Text

Requests Approval of Encl Proposed Equipment Qualification Program Plan
	ML19252A885
Person / Time
Issue date:	08/20/1981
From:	Dircks W; NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	;
Shared Package
ML19252A886	List: ML19252A885; ML20033A898; ML20033A900; ML20033A901; ML20033A902;
References
	REF-10CFR9.7, TASK-PINV, TASK-SE SECY-81-504, NUDOCS 8109220949
	Download: ML19252A885 (38)
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August 20, 1931 POLICY ISSUE seCv-8,-504 The Commissione(rsNotation Vote)

For:

From:

William J. Dircks Executive Director for Operations Subiect:

EQUIPMENT QUALIFICATION PROGRAM PLAN

Purpose:

To inform the Commission of the staff's program plan for qualification of equipment important to safety used in nuclear power facilities and to obtain the Commission's consent to implement the program.

Discussion:

Background

In November 1977, the Union of Concerned Scientists (USC) petitioned the Commission to upgrade the environmental qualification of equipment

'in operating facilities to current standards.

This petition ultimately led to the Commission's Memorandum and Order of May 23, 1980 (CLI-80-21),

which provides guidance and directives to resolve this matter in an expeditious manner.

In July 1980, the Office of Inspection and Enforcement submitted to the Commission (SECY-80-319) an analysis of alternatives for conducting independent verification testing of environmentally qualified equipment.

By a memorandum dated September 16, 1980, the Ccmmissioners approved the recommendations of this paper, subject to prior Commission comments and directives provided in a SECY to EDO memorandum of July 18, 1980 and in the Commission meeting of July 15, 1980.

The enclosed Equipment Qualification Program Plan (EQPP) discusses how the directives of the Commission's Memorandum and Order and the inde-pendent verification testing program are integrated into the overall program plan, which includes an environmental, seismic, and dynamic qualification testing program, rulemaking activities, and research to be conducted in support of the program.

Objective of the Program Plan This program plan is to provide a systematic approach to ensure that all equipment important to safety in both operating and new facilities is properly qualified to perform its safety functions if subjected to postulated accident conditions or a seismic event.

The program is expected to take about 4 years to complete and by that time to have accomplished:

Contact:

8109220949 slosso "8d Z. R. Rosztoczy, NRR:0E: EQB CF 492-8035

The Commissioners 2

A review of the qualification status of equipment important to safety in operating facilities and identification of inadequately qualified equipment.

Enforcement of appropriate corrective actions, including reloca-tion, replacement, or requalification of the equipment.

The development of standardized NRC review procedures for equip-ment qualification to be utilized in the review of new facilities.

Thedevelopmentofaruieonthequalificationofequipment important to safety and the development of regulatory guides in support of the rule.

Development of technology (analytical and experimental) in support of the equipment qualification reviews and the development of-the rule on equipment qualification.

Testing and inspection of selected equipment by NRC to independ-ently verify equipment performance under accident conditions.

The development and implementation of an accreditation program for test laboratories.

The approximate 4-year schedule to accomplish the above objectives is based on currently projected manpower. The Commission action on the recent " Petition for Extension of Deadline for Compliance with CLI 21" may also affect the schedule and staff resources.

This effect is not expected to be significant if the staff recommendations are adopted by the Commission.

The following table lists the requirements for the 4-year program which is recommended by the staff:

FY 1981 FY 1982 FY 1983 FY 1984 PY SK PY SK PY SK PY SK NRR 21.3 3250 23.2 3800 20.0 3300 20.7 1900 IE 11.1 600 11.6 900 12.1 1100 11.5 1500 RES 4.8 2450 5.8 2850 5.5 3000 5.5 2000 Total NRC 37.2 6300 40.6 7550 37.6 7 00 33.7 5400 Should the Commission decide that this program, as outlined, needs to proceed more rapioly, the staff believes that a maximum of 1 year could be cut from the program; NRC manpower needs will increase about 10 PY per year through FY 1983.

The technical assistance will cost about 54.5 million less in the accelerated program.

The Commissioners 3

The resources shown in the projected budgets by the Offices of Inspection and Enforcement (IE) and Research (RES) are not affected whether the program is 3 or 4 years.

The technical assistance funds required by the Office of Nuclear Reactor Regulation (NRR) for the conduct of this program in FY81 is currently available but some reprogramming within NRR will be necessary.

The above resource requirements have been estimated through FY 1984. We expect that some followup work will be necessary beyond this period; however, it is difficult to make estimates at this time.

Recommendation:

We request that the Commission approve the proposed Equipment Qualification Program Plan.

William J. Dircks Executive Director for Operations

Enclosure:

Proposed Equipment Qualification Program Plan Commissioners' comments should be provided directly to the Office of the Secretary by c.c.b. Tuesday, September 8,1981.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT August 31, 1981, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additio:al time for analytical review and comment, the Commissioners and the Secretarict should be apprised of when comments may be expected.

DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations Exec Legal Director ACRS ASLBP Secretariat

CONTENTS Page ABBREVIATIONS..................................................

vii

1.0 BACKGROUND

1

2. 0 OBJECTIVE OF THE PROGRAM PLAN.............................

4

3. 0 EQUIPMENT QUALIFICATION REVIEW APPR0ACH.................

6 4.0 ENVIRONMENTAL QUALIFICATION REVIEWS AND IMPLEMENTATION....

8 4.1 Introduction.........................................

8 4.2 Task Objective......................................

8 4.3 Task Plan............................................

8 4.4 Schedule.............................................

9 4.5 Resources............................................

11 5.0 SEISMIC AND DYNAMIC QUALIFICATION REVIEWS AND IMPLEMENTATION............................................

13 5.1 Introduction.........................................

13 5.2 Task 0bjective.......................................

14 5.3 Task Plan............................................

14 5.4 Schedule.............................................

15

5.,

Resources............................................

15 6.0 EQUIPMENT QUALIFICATION STANDARDS DEVELOPMENT.............

17 6.1 Introduction.........................................

17 6.2 Task 0bjective.......................................

17 6.3 Task Plan................

17 6.4 Schedules........................

18

6. 5 Resources............................................

18 7.0 EQUIPMENT QUALIFICATION TEST PROGRAM REVIEWS AND IMPLEMENTATION............................................

19 7.1 Introduction.........................................

19 7.2 Task 0bjective.................................

19 7.3 Task Plan............................................

19 7.4 Schedule.............................................

