ML19291A213

IP 71111.19 Post-Maintenance Testing

ML19291A213
Person / Time
Issue date:	10/06/2020
From:	Cauffman C NRC/NRR/DRO/IRIB
To:
Cauffman C
Shared Package
ML19316A849, ML20233A512, ML20279A719	List:
References
CN 20-047, DC 19-029, DC 20-025
Download: ML19291A213 (6)

Text

Issue Date: 10/06/20 1

71111.19 NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 19 POST-MAINTENANCE TESTING Effective Date: 01/01/2021 PROGRAM APPLICABILITY: IMC 2515 A CORNERSTONES:

Initiating Events Mitigating Systems Barrier Integrity INSPECTION BASES:

See IMC 0308, Reactor Oversight Process Basis Document,, Technical Basis for Inspection Program SAMPLE REQUIREMENTS:

Sample Requirements Minimum Baseline Sample Completion Requirements Budgeted Range Sample Type Section(s) Frequency Sample Size Samples Hours Post-Maintenance Test (PMT) 03.01 Annual 20 per site 20 to 28 84 +/- 13 per site 9 at Vogtle Units 3 & 4 9 to 11 at Vogtle Units 3 & 4 35+/-4 at Vogtle Units 3 & 4 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: 10/06/20 2

71111.19 Sample Candidates Priority Example Systems that the licensee credited as operable or functional that are adversely impacted by failure to adequately test or realign (e.g., remove test equipment)

Select activities with the potential for common-mode failures or systems with a risk achievement worth (RAW)*

greater than or equal to 1.3.

Select activities with a recent record of maintenance and testing errors.

Select activities across technical disciplines (e.g., electrical, mechanical, instrumentation and control)

Select activities that are difficult to test at power.

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

PMT of the following:

online emergency diesel generator engine repairs newly installed electrical/

instrumentation components that control multiple integrated systems (e.g., loss of offsite power and loss-of-coolant accident circuits) containment air lock leakage

• 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.

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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.

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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 IMC 2515, Appendix A, Risk-Informed Baseline Inspection Program IMC 0308, Attachment 2, Technical Basis for Inspection Program IP 71152, Problem Identification and Resolution NUREG-2122, Glossary of Risk-Related Terms In Support Of Risk-Informed Decisionmaking 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)

Issue Date: 10/06/20 5

71111.19 IHS Codes and Standards:

https://drupal.nrc.gov/tech-lib/35748 (nonpublic)

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

https://drupal.nrc.gov/tech-lib (nonpublic)

END

Issue Date: 10/06/20 Att 1-1 71111.19 Revision History for IP 71111.19 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Number (Pre-decisional, Non-Public Information) 04/03/00 CN 00-003 Initial Issuance.

None ML020400004 1/17/02 CN 02-001 Revision history reviewed for the last four years. Revised resource estimates and inspection level of effort.

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

None ML112840030 ML13093A416 09/24/14 CN 14-022 Incorporated ROP Enhancement Initiative Improvements (ML14017A340 & ML14017A381)

None ML14233A107 ML18089A591 06/07/18 CN 18-014 Added guidance to assess system filling, venting, and water hammer. Reformatted the guidance. Eliminate redundancy and improved the guidance for plain writing.

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.

None ML18094A299 71111.19-2280 ML18109A172 ML19291A213 10/06/20 CN 20-047 Added AP1000 sample requirements. Updated references.

None ML19316B055 (2019)

ML20233A520 (2020)