ML091320489

Staff Responses to Comments on Draft Regulatory Guide DG-1175 (Regulatory Guide 1.100, Rev. 3)

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Staff Responses to Public Comments on Draft Regulatory Guide DG-1175 (Proposed Revision 3 of Regulatory Guide 1.100)

(Public comments have been edited for clarity)

IEEE Power Engineering Society Nuclear Utility Group on Equipment Nuclear Energy Institute Nuclear Power Engineering Committee Qualification 1776 I Street NW, Suite 400 (ML082000783) (ML082000784) Washington, DC 2006-3708 (ML082540405)

Westinghouse Electric Company Duke Energy Carolinas, LLC Dominion P. O. Box 355 EC07H / P.O. Box 1006 One James Rive Plaza Pittsburgh, PA 15230-0355 Charlotte, NC 28201-1006 Richmond, VA 23219 (ML082000782) (ML082000785) (ML082200057)

ASME Nuclear Codes and Standards (ML082660608)

Comments NRC Comment Resolution DG-1175 Originator Specific Comment NRC Staff Response Section IEEE-1 B.1 In paragraph (5), we disagree with the NRC comment The staff has reviewed and considered the about the seismic vulnerability of solid state comment. The statement is revised to Some components. Test results experienced by members solid-state relays and microprocessor-based have shown high capacities for solid state relays. The components may be sensitive to earthquake specific nature of the NRC data showing issues for excitations. A test would be needed to these types of components should be examined. confirm if particular equipment is not sensitive Recommend deleting these sentences to high-frequency ground motion.

IEEE-2 B.1 In paragraph (5), the term equipment capacity factor is The staff reviewed the comment and revised not defined. the statement in the final version of DG-1175.

Recommend defining this term.

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IEEE-3 B.1 In paragraph (5), the statement Third, since no new The statement is rewritten as Furthermore, NPPs were built after the early 1980s, a number of since no new NPPs were built in the USA manufacturers for electric or active mechanical after the early 1980s, a number of equipment are no longer in business, and the manufacturers for electric or active appropriateness of using the test experience of old mechanical equipment are no longer in equipment made by manufacturers no longer in business While the staff agrees that many business for the seismic qualification of modern NPPs have been built outside the USA, not all equipment designs made by different manufacturers is seismic and test experience database were highly questionable, is misleading and should be available to the staff.

corrected or deleted. Many NPPs have been built since the early 1980s. Kashiwazaki-Kariwa Nuclear Power Plants has five BWR units, which entered commercial operation in 1985 and 1994 and two ABWRs which entered commercial operation between 1996 and 1997.

There are at least 29 NPPs worldwide that have been built since early 1980s that have utilized IEEE 344 standard for qualification. We also disagree with the suggestion that seismic fragilities are manufacturer-specific. The construction of the equipment and the observed failure modes which are addressed by the similarity requirements in the Standard, are of significantly greater importance. U.S. NRC concern about use of experience data for older equipment is not warranted since such equipment would not be similar to more current components. IEEE Std 344-2004 Section 10.4.2 (a) excludes the use of data for components that have changed in time (such as microprocessor systems).

Recommend deleting this entire discussion.

IEEE-4 B.1 In paragraph (6) the U.S. NRC concern about using The staff reviewed the comments and deleted experience data for equipment exposed to harsh the paragraph in the final version of DG-1175.

environment is not valid. Aging and other environmental requirements are governed by IEEE 323 standard. In addition, EPRI has conducted substantial research (NP3326) to identify those components that do not have a seismic aging correlation.

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Recommend removing the beginning The NRC staff -

IEEE Std 344-2004.

IEEE-5 B.1 In paragraph (7) the statement "Ball joints and The staff has reviewed and considered the kinematics linkages of the shake tables generated these comment. Even though IEEE Std 344-2004 inadvertent high frequencies, which the NRC staff may have safeguards to ensure that the input considers to be noise signals that may not have the is generated and in compliance with the proper frequency content with sufficient energy to be frequency range of interest, the statement is compatible with the amplified region of the RRS at high needed to prevent potential misuse of the frequencies" is misleading and should be corrected or previous test data. The statement is revised deleted. Since the high-frequency range has been to Therefore, any attempt to use such past characterized as (20 hertz (Hz) and above), RRS used test experience data for the seismic in seismic testing envelope plant equipment location qualification of high-frequency-sensitive requirements almost always exceed 20 Hz and often equipment or fragile components in such plant contain higher than 33 Hz content purposely input into is not appropriate unless frequency content of the seismic test table, there is no basis to state with the power spectral density (PSD) of the test certainty that "Ball joints and kinematics linkages of the waveform has been evaluated in accordance shake tables generated these inadvertent high with Annex B of IEEE 344-2004.

frequencies".

Recommend removing this discussion.

IEEE-6 B.1 In paragraph (7) the statement However, the vast The staff has revised the statement for majority of existing seismic qualification tests used input clarification as although the TRS may have frequencies up to only 33 Hz, although the TRS may shown a zero period acceleration (non have shown a zero period acceleration (ZPA) up to 100 amplified frequency range) up to 100 Hz.

Hz" is misleading and should be corrected or deleted.

The statement intertwines two seismic qualification elements and generates a misunderstanding. The seismic test frequency range is the amplified range, which is defined by the RRS. The ZPA is by definition the acceleration level of the high-frequency, non-amplified portion of the response spectrum.

Recommend removing this discussion.

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IEEE-7 B.1 In paragraph (7) per U.S. NRC concurrence, new plants All equipment in new nuclear plants must are not being qualified for high frequency ground- satisfy the regulations for seismic qualification motions rather they are being screened for high delineated in Appendix A of 10 CFR Part 100 frequency sensitivity. Such high-frequency motions are and Appendix S of 10 CFR Part 50. The staff not part of the certified design basis. Refer to COL/DC- acknowledges that there is no inconsistency ISG-1, "Interim Staff Guidance on Seismic Issues between COL/DC-ISG-1 and DG1175. The Associated with High Frequency Ground Motion in ISG provided guidance on the methodology to Design Certification and Combined License determine whether the equipment is sensitive Applications to the effects of high frequency ground motion. DG-1175 described methods that the Recommend removing the discussion beginning When staff considered acceptable for use in seismic new - motion concerned." qualification of electric and active mechanical equipment.

IEEE Std 344 is mentioned in the ISG-1 twice.

In Section 4.1.1 of COL/DC-ISG-1, If existing test data are used to demonstrate functionality, the use of such data should be evaluated over the required frequency range of interest in accordance with IEEE Standard 344 to demonstrate that the proper frequency content with sufficient amplitude was used as input to the component that has been previously tested. For the screening procedure and justification of high frequency sensitive equipment, requirements in IEEE Std 344 should be used to demonstrate that the proper frequency range and sufficient amplitude was used.

Section 4.3.1 in COL/DC-ISG-1 indicated that The test procedure is to be consistent with the requirements of IEEE-344 as supplemented by NRC RG 1.100. For seismic qualification of screened-in equipment/components, any test procedure should be consistent with IEEE Std 344.

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IEEE-8 B.1 In paragraph (7) U.S. NRC defines high-frequency The staff agrees that the bound of the high-range as 20 Hz and above. It is understandable that a frequency range depends on the frequency bound was not defined because it is dependent on the range of floor response spectrum of the hard frequency range of interest of the hard rock site. rock site. Defining an upper limit would not be Recommend adding a statement in this section to define appropriate in the guidance document. Thus, the upper limit to the high frequency range. no change is necessary in the final version of DG-1175.

IEEE-9 B.1 In paragraph (7) it appears that the NRC position in this See responses to IEEE-5 and IEEE-7 section is that previous seismic test programs which did not require HF content cannot be used for qualification of equipment at HF sites. Is it the NRC position that only seismic test programs that required HF content (i.e.,

hydrodynamic loadings associated with BWR) are acceptable? All seismic tests should be acceptable provided there is sufficient energy content over the frequency range of interest.

Recommend this section be revised to be consistent with COL/DC-ISG-1, Interim Staff Guidance on Seismic Issues Associated with High Frequency Ground Motion in Design Certification and Combined License Applications."

IEEE-10 B.2 In paragraph (1) the major change from ASME QME The NRC staff plans to withdraw Regulatory 2002 to ASME QME-1-2007 in terms of the functional Guide (RG) 1.148 after this revision to RG qualification of mechanical equipment is a complete 1.100 is finalized. RG 1.148 also discusses rewrite of Section QV and the new Mandatory Appendix functional specification of active valves and QV-1. This entire section seems out of place in a primarily endorses ANSI N278.1-1975. In the seismic qualification document. This material addresses Foreword of ASME QME-1-2007, it was functional qualification and may be a better fit in explained that the ANSI N45 Committees Regulatory Guide (RG) 1.148, "Functional valve task force (N278) was reassigned to the Specification for Active Valve Assemblies in Systems ASME QME in 1982 and designated the Important to safety in nuclear Power plants." RG 1.148 Subcommittee on Qualification of Valve also discusses functional specification of active valves Assemblies. In addition, ANSI N278.1 has not and primarily endorses ANSI N278.1-1975. Although the been updated since 1975 and the staff ANSI standard by itself does not provided complete believes that there is no need to revise assurance of operability, there is an overlap between RG1.148. Endorsing the ASME QME-1-2007, DG1175 and RG 1.148 for functional qualification of which incorporated all the lesson-learned and Page 5 of 62

active valves. operating experience of active mechanical equipment, for functional qualification is Recommend that functional qualification of active appropriate and prudent.

mechanical components (which have no direct bearing on seismic qualification) should be discussed in a revision to RG 1.148 and the RG 1.100 should only provide guidance for seismic qualification of electric and mechanical equipment. Therefore, Section 2.

(Functional Qualification of Active Mechanical Equipment) should be move to RG 1.148 and the title for this document reverted back to Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants IEEE-11 C.1.1.1b In subsection (1) of C.1.1.1b the word credibility is The staff disagrees with the comment. Not all used. This word may imply a negative bias and is not test and earthquake experience data have suggested for use in a regulatory position document. equal technical quality. The credibility, or the The following change is recommended: quality of the data, should be justified.

1) The wordings "the credibility and" be removed. The remaining wording is sufficient.

or

2) Change to the following: (1) seismic experience data for its completeness and the information that would be generated in the process of establishing evidence of qualification.

IEEE-12 C.1.1.1c This sub-section states The NRC staff does not The staff does not disallow the use of generally find it acceptable to use experience data experience-based methods. As delineated in (earthquake or test experience data) for ..." and goes on C.1.1.1b, the use of experience-based to provide three categories of equipment which are very method for seismic qualification of electric extensive and encompass the majority of safety-related equipment will be subject to the review and electrical and electromechanical equipment provided to approval by the NRC staff.

Nuclear Power Plants (NPPs). It is unclear why the NRC find experience based qualification to be an Even though IEEE Std 344-2004 identified unacceptable method. As written the DG-1175 position limitation of earthquake or test experience -

suggests that test-based experience performed in based qualification, the staff believes that the accordance with IEEE Std 344-2004 requirements (per list in IEEE Std 344-2004 sub-clause Section 10.3) does not adequately qualify chatter 10.4.2(b) should be supplemented by the sensitive equipment. This is unclear since sub-clause additional items listed in C.1.1.1c. However, Page 6 of 62

10.4.2 (b) of IEEE Std 344-2004 provided exclusion to C.1.1.1c should not be considered as a such things as relays, contactors, switches and complete list.

breakers. Experience based method as defined in IEEE Std 344-2004 provides sufficient evidence of seismic qualification. Further clarification is recommended to understand the DG-1175 position.

IEEE-13 C.1.1.1c Please clarify what are fragile electronic components, The staff has reviewed and considered the such as solid-state relays and microprocessors-based comment. The statement is revised in the components This paragraph provides an inappropriate final version of DG-1175 conclusion that safety-related solid-state relays and microprocessor-based components are fragile. Test results experienced by IEEE Std 344-2004 Working Group (WG) have shown high capacities for equipment like solid-state relays. Safety-related solid-state relays and microprocessor-based components have been seismically qualified to IEEE Std 344-2004 by testing and have recently experienced actual earthquakes, such as the Niigataken Chuetsu-Oki earthquake at the Kashiwazaki-Kariwa Nuclear Power Plant in which safety-related digital l&C operated properly during and after the earthquake. Seismic qualification test programs and earthquake experience demonstrated that safety-related solid-state relays and microprocessors-based components are not fragile. Therefore, the characterization fragile electronic components" must mean non-safety-related solid-state relays and microprocessor-based components.

Recommend DG-1175 data identifying fragile electronic components be provided for review and the statement further clarified or deleted since as written it is misleading.