22 7.5 Resources...........................................

24 v

Page 8.0 SENSITIVITY AND SURVIVABILITY OF EQUIPMENT EXPOSED TO HYDROGEN-8 URN ENVIRONMENTS.............................

26 8.1 Introduction............................................

26 8.2 Task 0bjective..........................................

26 8.3 Task Plan...............................................

26 8.4 Schedule................................................

26 8.5 Resources...............................................

27 9.0

SUMMARY

28 9.1 Introduction.............................................

28 9.2 Summary of Planned Accomplishments and Resource Requirements.............................................

28 9.3 Resource Requirements....................................

29 REFERENCES.........................................................

32 vi

ABBREVIATIONS AEB Accident Evaluation Branch AEC U.S. Atomic Energy Commission ASB Auxiliary Systems Branch ASME American Society of Mechanical Engineers B&W Babcock and Wilcox BWR boiling-water reactor CE Combustion Engineering CEM Chemical Engineering Branch CFR Code of Federal Regulations CSB Containment Systems Branch D0R Division of Operating Reactors DSI Division of Systems Integration EQB Equipment Qualification Branch FRC Franklin Research Center GDC General Design Criteria GE General Electric Company GSB Geosciences Branch HELB high energy-line break ICSE Instrumentation and Control Systems Branch IE Office of Inspection and Enforcement IEEE Institute of Electrical and Electronics Engineers LER Licensee Event Report LOCA loss-of-coolant accident MEB Mechanical Engineering Branch MTEB Materials Engineering Branch NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSSS nuclear steam supply system (vendor)

NT0L near-term operating license ORAB Operating Reactors Assessment Branch ORNL Oak Ridge National Laboratory PORV power-operated relief valve PWR pressurized-water reactor QAB Quality Assurance Branch RES Office of Nuclear Regulatory Research RSB Reactor Systems Branch SD Office of Standards Development SEB Structural Engineering Branch SEP Systematic Evaluation Program SER Safety Evaluation Report SRP Standard Review Plan TMI Three Mile Island TMI-2 Three Mile Island Unit 2 W

Westinghouse Corporation vii

EQUIPMENT QUALIFICATION PROGRAM PLAN

1. 0 BACKGROUND The need for equipment that could function under postulated accident conditions was recognized very early in the history of atomic energy.

Critical components were specified to be of high quality in accordance with the industrial standards existing at that time.

Consideration was given to potential radiation fields as well as to thermal, pressure, and moisture environments to which the equipment might be exposed.

In some cases, components were tested under research and development programs to verify that they would work under accident conditions.

To quote from the safeguards report for Pathfinder Atomic Power Plant, a facility designed more than 20 years ago:

The seal materials and designs used for electrical cable penetrations through the containment shell were tested prior to application on Pathfinder.

The tests consisted of a series of experiments which exposed full scale mockups of cable seals to steam for periods ranging from 5 to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and at pressures between 75 and 100 psig and temperatures from 310 to 325 F which are expected during the maximum design accident.

No leakage was detected during these laboratory tests.

Radiation levels at the cable penetrations under conditions due to the maximum design accident are not high enough to produce any deterioration of seal materials.

There are few records of qualification tests performed during this period on other equipment and they probably wcC d be difficult to resurrect.

Although the assumed conditions following a postulated loss-of-c_oolant accident (LOCA) were generally the same in the early days of the atomic age as they are now, and although some qualification tests were perfurmed for LOCA environments, the seismic design requirements were generally those found in then-existing building codes and, except for military applications, dynamic tests of equipment were generally not performed.

Equipment was, however, specified and designed to fail in a safe condition, should it fail because of adverse conditions.

Subsequently, both the industry standards and the U.S. Nuclear Regulatory Commission (NRC) (previously the U.S. Atomic Energy Commission (AEC)), require-ments have become more specific and more demanding.

The current regulations for equipment qualification are embodied in the General Design Criteria (GDC) 1, 2, 4, and 23 of Appendix A and Sections III and XI of Appendix B to 10 CFR Part 50..

More detailed guidance relating to methods, procedures, and guidelines for demonstrating this capability have been set forth in various industry standards and in NRC regulatory guides.

Since the early days of AEC and NRC, the scope and depth of licensing reviews of equipment quality have broadened.

Conclusions reached in early reviews were based primarily on the reviewer's experience and judgment.

Later, the review procedure became codified in the Standard Review Plan (SRP).

1

In view of changes in equipment qualification requirements and review procedures, the quality of installed equipment, especially that equipment in older operating facilities, has been questioned.

This does not necessarily mean that the equip-me.,t is not of good quality, but rather that the quality has not been demon-strated and documented in accordance with current standards.

In November 1977, the Union of Concerned Scientists petitioned the Commission to upgrade current standards for the envircnmental qualification of equipment in operating facilities.

This petition ultimately led to the Commission's Memorandum and Order of May 23, 1980 (CLI-80-21) (Ref. 1) which provides guidance and directives to resolve this matter in an expeditious manner.

Therefore, the immediate goal of the Equipment Qualification Program is to assure that equipment important to safety in operating facilities is demonstrated to be qualified to function in a harsh environment such as might result from a LOCA or high-energy-line break (HELB).

The figure included with this plan (Fig. 1) depicts the organization and coordination structure within NRC to accomplish the immediate objectives.

2

Equipment Qual.

Program Coordination NRR/DE Z.R. Rosztoczy I

Environmental Qual.

Sels./Dyn. Qual.

Equipment Qual.

Equip. Qual. Test Equip. Survivability Reviews & Implem.

Reviews & Implem.

Standards Dev.

Program Coord.

In flydrogen Env.

NRR/EQ3 NRR/EQU RES/ dei NRR/EQB NRR/lQB P.A. DiPenedetto To De Designated G. Arlotto Z.R. Rosztoczy ll.C. Garg Electrical Equip.

Seismic Qual. of Rule for Qual, of Accreditation Development liarsh Environment Electrical Equip.

Electrical Equip.

of Test Labs.

of Methodology NRR/EQB NRR/EQB RES/EEB IE/V;P8 NRR/CEB P.A. DiDenedetto A.J. Lee D.F. Sullivan W.R. Rutherford C.I. Parczewski Electrical Equip.

Seismic Qual.

Rule for Qual.

Industry Test Hild Environment of Mech. Equip.

of Mech. Equip.

