The inspectors identified a non-cited violation of
Technical Specification (TS) 5.4.1.a for failure to establish an adequate procedure to test
main steam isolation valves (
MSIVs). Specifically, written test control procedures did not prevent and, therefore, resulted in pre-conditioning of the valves prior to their surveillance requirement
stroke time testing. This finding is more than minor because the use of test procedures that allow preconditioning, if left uncorrected, could become a more significant safety concern.
Inspection Manual Chapter 9900 Section C.1.c defines pre-conditioning as the alteration, variation, manipulation, or adjustment, of the physical condition of structures, systems and components (
SSCs) before TS surveillance or
ASME code testing. Pre-conditioning can affect the acceptability of test results and can have a direct effect on the determination of operability of the affected system or component by masking the true as-found condition. As such, this issue also affects the
barrier integrity cornerstone objective of maintaining containment functionality and the associated attributes of
SSC barrier performance, and procedure quality, by affecting the determination of operability related to the containment isolation function of the
MSIVs. This issue is of very low safety significance because there was insufficient information to show that the
MSIVs were
inoperable during the short period of time that they were required in Modes 3, 2 and 1; therefore, it did not represent an actual open pathway in the physical integrity of the containment. This finding has a crosscutting aspect of decision making in the area of human performance [H.1.(b)]. (Section 1R22