IEEE-14 C.1.1.1c Item (3) identifies a concern with the using of The staff has reviewed and considered the experience data for subcomponents that are defined in comment. The statement is revised in the Items (1) and (2). This exclusion is presently addressed final version of DG-1175 in IEEE Std 344-2004 in the Introduction and the exclusion defined in sub-clause 10.4.2 (b). Therefore, Page 7 of 62

since this item is addressed in. IEEE Std 344-2004, no restriction is required.

Recommend this exclusion be removed since it is presently addressed in IEEE Std 344-2004.

IEEE-15 C.1.1.1d This sub-section as written seems to impose new C.1.1.1d is applicable only to applicant or requirements on the common practice of seismic testing licensee who is proposing to use test-selected items to qualify a family of similar items in experience data (in IEEE St 344-2004 Clause accordance with Claus 8 (Testing) of IEEE Std 344- 10.3) to perform seismic qualification.

2004. If so, this is a change from traditional seismic C.1.1.1d is not applicable to the provision in qualification methods used in the past. Clause 8 (Testing) and Clause 9 (Combined analysis and testing).

Recommended this statement be further clarified to better define the intent of the section and the relationship to similarity method defined in sub-clause 9.3 (Extrapolation for similar equipment) of IEEE Std 344-2004 or be deleted. This section should allow the industry to qualify similar equipment without having to obtain NRC approval.

IEEE-16 C.1.1.1f Seismic qualification of equipment should be performed The staff agrees the wording in IEEE Std 344-over the frequency range of interest. DG-1175 wording 2004 concerning the frequency range has not does not allow a limit lower than 33 Hz to be performed changed from the IEEE Std 344-1987 version.

but mandates a higher cutoff is required by the RRS of a However, recent studies identified that the specific plant. There may be instances where a lower response spectrum for certain sites in the cut-off would be allowed by a site specific RRS and Central and Eastern United States may have therefore should be allowed. IEEE 344 standard uses amplified region in the beyond 33 Hz. The the following wordings throughout the standard to staff agrees that defining an upper limit would address this item. ...over the frequency range of not be appropriate in the guidance document.

interest (typically, 1 Hz to 33 Hz) or up to the cutoff The upper bound of the frequency range frequency. Where the cutoff frequency is defined as should be depends on the frequency range of "The frequency in the response spectrum where the the RRS of the specific plant equipment. The ZPA asymptote begins... statement is revised to The NRC staff does not generally find it acceptable to restrict the The IEEE Std 344-2004 wording above is appropriate. frequency range of testing up to 33 Hz. The The wording has not changed from the IEEE Std 344- frequency range should be consistent with the 1987 version. Recommend removing this discussion. RRS of specific plant equipment.

Due to other changes in the draft guide, this is Page 8 of 62

now Section 1.1.1 e.

A statement has also been added to address 1/6 octave testing.

IEEE-17 C1.1.1g This section excludes the use of previous testing to The staff has reviewed and considered the address high frequency concerns because the high comment. Even though IEEE Std 344-2004 frequency motions were not intentionally input to the may have safeguards to ensure that the input test. An assessment of the test input waveform should is generated and in compliance with the be conducted to verify the test specimen was frequency range of interest, the statement is adequately tested over the frequency range of interest. needed to prevent potential misuse of the If the test data demonstrate sufficient frequency content previous test data. The statement is rewritten in the high-frequency range throughout the time history as The vast majority of existing seismic then the data should be acceptable. This approach is qualification tests used input frequencies up consistent with Section C.1.1 1.h. to only 33 Hz. The use of these prior testing results should be justified by demonstrating IEEE Std 344-2004 has sufficient safeguards to ensure that the frequency content of the power that the input is generated and in compliance with the spectral density (PSD) of the test waveform is frequency range of interest. The DG-1175 position is not sufficient in accordance with Annex B of IEEE necessary since the present requirements in IEEE Std 344-2004.

344-2004 are adequate to verify the test data has sufficient content over the frequency range of interest throughout the input time history.

This requirement is addressed in the stationary requirements in the strong motion portion of the test inputs through time segment analysis as defined in IEEE Std 344-2004 Annex B. If there is sufficient content in each of the time segments then the test input is acceptable and the origins of the energy input to the test (ball joints and kinematic linkages) are immaterial.

The test specimen experienced the required environment regardless of source.

Recommended this section be revised to require high frequency motions evaluated in accordance with IEEE Page 9 of 62

Std 344-2004 Annex: B (Frequency Content and Stationarity).

IEEE-18 C.1.1.1i The statement Electric equipment should be qualified The statement is revised for clarification. For with five one-half SSE events followed by one full SSE NPPs that were licensed with the elimination event (SECY-93-087) even if the OBE of a plant is of the OBE, electric equipment should be defined to be one-third of SSE or less," should be qualified with five one-half SSE events deleted since the statement as-is creates a situation followed by one full SSE event or, where current acceptable testing may be rendered alternatively, a number of fractional peak unacceptable. The DG-1175 position does not cycles equivalent to the maximum peak recognize that some plants are licensed with an OBE cycles for five one-half SSE events in that is greater or less than one-half the SSE. The plant accordance with Annex D of IEEE 344-2004 licensing basis should define whether the OBE is one- when followed by one full SSE (SECY third or one-half of the SSE, or has no relationship to the 087) even if the OBE of a plant is defined to SSE. be one-third of SSE or less. For other reactors, the staff will review the seismic The SECY-93-087 document specifically addressed qualification based the OBE level in issues affecting Advanced Light-Water Reactors accordance with the licensing basis.

(ALWRS), for which the OBE was eliminated as a design case by making it one-third of SSE or less. The five one-half SSEs provision in SECY-93-087 is intended for ALWR applications. It is also noted that the DG-1175 phrase ,..even if the OBE of a plant is defined to be one-third of SSE or less is not in SECY-93-087.

The OBE tests in IEEE 344 standard are intended to simulate vibratory aging effects for conditions where plant operation is expected to proceed without requiring shutdown.

Recommend this section be revised to reflect that the OBE amplitude should be based on the applicable plant licensing requirements.

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IEEE-19 C.1.1.1j This section states The IEEE Std 344-2004 The statement is revised for clarification.

recommended no damping values." This is not correct The damping values used in analysis should as written. be in accordance with the damping values listed in Table 6 of NRC Regulatory Guide IEEE Std 344-2004, Clause 6 (Damping) provides 1.61, Revision 1, Damping Values for specific details regarding the application of damping. Seismic Design of Nuclear Power Plants, Sub-clause 6.3.1 (Application of damping in analysis) (Ref. 31) issued in March 2007, or as identifies Appropriate values of damping may be approved in the plant licensing basis..

obtained from tests or other Justifiable sources" Further Damping values other than those provided in clarifications are provided in subclauses 6.3.2 the plant licensing/design basis or RG 1.61 (Application of damping in testing) and 8.6.1.3 (Damping may be used, subjected to staff review and selection) to provide additional guidance on the approval, if documented test data supports damping to be used for testing. the higher values.

It should be noted that U.S. Regulatory Guide 1.61, which provides acceptable damping values for seismic analysis and design, also allows for higher damping values if test data is available to support.

Recommended this statement be reworded to say IEEE Std 344-2004 recommends appropriate values of damping for analysis may be obtained from tests or other justifiable sources" or deleted since it incorrectly states that IEEE Std 344-2004 does not recommend damping values.

IEEE-20 C.1.1.2a This section addresses the susceptibility of safety- The staff disagrees. The section addresses related equipment to low cycle fatigue. Low cycle not only the low cycle fatigue but also all the fatigue is the result of materials experiencing structural possible failure modes that will affect the damage when subjected to cyclic loading. Low cycle functionality of the equipment under OBE fatigue is related to structural integrity which can excitation. The guidance of using five OBE indirectly affect functionality. Low cycle fatigue and one SSE, or the equivalent, has been a susceptibility is a material property that can be screened consistence staff position for seismic out. Functionality is a separate issue and IEEE Std qualification of electric and mechanical 344-2004 requires a separate evaluation for it. Since components to meet the regulations in earthquakes impose repeated cyclic loadings on SSCs, Appendix A of 10 CFR Part 100 and Appendix the possibility of fatigue has been identified as a S of 10 CFR Part 50.

potential failure mechanism. The potential for such failure mechanisms is relatively small because Page 11 of 62

earthquakes create only a few cycles of strong motion and most materials are not susceptible to low-cycle fatigue (typically only brittle materials are susceptible to low-cycle fatigue). IEEE Std 344-2004 recognizes this situation in sub-clause 7.6 (OBE and SSE Analysis) where it limits the scope of what is necessary for analysis to only low-cycle fatigue-sensitive equipment:

The number of OBEs and the fatigue-inducing potential per OBE is important only for low-cycle fatigue-sensitive equipment."

However, DG-1175 does not take exception to the underlying premise for performing repeated OBE tests or analyses. Instead five OBEs are arbitrarily imposed, even though there are other ways to address this issue.

One other method for addressing the potential for low-cycle fatigue is to exclude use of experience data for low-cycle fatigue-sensitive equipment as required in IEEE Std 344-2004 subclauses 10.2.3.1 and 10.3.3.1.

Recommend this section be revised to remove discussion on low cycle fatigue.

IEEE-21 C.1.1.2c The capacity derived from earthquake experience data The staff reviewed the comment and revised is an average capacity from many samples. It is the statement to In-structure response appropriate to compare it to an "average" demand such spectra used as the RRS for the qualification as median-centered. It would also be overly of candidate equipment should be in conservative to require the RRS be developed using accordance with the licensing/design basis or normally conservative analytical approaches in RG the Standard Review Plan, (Ref 33), Section 1.122 and also implement the conservative assumption 3.7.2, as applicable. The use of RRS other of the ground motion for the experience data than those described in the licensing/design earthquakes to represent the capacity for th e class. In a basis should be submitted for NRC staff manner similar to modern code development there review and approval.

should be relative consistency in margin between all The proposition to use median centered in-approaches. Therefore, the use of conservatively structure response spectra within the context calculated demand (e.g., RG 1.122) is inappropriate. of equipment qualification license amendment would require the development of detailed Recommend this section be deleted. technical justification.

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IEEE-22 C.1.1.2d This staff position on the first paragraph of sub-clause The staff reviewed the comments and 10.3.2 imposes the requirement to divide the Test revised the statements. A factor of 1.4 Experience Spectrum (TES) by a factor of 1.4 and cites will not be imposed in the final version References 32 and 33 as the basis, The proposed of DG-1175. The statement is revised equipment capacity factor of 1.4 is not applied as a to The TES shall be the frequency-by-capacity reduction factor. Rather, it is applied as a frequency mean of the response demand increase factor; i.e., one increases the seismic spectra from successful tests without demand by 1.4 and compares to the capacity malfunction. When using test determined by test or test experience to demonstrate experience data, both the mean and adequate margin in order to meet a stated performance the standard deviation of the data goal. leading to the TES curve should be provided for review and approval. .

The IEEE 344 standard is intended for equipment qualification in a deterministic evaluation for meeting a The staff did not take any exception in Clause design requirement rather than in an evaluation for 8 (Testing) for this issue.

meeting a probability-based performance goal.

The specific staff position C.1.1.2.d.ii is IEEE 344 standard has never specified a numerical necessary because new reactors are licensed value of test margin. Instead it simply states that the with the elimination of OBE when the OBE is qualification specification should state what margin is 1/3 or less of the SSE, not 1/2 the SSE as required and refers to IEEE 323 standard, which indicated in subclause 10.3.2 currently has the suggested margin of 1.1. The RRS, including any required margin, is part of the qualification specification and any margin is controlled by documents external from IEEE 344 standard. In fact, in IEEE Std 344-2004 sub clause 10.3 (Test experience data) is consistent with clause 8 (testing) in that both require seismic demand (Required Response spectrum) to be based on conservative design response spectra rather than realistic median spectra as for Section 10.2 (earthquake experience data). This difference recognizes the relative levels of confidence for qualification by test or test experience and qualification by earthquake experience that was the intent in References 32 and 33.

The staff position relative to the second paragraph of sub-clause 10.3.2 does not recognize this section Page 13 of 62

requires the items in the reference equipment class must be tested with five OBE and one SSE, as per current staff guidance. This sub-clause was intended to define the requirement for when the development of an OBE test experience spectra TES is required.

Recommend this DG-1175 discussion be deleted and that References 32 and 33 not be cited.