Program Reviews Test Program NRR/EQB NRR/EQB RES/MSEB IE/V5PB RES/fBRB N.B. Le R.G. LaGrange W.F. Anderson W.R. Rutherford D.A. Iloatson Mechanical Equip.

Rule for Lab.

Review of Test Equipment Qualification Accreditation Reports Survivability Reviews NRR/EQB RES/IIFB NRR/EQB NRR/EQB li.C. Gary 5.D. Richardson K. Desai ll.C. Garg Equip. Qual.

Independent Data System Verification Tests NRR/EQB & FRC IE/VSPB W. Booth W.R. Rutherford Dev. of Equip.

Qual. Technology RES/MSEB & EEB J.E. Richardson D.F. Sullivan Figure 1 Nuclear Regulatory Commission coordination structure for the conduct of the overall Equipment Qualification Program t

2.0 OBJECTIVE OF THE PROGRAM PLAN It is the objective of this plan to provide a systematic approach for assuring that all equipmcat important to safety in both operating and new facilities is properly qualified to perform its safety functions, even if postulated accident conditions should occur.

It is anticipated tnat this program, expected to take about 4 years to complete, will by that time have accomplished:

An expedited review of the qualification status of equipment important to safety in operating facilities and identification of unqualified or improperly qualified equipment, Enforcement of corrective act'ons, including relocation, replacement, or requalification of inadequatel,/ qualified equipment, The development of standardized NRC review procedures for equipment qualifi-cation to be utilized in the review ;f new facilities, The development of a rule on the qualification of equipment important to safety and the development of supporting regulatory guides, Development of technology (analytical and experimental) in support of the equipment qualification reviews and the development of the rule on equipment qualification, Testing of selected equipment by NRC to independently verify equipment performance under accident conditions, The development and implementation of an accreditation program for test laboratories.

Three NRC offices will be involved in the execution of the program, namely:

the Office of Nuclear Reactor Regulation (NRR), the Office of Nuclear Regulatory Research (RES) which now includes the former Office of Standards Development (SD), and the Office of Inspection and Enforcement (IE).

Each NRC line organization will perform its normal function so far as this program goes, and normal channels of communication will be utilized for routine operation.

Thus, overall responsibility for directing the various program components resides with the appropriate NRC office.

Because of the many interfaces between the activities of the various offices, close coordination e.nd cooperation is envisioned.

To facilitate the implementation of this program, the Equipment Qualification Branch (EQB) in the Division of Engineering of NRR will provide overall inter-of fice coordination.

EQB's routine responsibility is to evaluate the capability of systems and components important to safety to perform their design functions under all normal, tinormal, and accident environment conditions and in the event of seismic occurrences and other pertinent dynamic loads.

4

With coordination of the Equipment Qualification Program provided by NRR, the Office of Inspection and Enforcement will witness selected licensee tests, perform inspections of equipment at the various sites, and direct the activities associated with the accreditation of testing laboratnries and independent testing of selected equipment.

The new Office of Nuclear Regulatory Research will be responsible for developing a rule and associated regulatory guides addressing NRC requirements regarding equipment qualification.

This office also will develop and execute research programs to provide pertinent technical information and support for the Equipment Qualification Program.

In addition to coordinating the overall Equipment Qualification Program, NRR will also review licensee suomittals, develop an equipment qualification data bank, develop standard qualfication criteria, and perform the necessary licensing activities associated with the program.

NRR and IE will also review cad monitor the equipment testing programs conducted by the industry and by testing laboratories on behalf of NRC.

This is to assure that the objectives of the Equipment Qualification Program are being met.

The NRC coordination structure for the conduct of the overall Equipment Quali-fication Program is shown in Figure 1.

As indicated on the figure, tne basic equipment qualification program consists of five principal parts:

Environnental qualification reviews and implementation (review of licensee /

applicart sut%ittals and licensing and enforcement actions, as necessary),

Seismic and dynamic qualification reviews and implementation (review of licensee /ar;plicant submittals anc licensing and enforcement actions, as necessary >,

Equipment qualification standards development (development of qualification role and associated regulatory guides),

E pipment qualification test program reviews and implementation (both industry-and NRC-sponsored tests).

Evaluation of the sensitivity and survivability of equipment exposed to hydrogen-burn environments.

These program parts are described in Sections 4.0, 5.0, 6.0, 7.0, and 8.0, respectively.

5

3.0 EQUIPMENT QUALIFICATION REVIEW APPROACH A typical nuclear power plant might have approximately 30 systems important to safety that need to function in an accident environment.

In addition, there are approximately 20 display instruments important to safety used by the plant operators in the performance of their functions important to safety.

Each of thr<se systems and instruments has many components that must be qualified for the expected environment.

It is the responsibility of the licensee / applicant to:

Identify all systems important to safety and display instruments and all components of these systems and instruments, Establish expected environmental, seismic, and dynamic conditions far various parts (zones) of the plant following postulated accidents or earthquakes, Qualify the systems and components to enviromental, seismic, and dynamic conditions corresponding to the location of the equipment, Submit to NRC the list of equipment important to safety, the expected environmental, seismic, and dynamic conditions, and a summary sheet on the qualification of each component type, Maintain an auditable central fDe of all relevant qualification data for the lifetime of the plar:t, Thus, the main ef" ort regarding equipment qualification will be taken by the licensees and appli_ ants.

The reports submit.ted by the utilities will contain a large amount of detailed information is well as the licensee's or applicant's conclusions.

To review this information within a reasonable period of time (given the resources available), the NRC staff will audit only a portion of it.

To obtain reasonable confidence that each submittal is thorough and factual, NRC will audit about 20% of the information pertaining to specific equipment, equipment tests, and test reports for that equipment which the licensee or applicant concludes is qualified and meets NRC regulations.

In addition, NRC will evaluate the licensee's or applicant's quality assurance procedures used in his indepth review.

If, based on this limited review, NRC findings and conclusions are generally consistent with those in the submittal, no further review will be deemed necessary.

If however, the staff disagrees with the licensee or applicant regarding more than 10% of the audited findings regarding equipment qualification (about 2% of the total), the submittal, identifying the shortcomings found, will be returned to the licensee.

It will be the licensee's responsibility to review and correct the entire report.

Once the corrected report is resubmitted, a new NRC audit will take place.

The NRC will review the licensee's or applicant's conclusions regarding all of the equipment identified as not meeting the NRC requirements for any reasons such as lack of proper documentation or test limitations or deficiencies.

