The licensee identified a finding of very low safety significance (Green) and associated
NCV of
10 CFR Part 50, Appendix B, Criterion XI, Test Control. This regulation requires in part that a test program be established to assure that all testing required to demonstrate that
SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, on August 17, 2012, the licensees test procedure IT-08A, Cold Start of Turbine-Driven Auxiliary Feed Pump and Valve Test, did not prevent pre-conditioning of the
overspeed trip valve (
1MS-2082). The cause of the issue was determined to be a result of the procedure allowing valve
1MS-2082 to be stroked in two different manners with only the second stroking being time-tested. Therefore, the initial stroking of the valve preconditioned the valve for the second timed test. The licensee entered this into the
CAP as
AR01794746 and implemented corrective actions to revise the Units 1 and 2 testing procedures (IT-08A and IT-09A) to stroke time-test the valve for both of these tests to prevent the preconditioning of valve MS-2082 on both units. The performance deficiency was determined to be more than minor in accordance with
IMC 0612, Appendix B, because it was associated with the
Mitigating Systems Cornerstone attribute of procedure quality, and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, the procedure allowed preconditioning of the Unit 1 valve MS-2082, which could mask its actual as-found condition and result in an inability to verify its operability and potentially make it difficult to determine whether the valve would perform its intended safety function during an event. The inspectors evaluated the issue using
IMC 0609, Attachment 0609.04, Tables 2 and 3, and
IMC 0609, Appendix A, Exhibit 2 for the Mitigating System Cornerstone, and answered No to the mitigating
SSCs and functionality questions; therefore, the issue screened as very low safety significance
