The inspectors questioned Entergy regarding the applicability of
TS 4.0.3 given that the time response test had never been performed on four of the
RPS scram contactors, as compared to missing a surveillance test following satisfactory initial system baseline testing that originally showed system operability. Entergy identified that industry guidance had been issued on this question in the form of Technical Specification Task Force (
TSTF)-IG-06-01 dated May 2006. In the
TSTF, the following question is asked, If it is discovered that a Surveillance has never been performed or has never been completely performed, can
SR 3.0.3 be used? [Note:
SR 3.0.3 is the standard TS equivalent of Pilgrim
TS 4.0.3] The
TSTF response states, Yes,
SR 3.0.3 applies in conditions in which a Surveillance has never been performed or has never been performed completely provided that there is an expectation that the Surveillance will pass when it is performed and that the associated system is
OPERABLE. An Unresolved Item (
URI) will track NRC evaluation of this industry guidance to determine if additional NRC guidance is necessary to specify when
TS 4.0.3 applies in the case of a
missed surveillance where it is determined that the surveillance was never originally performed to establish initial system operability. (
URI 05000293/2007003-04, Application of
TS 4.0.3 When it is Discovered that a Surveillance Has Never Been Performed) Entergy modified the applicable surveillance procedures and successfully response time response tested all
RPS scram contactors