Detailed guidance and instructions for reviewers are being prepared.

6

In reaching their conclusions, the licensees / applicants as well as the staff will have to make certain judgments regarding the qualification of specific equipment.

One problem anticipated is the adequacy of documentation for existing equipment in operating facilities.

Other problems or discrepancies might include deficiencies in the test program or differences of opinion as to the safety significance of certain equipment.

Recognizing that the judgments of technical experts may vary, the staff will consider the rationi aesented in the submittal and resolve outstanding issues.

When the staff has completed its review, a Safety Evaluation Report (SER) will be issued to document the NRC conclusions.

It will identify the equiprnent found qualified according to NRC regulations as well as the equipment that still needs to be justified, tested further, or replaced.

Licensing activities associated with the Equipment Qualification Program such as issuance of orders and SERs and implementing changes in technical specifica-tions will be handled within the NRR Division of Licensing.

NRR (EQB) will direct and monitor the establishment of an NRC equipment qualifi-cation data bank.

The programming and assimilation of the data base is being performed by Franklin Research Center (FRC).

During FY 1981, this data will be transferred to the NIH computer system, iesignated NEW WYLBUR, and will be available to NRC headquarters and regional.ffices.

The NRC staff will also keep informed of the status of a similar data bank being developed by Electric Power Research Institute.

The purpose of these two de r

,ystems is to provide the current qualification status of equipment impor'...it to safety and references to pertinent documents related to their qualification tests.

The data banks can be utilized by licensees, applicants, and NRC staff to support conclusions in submittals regarding equipment qualification as well as the staff's conclusions reported in SERs.

7

4.0 ENVIRONMENTAL QUALIFICATION REVIEW AND IMPLEMENTATION 4.1 Introduction Environmental qualification of equipment important to safety concerns both electrical and mechanical equipment and the environments associated with normal, abnormal, and accident conditions.

The normal and abnormal environ-ments are referred to as " mild." They are the typical variances one would expect to experience from events not associated with the breach of a high-pressure fluid boundary.

Mild environments result from an uncontrolled change in the environmental conditions because of accidents other than the LOCA or HELB and from anticipated operational occurrences.

As an example, the loss of electrical power could result in a loss of ventilating equipment and change the normal environment to a mild environment.

The " harsh" environment is a result of postulated LOCAs, HELBs, and core damage.

These conditions could affect environmental parameters significantly.

The parameters to be considered for environmental qualification (seismic and dynamic qualification discussed in Section 5.0) are:

Temperature Radiation Aging Chemical environment Pressure Humidity Submergence Dust By the Commission Memorandum and Order (CLI-80-21), dated May 23, 1980 (Ref. 1),

the interim criteria associated with environmental qualification of electrical equipment have been established as the 00R Guidelines (Ref. 2) and NUREG-0588 (Ref. 3).

The establishment of criteria for mechanical equipment environmental qualification is the subject of a subtask listed below.

4.2 Task Objective The objective of this task is to (1) assess the environmental qualification of all equipment important to safety in operating facilities during normal, abnormal, and accident environments; (2) develop interim guidelines and criteria to be used to evaluate the qualification status of equipment important to safety; (3) identify unqualified or insufficiently qualified equipment; (4) enforce appropriate corrective actions, including relocation, replacement, or requalification; and (5) develop a qualification data system compiling all environmental seismic and dynamic qualification data.

4.3 Task Plan Subtask 1--Assess the adequacy of environmental qualification of electrical equipment important to safety exposed to a harsh environment using the interim criteria established by the Commission Memorandum and Order (CLI-80-21), dated May 23, 1980 (Ref. 1).

Review and evaluate licensee submittals relating to 8

unresolved issues, corrective actions, and justifications for continued operation.

Take necessary enforcement actions.

Subtask 2--Develop review requirements and issue requests to both licensees and applicants for the review of electrical equipment important to safety in mild environments.

The licensees and applicants are to dor ment the extent the equipmant is qualified and propose corrective actions w:.are required.

Review and evaluate licensee / applicant response.

Review and evaluate licensee submittals relating to unresolved issues and corrective actions.

Subtask 3--Establish requirements for the environmental qualification of mechanical equipment important to safety.

Issue request to utilities.

The licensees and applicants are to document the extent the equipment is qualified and propose corrective actions where required.

Review and evaluate licensee /

applicant response.

Take necessary enforcement actions.

Subtask 4--Develop an environmental qualification data system with capabilities to cross-reference qualification data from plant to plant.

Input test report data for use in determining applicability.

Input replacement program schedules for use in determining continuous qualification status'of licensees.

Extend the data system to include pertinent seismic and dynamic qualification information.

4.4 Schedule The following milestones have been established for completing each subtask:

Completion Subtask 1, Electrical Equipment Exposed to Harsh Enviroments Date Review licensee's April 14 and November 1 submittals.

Issue 6/15/81 SER for all operating facilities.

Identify all unqualified or insufficiently qualified equipment 3/1/82 including equipment needed for cold shutdown and new equip-ment installed as a result of the lessons learned from the Three Mile Island (TMI) accident; require corrective actions; take enforcement action if submittal was insufficient.

Review licensee's proposed corrective actions, including 3/1/82 requalif.ication program and replacement schedule All electrical equipment important to safety must conform 6/30/82 to qualification requirements (per CLI-80-21).

Inspect conformance with qualification requirements; take 6/30/83 enforcement actions.

Review, audit, and evaluate equipmeat qualification Continuous information provided in support of operating licensee applications; inspect new facilities prior to operation; issue SER 4 months afcer receipt of complete submittal.

Review and evaluate equipment qualification concerns related Continuous to operating facilities (Licensee Event Reports (LERs)).

Inspect licensee's central files on equipment qualification.

Continuous Approximately 10 facilities per year will be inspected.

9

Completion Subtask 2, Electrical Equipment Exposed to Mild Environment Date Develop qualification criteria for mild environments; 9/1/81 issue request to licensees and applicants.

Licensees respond to request.

12/1/81 Review, audit, and evaluate licensee response; identify 3/1/82 shortcomings; require necessary corrective actions.

All electrical equipment important to safety must conform 6/30/82 to qualification requirements (per CLI-80-21).

Inspect conformance with qualification requirements; 6/30/83 take enforcement actions.

Completion Subtask 3, Mechanical Equipment Qualification Date Establish qualification criteria for mechanical equipment 9/1/81 important to safety to be qualified; issue request to licensees and applicants.