IEEE-23 C.1.1.2e This section provides a restriction for test experience The use of 1/3 octave will miss the data that the tested equipment be so similar to each identification of the natural frequency of the other (1/6 octave) that it becomes a one to one similarity equipment and devices especially in the high-qualification process. The basis of the requirement of frequency range. Thus, the final version of 1/6 octave range for class definition natural frequency is DG-1175 was changed both here and very restrictive and not understood. If the plant's Sections 1.1.1 e and 1.2.1.f to clarify the licensing basis (especially older operating plants) would concern is in the high frequency range.

allow data analyzed at 1/3 octaves then such criteria This is considered to be a consistent position should also be acceptable for test experience data. with COL/DC-ISG-1, "Interim Staff Guidance on Seismic Issues Associated with High Recommend deleting this discussion. Frequency Ground Motion in Design Certification and Combined License Applications

IEEE-24 C.1.1.2g This section states that median-centered horizontal in- The staff has reviewed the comment and structure response spectrum as the RRS for the agreed that subclause 10.3.4 does not identify candidate equipment is not acceptable. The median- the method of developing the in-structure centered RRS are not used with Test Experience Data response spectrum to be used with Test and not referenced in sub-clause 10.3.4 of IEEE Std Experience Data. The staff has deleted this 344-2004. guidance in the final version of DG1175.

Recommend deleting this discussion.

IEEE-25 C.1.1.2k 1.0

SUMMARY

OF ISSUE The staff reviewed the written comments and The NRC in DG-1175 has recommended changes to the input from the public meeting. The staff has Coherence and Correlation limits on shake table testing deleted this guidance.

performance that are contained in IEEE Std 344-1987 and IEEE Std 344-2004 versions. The following sections address our technical issue with the position in DG-1175 Page 14 of 62

and provide the rational for why the values should not be changed. NRC comments on the following points are requested, as well as technical justification for the basis under which the NRC would recommend such reductions.

2.0 The current Coherence and Correlation limits have been used for over 20 years. This issue involves the performance of seismic shake tables with multiple degrees-of-freedom (DOF). In a biaxial table, for example the motion may be in the horizontal (X) direction and independently in the vertical (Z) direction.

For reasons discussed below it is desired that the motion in these two directions not be too similar. That is they must have limited Correlation or Coherence.

TECHNICAL BACKGROUND ON COHERENCE AND CORRELATION The Coherence function is a frequency dependent function describing the similarity of two signals on a frequency by frequency basis. By mathematical definition the Coherence function is real valued between 0.0 and 1.0. If two time histories, X and Y, have a Coherence Function of 1.0 for all frequencies of interest they are essentially identical and are totally coherent.

They are very similar. lf they have a Coherence function of 0.0 for all frequencies of interest then they are very different and independent from each other (they are not coherent at all). If, for example, they have Coherence in a particular frequency range around 0.5 then they are somewhat similar to each other in this frequency range (somewhat coherent). For reasons discussed below IEEE-344 standard has held that the perpendicular motions on a shake table should have Coherence equal or less than 0.5 at all frequencies of seismic interest.

(This typically means between 1 Hz and 33 Hz.)

The Correlation Factor of two signals is related to the Page 15 of 62

Coherence Function mathematically but is a single real valued number between -1.0 and +1.0. Generally the absolute value of the Correlation Factor is used and it runs between 0.0 and 1.0. Again signals with a Correlation factor of 0.0 are very different and those with a Correlation factor of 1.0 are essentially identical. For reasons discussed below IEEE Std 344-2004 holds that the Correlation Factor between perpendicular motions on a shake table must be equal to or less than 0.3.

IEEE Std 344-2004 specifies that either of these two above criteria must be met for the shake table test to be valid. That is: either the Coherence must be less than or equal to 0.5 at all frequencies of interest or the Correlation Factor need be less than 0.3. Both criteria need not be passed, just one or the other.

This test must be done between all pairs of perpendicular motions on the shake table. For a biaxial table this refers to the X and Z directions. For a triaxial table this refers to the X and Z, X and Y (where Y is the other horizontal direction), and Y and Z directions.

3.0 TECHNICAL BACKGROUND ON EARTHQUAKE SUGGESTED LIMITS These requirements on Coherence and Correlation came from ASME Paper 83,PVP-22, Suitability of Synthesized Waveforms for Seismic Qualifications" and others in the IEEE 344 WG. The concern leading to this work and suggested limits was that some early shake tables had certain inadequacies that could potentially lead to un-conservative testing. At the most extreme would be the attempt to present a Vector Biaxial table as a true Independent biaxial table. A Vector Biaxial table runs in a single direction (single axis, single DOF) but this axis is tilted with respects to the X and Z axes, for example. Hence such a table can produce both X and Z motion, but these two motions would be nearly Page 16 of 62

identical except for a scaling factor depending on the angle of tilt. In this case the XZ Coherence and Correlation would be nearly 1.0. Hence, the IEEE 344 standard limits would clearly invalidate calling such a table an independent triaxial table. (Note that IEEE 344 standard does allow the use of Vector Biaxial tables, but under limited conditions and with test level penalties that do not apply to Independent Biaxial tables.)

A second and more subtle concern was that the dynamic stiffness or control system of an independent biaxial (or triaxial) table was insufficient and allowed either table resonances or test item resonance feedback to significantly distort the test motions. This could also occur if the artificial time histories generated to drive the table were inadequately prepared. If this was the case then it was possible that, in a certain frequency range, the X and Y motions could be independent but in the region near the resonances they would be dependent (similar). One can postulate certain cases for certain structures, where such similarity could cause an under test. That is the Test Response Spectra (TRS) measured on the table would, in both directions meet or exceed the Required Response Spectra (RRS), but that certain modes of test object vibration would not be sufficiently excited.

Hence, the IEEE-344 WG felt that there must be some limitation on the amount of similarity allowed in a valid test. To answer what kind of limitation the ASME Paper 83-PVP-22 studied the actual correlation between several measured earthquake ground motions.

It evaluated the Coherence Function and correlation Factor as these actual earthquakes, and concluded that actual earthquakes do in fact have some non zero values of these factors. The ASME Paper 83-PVP-22 then argued, and the committee and technical community at large eventually accepted, that the Page 17 of 62

restrictions placed on shake tables should be similar to the values found in these actual earthquakes. Review of the actual earthquake data suggested that the value of 0.5 for Coherence and 0.3 for Correlation were reasonable. Hence these factors are based on study of actual earthquake ground motion properties. The values of 0.5/0.3 are slightly rounded up averages of the actual earthquake motions in ASME Paper 83-PVP-22. These numbers and concepts are presented in Annex E of IEEE Std 344-2004 and earlier version.

The recent NRC recommendations suggest that these limits should be reduced from 0.30 for Correlation Factor. In addition the NRC recommends a Coherence function between 0.0 and 0.3 with an average of 0.2.

This reduced from the current IEEE Std 344-2004 requirement of 0.5.

4.0 FIRST REASON FOR NOR REDUCING THESE LIMITS As these limits reflect actual earthquake behavior, reducing the shake table limits further appears unfounded. Reducing these limits would, in a sense, make the shake table tests less "earthquake-like not more. No reason has been presented why further reduction of the limits is needed, or why this would lead to a more conservative test. It is unlikely that this reduction would provide any significant increase in conservatism or quality of test.

5.0 IN-STRUCTURE SPECTRA - THE SECOND REASON FOR NOT REDUCING LIMITS The ASME Paper 83-PVP.22 study used actual ground motion data. Most equipment is tested to RRS computed in structures. The intervening structure often has resonances that significantly increase the energy content in a selected frequency bands. Further they often do so in all directions. Hence we are often faced Page 18 of 62

with RRS that have strong energy peaks at the same narrow frequency bands in both X and Y directions.

These concentrated energy peaks correspond to time signals that are not quite sinusoidal and not fully random. Two sinusoidal or nearly sinusoidal signals at the same or nearly the same frequency are highly correlated. The signals required to match such RRS are, by their fundamental mathematical nature, more highly correlated than the more random ground motions. This phenomenon was recognized in ASME Paper 83-PVP-22.

Hence, it becomes difficult, and in some cases, mathematically impossible to simultaneously match such peak RRS and also satisfy low Coherence/Correlation criteria. This is not the result of poor shake table performance. It is the mathematical result of how we process and generate RRS in the nuclear power industry. This issue has plagued IEEE 344 standard shake table testing for years and often made test validation very difficult if not impossible. A further and arbitrary (in our opinion) reduction in Coherence/Correlation limits would only exacerbate this issue to the point of rendering shake table testing impossible. This would be an unfortunate move as in fact the motions found in higher levels of a structure are, in real earthquake, more, not less correlated. Regulation should direct us to use more realistic earthquake motions, not less realistic or mathematically impossible ones.

6.0 ROTATED MOTIONS - THE THIRD REASON FOR NOT REDUCING LIMITS Consider a shake table in which the X and Y perpendicular motions have in fact, somehow, have been generated to have 0.0 Coherence and Correlation.

Now consider the motion on this same table at the same Page 19 of 62

time in a set of coordinate's rotated 45 degrees to the X and Y axes. That is, consider two new motions A and B:

A = (X + Y) / SQRT(2)

B = (X - Y) / SQRT (2)

What are the Correlations and Coherence of A and B, which are perpendicular to each other? Assuming X and Y (and hence A and B) are of approximately the same energy level as is typically the case, then the Correlation factor of A and B will be approximately 0.5.

Hence when we contemplate trying to reduce the Correlation of shake table motions to near zero in the traditional X and Y axes, we need to remember that even if this task is achievable, the Correlation in a rotated set of axes on the same table will be significantly correlated.

Since equipment placement, structural orientation, and direction of earthquakes are somewhat random, there is nothing sacred about the transitional X and Y axes. So in reality, for both real earthquakes and real shake table tests, the motions imparted into the test structure in fact will have and must be somewhat Correlated under some set of axes. This is true even if under a different set of axes the motion is highly uncorrelated.

Therefore, we believe it is unreasonable to focus on extreme correlation limits in any one, arbitrary, set of axes.

7.0 PRACTICAL ISSUES - THE FOURTH REASON FOR NOT REDUCING LIMITS Hence real earthquakes are correlated and in-structure earthquakes are even more correlated than we are requiring of our shake tables.

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Shake table construction and control has been evolving over the years. There are shake tables today that could, with some difficulty, provide lower correlated motions, as long as the limit of mathematical possibility is not crossed. However, there are a number of older shake tables that may not be able to provide lower correlation limits. It would be unfortunate to exclude these tables from performing valuable seismic testing for the nuclear industry based on an unsubstantiated limit reduction.

8.0 ADDITIONAL

SUMMARY

POINTS AND REFERENCES RELATED TO THESE LIMITS The NRC staff seeks to imposes, in DG-1175, more stringent limits in IEEE Std 344- 2004 Annex E. This suggested limitation and modification of the consensus standard is not consistent with the following sound technical bases identified by the IEEE 344 WG that developed IEEE 344-2004.

a. The coherence function and the cross correlation coefficient were originally developed in ASME Paper 83-PVP-22 based on his review of several actual earthquakes. Some of actual earthquakes had factors higher than 0.5/0.3. The recommendation (0.5/0.3) is slightly higher than the average of the actual earthquake results and represents real data.

b. The earthquakes in ASME Paper 83-PVP-22 were for free field ground motions. They were not for motions in buildings. ASME Paper 83-PVP-22 noted that ground motions after entering buildings were likely to be more (not less) correlated, due to the multi-directional contribution of many structural modes of vibration.

Therefore, it is reasonable to expect that motions on upper floors of a structure will be more, not less, correlated than 0.5/0.3.

c. It is unrealistic and nearly impossible to have two real Page 21 of 62

narrow band floor spectra to be less correlated than 0.5/0.3. Requiring motions to have less correlation is unrealistic and mathematically approaching unrealizable

d. We have not identified any studies that suggest that a correlation less than 0.5/0.3 results in a significantly more severe test. With current seismic shake tables it will be very difficult, if not impossible, to achieve significantly less than 0.5/0.3. This is caused by a combination of table design/control limitations and the difficulties mathematically in achieving the task.

Lowering the 0.5/0.3 criteria would reduce the current seismic test capacity and not achieve any better results.

e. The commenter cites regulatory Guide 1.92 revision 1 as providing the NRC staff's position related to the unacceptable nature of using a coherence function of less than 0.5 and cross correlation coefficient of 0.3."

Regulatory Guide 1.92, Revision 1 Combining Modal responses and Spatial Components in Seismic Response Analysis states In footnote 2 that when using the Time-History Analysis Method, the earthquake motions specified in the three different directions should be statistically independent. For a discussion of statistical independence, see Reference 6." The reference referred to is a paper in the February 1975 edition of the Journal of the Structural Division, ASCE titled Definition of Statistically Independent Time Histories." Regulator Guide 1.92 Revision 1 itself does not establish a limiting value for coherence or cross correlation. ASCE standard 4-98 on seismic analysis of safety-related nuclear structures has the following requirement in Section 2.3 on time history input to structures:

When responses from three components of motion are calculated simultaneously on a time history basis, the input motions in the three orthogonal directions shall be Page 22 of 62

statistically independent and the time histories shall be different. Shifting the starting time of a single time history shall not constitute the establishment of a different time history. Two time histories shall be considered statistician independent if the absolute value of the correlation coefficients does not exceed 0.3.

