ML18089A591

IP 71111.19 Post Maintenance Testing

ML18089A591
Person / Time
Issue date:	06/07/2018
From:	Cauffman C NRC/NRR/DIRS/IRIB
To:
Cauffman C
Shared Package
ML18094A251, ML18158A297	List:
References
CN 18-014, DC 18-010
Download: ML18089A591 (5)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 19 POST-MAINTENANCE TESTING Effective Date: 06/07/2018 PROGRAM APPLICABILITY: Inspection Manual Chapter (IMC) 2515, Appendix A, Risk-Informed Baseline Inspection Program CORNERSTONES: Initiating Events Mitigating Systems Barrier Integrity INSPECTION BASES: See IMC 0308, Reactor Oversight Process Basis Document, Attachment 2, Technical Basis for Inspection Program SAMPLE REQUIREMENTS:

Sample Requirements Minimum Baseline Sample Budgeted Range Completion Requirements Sample Type Section(s) Frequency Sample Size Samples Hours Post-Maintenance 03.01 Annual 20 per site 20 to 28 84 +/- 13 Test (PMT) per site 71111.19-01 INSPECTION OBJECTIVE To confirm that PMT procedures and test activities adequately verify system operability and functionality.

71111.19-02 GENERAL GUIDANCE Select a reasonable distribution of PMT samples each quarter and on each unit at multiunit sites throughout the year. Performing more PMT samples during refueling outages may be appropriate.

Select PMT activities that affect risk-significant systems or components. The preferred sample candidates are risk-significant systems or components that have experienced recent performance problems or involve complex maintenance.

Issue Date: 06/07/18 1 71111.19

Sample Candidates Priority Example Systems that the licensee Select activities with the PMT of the following:

credited as operable or potential for common-mode functional that are adversely failures or systems with a risk online emergency diesel impacted by failure to achievement worth (RAW)* generator engine repairs adequately test or realign greater than or equal to 1.3.

(e.g., remove test equipment) newly installed electrical/

Select activities with a recent instrumentation record of maintenance and components that control testing errors. multiple integrated systems (e.g., loss of Select activities across offsite power and technical disciplines loss-of-coolant accident (e.g., electrical, mechanical, circuits) instrumentation and control) containment air lock Select activities that are leakage difficult to test at power.

Select activities that have undergone a change in work scope or experienced problems.

• RAW is defined in NUREG-2122, Glossary of Risk-Related Terms In Support Of Risk-Informed Decisionmaking.

For each sample, conduct a routine review of problem identification and resolution activities using Inspection Procedure (IP) 71152, Problem Identification and Resolution.

71111.19-03 INSPECTION SAMPLES 03.01 Post-Maintenance Test Sample Verify that PMT procedures and test activities adequately verify system operability and functionality.

Specific Guidance

a. For each testing activity selected, identify the affected system(s), component(s), or both and do the following:

1. Review the applicable licensing-basis and design-basis documents to identify the safety functions and functions important to safety for the affected systems and components, as appropriate.

2. Review applicable corrective action and maintenance documents.

3. If time permits, discuss the maintenance activity with plant personnel to gain insights.

Issue Date: 06/07/18 2 71111.19

4. If time permits, observe the associated maintenance activity to identify the affected safety function(s).

5. Review the licensees test procedure, completed maintenance activities, and work orders before observing the PMT to verify the following:

(a) The procedure adequately tests the safety function(s) and function(s) important to safety that completed maintenance activities could have affected.

(b) Acceptance criteria in the procedure are consistent with information in the applicable licensing-basis and design-basis documents or appropriate standards.

(c) The procedure has been properly reviewed and approved.

(d) As applicable, operations ensured adequate fill and vent for portions of safety systems potentially drained during the maintenance activity.

b. Observe prejob briefs, testing, and posttest critiques if time permits. Review the completed test procedure and data, perform a walkdown of the affected work site, and verify the following:

1. The performance of the affected system(s) and component(s) satisfies the procedures acceptance criteria.

2. The scope of the test and its acceptance criteria provide reasonable assurance of system operability or functionality considering the scope of work. For example, the residual heat removal (RHR) system functions under a wide range of pressures. As applicable for the work performed, does the licensee perform the PMT at the highest reasonable pressure for the RHR system component?