Licensees respond to request.

9/1/82 Review, audit, and evaluate licensee response; identify 5/1/83 shortcomings; require appropriate corrective actions.

All mechanical equipment important to safety must conform 5/1/84 to qualification requirements.

Inspect conformance with qualification requirements; 10/1/84 take enforcement actions.

Review, audit, and evaluate equipment qualification information Continuous provided in support of operating licensee applications.

Issue SER 4 months after receipt of complete submittal.

Review and evaluate equipment cualification concerns relating Continuous to operating facilities (LERs).

10

Completion Subtask 4, Equipment Qualification Data System Date Input information provided in November 1 submittals on 5/1/81 electrical equipment in harsh environment.

Exercise and query data system; issue user's manual.

1 0/1 /81 Input information provided in February 1 submittals 12/1/81 on cold shutdown and TMI related, if any.

Input information provided in licensee's 12/1/81 submittals.

2/1/82 Input information provided in licensee's 9/1/82 submittals 2/1/83 on environmental qualification of mechanica equipment and seismic and dynamic qualification of both mechanical and electrical equipment.

Input information provided by operating license applicants Continuous on equipment qualification (electrical and mechanical).

Input results of test report reviews Continuous 4.5 Resources The manpower and technical assistance required for the Equipment Qualification Branch to complete this program as scheduled are shown below.

Additional manpower from other NRR branches (ASB, CSB, ICSB, RSB, QAB, and AEB) will be required to assure consistency between EQB equipment qualification reviews and other NRR activities.

Assistance from IE will be required throughout the environmental qualification effort to inspect utilities and ensure that appropriate enforcement actions are being taken.

Additional assistance from IE, as an inspection effort, will be required (1) to verify that replacement schedules are being maintained for the service life of the equipment, (2) to assure that the licensee's equipment qualification files have been set up and are maintained; and (3) to ascertain that replacement parts installed by the licensee meet regulatory requirements.

The environmental part of the equipment qualification data bank is being developed at the Franklin Research Center (FRC) on a technical assistance contract.

Similarly, part of the plant audits and reviews are being performed by the Idaho National Engineering Laboratory (INEL) and FRC.

The NRC manpower estimates assume continuation of the technical assistance contracts as indicated.

The resources required to implement this task are shown below in terms of NRC manpower requirement (person years) and technical assistance requirement ($K):

11

Resource Requirements FY 1981 FY 1982 FY 1983 FY 1984 Organization PY SK PY SK PY

$K PY

$K EQB 8.6 1500 7.0 1450 7.0 1250 7.0 450 IE 6.0 3.0 3.0 3.0 Other NRR branches 2.0 1.0 1.0 0.5 TOTAL 16.6 1500 11.0 1450 11.0 1250 10.5 450 12

5.0 SEISMIC AND DYNAMIC QUALIFICATION REVIEWS AND IMPEMENTATIDN 5.1 Introduction The criteria and methods for the seismic qualification of mechanical and electrical equipment have changed significantly over the years.

Current licensing requirements are contained in GDC 2 and 4 and further guidance is provided in SRP Sections 3.9.2 and 3.10 and Regulatory Guide 1.100.

A number of operating reactors were licensed before the Standard Review Plans and Regulatory Guides were adopted.

Consequently, the margins of safety provided in existing equipment to resist seismic loads and the documentation to support the extent to which the equipment is qualified may vary considerably.

The seismic qualification of the equipment in operating plants must, therefore, be reassessed to assure that the plant can be brought to a safe shutdown condition when sub-jected to a seismic event.

Since current criteria are also subject to different interpretations, the margins in currently licensed plants may also vary and require reassessment, although not to the same extent as in older operating plants.

The seismic Category I equipment and supports in plants under construction with Mark II and III containments designed by the General Electric Company (GE) are required to be designed and qualified to withstand the effects of hydrodynamic vibratory loads associated with either safety / relief valve discharge or LOCA blowdown into the pressure suppression pool in addition to the effects of dynamic loads arising from earthquak'es.

This requirement, coupled with the need to address current licensing criteria with respect to seismic design, has resulted in a reevaluation and requalification effort on the part of boiling-water reactor (BWR) near-term operating license (NTOL) plants.

In addition to considering hydrodynamic loads in the suppression pool, other vibrations and accident-induced dynamic loads may have a noticeable effect on the functional capability of safety-related mechanical or electrical equipment.

These dynamic loads may not have been taken into consideration by the industry in their present qualification program.

In the past it has been generally accepted that the seismic qualification of equipment is sufficient to cover the effects of other undefined vibratory loads that may occur during the life of a plant.. Information is needed to define the anticipated vibratory environ-ment in various locations of a plant during seismic and accident conditions and to dete mine whether such environments exceed the design-basis envelope for the installed equipment.

The criteria and methods for demonstrating the operability of active safety-related pumps and valves during transient and accident conditions have also changed over the years.

Current licensing guidance is contained in 51?

Section 3.9.3 and Regulatory Guide 1.48.

Current practices va y for the methods and requirements for the design, specification, quali. cation, and preoperational and surveillance testing of these pumps and valves; often performance requirements are unclear, unspecified, or improperly specified.

13

A few examples are the PORV and block vaiver used at pressurized-water-reactor (PWR) facilities whose qualifications are now being reevaluated in view of the Three Mile Island Unit 2 (TMI-2) accident, the containment purge and vent system valves at many facilities whose design and operating requiremerits were in many cases not properly specified, and deep draft pumps at some facilities whose operability assurance programs are suspect because of improper quality assurance and inadequate preoperational testing.

5.2 Task Objective The objectives of this task are:

(1) to assess the qualification of all equip-ment important to safety

_ssure the ability of this equipment to function during and after a safe shutdown earthquake and other postulated vibrations and accident-induced dynamic loads, and (2) to assess the operability of active mechanical equipment important to safety including pumps and valves during transient and accident conditions.

This task is applicable to both operating and new facilities.

Equipment will be considered acceptable if it qualifies in accordance with the criteria contained in SRP Sections 3.9.2, 3.9.3, and 3.10 and Regulatory Guide 1.100.

It is recognized that equipment in older facilities may not meet these criteria, but may still be adequate.

Therefore, an additional objective of this task is to develop more definitive criteria to be used in judging whether equipment needs to be requalified if found deficient with respect to the criteria con-sidered acceptable today.