ASCE standard is an industry consensus standard for seismic analysis of safety- related nuclear structures and is in agreement with the intent of information provided in IEEE Std 344-2004 Annex E.

IEEE-26 C.1.2.1d In subsection (1) of C.1.2.1d the word "credibility" is See IEEE-11 used. This word may imply a negative bias and is not suggested for use in a regulatory position document.

The following is recommended: 1) The wording "the credibility and be removed. The remaining wording is sufficient. Or 2) Change to the following: (1) seismic experience data for its completeness and the information that would be generated in the process of establishing evidence of qualification.

IEEE-27 C.1.2.1e This subsection as written seems to impose new See IEEE-15 requirements practice of seismic testing selected items to qualify a family of similar items in accordance with QR-A7200 (Qualification by Testing, note that ASME QME has a typographical error and QR-A7200 is mislabeling Qualification by Analysis) of ASME QME 2007.If so, this is a change from traditional seismic qualification methods on the common used in the past.

It is recommended that the statement be further clarified to better define the intent of this subsection and the relationship to similarity method defined in QR-A7300 (Qualification by Similarity) of ASME QME-1-2007 or be deleted. This section should continue to allow the Page 23 of 62

industry to qualify similar equipment without requiring prior NRC approval.

IEEE-28 C.1.2.1f Seismic qualification of equipment should be deformed See IEEE-16 over the frequency range of interest. DG-1175 wording does not allow a limit lower than 33 Hz to be performed but mandates a higher cutoff is required by the RRS of a specific plant. There may be instances where a lower cut-off would be allowed by a site specific RRS and therefore should be allowed. That is why the ASME QME standard uses the following wordings ...over the frequency range of interest (typically, 1 Hz to 33 Hz).

The ASME QME-1-2007 wording is appropriate. It is recommended that this statement be reworded or deleted.

IEEE-29 C.1.2.1g This section excludes the use of previous testing to See IEEE-17.

address high frequency concerns because the high frequency motions were not intentionally input to the test. An assessment of the sufficiency of the input waveform should be conducted on the basis of a measurement as defined in ASME QME-1-2007 QR-A7232 or IEEE 344- 2004 Annex B. That will determine whether the component has adequately challenged in all frequency ranges. The origins of the energy input to the test (ball joints and kinematic linkages) are immaterial.

DG-1175 does not consider the unintentional vibration due to test table mechanical characteristics to be adequate to meet this requirement even if the ASME QME-1-2007 QR-A7232 or IEEE 344-2004 Annex B frequency content and stationarity requirements are met. The current requirements to demonstrate frequency content and stationarity over the amplified portion of the RRS are adequate, regardless of whether Page 24 of 62

the test table vibrations are intentional, unintentional, or a combination of the two.

Recommend this section be revised to require the high frequency motions to be evaluated in accordance with ASME QME-1-2007 QR-A7232 or IEEE Std 344-2004 Annex B.

IEEE-30 C.1.2.1j The statement Active mechanical equipment should be The statement is revised for clarification. For qualified with five one-half SSE events followed by one NPPs that were licensed with the elimination full SSE event (SECY-93-087) even if the OBE of a of the OBE, active mechanical equipment plant is defined to be one-third of SSE or less, should should be qualified with five one-half SSE be deleted since the statement as-is creates a situation events followed by one full SSE event or, where currently acceptable testing may be rendered alternatively, a number of fractional peak unacceptable. The DG-1175 position does not cycles equivalent to the maximum peak recognize that some plants are licensed with an OBE cycles for five one-half SSE events in that is greater or less than one-half the SSE. The plant accordance with Annex D of IEEE 344-2004 licensing basis should define whether the OBE is one- when followed by one full SSE (SECY third or one-half of the SSE, or has no relationship to the 087) even if the OBE of a plant is defined to SSE. be one-third of SSE or less. For other reactors, the staff will review the seismic The SECY-93-087 document specifically addressed qualification based on the OBE level in Light-Water Reactors (ALWRS), for which the OBE was accordance with the licensing basis.

eliminated as a design case by making it one-third of SSE or less. The five one-half SSEs provision in SECY-93087 is intended for ALWR applications. It is also noted that the DG-1175 phrase ...even if the OBE of a plant is defined to be one-third of SSE or less is not in SECY-93-087.

The OBE tests in IEEE 344 standard are intended to simulate vibratory aging effects for conditions where plant operation is expected to proceed without requiring shutdown.

Recommend this section be revised to reflect that the OBE amplitude should be based on the applicable plant licensing requirements.

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IEEE-31 C.1.2.2a The specified damping values in a plant licensing basis The statement is revised for clarification.

may be higher or lower than those specified in table QR- The damping values used in analysis should A6210-1 or Regulatory Guide 1.61, Revision 1. be in accordance with the damping values listed in Table 6 of NRC Regulatory Guide This subsection should be revised to note that the 1.61, Revision 1, Damping Values for specified damping values should be in accordance with Seismic Design of Nuclear Power Plants, the plant licensing basis or otherwise determined from (Ref. 31) issued in March 2007, or as testing. approved in the plant licensing basis.

Damping values other than those provided in the plant licensing/design basis or RG 1.61 may be used, subjected to staff review and approval, if documented test data supports the higher values.

IEEE-32 C.1.2.2b Since the Earthquake Experience Spectrum (EES) is The staff disagrees. For piping design, the based on free field ground motions, and ignores in- piping system could be relatively flexible to structure and in-line amplification at the earthquake site, account for thermal expansion. Due to the it is reasonable and conservative to use the demand flexibility, the amplification of the seismic spectra at the distribution system support location. motion at the equipment location could be Further complications of accounting for in-line very significant depending on the location of amplification of the earthquake site facility and the the active equipment.

nuclear facility add unnecessary complexity to the qualification.

In addition, the nature of the in-line mechanical equipment being discussed is that these equipment classes have adequate variety within the class (supports, frequencies, configurations, etc.) to establish that the in-line amplification is already accounted for within the class.

This criterion is adequately addressed in ASME QME 2007, and no additional restrictions are required.

Therefore, this subsection should be deleted.

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IEEE-33 C.1.2.2d ASME QME Section QR-A7421 already requires items See IEEE-20.

susceptible to low cycle fatigue failures be evaluated in accordance with QR-A6800, Fatigue and Aging Considerations. The OBE evaluation is performed to consider aging, and it is not required to demonstrate functionality during the OBE.

This criterion is adequately addressed in ASME QME 2007, and no additional restrictions are required.

Therefore, this subsection should be deleted.

IEEE-34 C.1.2.2h The capacity derived from earthquake experience many See IEEE-21 samples. It is appropriate to compare it to an average demand such as median-centered. It would also be overly consecutive to require the RRS be developed using normally conservative analytical approaches in RG 1.122 and also implement the conservative assumption of the ground motion for the experience data earthquakes to represent the capacity for the class.

In a manner similar to modern code development there should be relative consistency in margin between all approaches. Therefore, the use of conservatively calculated demand (e.g., RG.1.122) is inappropriate.

This criterion is appropriately addressed in ASME QME-1-2007 and no additional restrictions are required.

Therefore, this subsection should be deleted.

IEEE-35 C.2 This entire section seems out of place in a seismic See IEEE-10 qualification document. This material addresses functional qualification and may be a better fit in Regulator Guide (RG) 1.148, Functional Specification for Active Valve Assemblies in Systems Important to safety in Nuclear Power Plants. RG 1.148 also discusses functional specification of active valves and primarily endorses ANSI N278.1-1975. Although the ANSI standard by itself does not provided complete Page 27 of 62

assurance of operability, there is an overlap between DG-1175 and RG 1.148 for functional qualification of active valves.

Recommend that functional qualification of active mechanical components (which have no direct bearing on seismic qualification) should be discussed in a revision to RG 1.148 and the RG 1.100 should only provide guidance for seismic qualification of electric and mechanical equipment. Therefore, Section 2.

(Functional Qualification of Active Mechanical Equipment) and the title for this document should revert back to Seismic Qualification of Electrical and Mechanical Equipment for Nuclear power Plants.

NEI-1 General The draft RG title and scope have been changed to See IEEE-10 include functional qualification of active mechanical equipment, as compared to the two previous revisions of RG 1.100 which only discussed seismic qualification of electrical and mechanical equipment. This change is because the RG now endorses ASME QME-1-1994, which covers functional qualification of active mechanical equipment. The main discussion on pages 5 through 8 of the DG is for active, motor-operated valves.

It is noted that RG 1.148 also discusses functional specification of active valves and primarily endorses ANSI N278.1-1975. Although the ANSI standard by itself does not provided complete assurance of operability, there is an overlap between DG-1175 and RG 1.148 for functional qualification of active valves. It is recommended that functional qualification of active mechanical components (which have no direct bearing on seismic qualification) should be discussed in a revision to RG 1.148. RG 1.100 should focus solely on guidance for seismic qualification of electric and mechanical equipment.

Remove functional qualification of active mechanical equipment from this DG (address in RG 1.148) such Page 28 of 62

that RG 1.100 focuses solely on guidance for seismic qualification of electric and mechanical equipment. If this is not done, reconcile the overlap between DG-1175 and RG 1.148 in another manner.

NEI-2 Page 4, In the SERs that NRC sent to the USI A-46 plants in the The staff has reviewed the comment. The (4th para past, it was stated that older vintage plants could use statement in B.1 indicated that the use of from top- the experience-based SQUG-GIP method for seismic experience data was feasible for the purpose Large) verification of new and replacement equipment provided of verifying equipment seismic adequacy for they revised their licensing bases. Many older plants are the older vintage USI A-46 plants. For C.1.1.1 b currently using the SQUG-GIP method. The DG is silent clarification, the staff added The staff does on this. not accept the use of SQUG guidelines for C.1.1.2b,c seismic qualification of equipment in non USI Add a sentence at the end of this paragraph to this A-46 plants licensed under 10 CFR Part 50 or effect: However, older vintage plants can, with a few in plants licensed under 10 CFR Part 52.

exceptions, use the experience-based SQUG-GIP method for seismic verification of new and replacement equipment provided they revise their licensing bases via safety evaluations. Alternatively, reconcile the fact in the DG that NRC has previously accepted earthquake experience-based qualification of new/replacement equipment in older plants.

NEI-3 B.1 The middle of the 5th paragraph in Section B.1 says See IEEE-13 Some solid-state relays and microprocessor-based components are quite fragile in terms of withstanding earthquake excitations.

This is specifically counter to testing experience and counter to the experience of the April 8 IEEE SC2 meeting attendees who were not aware of any experience showing solid-state relays and microprocessor-based components to be particularly vulnerable to earthquake motions.

This sentence should be deleted as well as the following sentence based on this conclusion.

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NEI-4 B.1 The end of the 5th paragraph in Section B.1 says Third, See IEEE-3.

since no new NPPs were built after the early 1980s, a number of manufacturers for electric or active mechanical equipment are no longer in business, and the appropriateness of using the test experience of old equipment made by manufacturers no longer in business for the seismic qualification of modern equipment designs made by different manufacturers is highly questionable.

This specific concern is addressed in IEEE 344 Section 10.3.4h and ASME QR-A7432(a); therefore, this concern is not valid for items qualified in accordance with the two standards.

This sentence should be deleted.

NEI-5 B.1 The high frequency content, which exists in most See IEEE-5 and IEEE -17 C.1.1.1g existing tests, whether inadvertent or deliberate, will still C.1.2.1g be imparted to an item on equipment on the shake table. Therefore, high frequency vibratory motions generated on a shake table in an inadvertent manner can be of significance. The DG should clarify that such inadvertent motions can be credited provided they are shown to meet stationarity requirements per Appendix B of IEEE Std 344-1987 or 2004 (when one of these versions of the IEEE Standard is the plants commitment). However, in IEEE Std 344-1975, there was no requirement for stationarity check. For example, previous seismic shake tests for BWR Mark II and III plants (committed to the 1975 version of the standard) were frequently utilized to qualify equipment for the combined seismic and hydrodynamic loads with high frequency content up to 100 Hz and were accepted by the NRC staff in SQRT audits.

Revise to require the high frequency motions to be evaluated in accordance with QR-A7232 or IEEE 344 Annex B, Frequency Content and Stationarity.

