05000293/FIN-2008005-03
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Finding | |
|---|---|
| Title | Application of TS 4.0.3 When It Was Discovered That a Surveillance Had Never Been Performed |
| Description | On June 25, 2007, Entergy informed the Nuclear Regulatory Commission (NRC) staff that it had missed a Technical Specification (TS) surveillance requirement to perform time response testing of four Reactor Protection System (RPS) scram contactors. During their review, Entergy identified that the four RPS scram contactors had never been tested. Entergy evaluated the operability of the RPS system and determined that the system remained operable and that TS 4.0.3, Surveillance Requirement Applicability, would allow a delay period up to the limit of the specified surveillance frequency. The inspectors questioned Entergy regarding the applicability of TS 4.0.3 given that the time response test had never been performed on the RPS scram contactors, as compared to missing a surveillance test following satisfactory initial system baseline testing that originally showed system operability. As a result of this implementation of TS 4.0.3, Entergy failed to take action in accordance with TS 3.1, Reactor Protective System, which constituted a violation of NRC requirements. Entergy later modified the applicable surveillance procedures and successfully response time tested all RPS scram contactors. In Task Interface Agreement (TIA) 2008-004, the NRC staff disagreed with Entergy on its implementation of TS 4.0.3 and considered Entergy to have been in violation of TS 3.1, Reactor Protection System, as a result. Discretion is warranted because: (1) licensee current basis documents do not specifically clarify the distinction between a missed surveillance and one that has never been performed, (2) the licensee subsequently completed the surveillance testing satisfactorily, and (3) the issue was of very low safety significance, since when the correct testing was accomplished, it was completed satisfactorily indicating that the timing of the reactor scram function was not negatively impacted. Accordingly, the NRC staff is exercising enforcement discretion for the TS 3.1 violation in accordance with Section VII.B.6 of the NRC Enforcement Policy and no violation will be issued. |
| Site: | Pilgrim |
|---|---|
| Report | IR 05000293/2008005 Section 4OA5 |
| Date counted | Dec 31, 2008 (2008Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | R Fuhrmeister A Ziedonis R Rolph B Smith M Schneider D Lew |
| INPO aspect | |
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Finding - Pilgrim - IR 05000293/2008005 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2008Q4
Self-Identified List (Pilgrim)
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