to decrease. The proposed changes are also consistent with the guidance provided in Generic. Letter 87-09 (10CFR50.92(c)(1)).

2.

Create the possibility of a new or different kind of accident from any previously evaluated because the Surveillance Requirements will still be performed at their desired frequencies.

By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveilla'nce, unnecessary plant transients (required by Action Requirements), and' consequently potential plant upsets that would lead to a demand for the~ system /

component being tested, would be reduced. Thus, the probability of an accident previously evaluated in the USAR is actually expected to decrease. The proposed changes are also consistenc with the guidance provided in Generic Letter 87-09 (10CFR50.92(c)(2)).

3.

Involve a significant reduction in a margin of safety because the Surveillance Requirements will still be performed at their desired frequencies. By allowing up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perfCrm a missed surveillance, unnecessary plant transients (requiref by Action Requirements), and consequently potential plant upsets that would lead to a demand for the system / component being tosted, would be reduced. Thus, the probabilityof an accident previously-evaluated in the USAR is actually expected to decrease. The proposed changes are also consistent with the guidance provided in Generic Letter 87-09' (10CFR50.92(c)(3).

, CONCLUSION On'the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.

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ML20239A294

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