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,” Attachment 2, “Technical Basis for Inspection Program”

SAMPLE REQUIREMENTS:

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 risksignificant systems or components.  The preferred sample candidates are risksignificant systems or components that have experienced recent performance problems or involve complex maintenance.

* 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 designbasis 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.

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

5. Review the licensee’s 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 designbasis 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 procedure’s 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.

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 licensee’s 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, “RiskInformed 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”

CrossReference 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:

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	1	71111.19

Attachment 1

Revision History for IP 71111.19

Issue Date:  10/06/20	Att 1-1	71111.19