5.3 Task Plan Subtask 1--Assess the adequacy of the seismic qualification of all electrical equipment important to safety in operating facilities to assure the ability of this equipment to function during and after a safe shutdown earthquake.

Con-sider normal and accident-induced vibrations and dynamic loads and combinations of the seismic and dynamic loads.

Request pertinent information from licensees.

Review, audit, and evaluate the licensec'c submittals.

Take appropriate enforce-ment actions.

Subtask 2--Review the adequacy of the seismic qualification of mecnanical equip-ment important to safety in the same manner as it is described under Subtask 1.

Assess the adequacy of the operability assurance program for mechanical equipment important to safety, including pumps and valves, to assure the ability of this equipment to function during and after transient and accident conditions.

Con-sider the combination of loading conditions for which the pump or valve is expected to function.

Evaluate the test procedure, the test conditions, and loads which are imposed on the pump cr valve and the comparisons showing that this test and test loading are representative of those conditions and load combinations specified in the plant-design specifications.

Assess any analytical methods used in lieu of testing.

Request pertinent info 1mation from licensees.

Review, audit, and evaluate the licensees' submittals.

Take appropriate enforce-ment action.

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5.4 Schedule The following milestones have been established for completing both subtasks:

Assess the adequacy of the seismic input level and floor response spectra defined for each operating p_lant.

Where inadequacies are identified, additional effort outside this program will be required before the following tasks can be completed.

Separate schedules will need to be defined for such plants................. 8/1/a1 Develop review requirements, including criteria to be used and the equipment to be assessed, and issue request to both applicants and licensees to document the extent to which each piece of equipment is qualified.

Provide additional guidance on the interpretation of GDC 2 as it relates to the combination of accident and earth-quake loads....................................................... 9/1/81 Licensees and applicants respond to request.

Equipment identi-fied as not meeting current requirements should be assessed by licensees / applicants and a determination made as to whether this equipment is adequately qualified or if it must be requali-find or replaced.

The basis for such conclusions should be documented in the response........................................ 9/1/82 Recognizing that the qualification of some equipment may be marginal but still acceptable, develop more definitive criteria to judge the positions that may be taken by the licensees /

applicants........................................................ 9/1/82 Review licensees'/ applicants' submittals and issue SER which descibes NRC evaluation of the licensees'/ applicants' findings relative to the equipment which inust be requalified or replaced... 5/1/83 All equipment important to safety must conform to the seismic qualification requirements....................................... 5/1/84 Inspect conformance with qualification requirements; take enforcement actions...............................................

10/1/84 Review, audit, and evaluate seismic and dynamic qualification information, and pump and valve operability data provided in support of operating license applications.

Issue SER 4 months after receipt of submittal............................... Continuous Review and evaluate equipment qualification concerns relating to operating facilities (LERs)..................................... Continuous 5.5 Resources The manpower and technical assistance required for the Equipment Qualification Branch to complete this program as scheduled are shown belcw.

Additional man-power from other branches also will be required as discussed below.

Assistance from the Office of Inspection and Enforcement will be required in FY 1982, FY 1983 and FY 1984.

IE is responsible for inspecting a representative sample of the equipment to provide assurance that the equipment is installed in accordance with the design documents sr,ecified by the licensees / applicants.

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IE will also evaluate LERs and inspect conformance with the cualification requirements specified in the staff SERs, and will take appropriate enforcement

tions.

The Geosciences Branch (G"?) and the Structural Engineering Branch (SEB) will provide the assessment of input and floor spectra.

The Mechanical Engineering Branch (MEB) will (1) provide guidance on the interpretation of GDC2 as it relates to the combination of accident and earthquake loads and (2) provide guidance on the definition of the anticipated vibratory environments to be considered in the qualification of the equipment.

QAB is responsible for assessing the extent to which each licensee's equipment qualification program is in compliance wi~th GDC1 and Appendix B to 10 CFR 50.

The resources needed to implement this task are shown below in terms of NRC manpower requirement (person years) and technical assistance requirement ($K):

Resource Requirements FY 81 FY 82 FY 83 FY 84 Organization PY

$(K)

PY

$(K)

PY

$(K)

PY

$(K)

EQB 2.5 1000 6.0 1500 6.0 1550 9.0 950 IE 3.0 3.0 3.0 Other NRR branches 1.0 2.0 1.0 0.5 TOTAL 3.5 1000 11.5 1500 10.0 1550 12.5 950 16

6.0 EQUIPMENT QUALIFICATION STANDARDS DEVELOPMENT 6.1 Introduction The Commissioner's Memorandum and Order of May 23,1980 (CLI-80-21) (Ref.1) directed that the staff initiate a rulemaking on the subject of environmental qualification of electrical equipment important to safety.

In addition, NRR has requested that a broad single rulemaking action be evaluated such as an amendment to 10 CFR 50 which would include:

(1) the rule-making directed by the Commission on environmental qualification of electrical equipment, (2) addressing the qualification of both electrical and mechanical equipment for seismic and dynamic loading conditions as well as other environ-mental conditions, and (3) the rulemaking proposed in the Commission paper from IE (SECY-80-319) (Ref. 4) on the accreditation of testing laboratories.

The proposed broad rule would address requirements for operating as well as for new facilities.

6.2 Task Objective The objective of this task is to develop a rule (or rules), possibly as an amendment to 10 CFR 50, to give guidance and requirements for the qualification of equipment important to safety used in nuclear power facilities.

6.3 Task Plan The Office of Nuci Regulatory Research will initially pursue this effort as three separate and concurrent subtasks; it may be consolidated later in the program if circumstances warrant it.

The rationale for this approach is that subtask 1 (described below) may be completed earlier, if pursued separately, than if it were incorporated into a single rulemaking effort.

Subtask 1-~ Develop a rule addressing the environmental, seismic, and dynamic qualification of electrical equipment as directed by the Commission's Memorandum and Order (.Ref. 1).

A number of standards and regulatory guides are available on this subject and can serve as the bases for this rule.

Subtask 2--Develop a general rule addressing all mechanical equipment important to safety.

The rule will provide only general criteria and requirements for review of applicants' submittals; guides and standards give detailed guidance.

At present, no regulatory guides are available on environmental, seismic, and dynamic qualification of mechanical equipment.

Consequently, NRR will need to perform detailed review of applicant's submittals for conformance and provide the necessary specifics for IE.

Hence, the principal effort in support of this subtask will be the development of guides and standards for qualification of this equipment.