3. The effects of testing on the plant have been adequately addressed.

4. Test equipment is calibrated and is within its current calibration cycle.

5. The test equipment used is within its required range and accuracy.

6. Applicable prerequisites described in the test procedure are satisfied.

7. Affected systems or components are removed from service in accordance with approved procedures.

8. The test is performed in accordance with the test procedure and other applicable procedures.

For example, during filling and venting operations, look and listen for potential signs of water hammer following pump starts, valve manipulations, or both.

Following testing, review operating logs, PMT work orders, and corrective action condition reports for potential adverse conditions caused by the system water hammer. Perform walkdowns to independently verify this condition when appropriate.

Issue Date: 06/07/18 3 71111.19

9. Quality control hold points that are used to verify quality attributes that cannot be verified later were properly performed, second checked, and documented as appropriate.

10. Jumpers that are installed and leads that are lifted during testing are appropriately controlled, restored, and removed.

11. Test equipment is removed after testing.

12. Electrical connections are secure and maintain their intended design function.

13. After testing is completed, equipment is returned to the positions/status required to maintain the system in an operable or functional condition in accordance with approved procedures.

14. Enclosures, seals, shielding, and protective features are appropriately restored.

15. Work site cleanliness is maintained. Tools, rags, and other debris are not left adrift where they may impede required system, component, or operator functions.

16. Problems noted during testing are appropriately documented.

c. For each testing activity, review the licensees completed test results, completed maintenance activities, and work orders after the system or component has been declared operable or considered functional to verify the following:

1. The PMT results are accurate, complete, and valid and have been properly reviewed and accepted.

2. The PMT adequately tested the safety function(s) and function(s) important to safety considering all completed maintenance activities. Specifically, consider those maintenance activities that could have subsequently disabled functions after completion of the PMT or created the need to perform additional testing.

71111.19-04 REFERENCES Cross-Reference of Generic Communications to IP 71111.19 and Inspection Resources:

http://drupal.nrc.gov/nrr/ope/34015 (nonpublic)

Operating Experience Gateway:

http://drupal.nrc.gov/nrr/ope (nonpublic)

IHS Codes and Standards:

http://www.internal.nrc.gov/TICS/library/standards/ihs.html (nonpublic)

U.S. Nuclear Regulatory Commission (NRC) Technical Library:

http://www.internal.nrc.gov/TICS/library/index.html (nonpublic)

END Issue Date: 06/07/18 4 71111.19

Attachment 1 Revision History for IP 71111.19 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Feedback Number Issue Date Required and Form Accession Number Change Notice Completion (Pre-decisional, Non-Date public Information) 04/03/00 Initial Issuance. None CN 00-003 ML020400004 Revision history reviewed for the last four years. Revised None 1/17/02 resource estimates and inspection level of effort.

CN 02-001 ML11213A002 Revised to incorporate feedback associated with Feedback None ML112840030 11/08/11 Form No. 71111.19-1549. A four-year historical search for CN 11-031 commitments was conducted and no commitments were found.

ML13093A416 Incorporated ROP Enhancement Initiative Improvements None ML14233A107 09/24/14 (ML14017A340 & ML14017A381)

CN 14-022 ML18089A591 Added guidance to assess system filling, venting, and None ML18094A299 06/07/18 water hammer. Reformatted the guidance. Eliminate 71111.19-2280 CN 18-014 redundancy and improved the guidance for plain writing. ML18109A172 Relocated optional requirements to the guidance section to better align with the sample completion requirements in Section 8.04 of Inspection Manual Chapter 2515, Light-Water Reactor Inspection ProgramOperations Phase.

Issue Date: 06/07/18 Att 1-1 71111.19