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NEI-6 B.1 In the last sentence of this paragraph, it says that the See IEEE-18 and IEEE-30 C.1.1.1i test sample shall be subjected to simulated OBE and C.1.2.1j SSE vibrations. per IEEE Std. 344-2004. In section C.1.1.1i (p. 10) two alternatives for the number of tests/cyclic considerations are provided. However, another alternative when OBE is defined as 1/3 or less of SSE is to use two SSE events (with 10 maximum stress cycles per event) in accordance with SRP 3.7.3 (p. 4), March 2007. The SRP considers this alternative to be equivalent to the cyclic load basis of one SSE and five OBEs. This alternative can save testing duration and should also be listed.

Revise these sections to include an option that 2 SSE tests, as an alternative to 5 OBE and 1 SSE are also acceptable when the OBE is designated as 1/3 or less of the SSE.

NEI-7 C.1.1.1c This paragraph repeats the inappropriate conclusion See IEEE-13 that solid-state relays and microprocessor-based components are fragile and suggests that test-based experience performed in accordance with IEEE 344 requirements (per Section 10.3) does not adequately qualify chatter sensitive equipment. Both of these comments are incorrect.

These sentences should be deleted NEI-8 C.1.1.1d This paragraph as written seems to impose new See IEEE-15 requirements on the common practice of testing selected items to qualify a family of similar items in accordance with IEEE 344 Section 8.

This section should be deleted or rewritten.

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NEI-9 C.1.1.1f, This section states: The NRC staff does not generally See IEEE-16 C.1.2.1f find it acceptable to restrict the frequency range of testing up to 33 Hz. The frequency range should be continued beyond 33 Hz, in accordance with the RRS of a specific plant.

This last sentence could be reworded to provide more clarity.

Reword second sentence to read as follows: For RRS with ZPA frequency in excess of 33 Hz, the frequency range of testing should be accordingly extended to match the RRS.

NEI-10 C.1.1.1i This section requires that the OBE amplitude be set to See IEEE-18 1/2 the SSE, even if the plant license OBE is 1/3 of the SSE.

The OBE qualification level should be based on the plant license.

NEI-11 C.1.1.1j The IEEE Std. 344-2004 has a section on damping. See IEEE-19 While the damping values in RG 1.61 can be used when qualification is by analysis, there should be no specific requirement on damping values to be used for shake-testing, only that the equipment damping at which the RRS is developed should be the same or lower than the TRS damping value. This is not mentioned.

Clarify the statement in this section that for qualification by shake-table testing, RRS with any reasonable damping value (such as 5% of critical damping) can be used provided that the TRS is also plotted at the same damping value or a higher damping value.

NEI-12 C.1.1.2a IEEE 344 Sections 10.2.3.1 and 10.3.3.1 provide See IEEE-20 specific criteria for addressing low-cycle loads. Five OBE tests, or actual earthquakes at the same site, are not the only permitted methods to evaluating low-cycle loads. The standard as written properly imposes those requirements on the qualification.

Page 32 of 62

The section should be deleted.

NEI-13 C.1.1.2c The capacity spectra are based on a weighted average See IEEE-21 of the ground motions, neglecting the in-structure amplification from the experience sites. Therefore, the use of median centered demand spectra results in a conservative capacity/demand comparison.

The section should be deleted.

NEI-14 C.1.1.2d Application of the concepts in References 32 and 33 See IEEE-22 would dramatically revise current qualification practices.

For example, the 1.4 factor would have to be applied to every test qualification performed in accordance with IEEE 344 Section 8. The mixing and mismatching of these criteria between the goals of IEEE 344 and References 32 and 33 would need careful consideration and would need to be consistently applied throughout the qualification standard.

The criteria in References 32 and 33 need to be deleted from this Section or applied consistently throughout IEEE 344. Without substantial further study, it is recommended that the concepts in references 32 and 33 not be incorporated.

NEI-15 C.1.1.2g This section says that you can not use median centered See IEEE-24 demand spectra for comparison with the TES. IEEE 344 10.3.4b already requires the use of computed in-structure spectra for the demand as opposed to 10.2.4b which specifies median-centered spectra for comparison with the EES).

The section should be deleted.

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NEI-16 C.1.1.2k This section requires changing the coherence criteria to See IEEE-25 lower values. This was discussed in the IEEE 344 Working Group and rejected on sound technical bases as follows:

The Working Group believes the criteria established in Annex E are acceptable. Our reasons for objecting to the suggested change are noted below:

1. The coherence function and cross correlation coefficient were originally developed by Kana based on his review of several actual earthquakes. Some of the actual earthquakes had factors higher than 0.5/0.3. The recommendation (0.5/0.3) is slightly higher than the average of the actual earthquake results and represents real data.

2. The earthquakes that Kana used were for free-field ground motions. They were not for motions in buildings.

Kana noted that ground motions after entering buildings were likely to be more (not less) correlated, due to the multi-directional contribution of many structural modes of vibration. Therefore, it is reasonable to expect that motions on upper floors of a structure will be more, not less, correlated than 0.5/0.3.

3. It is unrealistic and nearly impossible to have two real narrow band floor spectra to be less correlated than 0.5/0.3. Requiring motions to have less correlation is unrealistic and mathematically approaching unrealizable.

4. We have not identified any studies that suggest that a correlation less than 0.5/0.3 results in a significantly more severe test. With current seismic shake tables it will be very difficult, if not impossible, to achieve significantly less than 0.5/0.3. This is caused by a combination of table design/control limitations and the difficulties mathematically in achieving the task.

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Lowering the 0.5/0.3 criteria would reduce the current seismic test capacity and not achieve any better results.

5. The commenter cites Regulatory Guide 1.92 Revision 1 as providing the NRC staffs position related to the unacceptable nature of using a coherence function of less than 0.5 and cross correlation coefficient of 0.3.

Regulatory Guide 1.92, Revision 1 Combining Modal Responses and Spatial Components in Seismic Response Analysis states in footnote 2 that when using the Time-History Analysis Method, the earthquake motions specified in the three different directions should be statistically independent. For a discussion of statistical independence, see Reference 6. The reference referred to is a paper in the February 1975 edition of the Journal of the Structural Division, ASCE, titled Definition of Statistically Independent Time Histories. Regulatory Guide 1.92 Revision 1 itself does not establish a limiting value for coherence or cross correlation. ASCE standard 4-98 on seismic analysis of safety-related nuclear structures has the following requirement in Section 2.3 on time history input to structures:

When responses from three components of motion are calculated simultaneously on a time history basis, the input motions in the three orthogonal directions shall be statistically independent and the time histories shall be different. Shifting the starting time of a single time history shall not constitute the establishment of a different time history. Two time histories shall be considered statistically independent if the absolute value of the correlation coefficient does not exceed 0.3.

The ASCE standard is an industry consensus standard for seismic analysis of safety-related nuclear structures and is in agreement with the intent of information provided in IEEE 344 Annex E.

6. The commenter goes on to state that the NRC staffs Page 35 of 62

position on the numerical values for the cross correlation coefficient and the coherence function for defining statistically independent motions are also reflected in Section N-1213.1 of Appendix N of the ASME Section III Code. N-1213.1 states that:

The peak acceleration of the three orthogonal synthetic time histories generally need not occur at the same time. In order to simulate natural earthquake occurrences, the correlation of the synthesized time histories may be evaluated by calculating the cross correlation coefficients and the coherence functions.

The artificially generated time histories are acceptable if both their cross correlation coefficients and their coherence functions are approximately equal to the respective functions for past earthquake records. An absolute value of the correlation coefficient less than 0.16 is acceptable. For the coherence function the numerical values ranging between 0.0 and 0.3 with an average of approximately 0.2 are acceptable.

Note that this section of the appendix does not prohibit use of coefficients higher than 0.16 or 0.3 and focuses on the goal to have synthetic time histories that are representative of past earthquakes. The current version of IEEE 344 (to which the NRC did not object in Regulatory Guide 1.100) was based on the study of actual earthquakes.

NEI-17 C.1.2.1d This section discusses similarity between the The staff reviewed the comments and excitation documented in the experience database and acknowledged IEEE 344-2004 provided the required seismic excitation. The term similarity is guidance on this issue. The discussion has too strong as the only spectrum comparison been deleted in the final version of DG1175.

requirement should be that the RRS be enveloped by the test spectrum used in the experience database.

Suggest deleting the last part of the last sentence that starts with as well as similarity between. Add a sentence to read as follows: Additionally, the test response spectrum documented in the experience database shall exceed the RRS.

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NEI-18 C.1.2.1e This paragraph as written seems to impose new See IEEE-15 requirements on the common practice of testing selected items to qualify a family of similar items (e.g.

valve actuators) in accordance with ASME QME QR-A7200.

This section should deleted or rewritten.

NEI-19 C.1.2.1j This section requires that the OBE amplitude be set to See IEEE-18 1/2 the SSE, even if the plant license OBE is 1/3 of the SSE.

The OBE qualification level should be based on the plant license.

NEI-20 C.1.2.2b Since the EES is based on free field ground motions, See IEEE-32 and ignores in-structure and in-line amplification at the earthquake site, it is reasonable and conservative to use the demand spectra at the distribution system support location. Further complications of accounting for in-line amplification of the earthquake site facility and the nuclear facility add unnecessary complexity to the qualification.

This section should be deleted.

NEI-21 C.1.2.2d QME Section QR-A7421 already requires items See IEEE-33 susceptible to low cycle fatigue failures be evaluated in accordance with QR-A6800, Fatigue and Aging Considerations.

This section should be deleted.

NEI-22 C.1.2.2h The capacity spectra are based on a weighted average See IEEE-21 of the ground motions, neglecting the in-structure amplification from the experience sites. Therefore, the use of median centered demand spectra results in a conservative capacity/demand.

This section should be deleted.

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NUGEQ- B.1, Do Not Impose OBE/SSE Testing for Equipment Also For section B.1 paragraph 6, the statement 1 C.1.2.1i Exposed to Harsh Environments The NRC staff has two other concerns as well in accordance with IEEE Std 344-B.1. Seismic Qualification of Electric and Active 2004 has been deleted in the final version of Mechanical Equipment (page 5): DG-1175.

The NRC staff has a concern regarding electric and active mechanical equipment exposed to harsh For C.1.2.1i, The staff reviewed the environments, aging, and earthquakes. In such cases, comments and agreed that the use of the NRC staff does not find it acceptable to use experience-based methods for equipment experience data (earthquake or test experience data) for exposed to harsh environment, or aging are seismic qualification of equipment. The test sample shall limited as indicated in Limitations of IEEE Std be subjected to simulated operating-basis earthquake 344-2004 Clause 10.4.2 (f) and ASME QME-(OBE) and SSE seismic vibrations in accordance with 1-2007 Section QR-A7432 (e). This guidance IEEE Std 344-2004. has been deleted in the final version of DG-1.2.1 General NRC Staff Positions - i (page 13): 1175.

For active mechanical equipment exposed to harsh environments, aging, and earthquakes, the staff does not find it acceptable to use experience data (earthquake or test experience data) for seismic qualification of equipment. The test sample shall be subjected to simulated OBE and SSE seismic vibrations in accordance with IEEE Std 344-2004.

NUGEQ Comment: The NRC fails to articulate the technical basis for its concern regarding the use of seismic experience data for equipment also exposed to harsh environments and aging. Importantly, the design basis for US plants does not postulate concurrent or sequential seismic and LOCA or HELB events.

Consequently, the design basis of these plants does not require that equipment function after an SSE and then a LOCA (or visa versa). The NRC concurred with this fact in prior Regulatory Guide 1.89 comment resolutions but indicated a preference for using the same test sample for both seismic and environmental qualification as a conservative practice.

The IEEE acknowledged this fact and reaffirmed the NRC perspectives in IEEE 323-2003 which states:

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NOTEA seismic event is not assumed to occur in conjunction with a loss-of-coolant accident. Rather, the sequence described previously has been developed as the basis of a conservative qualification, not one indicative of a sequence of expected plant events.

(IEEE 323-2003 page 10)

DG-1175 takes a stated NRC preference for electrical equipment qualification and transforms it into an expectation for mechanical equipment without providing any supportable technical basis. The NRC should provide a coherent basis for its concern that warrants establishing this "required" regulatory position. The NUGEQ notes that not all mechanical equipment will be qualified using either experience or OBE/SSE testing. A significant amount of mechanical equipment will be seismically qualified using stress analysis combined with limited but supporting stress tests. The DG-1175 position is silent on the use of such analysis but implies that such analysis is not acceptable since it would direct qualification based on subjecting a test sample to simulated OBE and SSE seismic vibrations in accordance with IEEE 344-2004.

Finally, the staff is unclear regarding the significance of aging to this position. Virtually all installed active equipment experience some form of in-service aging.

Only significant aging mechanisms need to be considered as part of qualification. If the aging is not significant does the stated position permit the use of experience data for equipment whose design basis includes seismic events and harsh environment accidents?

NUGEQ Recommendation: Delete the Background and Regulatory Position text which dictates the use of seismic testing to establish seismic qualification for all active mechanical equipment exposed to harsh Page 39 of 62

environments, aging, and earthquakes. Alternatively, the NRC may indicate its preference for the use of OBE and SSE testing for this equipment in lieu of experience data. If the NRC states such a preference then it should also make clear that analysis remains a valid method to seismically qualify such equipment.

NUGEQ- B Regulatory Guide 1.100 Scope - Limit to The NRC staff plans to withdraw Regulatory 2 Seismic/Dynamic Qualification Guide (RG) 1.148 after this revision to RG 1.100 is finalized. RG 1.148 also discusses B Discussion Background (page 1): functional specification of active valves and The NRC developed this regulatory guide (i.e., primarily endorses ANSI N278.1-1975. In the Revision 3) to endorse, with exceptions and Foreword of ASME QME-1-2007, it was clarifications, the IEEE Std 344-2004 and the ASME explained that the ANSI N45 Committees QME-1-2007. (This is the first time the NRC is valve task force (N278) was reassigned to the endorsing ASME QME-1). . . . Sections B.2 and C.2 of ASME QME in 1982 and designated the this regulatory guide endorse, with exceptions and Subcommittee on Qualification of Valve clarifications, Section QR and the remaining sections of Assemblies. In addition, ANSI N278.1 has not ASME QME-1-2007 (except Nonmandatory Appendix been updated since 1975 and the staff QR-A) for the functional qualification of active believes that there is no need to revise mechanical equipment. RG1.148. Endorsing the ASME QME-1-2007, which incorporated all the lesson-learned and NUGEQ Comment: The scope of this proposed revision operating experience of active mechanical to Regulatory Guide 1.100 should be consistent with equipment, for functional qualification is prior versions and should be limited to seismic appropriate and prudent.

qualification of mechanical and electrical equipment.

The functional qualification provisions of QME-1 should be addressed in separate regulatory guidance, either the Standard Review Plan or a separate regulatory guide, or both. A revision to SRP 3.9.6 Functional Design, Qualification, and Inservice Testing Programs for Pumps, Valves, and Dynamic Restraints and Regulatory Guide 1.48 Functional Specification for Active Valve Assemblies in Systems Important to Safety in Nuclear Power Plants may be the most appropriate methods of addressing the functional qualification provisions of QME-1.

Page 40 of 62

NUGEQ Recommendation: Limit the scope of RG 1.100 to IEEE 344-2004 and the seismic and dynamic provisions of QME-1 and delete DG-1175 Sections B.2 and C.2. Issue guidance on the functional qualification of active mechanical equipment in separate guidance documents, possibly in SRP 3.9.6 and Regulatory Guide 1.48.

NUGEQ- General Regulatory Analysis Fails to Evaluate Differences in Contrary to the NUGEQ comment, there are 3 DG-1175 and SRP 3.9.6 no significant differences between the functional qualification provisions of ASME Regulatory Analysis 3. Alternatives Approaches: (page Standard QME-1-2007 and the March 2007

19) revision of Standard Review Plan (SRP)

The NRC staff considered the following alternative Section 3.9.6, Functional Design, approaches: Qualification, and Inservice Testing Programs

• Do not revise Regulatory Guide 1.100. for Pumps, Valves, and Dynamic Restraints.

• Update Regulatory Guide 1.100. Both QME-1 and SRP Section 3.9.6 were revised in response to lessons learned from NUGEQ Comment: The NRC has failed to consider the valve performance experience at current significant differences between the functional operating nuclear power plants, and through qualification provisions of QME-1 as modified by DG- NRC and industry research programs.

1175 and the recently issued NRC guidance in the Section B.2 in Draft Guide DG-1175 March 2007 revision of SRP 3.9.6 Functional Design, discusses the valve performance experience Qualification, and Inservice Testing Programs for that resulted in the preparation of QME Pumps, Valves, and Dynamic Restraints. These 2007 and the revision to SRP Section 3.9.6.

differences suggest significant additional licensee SRP Section 3.9.6 Acceptance Criterion II.1.B burdens regarding the methods and procedures used to on page 3.9.6-8 states that functional design establish functional qualification and the documents and qualification of each safety-related pump used to demonstrate such functional qualification. and valve should be accomplished such that The March 2007 revision of SRP 3.9.6, without each pump and valve is capable of performing reference to any QME-1 functional qualification its intended function for a full range of system provisions and guidance, states: Conformance with the differential pressure and flow, ambient specific guidance in Subsection II of this SRP section temperatures, and available voltage (as will provide reasonable assurance that the functional applicable) under all conditions ranging from design and qualification of pumps, valves, and dynamic normal conditions to design-basis accident restraints within the scope of this SRP section and conditions. The SRP Section 3.9.6 their associated IST programs satisfy the applicable acceptance criteria are consistent with the requirements of 10 CFR 50.55a, particularly the IST provisions in QME-1-2007 to demonstrate that program requirements of the ASME Code for Operation pumps and valves are capable of performing Page 41 of 62

and Maintenance of Nuclear Power Plants (OM Code); their design-basis functions. The ASME General Design Criteria (GDC) 1, 2, 4, 14, 15, 37, 40, Standard QME-1-2007 represents one 43, 46, and 54 in Appendix A to 10 CFR Part 50; acceptable method to satisfy the acceptance Appendix B to 10 CFR Part 50; 10 CFR 52.47(b)(1) and criteria in SRP Section 3.9.6 for the functional 10 CFR 52.80(a). The NRC Regulatory Analysis does design and qualification of pumps, valves, and not evaluate or justify the apparent significant dynamic restraints, consistent with DG-1175.

differences and licensee burdens when QME-1 is used The NRC staff will evaluate Design in lieu of the existing SRP guidance on functional Certification applications and COL qualification of mechanical equipment. The NRC applications based on the SRP Section 3.9.6 determined last year that this SRP guidance meets all acceptance criteria for the functional design applicable regulatory requirements. This burden is and qualification of pumps, valves, and exacerbated by the DG-1175 provision, without further dynamic restraints. The ASME Standard analysis or justification, requiring compliance with all the QME-1-2007, as addressed in DG-1175, nonmandatory sections of QME-1. provides an efficient and effective approach for satisfying the SRP Section 3.9.6 NUGEQ Recommendation: The NRC should provide a acceptance criteria. Compliance to the detailed evaluation and justification for using the more provisions and guidance is optional. The NRC prescriptive provisions of QME-1 in lieu of the existing staff will also consider other approaches for mechanical equipment functional qualification guidance the functional design and qualification of in SRP 3.9.6 and its referenced documents/standards. pumps, valves, and dynamic restraints This evaluation should include the technical basis for proposed by Design Certification and COL requiring compliance with each of the nonmandatory Applicants in meeting the SRP Section 3.9.6 sections of QME-1. acceptance criteria.

Alternatively, and as suggested in Comment 2 the NRC should limit this revision of Regulatory Guide 1.100 to seismic and dynamic qualification and issued separate guidance on functional qualification of active mechanical equipment.

NUGEQ- C2.1.1a NRC Should Not Dictate Compliance with The staff agreed that Mandatory Appendices 4 Nonmandatory Appendices contained provisions must be followed.

Compliance of Nonmandatory Appendices, 2.1.1 General NRC Staff Positions - a: (page 13): which provided information or guidance, is In endorsing the use of ASME QME-1-2007, the staff voluntary.

noticed that several appendices are designated as either nonmandatory or mandatory (e.g., Nonmandatory The statement is revised to clarify. The staff Appendix QR-A; Nonmandatory Appendix QR-B; position is that, if a licensee commits to the Nonmandatory Appendices QDR-A, QDR-B, and QDR- use of non-mandatory appendices in ASME Page 42 of 62

C; Nonmandatory Appendices QP-A, QP-B, QP-C, QP- QME-1-2007 for its qualification of active D, and QP-E; and Mandatory Appendix QV-1). The staff mechanical equipment in NPPs, then the position is that, once the user commits to the use of criteria and procedures delineated in those ASME QME 2007 for its qualification of active non-mandatory appendices become part of mechanical equipment in NPPs, the criteria and the requirements for its qualification program, procedures delineated in those appendices then unless specific deviations are requested and become the requirements for its qualification program, justified.

unless the deviations are justified.

NUGEQ Comment: The NUGEQ disagrees with requiring the use of the nonmandatory appendices and believes this may be counterproductive and limit licensee commitments to the use of ASME QME-1.

QME-1 makes clear that mandatory appendices contain provisions that must be followed and nonmandatory appendices provide information or guidance that is not imposed.

The QME-1 committee has issued several revisions to QME-1 and has clearly determined that the nonmandatory appendices provide information/guidance and do not constitute required elements of the standard.

Industry experience with interpreting and implementing QME-1 is needed to refine both the mandatory and nonmandatory portions of QME-1. This lack of experience and recognition that acceptable alternative methods may be available were likely considerations that prompted the QME-1 committee to specify certain appendices as nonmandatory. The NRC states that this is the first time that the NRC is endorsing QME-1. The NRC and many in the industry have little experience interpreting or implementing the provisions of QME-1.

This is exemplified by the limited number of QME-1 code cases attached to the 2007 revision.

The NUGEQ is concerned that unilaterally dictating implementation of all the nonmandatory appendices represents a significant departure from current accepted Page 43 of 62

industry practices that have been endorsed by the NRC.

See for example our subsequent comment regarding Nonmandatory Appendix QR-B, Guide for Qualification of Nonmetallic Parts. If the NRC believes it has sufficient experience interpreting the nonmandatory appendices then it may be appropriate for the staff to indicate that the NRC has determined that these appendices represent acceptable methods of complying with QME-1. The NRC needs to be clear that they remain guidance and that other methods may be approved on a case-by-case basis.

NUGEQ Recommendation: Delete those portions of DG-1175 that dictate compliance with the nonmandatory portions of QME-1 for licensees that commit to the use of ASME QME 2007. If the NRC accepts the guidance in these appendices then the DG-1175 -

NUGEQ Comments 5 NRC should delete the existing language beginning with The staff position is that, once the user commits to the use of ASME QME 2007 and replace it with the following: The staff has determined that the contents of these nonmandatory appendices are acceptable for meeting applicable QME-1 provisions for the qualification of active mechanical equipment. Other appropriately justified methods not addressed in these QME-1 appendices may also be accepted on a case-by-case basis.

NUGEQ- C.2.1.1a Nonmandatory Appendix QR-B Not Appropriate for All The staff agreed that Mandatory Appendices 5 Equipment contained provisions that must be followed.

Compliance of Nonmandatory Appendices, 2.1.1 General NRC Staff Positions - a: (page 13): which provided information or guidance, is In endorsing the use of ASME QME-1-2007, the staff voluntary.

noticed that several appendices are designated as either nonmandatory or mandatory (e.g., Nonmandatory However, if a user commits to use QR-B for Appendix QR-A; Nonmandatory Appendix QR-B; its qualification of active mechanical Nonmandatory Appendices QDR-A, QDR-B, and QDR- equipment in NPPs, all the criteria and Page 44 of 62

C; Nonmandatory Appendices QP-A, QP-B, QP-C, QP- procedures that delineated in both the D, and QP-E; and Mandatory Appendix QV-1). The staff Mandatory Appendices and QR-B then position is that, once the user commits to the use of become the requirements for its qualification ASME QME 2007 for its qualification of active program. Justification must be provided for mechanical equipment in NPPs, the criteria and any deviations, which will be subjected to procedures delineated in those appendices then NRC staff review and approval.

become the requirements for its qualification program, unless the deviations are justified.

NUGEQ Comment: The NUGEQ is concerned that requiring compliance with Nonmandatory Appendix QR-B, Guide for Qualification of Nonmetallic Parts for all active mechanical equipment will result in excessive and unnecessary procedures, methods, and documentation burdens on licensees for some equipment, including all such equipment located in mild environments. Rigid application of the appendix to all equipment regardless of its plant location or potential for exposure to harsh environmental conditions is inconsistent with existing regulatory guidance.

The most recent regulatory guidance regarding environmental qualification of such nonmetallic parts is contained in the March 2007 revision of SRP 3.11, Environmental Qualification of Mechanical and Electrical Equipment. SRP 3.11 states in part (page 3.11-2): For mechanical equipment located in a harsh environment, compliance with the environmental design provisions of GDC 4 are generally achieved by demonstrating that the non-metallic parts/components are suitable for the postulated design basis environmental conditions.

For electrical and mechanical devices located in mild environments, compliance with the environmental design provisions of GDC 4 are generally achieved and demonstrated by proper incorporation of all relevant environmental conditions into the design process, Page 45 of 62

including the equipment specification.

SRP 3.11 also states that while environmental design requirements apply to all equipment important to safety (i.e., both mild and harsh environments) that environmental qualification is verification of design, limited to demonstrating that DG-1175 - NUGEQ Comments 6 electrical or mechanical or I&C equipment are capable of performing their safety function under significant environmental stresses (i.e., harsh environments) resulting from design basis events in order to avoid common-cause failure.

Regarding mechanical equipment SRP 3.11 makes important distinctions between the methodologies and documentation expectations for harsh and mild mechanical equipment. In both cases the SRP 3.11 establishes flexible guidance and does not dictate the more restrictive methods and documentation provisions contained in Appendix QR-B. SRP 3.11 indicates that for mechanical equipment, the staff concentrates its review on materials that are sensitive to environmental effects (e.g., seals, gaskets, lubricants, fluids for hydraulic systems, and diaphragms) and verifies that the licensee has identified the equipments location, service parameters, and nonmetallic material capabilities, and has evaluated the environmental effects. For mechanical equipment located in mild environments SRP 3.11 indicates that acceptable environmental design can be demonstrated by the "design/purchase" specifications containing a description of the functional requirements for a specific environmental zone during normal environmental conditions and anticipated operational occurrences. In contrast, it appears that Appendix QR-B would dictate that the equipment qualification report for all affected equipment regardless of location (i.e., harsh or mild) contain detailed information on the equipments Page 46 of 62

nonmetallics, including their function, formulation identification, activation energy, service conditions, failure modes and aging significance evaluations, qualification basis, qualified life, and maintenance/replacement requirements. While such information is similar to that developed to achieve compliance with 10 CFR 50.49 for electrical equipment located in a harsh environment, it is not required by any NRC guidance documents or the IEEE standards for electrical equipment located in a mild environment.

In summary the rigid application of Appendix QR-B to all active mechanical equipment is inconsistent with, and would be an unwarranted expansion of, existing regulatory guidance for the environmental design of such equipment. Its application would likely require the expenditure of significant additional licensee resources to address the more restrictive methods and documentation provisions of this nonmandatory Appendix.

NUGEQ Recommendation: As suggested in Comment 2 the NRC should limit this revision of Regulatory Guide 1.100 to seismic and dynamic qualification and issued separate guidance on functional qualification of active mechanical equipment. Any regulatory positions that establish NRC expectations for complying with QME-1 Appendix QR-B should be deleted.

WEC-1 B.1 "Specifically, Sections B. 1 and C. 1 of this regulatory The staff revised the statement for guide endorse, with exceptions and clarifications, the clarification.

entire IEEE Std 344-2004 and Section QR "General Requirements," and Nonmandatory Appendix QR-A, "Seismic Qualification of Active Mechanical Equipment,"

of ASME QME-1 -2007 for the seismic qualification of electrical and active mechanical equipment, respectively."

Comment (Editorial)

The word "respectively" should be deleted since there are more than two documents and all of the documents Page 47 of 62

can be used in the seismic qualification of active mechanical equipment.

Recommended Change Delete the word "respectively."

WEC-2 B.1 "Some solid-state relays and microprocessor-based See IEEE-13 components are quite fragile in terms of withstanding earthquake excitations."

Comment The following statement in our opinion has not been the case. "Some solid-state relays and microprocessor-based components are quite fragile in terms of withstanding earthquake excitations." We are not aware of any seismic issues that involve solid state relays.

There are no solid-state relays and microprocessor-based components which we would consider fragile.

The concern with microprocessors may be related to the connections to the buses and interfaces.

Recommended Change The statement on solid state relays and microprocessors being sensitive should be deleted.

WEC-3 B.1 "Recent studies related to the early site permit See IEEE-8 applications at certain hard-rock based plants along the east coast of the United States indicated that the site-specific spectra may exceed the certified design spectra of those new plants in the high-frequency range (20 hertz (Hz) and above)."

Comment DG-1175 defines high-frequency range as 20 Hz and above. It is understandable that an upper bound was not defined because it is dependent on the cutoff frequency of the hard rock site. The NRC should add a statement in this section to clarify.

Recommended Change Further clarification should be added on how the upper limit to the high-frequency range should be defined.

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WEC-4 B.1 "Therefore, any attempt to use such past test See IEEE-5 experience data for the seismic qualification of high-frequency-sensitive equipment or fragile components in such plants clearly is not appropriate."

Comment This section excludes the use of previous seismic testing to address qualification of for high frequency sensitive equipment or fragile components because the high frequency motions were not intentionally input to the test. DG-1175 Section C. 1.1.1 .h specifies how new seismic qualification tests planned for equipment in plants with the high-frequency ground motion concern should be addressed. The criteria specified are already in IEEE Std 344-2004. Therefore, seismic test programs in compliance with IEEE Std 344-2004 (including seismic test motion) which have sufficient frequency content in the high-frequency range demonstrated through power spectral density (PSD) analysis should be acceptable. It is unclear why does DG-1 175 call out "fragile components" and what is the definition?

Recommended Change Update section to allow pass seismic test data to permitted for addressing high frequency conditions as provided the data is in compliance with IEEE Std 344-2004 and demonstrates sufficient frequency content in the high-frequency range. Provide addition information as to the definition and usage of the term "fragile components."

WEC-5 B.2 Comment See IEEE-10 DG-1175 Section B.2 provides information associated with functional qualification of active mechanical equipment. Regulatory Guide (RG) 1.148 also provides information on functional specification of active valves and primarily endorses ANSI N278.1-1975. Functional qualification of active mechanical equipment discuss in DG-1 175 may be better suited for RG 1.148 since it presently exists.

Recommended Change Page 49 of 62

Recommend that functional qualification of active mechanical components not related to seismic qualification be discussed in a revision to RG 1.148. RG 1.100 should only provide guidance in the area of seismic qualification of electric and mechanical equipment. DG-1 175 Section B.2 (Functional Qualification of Active Mechanical Equipment) should be removed and the title of DG-1 175 should revert back to "Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants."

WEC-6 C.1.1.1c "(2) fragile electronic components, such as solid-state See IEEE-13 relays and microprocessors-based components;..."

Comment The phrase "fragile electronic components" in our opinion has not been observed in the seismic qualification of solid-state relays and microprocessor-based components. There are no solid-state relays and microprocessor-based components which we would consider fragile. The concern with microprocessors may be related to the connections to the buses and interfaces.

Recommended Change The condition "(2) fragile electronic components, such as solid-state relays and microprocessors-based components: should be deleted.

WEC-7 C.1.1.1g "Furthermore, credit should not be taken for the See IEEE-17 inadvertent high frequencies present in some of the IEEE-344-type seismic qualification tests of equipment in the past, which may have shown the ZPA of the TRS to be up to 100 Hz."

Comment Request further clarification as to why this position is taken in DG-1 175. As written the statement would exclude the use of previous testing to address high frequency concerns since the test motion did not intentionally require input in the high frequency range. If an evaluation of the test input is performed and the data Page 50 of 62

demonstrate sufficient frequency content in the high-frequency range throughout the time history through PSD analysis then the data should be acceptable. This approach is consistent with regulatory guidance in Section C. 1.1.1 h (also Section C.1.2.1h). We believe IEEE Std 344-2004 provides sufficient guidance to ensure that the input is generated and in compliance with the frequency range of interest. IEEE Std 344-2004 Annex B defines how to verify the test data has sufficient content over the frequency range of interest throughout the input time history.

Recommended Change Clarify that the subject test data is not acceptable unless further evaluation is performed and data generated to demonstrate there is sufficient frequency content over the frequency range of interest.

WEC-8 C.1.1.1i "Electric equipment should be qualified with five one- See IEEE-18 half SSE events followed by one full SSE event (SECY-93-087) (Ref. 28) even if the OBE of a plant is defined to be one-third of SSE or less. Alternatively, a number of fractional peak cycles equivalent to the maximum peak cycle for five one-half SSE events may be used in accordance with Annex D, "Test Duration and Number of Cycles," to IEEE Std 344-2004, when followed by one full SSE."

Comment The DG-1175 position does not recognize that some plants are licensed with an OBE that is greater or less than one-half SSE. The document SECY-93-087 addressed issues affecting Advanced Light-Water Reactors (ALWRs), for which the OBE eliminated from design certification when the OBE is established at less than or equal to one-third the SSE. It also states the following:

"With the elimination of the OBE, two alternatives exist that will essentially maintain the requirements provided in IEEE Standard 344-1987 to qualify equipment with the equivalent of five OBE events followed by one SSE Page 51 of 62

event (with 10 maximum stress cycles per event). Of these alternatives, the staff concludes that equipment should be qualified with five one-half SSE events followed by one full SSE event. Alternatively, a number of fractional peak cycles equivalent to the maximum peak cycles for five one-half SSE events may be used in accordance with Appendix D of IEEE Standard 344-1987 when followed by one full SSE."

Recommended Change This section should be updated to identify the present wording is associated with qualification of equipment for new plant designs. Wording should also be added to identify for other applications the OBE requirement is based on plant specific licensing requirements.

[For Section C.1.2.1j, Page 14 the recommended change is applicable to active mechanical equipment.]

WEC-9 C1.1.1j "The IEEE Std 344-2004 recommended no damping See IEEE-19 values. The damping values listed in Table 6 of NRC Regulatory Guide 1.61, Revision 1, "Damping Values for Seismic Design of Nuclear Power Plants," (Ref. 29) issued in March 2007, are recommended. These damping values are the updated values currently acceptable to the NRC staff."

Comment DG-1175 is recommending use of NRC Regulatory Guide 1.61, Revision 1 damping values. This is not appropriate since older plants as well as AP1000 uses damping values consistent with Regulatory Guide 1.61, Rev. 0. In addition, IEEE Std 344-2004 sub-clause 6.3.1 (Application of damping in analysis) identifies "Appropriate values of damping may be obtained from tests or other justifiable sources." IEEE Std 344-2004 sub-clause 6.3.2 (Application of damping in testing) and 8.6.1.3 (Damping selection) identify for testing "The RRS are usually specified at several levels of damping.

When available, the RRS with a damping of 5% is the recommended choice for use in testing."

Recommended Change Page 52 of 62

This section should be reworded to indicate the version of Regulatory Guide 1.61 as included in the plant licensing basis. This sentence dealing with damping in IEEE Std 344-2004 should also be deleted.

WEC-10 C.1.1.2k "A coherence function of less than 0.5 and an absolute See IEEE-25 value of the correlation coefficient function of less than 0.3 are not acceptable. The NRC positions on the numerical values for the coherence function and the correlation coefficient function for defining statistically independent motions are the same as in Reference 34, particularly the following: i. For the coherence function, numerical values ranging from 0.0 to a maximum of 0.3 and an average of approximately 0.2 are acceptable.

ii. An absolute value of less than 0.16 for the correlation coefficient function is acceptable."

Comment The coherence function and correlation coefficient limits appear to be restrictive. IEEE Std 344-2004 and IEEE Std 344-1987 specifies that either coherence function and correlation coefficient limits criteria must be met for the shake table test to be valid. That is: either the coherence function must be less than or equal to 0.5 at all frequencies of interest or the correlation coefficient need be less than 0.3. Both criteria need not be passed, just one or the other. The coherence function and cross correlation coefficient were originally developed in ASME Paper 83-PVP-22 based on his review of several actual earthquakes and used in the development of requirements initially in IEEE Std 344-1987. We are not aware of any new industry data which would change this position. In addition, Reference 34 (ASME Boiler and Pressure Vessel Code,Section III Division 1, Article N-1213.1 of Nonmandatory Appendix N) of DG-1175 is addressing the development of time history input for analysis where you are developing inputs associated Page 53 of 62

with a specific in-structure required response spectrum.

Where as, for seismic testing, the inputs are normal generic in nature (multiple plant sites/locations) and the RRS will be most likely the same in both horizontal axes as a minimum.

Recommended Change This section should be updated to concur with the present criteria in IEEE Std 344-2004 for test input generation associated with coherence function and correlation coefficient limits and its usage.

WEC-11 C.1.2.1a "In endorsing the use of ASME QME-1-2007, the staff See IEEE-10 noticed that several appendices are designated as either nonmandatory or mandatory (e.g., Nonmandatory Appendix QR-A; Nonmandatory Appendix QR-B; Nonmandatory Appendices QDR-A, QDR-B, and QDR-C; Nonmandatory Appendices QP-A, QPB, QP-C, QP-D, and QP-E; and Mandatory Appendix QV-1). The staff position is that, once the user commits to the use of ASME QME-1-2007 for its qualification of active mechanical equipment in NPPs, the criteria and procedures delineated in those appendices then become the requirements for its qualification program, unless the deviations are justified."

Comment RG 1.148 may be a more correct place for the Operability portion of QME-1. Including the operability portions of ASME QME-1-2007 into DG-1175 may create a potential conflict with RG 1.148. DG-1175 indicates that 'The staff position is that, once the user commits to the use of ASME QME-1-2007 for its qualification of active mechanical equipment in NPPs, the criteria and procedures delineated in those appendices then become the requirements for its qualification program, unless the deviations are justified."

ASME QME-1-2007 includes Nonmandatory Appendix QV-A "Functional Specification for Active Valves for Nuclear Power Plants." This nonmandatory appendix Page 54 of 62

represents a potential for conflict with RG 1.148. RG 1.148 Value/Impact Statement, Section Value (page 5) states, "It is anticipated that the most important contributions from ANSI N278.1-1975 will be realized when subsequent standards, which are currently being developed to address such topics as valve assembly functional qualification and production, are in place to provide a set of requirements covering various aspects of valve assembly operability." ASME QME-1-2007 represents the latest development in valve assembly functional qualification and production indicated. While it is not specifically noted that RG 1.148 will be revised to endorse these requirements it seems logical that all requirements regards functional qualification should be gathered into a single regulatory position. Because RG 1.148 already addresses some portion of functional qualification it would be the logical place for all functional qualification to be gathered. RG 1.100 has previously only addressed seismic qualification which is only of functional qualification.

Recommended Change Recommend regulations dealing with ASME QME 2007 in the area functional qualification be moved to RG 1.148.

WEC-12 C.1.2.1g "For certain hard-rock-based plants, the site-specific See IEEE-17 spectra may exceed the certified design spectra in the high-frequency range. This guide refers to this phenomenon as the high-frequency ground motion concern. As a result of the high-frequency ground motion, the seismic input to SSCs may also contain high frequency excitations. For operating BWR plants, the seismic qualification of some safety-related active mechanical equipment were performed using IEEE-344-type tests with intentional high-frequency contents to account for concurrent BWR hydrodynamic loads.

However, the vast majority of existing seismic qualification tests used input frequencies up to only 33 Hz. These past test experience data are therefore not Page 55 of 62

acceptable for the seismic qualification of high frequency- sensitive equipment or fragile components.

Furthermore, credit should not be taken for the inadvertent high frequencies present in some of the IEEE-344-type seismic qualification tests of equipment in the past, which may have shown the ZPA of the TRS to be up to 100 Hz. Ball joints and kinematics linkages of the shake tables could have generated these inadvertent high frequencies, and the NRC staff considers them to be noise signals that may not have the proper frequency content with sufficient energy to be compatible with the amplified region of the RRS at high frequencies."

Comment Request further clarification as to why DG-1175 (Regulatory Positions on ASME QME-1) discusses high frequency response. The DG-1175 should limit discussions and positions to high frequency sensitive equipment. We believe that mechanical equipment is not sensitive to high frequency. DG-1175 position on high frequency sensitive equipment should only be applied to sensitive electrical component which may be attached to the mechanical equipment. As written the statement would exclude the use of previous testing to address high frequency concerns since the test motion did not intentionally require input in the high frequency range. If an evaluation of the test input is performed and the data demonstrate sufficient frequency content in the high-frequency range throughout the time history then the data should be acceptable. This approach is consistent with regulatory guidance in Section C.

1.1.1.h.

We believe IEEE Std 344-2004 provides sufficient guidance to ensure that the input is generated and in compliance with the frequency range of interest. IEEE Std 344-2004 Annex B defines how to verify the test data has sufficient content over the frequency range of interest throughout the input time history. Therefore, Page 56 of 62

seismic test programs in compliance with IEEE Std 344-2004 (including seismic test motion) which have sufficient frequency content in the high-frequency range demonstrated through PSD analysis should be acceptable.

Recommended Change Update section to clarify that electrical component which may be attached to the mechanical equipment may be high frequency sensitive and are address by this section. Allow pass seismic test data to permitted for addressing high frequency conditions as provided the data is in compliance with IEEE Std 344-2004 and demonstrates sufficient frequency content in the high-frequency range.

WEC-13 C.2.1 "In general, the NRC staff finds ASME QME-1-2007 See IEEE-10 acceptable for the functional qualification of (1) active mechanical equipment in new NPPs; and (2) new addition or replacement of active mechanical equipment in operating NPPs, subject to the following provisions:

Comment Section C.2 of DG-1175 provides information associated with functional qualification of active mechanical equipment. Regulatory Guide (RG) 1.148 also provides information on functional specification of active valves and primarily endorses ANSI N278.1-1975. Functional qualification of active mechanical equipment discuss in DG-1175 may be better suited for RG 1.148 since it presently exists.

Recommended Change Recommend that functional qualification of active mechanical components not related to seismic qualification be discussed in a revision to RG 1.148. RG 1.100 should only provide guidance in the area of seismic qualification of electric and mechanical equipment. DG-1 175 Section B.2 (Functional Qualification of Active Mechanical Equipment) should be removed and the title of DG-1 175 should revert back to "Seismic Qualification of Electrical and Mechanical Page 57 of 62

Equipment for Nuclear Power Plants."

Dom-1 General The draft RG title and scope have been changed to See IEEE-10 include functional qualification of active mechanical equipment, as compared to the two previous revisions of RG 1.100 which only discussed seismic qualification of electrical and mechanical equipment. This change is because the RG now endorses ASME QME-1-1994, which covers functional qualification of active mechanical equipment. The main discussion on pages 5 through 8 of the DG is for active, motor-operated valves. It is noted that RG 1.148 also discusses functional specification of active valves and primarily endorses ANSI N278.1-1975. Although the ANSI standard by itself does not provided complete assurance of operability, there is an overlap between DG-1175 and RG 1.148 for functional qualification of active valves. It is recommended that functional qualification of active mechanical components (which have no direct bearing on seismic qualification) should be discussed in a revision to RG 1.148. RG 1.100 should provide guidance just for seismic qualification of electric and mechanical equipment.

Either remove functional qualification of active mechanical equipment from this DG or reconcile the overlap between DG-1175 and RG 1.148 in another manner.

Dom-2 B.1 In the SERs that NRC sent to the USI A-46 plants in the See NEI - 2 C.1.1.1b past, it was stated that older vintage plants could use C.1.1.2b,c the experience-based SQUG-GIP method for seismic verification of new and replacement equipment provided they revised their licensing bases. Many older plants are currently using the SQUG-GIP method. The DG is silent on this.

Add a sentence at the end of this paragraph to this Page 58 of 62

effect: However, older vintage plants can, with a few exceptions, use the experience-based SQUG-GIP method for seismic verification of new and replacement equipment provided they revise their licensing bases via safety evaluations. Alternatively, reconcile the fact in the DG that NRC has previously accepted earthquake experience-based qualification of new/replacement equipment in older plants.

Dom-3 B.1 The high frequency content, which exists in most See IEEE-5 and IEEE-17 C.1.1.1g existing tests, whether inadvertent or deliberate, will still C.1.2.1g be imparted to an item on equipment on the shake table. Therefore, high frequency vibratory motions generated on a shake table in an inadvertent manner may not be inconsequential. The DG should clarify that such inadvertent motions can be credited provided they are shown to meet stationarity requirements per Appendix B of IEEE Std 344-1987 or 2004 (when one of these versions of the IEEE Standard is the plants commitment). However, in IEEE Std 344-1975, there was no requirement for stationarity check. For example, previous seismic shake tests for BWR Mark II and III plants (committed to the 1975 version of the standard) were frequently utilized to qualify equipment for the combined seismic and hydrodynamic loads with high frequency content up to 100 Hz and were accepted by the NRC staff in SQRT audits.

Revise this section appropriately, such as adding a sentence to this effect: When the existing seismic tests contain inadvertent high frequency motions due to ball joints and kinematics linkages, such tests shall be shown to meet the stationarity requirements discussed in Appendix B of IEEE Std. 344-2004.

Dom-4 B.1 In the last sentence of this paragraph, it says that the See IEEE-18 C.1.1.1.i test sample shall be subjected to simulated OBE and C.1.2.1.j SSE vibrations per IEEE Std. 344-2004. In section Page 59 of 62

C.1.1.1i (p. 10) two alternatives for the number of tests/cyclic considerations are provided. However, another alternative when OBE is defined as 1/3 or less of SSE is to use two SSE events with 10 maximum stress cycles per event in accordance with SRP 3.7.3 (p. 4), March 2007. This alternative should also be listed.

Revise these sections to include an option that 2 SSE tests, as an alternative to 5 OBE and 1 SSE are also acceptable when the OBE is designated as 1/3 or less of the SSE.

Dom-5 C.1.1.1.j The IEEE Std. 344-2004 has a section on damping. See IEEE-19 While the damping values in RG 1.61 can be used when qualification is by analysis, there should be no specific requirement on damping values to be used for shake-testing, only that the equipment damping at which the RRS is developed should be the same or lower than the TRS damping value.

Clarify the statement in this section that for qualification by shake-table testing, RRS with any reasonable damping value (such as 5% of critical damping) can be used provided that the TRS is also plotted at the same damping value or a higher damping value.

Dom-6 General There is no discussion of required margins for seismic See IEEE-22 testing, except in Section C1.1.2d re. test experience spectra. A 10% margin is recommended in IEEE Std 323. Also, SRM on SECY-93-087 states that the Commission approved the use of a 1.67 margin over SSE for a margin type assessment. The intent of these margins should be clarified, particularly for seismic testing.

The required margins and/or the intent of margins in TRS vs. RRS over the applicable frequency range should be discussed in the RG so that there is no Page 60 of 62

confusion by the practitioners.

ASME-1 General The mechanical equipment functional qualifications Also see NUGEQ -2 and NUGEQ-3.

included in DG-1175 are an expansion of RG-1.100 and overlaps with several older NRC documents (Regulatory Guides and Standard Review Plan). There needs to be a discussion to foster a better understanding of the regulatory position with regard to mechanical equipment functional qualification and QME-1-2007 requirements.

ASME-2 General The restrictions on the use of experience-based seismic As delineated in C.1.1.1b, the use of qualification to USI A-46 power plants results in this experience-based method for seismic method of seismic qualification being disallowed by the qualification of electric equipment will be DG for new plants. The experience-based seismic subject to the review and approval by the methods have been in developed and used by the NRC staff. Even though IEEE Std 344-2004 nuclear industry for quite some time. These methods and ASME QME-1-2007 indicated limitation of were approved by the consensus committee process earthquake or test experience-based based on sound and accepted engineering judgment, qualification, the staff found that there are information, and practices, and ASME requests that use difficulties to justify the demonstration of of experience-based methods be allowed and accepted. similarity in seismic excitation, physical ,

functional, and dynamic characteristics between electric equipment in the experience database and those in the NPP to be seismically qualified.

The staff does not accept the use of SQUG guidelines for seismic qualification of equipment in non-USI A-46 plants licensed under 10CFR50 or in plants licensed to 10CFR52.

ASME-3 General ASME and IEEE need to work together in order to better The NRC staff will continue to work with IEEE define scope and responsibility of each of our respective and ASME in developing standards organizations. For example, we should cross-reference documents.

requirements between each of our standards rather than to duplicate them. Redundant standards documents cause confusion and may make it very difficult for NRC to provide regulatory endorsement and appropriate guidance on their application.

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ASME-4 General The NRC has made the QME Nonmandatory The staff agreed that Mandatory Appendices Appendices mandatory. The intent of the QME standard contained provisions must be followed.

is to provide an acceptable method to meet a particular Compliance of Nonmandatory Appendices, qualification requirement while providing some flexibility which provided information or guidance, is for a user. If the Nonmandatory Appendix is committed voluntary.

to by a user, all aspects of that Nonmandatory Appendix become mandatory. There needs to be a better However, if a user commits to use any understanding of what the minimum requirements are Nonmandatory Appendices for its qualification and when it is appropriate to have non-mandatory of active mechanical equipment in NPPs, all approaches for equipment qualification. the criteria and procedures that delineated in both the Mandatory Appendices and those committed Nonmandatory Appendices then become the requirements for its qualification program. Justification must be provided for any deviations, which will be subjected to NRC staff review and approval.

Duke General Duke supports and adopts the comments submitted by The staff has reviewed and provided Energy-1 the Institute of Electrical and Electronics Engineer responses to the comments from IEEE NPEC (IEEE) Nuclear Power Engineering Committee and the committee and Nuclear Energy Institute.

Nuclear Energy Institute by letters dated July 10, 2008 and July 11, 2008, respectively Page 62 of 62