Subtask 3--Develop a rule addressing laboratory accreditation as approved by the Commission.

These efforts will be coordinated with the Office cf Inspection and Enforcement task on this subject in Section 7.3.

17

6.4 Schedule The following milestones have been established for completing each subtask:

Subtask Completion Date Subtask 1, T.ule for Qualification of Electrical Equipment

- Rule for comment 12/1/81

- Issue rule 1/1/83 Subtask 2, Rule for Qualification of Mechanical Equipment Advanced notice for rulemaking +

8/28/81 Rule for comment 6/1/82

- Issue rule 4/1/83 Subtask 3, Rule for Laboratory Accreditation

- Rule for comment 12/1/82 Issue rule 9/1/83 Note:

In January 1982 and 1983 a review will be made to determine the pretL?cality oi combining the three separate rules into a single rule.

+ Asst.mes AMR will be issued by the EDO.

6.5 Resources The resources needed to isplement this task are shown below in terms of NRC manpower requirement (pe"stn years) and technical assistance requirement (SK):

Resource Requirements Organization FY 81 FY 82 FY 83 FY 84 NRR (EQB)

1. 0 1.5 RE5*

3.0 4.0 4.0 4.0 IE 0.1 0.1 0.1 TOTAL 4.1 5.6 4.1 4.0 xDevelopment and maintenance of regulations, guides and standards will be a continuing effort through FY 84 and beyond.

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7. 0 EQUIPMENT QUALIFICATION TEST PROGRAM REVIEW AND IMPLEMENTATION 7.1 Introduction This part of the program consists of five subtasks involving three offices of the NRC.

Coordination of these subtasks is performed by the Equipment Qualifi-cation Branch of NRR; however, direct responsibility for the conduct of the work under each subtask resides with the indicated NRC office.

Review and guidance for most of the subtasks is provided by an interoffice team.

Many of these subtasks were mandated by the Commission's Memorandum and Order of May 23, 1980 (CLI-80-21) (Ref. 1).

7.2 Task Obiective NRC requires that samples of equipment that could ae subjected to a harsh environment or seismic and dynamic loads be tested in an equivalent environment or the facility owners need to prove by analyses, based on existing test data, that the equipment is qualified.

The objective of this task is to (1) assure that qualification tests are conducted to provide reasonable assurance that equipment important to safety will perform its design functions, and (2) develop the technology for environmental, seismic, and dynanic qualification.

7.3 Task Plan Subtask 1:

Accreditation of Test Laboratories--As discussed in Section 6 of this program plan, NRC is preparing a new rule that will address in detail the subject of equipment qualification.

This rule will provide specific guidance and set requirements for meeting the Commission's present General Design Criteria for nuclear power plants.

One of the requirements will be that future equipment qualification tests be performed in a laboratory accredited for that purpose.

Accredited laboratories could be operated by equipment manufacturers, utilities, indepencent research and development institutes, universities, and independent testing laboratories.

NRC will work with either the Institute of Electrical and Electronics Engineers (IEEE) or the Au.trican Society of Mechanical Engineers (ASME) to initiate an accreditation program for laboratories _

Initially, the program will review the capabilities of laboratories already conducting tests on equipment for the nuclear industry.

Its purpose is to achieve greater uniformity and consistency in the testing process regarc'less of the specific organization interest.

Subtask 2:

Indepth Review of Incustry Test Programs--As part of its overall equipment qualification program, the NRC will inspect and review the industry test programs of selected critical components.

This will include an NRC review of equipment specifications, test plans, test procedures, and acceptance standards before the industry performs their qualificatiorc tests.

In addition, the inspections will include observation of the tests, review of test results, and site inspections of equipment installations.

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This review and inspection of the ongting qualification tests will afford NRC the opportunity to ensure that necessary changes or adjustments are made before the work is completed.

The inspections will le performed by an inspection team consisting of members from IE, NRR, and Se uia Laboratories.

Under the allotted resources for the

~

inspection program, approximately 10 complete equipment qualification packages will be inspected per year.

The initial inspections are scheduled to begin in December 1980.

The inspection teams will review each quaiification test phase and provide comments as to conformance to the test requirements.

Subtask 3:

Review of Test Reports--A successful completion of a qualification test culminates in a test report that fully describes the test and the test results.

A large number of such test reports have been and are being generated.

It is the intent of NRC to conduct an audit review of about 20% of these reports initially and then decide at that time whether or not the review of an additional fraction cf the reports is warranted.

The review effort is divided as follows:

Nuclecr steam supply system (NSSS) vendor reports (B&W, CE, GE, and W)--

technical assist;nce undesignatea SEP facility related reports--technical assistance provided by FRC FRC reports--EQB staff Miscellaneous selected reports--NRC staff Reports associated with NRC audit of industry's environmental qualification program--IE/NRR team.

Suotask 4:

Independent Verification Tests--In a memorandum to the Commissioners dated July 1,1980 (SECY-80-319) (Ref. di~and in a briefing held on July 15, 1980, IE identified the staff program for conducting independent testing and inspection of the environmental qualifications of equipment important to safety.

Subsequent memoranda provided further specific information requested by the Commission.

In addition to its audit of industry test programs, NRC will conduct independent qualification tests of important equipment to verify the industry results.

To the extent practicable, the NRC tests will be conducted on equipment which has been in use in a nuclear power facility.

When this is not practical, specimens will be obtained from stock designated for a nuclear power facility, artificially aged, and then tested.

Contracts have been let with Sandia Laboratories and Franklin Research Center to conduct independent verification tests of selected equipment previously qualified by the industry.

Equipment for the NRC tests will be selected for a variety of reasons such as:

safety significance, volume use in plants, complex-ity of equipment, scnsitivity of equipment, age (installed life vs. qualified life), installation concerns, degree of confideqce in qualification report, and so forth.

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To obtain naturally aged equipment and spare equipment, NRC will need the cooperation of the licensees of operating plants.

A number of licensees will be requested te provide samples at specified time intervals in order to accurately determine the effects of a natural nuclear plant envirowent on certain components or assemblies important to safety.

Initially, under this program, NRC will conduct four or five independent verification tests each year.

Depending upon results, the number of tests may be increased.

Subtask 5:

Development of Eouioment Cc-'ification Technolocy--This program consists of two parts:

(1) the development of technology for environmental qualification and (2) the development of technology related to seismic and dynamic qualification.

Although much is known about these subjects, there are still questions left unanswered, particularly as to extrapolating or inter-polating from one set of conditions to another.

Regarding environmental testing, methods available for accelerated aging of various materials will be reviewed.

The role of dust in the environcental Studies will qualification of nuclear power plant equipment will be assessed.

be made and experimentr, performed to compare radiation damage from commonly used radiation simulators to radiation sources that might result from an accident.

Guidelines will be developed for the preconditioning of equipment' prior to its being tested in a harsh environment.

Qualification tests will be performed on selected equipment:

(1) to verify recommended preconditioning and testing procedures, (2) to study failure modes, and (3) to establish Detailed examinatior. of equipment that was subjected to margins to failure.

the TMI-2 harsh environment will be performed to the extent practicable and conclusions published to provide information as to the survivability of a wide range of -devices under accident conditions.

A program to study seismic qualification testing criteria and methodology is-currently being initiated.

This program will evaluate past and present methods of seismically quai!fying the operability of mechanice.1 and electrical components and cor,@are these with current criteria.

A procedure also will be developed to extract fragility data f rom existing qualification test results for use in system-risk analyses.

Additional researcn efforts will include:

An analytical program with some testing to study the effects of various inputs to determine which wave forms are accepta.ble for simulation of earthquake excitation.

An evaluation of the influence of component aging and environmental degradation effects on the dynamic qualification of equipment, The performa:.ce of fragility tests to identify failure modes and failure levels on selected critical equipment identified by the Seismic Safety Margins Research Program, The development of scale modeling guidelines for the dynamic testing of equipment, An evaluation of the pump and valve operability assurance programs currently being conducted by the industry, 21

A progrc.m to identify vibrations and accident-induced dynamic loads that may have.a significant effect on the functicnal capability of mechanical and electrical equipment important to safety, An assessment of the reliability and uncertainty of dynamic qualification methods.

7.4 _ Schedule The following milestones have been established for completing each subtask:

Completion Subtask 1, Accreditation of Test Laboratories Date Reach agreement on accreditation program with the 6/15/81 appropriate professional organization (ASME or IEEE).

Develop accreditation criteria.

3/1/82 Start accreditation of laboratories.

9/1/83 Accredit 5 to 10 laboratories per year.

Continuous Completion Subtask 2, Review Industry Test Programs Date Obtain frca the industry a list of equipment 1/1/81 qualification tests planned for the next 2 years.

Select the 10 tests to be inspected in 1981.

5/1/81 Issue a tentative program for the review and 7/1/81 inspection of all 10 tests.

Perform the necessary reviews and inspections for 3/1/82 the 10 tests selected for 1981.

Issue final reports and SERs.

Will be done continuously during the year; the last SER will be issued by completion date.

Select the 10 tests to be inspected in 1982 and 11/1/81 issue tentative review and inspe: Lion schedule.

Perform the necessary reviews and inspections for 2/1/83 the 10 tests selected for 1982.

Issue final reports and SERs.

Will be done continuously during the year; the last SER will be issued by completion date.

Select the 10 tests to be inspected in 1982 and 11/1/82 issue tentative review and inspection sc W ':31 e.

Perform the necessary reviews and inspections for 1/1/84 the 10 tests selectea for 1983.

Issue final reports and SERs.

Will be done continuuusly during the year; the last SER will be issued by completion date.

22

Completion Subtask 3, Review of Test Reports Date Establish a master list of all test reports referenced 6/1/81 by licensees in the Nov. 1, 1980 and previous equipment qualification submittals.

Indicate the review status of each report.

Complete the review of approximately 20% of the 10/1/81 referenced test reports.

Review additional test reports as required.

Continuous Select a contractor for the review of NSSS vendor qualification programs and test reports.

9/1/81 Complete the review of all four NSSS vendor 3/1/83 programs and test reports.

Completion Subtask 4, Independent Verification Tests Date Selact the four to five tests to be conducted 2/1/81 in 1981.

Issue schr.'ule for these tests.

Complete test #1 (sliding link terminal block);

4/15/81 issue test report.

Complete test #2 (cable shop splice test);

9/18/81 issue test report.

Complete test #3 (solenoid valves); issue 11/1/81 test report.

Complete test #4 (electrical connectors).

9/1/81 Select the four to five tests to be conducted 11/1/81 in 1982.

Issue c'iedule for these tests.

Select the four t; five tests to be conducted 11/1/82 in 1983.

Issue schedule for these tests.

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Subtask 5, Development of Equipment Qualification Technology Date Prepare a users' need memorandum on additional information 7/1 / 81 -

needed from RES with respect to the environment 61 qualifi-of electrical equipment.

Prepare program assumptions (plans and schedule) for FY 82 8/1/81 on the evaluation of equipment qualification, including pumps and valves.

Interim report on methodology to precondition or age equip-3/1/82 ment for DBA Qualification.

Evaluation of accelerated aging methodology.

Continuous I';erim report on evaluation of simulator adequacy for 3/1/82 radiation qualification of safety related equipment.

Evaluation of radiation simulation methodology.

Continuous Continuous Conduct evaluation of equipment, including pumps and valves, removed from TMI-2.

Completed selection of contractor and nard contract for the 6/1/81 evaluation of the methodology for the seinic qualification of equipment important to safety.

Issue a detailed schedule and milestones for seismic quali-7/1/81 fication methodology evaluation program.

Prepare a users' request memorandum on additional seismic 7/1/81 and dynamic qualification information needed from RES.

Initiate supplemental program to evaluate seismic and dynamic 12/1/81 qualification criteria and methodologies consistent with the resources shown in the tables to Section 7.5 below.

Issue detailed schedule for supplemental program.

2/1/82 7.5 Resources The resources needed to implement this task are shown below in terms of NRC manpower requirement (person-years) and technical assistance requirement ($K):

Resource Requirements FY 81 FY 82 FY 83 FY 84 Oroanization PY

$(K PY

$(K PY 5(K)

PY

$(K)

NRR 4.2 500 4.0 500 4.0 500 3.7 500 IE 5.0 600 5.5 900 6.0 1,100 5.5 1,500 RES*

1.5 1.900 1.5 2,600 1.5 3,000 5.5 2,000 TOTAL 10.7 3,000 11.0 4,000 11.5 4,600 10.7 4.000

The Long Range Research Plan contemplates these research programs will continue beyond FY 84.

24

A breakdown of the resource requirements by subtasks is summarized below:

Subtask 1, Accreditation of Test Laboratories: