ML19175A048

Public Comments on Rg 1.180

ML19175A048
Person / Time
Issue date:	12/19/2019
From:	Office of Nuclear Regulatory Research
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Eudy M
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References
DG-1333, RG-1.180, Rev 2
Download: ML19175A048 (50)

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Response to Public Comments on Draft Regulatory Guide (DG)-1333 Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems Proposed Revision 2 of Regulatory Guide (RG) 1.180 On April 24, 2018, the NRC published a notice in the Federal Register (83 FR 17867) that Draft Regulatory Guide, DG-1333 (Proposed Revision 2 of RG 1.180), was available for public comment. The public comment period ended on June 25, 2018. The NRC received comments from the organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Daniel Cronin Mark Burzynski United States NewClear Day, Inc.

dcronin@ufl.edu United States ADAMS Accession No. ML18115A095 mjburzynski@newcleardayinc.com ADAMS Accession No. ML18120A101 David Herrell Westinghouse Electric Company (WEC)

MPR Associates Amanda Spalding/Edmond Mercier 320 King St Ste 400 1000 Westinghouse Drive Alexandria, VA, 22314 Cranberry Township, Pennsylvania 16066 dherrell@mpr.com mercieej@westinghouse.com ADAMS Accession No. ML18177A027 ADAMS Accession No. ML18178A161 Electric Power Research Institute (EPRI) Southern Nuclear Operating Company (SNC)

Stephen Lopez Susan Mitchell/Justin Wheat 1300 W W.T. Harris Blvd 40 Inverness Center*Parkway Charlotte, NC, 28262 Post Office Box 12~5 slopez@epri.com Birmingham, AL 35242 ADAMS Accession No. ML18177A026 ADAMS Accession No. ML18178A162

Commenter Section of DG-1333 Specific Comments NRC Resolution Daniel Cronin General It's unclear whether or not the draft RG is The NRC staff disagreed with the comment that intended to be applicable to non-power applicability of this regulatory guide (RG) is production and utilization facilities (NPUFs). unclear. This RG is identified within Division 1 Please consider making a definitive statement guidance, which applies to power reactors.

within the Applicability section that indicates NPUFs are not addressed within Division 1 whether or not NPUFs are included within the guidance. Therefore, NRC made no changes to scope of this draft RG. the RG.

Mark Burzynski Section C.6 Comment 1 - In TR-102323 Rl listed The NRC staff disagreed with the comment that electrostatic discharge (ESD) testing as optional ESD testing should be removed from the RG.

for safety-related equipment and was based in The discussion in the comment cites an example part on the conclusion that ESD is not a credible of an ESD-induced event, which further common mode failure vulnerability. DG-1333 reinforces the value of retaining the testing now endorses ESD testing is on how the RG guidance. The guidance applies to analog and will be applied for use of equipment qualified to digital I&C equipment in new applications or in an earlier version of the RG. The basis for this voluntarily initiated modifications so there is no change is not explained in DG-1333. impact on existing, installed equipment nor is ORNL/LTR-2015/254, Task 4 EMI/RFI Issues there any restriction of the testing to digital Potentially Impacting EMC ofl&C Systems, systems. Therefore, NRC made no changes to (MLl 7199A005), makes a thought argument the RG.

that ESD may actually be a common cause failure vulnerability:

Additionally, it should be recognized that the regulatory guidance on EMC applies to all safety-related I&C systems and components, which are not all implemented in redundant divisions. Therefore, the additional protection provided by redundancy with safety systems should not be the prevailing consideration in assessing potential threats. It is feasible for failure of a safety-related component to lead to immediate safety relevant effects.

A cursory search of the Licensee Event Report.database found a small number of events

Commenter Section of DG-1333 Specific Comments NRC Resolution over the past three decades that are attributed to ESD. As an example, a plant trip occurred at the Donald C. Cook Nuclear Generating Station on March 11, 1997, as a result ofESD. Specifically, the controller for a feedwater regulating valve failed when a reactor operator touched it to switch it to manual for mandated surveillance.

Consequently, the valve close, leading to a trip based on steam generator low level coincident with a steam flow/feed flow mismatch. Thus, it is seen that ESD can result in safety significant failures.

This argument does not make the case that digital systems are vulnerable to common cause failures from ESD, only that components may be. The ESD testing requirement should be removed from DG-1333.

Mark Burzynski General Comment 2 - DG-1333 does not address now The NRC staff disagreed with the comment.

equipment to be used in the future (e.g., an Section D of the RG provides clear guidance approved digitalI&C platform) that was regarding when this RG applies and how qualified to Regulatory Guide (RG) 1.180, previously-established acceptable methods of revision 1, will be treated in any NRC compliance with regulations are treated.

regulatory review. The past practice has been to Therefore, NRC made no changes to the RG.

require the licensees to provide an assessment of the changes to the standard between the one used and the one currently endorsed. This practice creates an expensive churn of paper that rarely results in any equipment of plant design change. In the case ofDG-1333, NRC has already been given the assessment performed for them by Oak Ridge National Laboratory in ORNL-SPR-2016-108, Task 5Technical Basis for EMC Regulatory Guidance Update (ML16112A369). DG-1333 should be revised to 3

Commenter Section of DG-1333 Specific Comments NRC Resolution clearly say that equipment qualified to RG 1.180, Revision 1, is considerable acceptable.

David Herrell General (1) Concern: The NRC staff disagreed with the recommended (pg. 8) MIL-STD-461 and the IEC Standards receive change in the comment. While the statement revisions much more frequently than the expressed under Concern is frequently true, it is Regulatory Guide. These revisions often provide also recognized that substantial changes in the valuable clarification and improved test test methods and associated guidance can occur direction. as these standards undergo revision (e.g.,

substantial changes in guidance transitioning Recommended Change: between MIL-STD 461C + 462 and 461D +

The revised RG 1.180 should include a 462D). Consequently, blind endorsement of statement that allows use of the latest versions future versions of any standard poses the risk of MIL-STD-461 and the IEC Standards, that the effectiveness of the endorsed method subject to the condition that the test levels and may be compromised by unreviewed changes.

frequency ranges specified in the RG take Therefore, NRC made no changes to the RG.

precedence over any revised test levels or frequency ranges cited in the latest MIL-STD-461 or IEC Standards.

David Herrell Section C.1 (2) Concern: The NRC staff disagreed with the comment.

(pg. 8) This document should provide a path forward Section D of the RG provides clear guidance for industry since current existing installations regarding when this RG applies and how use equipment qualified to RG 1.180 Rev. 1. previously-established acceptable methods of Further, pre-qualified platforms have mostly compliance with regulations are treated.

been qualified against the requirements of RG Therefore, NRC made no changes to the RG.

1.180 Rev. 1, and this document is silent about requirements for use of that equipment without repeating already-completed equipment qualification tests to new requirements.

Recommended Change:

Industry needs a statement that equipment previously qualified to RG 1.180 Rev 1 is still acceptable without having to generate an extensive comparison of RG 1.180 Rev 1 to Rev 4

Commenter Section of DG-1333 Specific Comments NRC Resolution 2 levels and an evaluation of acceptance for each application.

David Herrell Section C.1 (3) Concern: The NRC staff disagreed with the comment.

(pg. 8) This document indicates that new analog Section D of the RG provides clear guidance equipment is to be qualified to these levels. The regarding when this RG applies and how older analog safety systems (that we are previously-established acceptable methods of replacing with new analog safety system) would compliance with regulations are treated. The not pass many of these tests, and have operated comment appears to relate to replacement parts successfully for many years. What is the rather than modifications. However, if new, technical basis for requiring such tests as EFT previously unqualified equipment is proposed to and SWC to these replacement modules, when upgrade a system, then additional design EFT and SWC have not been demonstrated to qualification evidence may be necessary based be problems to the existing analog equipment? on the results of a 10 CFR 50.59 evaluation.

Nevertheless, as stated in Section D, an Recommended Change: applicant or licensee can propose an acceptable Provide a method or process that would allow alternate method for complying with replacement analog modules to be subjected regulations. Therefore, NRC made no changes only to those tests that the equipment being to the RG.

replaced would have passed, especially for the potentially destructive ring wave and combination wave tests that the existing analog modules would have failed, but also other challenging tests that operating experience shows are not required to demonstrate proper function of components in these environments.

David Herrell Section C.1 (4) Concern: The NRC staff agreed with the comment (pg. 8) The last line of the paragraph starting "The regarding the clarity of the clause. The wording electromagnetic conditions at the point of of this sentence was modified as follows.

installation ... " is not very clear.

In accordance with the EMC practices Recommended Change: endorsed herein, the EMI/RFI immunity of Replace "that are greater than 8 decibel (dB) safety-related I&C systems should be below the specified operating envelopes." with demonstrated with a minimum of an 8 decibel something more like "that provide at least 8 (dB) margin provided above expected exposure 5

Commenter Section of DG-1333 Specific Comments NRC Resolution decibels (dB) of margin below the specified levels from all identified sources under any operating envelopes." plant mode of operation (e.g., applied susceptibility operating envelopes provide an 8-dB margin above the anticipated highest exposure levels at the point of installation).

David Herrell Sections C.3 (5) Concern: The NRC staff agreed with the comment. No (pg. 11) and C.5 Allowing use of both IEC and MIL-STD changes to the RG were requested.

(pg. 14) methods to test emissions, based on the phenomena, provides appropriate test flexibility, along with appropriate directions to ensure that overlap exists between frequency ranges tested.

Recommended Change:

None.

David Herrell Section C.3.1 (6) Concern: The NRC staff agreed in part with the comment.

(pg. 12) The test ranges in the text and the figure should To improve clarity, the following sentence was match. added after the cited first sentence of the paragraph.

Recommended Change:

Replace the first sentence with two sentences For AC power leads, the frequency range over "For DC power leads, this test is performed which the test is performed starts at the second from 30 Hz to 10 kHz. For AC power harmonic of the power line frequency.

leads, this test is performed from the second harmonic of the power line frequency from 120 Hz for 60 Hz power or 100 Hz for 50 Hz power to 10 kHz."

David Herrell Section C.3.1 (7) Concern: The NRC staff agreed in part with the comment.

(pg. 12) In Figure 3.1, the AC curves have significant The referenced Technical Basis documentation relaxation, in requirements, especially for the does not capture the rationale for the change in previous curves with power >1 kVA. It appears the CE101 AC operating envelope. This change that eliminating the <1 kVA curve may generate occurred late in the revision process and was problems in qualifying equipment, as there is a inadvertently omitted from the technical basis 2-3 db decrease in allowable at 120 Hz between report (ORNL/SPR-2016/108, ML16112A369).

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Commenter Section of DG-1333 Specific Comments NRC Resolution Revision 1 and this revision. There is no The basis for the modified AC limit is described technical reason to reduce the limit for low below. No change to the RG was warranted.

power equipment for the lower harmonics.

NUREG/CR-6431 (ML003706139) gives the Recommended Change: technical basis for the CE101 operating The present allowable limit is slightly higher envelopes in RG 1.180, Rev. 0 and Rev 1. No from 120Hz to about 240Hz and the tighter limit change was initially proposed for this revision could especially affect qualification of of the RG. However, interactions with industry equipment < l KVA. Please consider whether at standards meetings indicated some difficulty providing an equivalent small second harmonic arising from application of the AC limits.

allowance when power levels are <1 kVA is Consequently, the technical basis for those reasonable. envelopes was reviewed. It was determined that the AC limits for the RG and those presented in the current versions of EPRI TR-102323 were derived from different platform limits in the MIL-STD. The RG had adopted the Navy surface ship and submarine limit as the operating envelope for AC-powered equipment with the rationale that a nuclear-powered submarine seemed more appropriate than aircraft as the basis for a nuclear power plant limit. Conversely, the EPRI Guide specifies the limit for Navy anti-submarine warfare aircraft and Army aircraft applications. In each case, the AC limits are more conservative than the limit accepted in the SER on EPRI TR-102323, Rev.

0/1. Additionally, the AC limits in each guide provide significant margin (>20 dB) between the emissions limits and the comparable susceptibility limits. Consequently, it was determined that adoption of the aircraft limit specified in the MIL-STD for AC power line emissions from equipment with source voltage greater than 28 V was justified. Given the substantial margin below the conducted 7

Commenter Section of DG-1333 Specific Comments NRC Resolution susceptibility limit, it was determined that this change resulted in no appreciable reduction in reasonable assurance of safety while promoting harmony between regulatory and industry guidance.

David Herrell Section C.3.4 (8) Concern: The NRC staff disagreed with the recommended (pg. 14) Incorporating requirements to test to 10 GHz is change in the comment. Section D of the RG appropriate. However, many older NRC Safety provides clear guidance regarding when this RG Evaluations and equipment in use were only applies and how previously-established tested to 1 GHz. acceptable methods of compliance with regulations are treated. No backfit for installed Recommended Change: equipment is required. Therefore, NRC made no Please provide a statement that equipment changes to the RG.

previously qualified to RG 1.180 Rev 1 is still acceptable without having to generate an extensive argument for the missing 1 GHz to 10 GHz testing for each application.

David Herrell Section C.3.2 (9) Concern: The NRC staff disagreed with the recommended (pg. 12) For the CE102 test, the allowable emissions change in the comment. The specification of the levels are dependent on the equipment operating limits is consistent with the MIL-STD. The voltage. It is not clear which level should be practice for relaxation in the limit is a stair step used when the equipment operating voltage falls in which the relaxation factor applies when the between two given levels. equipment voltage is greater than or equal to the specified level. No change to the RG was Recommended Change: warranted.

Provide a CE102 specific requirement for which test levels are to be used when the equipment operating voltage falls between two given test levels.

David Herrell Section C.3.5 (10) Concern: The NRC staff disagreed with the recommended (pg. 14) Section 3.5 describes two options for addressing change in the comment. The conditions for the lack of low frequency conducted or radiated omitting low frequency emissions testing were emissions measurement in IEC 61000-6-4. first established in accordance with agreements Option 1 states that omitting low frequency that formed the basis for acceptance of EPRI 8

Commenter Section of DG-1333 Specific Comments NRC Resolution emissions measurements is acceptable if "power TR-102323 by an SER. The statement of the quality controls are in place" as described in omission conditions is consistent throughout Section 3.1 for CE-101 testing. In Section 3.1 versions of the RG and the EPRI Guide. Power two conditions are given: 1) power quality quality practices relate specifically to the requirements of the equipment are consistent electrical power distribution system of a plant with the existing power supply, and 2) the and are outside the scope of this guide on EMC equipment does not impose additional harmonic for safety-related I&C systems. Extensive detail distortion on the existing power distribution on power quality practices (methods, system that exceeds 5% THD. It is not clear measurements, tests) would be suitable for how these two conditions would be treatment in separate guidance (see ORNL/SPR-demonstrated for new l&C equipment. 2016/108, ML16112A369). No change to the RG was warranted.

Recommended Change:

Condition 1) seems to require that the existing plant power supply can provide power quality within the specifications of the new equipment.

Provide examples of what these power quality specifications would be {voltage, frequency, current, ripple, dip and rise?), and explain why this is a concern regarding emissions from the new equipment. Condition 2) would seem to require a test that measures the change in the THD on the existing plant power distribution system when the new equipment is operated.

The THD of the new equipment could be measured separately but it is not understood how those results could be mathematically combined with the THD of the existing system.

Also, under what conditions would the THD of the existing system be measured? If this is intended to be an actual, practical approach to justifying omission of low frequency emissions testing, more guidance is needed on how to implement it.

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Commenter Section of DG-1333 Specific Comments NRC Resolution David Herrell Section C.4 (11) Concern: The NRC staff agreed with the comment. The (pg. 17) In Table 7, IEC 61000-4-16 applies from 0 Hz description for IEC 61000-4-16 in Table 7 was

{DC) to 150 kHz. changed to 0 Hz to 150 kHz. The same change was applied to Table 9.

Recommended Change:

In Table 7, revise the description for IEC 61000-4-16 to read "0 Hz to 150 kHz".

David Herrell Section C.4.1.1 (12) Concern: The NRC staff disagreed with the comment. The (pg. 18) The first sentence in the CS101 test definition first sentence specifies that the test method incorrectly specifies the frequency range, which ensures systems are not susceptible to EMI/RFI conflicts with the last sentences in the same present on power leads in the full frequency paragraph. range. The subsequent sentences clarify specific applicability based on equipment types. There is Recommended Change: no conflict. No change to the RG was Replace the end of the first sentence" ... in the warranted.

frequency range 30 Hz to 150 kHz." with" ... in the frequency ranges specified below." Since the ac powered devices start at a different frequency than dc powered devices.

David Herrell Section C.4.1.2 (13) Concern: The NRC staff agreed with the comment. The (pg. 19) Figure 4.2 does not specifically define the test specific levels (49 dBA and 72.5 dBA, levels at 0.01 MHz and 0.15 MHz. respectively) was added to Figure 4.2.

Recommended Change:

Revise Figure 4.2 to specifically define the test levels at 0.01 MHz and 0.15 MHz, both as dotted horizontal lines and numeric dBA values.

David Herrell Section C.4.1.3 (pg. 20) (14) Concern: The NRC staff agreed with the comment. The Table 10 has a blank row between Harmonic blank row was deleted from Table 10.

Nos. 7 and 9.

Recommended Change:

10

Commenter Section of DG-1333 Specific Comments NRC Resolution In Table 10, remove the blank row between Harmonic Nos. 7 and 9.

David Herrell Section C.4.2 (15) Concern: The NRC staff agreed in part with the comment.

(pg. 21) In Table 15, the CS115 levels increased from The basis for the change to 5 A is specified in 2A in Rev. l to 5 A in Rev. 2. Further, the text ORNL/SPR-2016/108 (ML16112A369). The requires doubling this limit for installations with MIL-STD gives one limit for power and signal greater exposure. There is no apparent technical lines so the 2 A limit in RG 1.180, Rev. 1, was reason provided for either of these substantial not consistent with the MIL-STD. Therefore, the increases in test levels. 5A limit was adopted from the MIL-STD and is justified. However, the MIL-STD does not Recommended Change: differentiate exposure according to locations Either provide a technical rationale for going and doubling the limit for CS115 is not clearly from 2 to 5 amps and for doubling the test levels supported by the MIL-STD. The appropriate in high exposure installations, or restore the interpretation is that the MIL-STD limits bound previous test levels. the anticipated surge environments for those platforms. Consequently, the signal line susceptibility limits for CS115 and CS116 were modified to directly adopt the MIL-STD limits with no variation. The sentence concerning test levels for areas with elevated surge conditions was modified to remove the guidance on doubling the test level for CS115 and CS116.

The CS116 test limit was modified to adopt the maximum peak current of 10 A as given in MIL-STD 461G. Therefore, the limit for CS116 in Table 15 was changed to reference the MIL-STD frequency-dependent limit given in Figure CS116-2 of the MIL-STD (see the response to the following comment by the same commenter). In addition, the cited sentence in the preceding paragraph of the RG was changed as follows.

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Commenter Section of DG-1333 Specific Comments NRC Resolution Regulatory Position 5) and, in those special cases, the operating envelopes given in Table 15 for CS115 and CS116 should be doubled. F .

Consequently, for the IEC tests, the operating envelopes in Table 17 should be used as a special case David Herrell Section C.4.2 (16) Concern: The NRC staff agreed in part with the comment.

(pg. 21) Table 15, the specification for CS116 is To avoid confusion, the envelope guidance in incomplete. Implementing CS116 requires Table 15 was modified to reference the MIL-specifying the frequencies that are to be tested STD frequency-dependent limit given in Figure (defaults are 0.01, 0.1, 1, 10, 30 and 100 MHz). CS116-2 of the MIL-STD. However, guidance The test level varies by frequency according to on the minimum set of frequencies at which the Figure CS116-2 in MIL-STD-461, and does not test must be conducted is explicitly specified in reach the maximum level until the test the test methods description of the MIL-STD frequency is at or above 1 MHz. and does not require repetition in the RG. Thus, the table entry for CS116 was changed from 5A Recommended Change: to the following.

Revise Table 15 to specifically state the frequency and test level criteria for performing CS116 Apply damped sinusoidal waveform CS116. using frequency-dependent peak current specified in Figure CS116-2 of the MIL-STD David Herrell Section C.4.2 (17) Concern: The NRC staff disagreed with the comment. The (pg. 22) In Tables 16 and 17, the legend uses Withstand IEEE standard C62.41.2-2002 discusses as does the text. However, the IEEE standard exposure levels (low, medium, and high) but no discusses Low, Medium, and High Exposure longer gives limits specific to the exposure which generates questions when trying to apply levels. Instead, a single limit is specified for all the. RG. While we see the distinction made in exposures. The RG takes an exception to the the text introducing the tables, the tables should IEEE guidance regarding limits for SWC. The provide a straightforward path to the standards. levels presented in the RG correspond to Changing the terminology does not provide that withstand levels that can be applied based on straightforward path. anticipated exposure; however, these levels do not strictly relate to the historical exposure categories in the IEEE standard. The RG is clear what specific local exposure conditions would 12

Commenter Section of DG-1333 Specific Comments NRC Resolution Recommended Change: lead to the application of the elevated withstand Replace "Withstand" with "Exposure" in the level. It is expected that this limit would be legends for Tables 16 and 17, as well as within applied only for special cases and the low the text associated with the figures. withstand level should generally apply for almost all plant locations. No change to the RG was warranted.

David Herrell Section C.4.2 (18) Concern: The NRC staff disagreed with the comment. The (pg. 22) In Table 16, the IEC 61000-4-5 test levels are basis for the change in test levels is specified in doubled when compared with RG 1.180 ORNL/SPR-2016/108 (ML16112A369). The Revision 1. The levels were 1,000 volts and 500 IEC standard gives one limit for power and amps which is increased to 2,000 and 1,000 signal lines so the 1 kV and 500 A limits in RG amps, with no .referenced technical rationale or 1.180, Rev. 1, were not consistent with the IEC requirement for increasing the susceptibility test standard. Therefore, to apply industry consensus levels. limits, the Level 3/Level 4 limits were adopted for signal lines as they had been for power lines Recommended Change: and are justified. No change to the RG was Provide a technical basis for doubling the test warranted.

levels (changing Level 2 to Level 3), or return to the test levels provided in RG 1.180, Rev. 1.

David Herrell Section C.4.3.2 (19) Concern: The NRC staff agreed with the comment. The (pg. 23) In Figure 4.3, there is no label on the vertical label (0.06) was added to the x-axis of Figure dashed line, which appears to be around 60 Hz. 4.3 at the intersection with the dashed line.

Recommended Change:

Please add a label defining the frequency on the vertical dashed line, between 0.01 Hz and 0.1 Hz.

David Herrell Section C.5 (20) Concern: The NRC staff disagreed with the comment. As (pg. 26) In Tables 21 and 22, the Ring Wave surge opposed to the Combination wave, only one waveform has short-circuit current waveform is specified for the Ring wave. IEEE specifications similar to those for the C62.41.2-2002 specifically states that No Combination wave specification. From IEC short-circuit current waveform is specified for 61000-4-123, the short circuit current rise time the 100 kHz Ring Wave. The current characteristics derive directly from the applied 13

Commenter Section of DG-1333 Specific Comments NRC Resolution is 0.6 s, the duration is 100 kHz, and the peak open-circuit voltage waveform and do not need current varies with peak voltage. to be specified. No change to the RG was warranted.

Recommended Change:

Revise Tables 21 and 22 to include the relevant Ring Wave surge waveform short-circuit current specifications. At 2 kV, the peak current is 66.7 A. At 4 kV, the peak current is 133.3 A.

David Herrell Section C.5.3 (21) Concern: The NRC staff disagreed with the comment. The (pg. 29) Section 5.3 for EFT testing does not specify the' burst period is shown in Figure 5.5 and is burst period (time between 15 msec bursts). specified in the IEEE and IEC standards. Thus, it does not need to be further specified in the Recommended Change: RG. No change to the RG was warranted.

Section 5.3 should be revised to specify the EFT testing burst period (presumably 300 msec).

David Herrell Section C.5.3 (22) Concern: The NRC staff agreed with the comment. The (pg. 29) The EFT testing specification states that for distinction between peak test voltages in peak test voltages less than or equal to 2 kV, the specifying pulse frequency (repetition rate) is a pulse frequency is 5 kHz, and for peak test legacy from 1990s equipment (pulse voltages greater than 2 kV, the pulse frequency generators). Current capabilities are reflected in is 2.5 kHz. IEC 61000-4-4 has no requirement the guidance within IEC 61000-4-4, which does for a pulse frequency of 2.5 kHz, regardless of not make the distinction and which gives an the peak test voltage. The two pulse frequencies additional pulse frequency option. The given in IEC 61000-4-4 are 5 kHz and 100 kHz, distinction no longer applies for IEC 61000-4-4.

where 5 kHz is traditional and 100 kHz is The RG was changed as follows.

optional. Test generators built for implementing IEC 61000-4-4 typically do not have the option The number of pulses in a burst is determined to use a pulse frequency of 2.5 kHz, requiring by the pulse frequency. The pulse frequency is 5 custom test equipment or justification for kHz+/-1 kHz. For testing under IEC 61000-4-4, deviation when working to this guideline. the 100 kHz+/-20kHz option for pulse frequency, with the associated 0.75 ms burst duration, can Recommended Change: be alternately selected. The selection of pulse frequency of 2.5 kHz+/-0.5 kHz for peaks greater 14

Commenter Section of DG-1333 Specific Comments NRC Resolution If implementing IEC 61000-4-4 EFT testing, than 2 kV, as specified in IEEE C62.41.2-2002, consider revising the requirement to include is not necessary.

only 5 kHz pulse frequencies.

David Herrell Section C.6 (23) Concern: The NRC staff agreed with the comment. No (pg. 30-31) With the restriction of ESD testing limited to changes to the RG were requested.

overt effects (i.e., visible or detectable disturbance) and the implicit elimination of latent damage to the electronics from ESD, the testing is acceptable.

Recommended Change:

No change recommended. Much like testing for smoke exposure, ESD exposure can create latent defects in integrated circuits, which manifest months or years later. The testing provided is appropriate.

David Herrell Section C.6 (24) Concern: The NRC staff disagreed with the recommended (pg. 30-31) With the restriction of ESD testing to that which change. Guidance for maintenance practices is can be touched during normal operation, there is not within the scope of the RG. No change to an implicit, unstated requirement for ESD the RG was warranted.

protection for maintenance of equipment not normally accessible.

Recommended Change:

Please provide an explicit statement that the licensee is responsible for ensuring that appropriate, effective ESD protection is worn during any evolution where equipment is touched that has not been ESD tested for overt effects.

David Herrell Section C.6 (25) Concern: The NRC staff disagreed with the recommended (pg. 31) Normally, the 8 kV and 15 kV requirements are change. The IEC standard 61000-4-2 specifies stated as bipolar exposures, +/-8 kV and +/-15 kV. both positive and negative polarity for testing so the limit is given in absolute values to be 15

Commenter Section of DG-1333 Specific Comments NRC Resolution This ensures that both polarities of ESD tests are consistent with the levels defined in the performed. standard. No change to the RG was warranted.

Recommended Change:

Unless the intent is to require only one of the tests, please add the +/- symbol to both the 8 kV and 15 kV requirements.

WEC Section C.1 (pg. 9) Table (1) Add N/A" under "Standards Endorsed" The NRC staff disagreed with the comment.

1 column. Consistent with past versions of this RG, the entry in this column is blank because the position addresses the overall program, not the endorsement of specific standards. A similar rationale applies to the entry in this column for Position 7. No change to the RG was warranted.

WEC Section C.1 (pg. 10) (2) The units for the values in parentheses The NRC staff agreed with the comment. The 1st paragraph should be dBV/m instead of dB/m in the units were changed in the cited text to following text: ...(140 dB/m), the size of the dBV/m.

exclusion zones ... and ...from the portable EMI/RFI emitters are limited to 4 V/m (132 dB/m) ... "

WEC Section C.3.4 (3) Remove the word "emissions" after 2MHz The NRC staff agreed in part with the comment.

(pg. 13) to 10 GHz. The editorial problem resulted from formatting 1st paragraph issues associated with Figure 3.3. The formatting of the Figure has been corrected. The wording in question now reads as follows:

from 2 MHz to 10 GHz. It is applicable for emissions WEC Section C.4.2 (4) Remove the f in front of methods in fIEC The NRC staff agreed with the comment. The (pg. 21) 61000-4. extraneous f has been removed from the cited 1st paragraph text.

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Commenter Section of DG-1333 Specific Comments NRC Resolution WEC Section C.4.2 (5) Table 13 should reference MIL-STD-461G The NRC staff agreed with the comment. The (pg. 21) instead of MIL-STD-461E. identification of the standard in Table 13 has Table 13 been corrected to MIL-STD-461G.

WEC Section C.4.2 (6) The IEC 61000-4-12 Level 3 test voltage is The NRC staff agreed with the comments. The (pg. 22) 2kV for line to ground, not 4 kV as documented IEC 61000-4-12 Level 3 test voltage in Table 17 Table 17 in the table. The Level 4 test voltage is 4kV. has been corrected to show 2kV.

WEC Section C.4.3 (7) Table 18 should reference MIL-STD-461G The NRC staff agreed with the comment. The (pg. 22) instead of MIL-STD-461E. identification of the standard in Table 18 has Table 18 been corrected to MIL-STD-461G.

WEC Section C.4.3 (8) Tables 18 and 19 identify different upper The NRC staff agreed in part with the comment.

(pg. 23) frequency limits for radiated susceptibility, Clarification has been added that the IEC test Tables 18 and 19 electric field tests (te., 10 GHz vs. 6 GHz). should be applied up to 10 GHz if wireless Please add clarification, noting that testing communication devices are expected to be used above 6 GHz is not required if the IEC 61000 at the site. The following sentence was added:

3 test method is used.

If wireless communication devices operating above 6 GHz are expected to be used at the site of installation, then the IEC test for high-frequency susceptibility should be applied up to 10 GHz.

WEC Section C.5.1 (9) The beginning of the section reads: "The The NRC staff disagreed with the comment. The (pg. 27) Ring Wave simulates oscillatory surges of practices in IEEE Std C62.41.1, C62.41.2, and 1st paragraph relatively high frequency on the ac power leads C62.45 only apply to AC power leads. The prior

... " Is the ring wave test not applicable to DC versions of the RG only addressed surge on AC power lines? power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-12 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

17

Commenter Section of DG-1333 Specific Comments NRC Resolution WEC Section C.5.2 (10) The beginning of the third line of this The NRC staff disagreed with the comment. The (pg. 28) paragraph reads: " ... switching on the ac power practices in IEEE Std C62.41.1, C62.41.2, and 1st paragraph leads of equipment and subsystems." Is the C62.45 only apply to AC power leads. The prior combination wave test not applicable to DC versions of the RG only addressed surge on AC power lines? power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-5 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

WEC Section C.5.3 (11) Is the Electrically Fast Transients test not The NRC staff disagreed with the comment. The (pg. 29) applicable to DC power lines? practices in IEEE Std C62.41.1, C62.41.2, and 1st paragraph C62.45 only apply to AC power leads. The prior versions of the RG only addressed surge on AC power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-4 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

EPRI Section B (1) paragraph starting The rationale seems The NRC staff disagreed with the comment.

(pg. 6) to indicate this RG is now applicable to ALL This sentence is a minor revision to a sentence I&C equipment (not just safety-related). Same that is present in RG 1.180, Rev. 1. No change comment as provided previously regarding to the RG is warranted.

references.

EPRI General (2) Recommend not deleting any reference or The NRC staff disagreed with the comment. The mention of EPRI TR102323. In many staff acceptance of EPRI TR-102323, Rev. 0/1, instances, Licensees have not committed to RG as an acceptable method is not withdrawn nor is 1.180 but do refer to EPRI TR102323 in their the EMC testing for any previously installed procedures and analyses. The proposed version systems affected by this revised RG. Section D 18

Commenter Section of DG-1333 Specific Comments NRC Resolution of the Regulatory Guide no longer mentions of the RG provides clear guidance regarding EPRI TR102323. The Licensees and their when this RG applies and how previously-contractors heavily reference and use EPRI established acceptable methods of compliance TR102323. with regulations are treated. Regarding whether the revised RG mentions the EPRI guide, it is important to recognize that RG 1.180 has never endorsed any version of EPRI TR-102323. The reference to the SER and EPRI guide in prior versions of the RG occurred in the Discussion section (Section B) and served as background information providing context. This discussion was not considered necessary for this revision since the RG itself has been in use for almost 20 years so context should be well understood. No change to the RG is warranted.

EPRI General (3) The revision removed dated references, but The NRC staff disagreed with the comment. (1) also removed all reference to the industrys Dated references are used for the endorsed guidance document. EPRI Technical Report standards. (2) The reference to the SER and (TR-102323) now at Revision 4, and the related EPRI guide in prior versions of the RG occurred NRC SER which was included in Revision 1 of in the Discussion section (Section B) and served TR-102323 are no longer listed. There is no as background information providing context.

explanation given for removal of these This discussion was not considered necessary references. The entire section from RG 1.180 for this revision since the RG itself has been in Rev.1 (Oct 2003) titled Regulatory Analysis use for almost 20 years so context should be was removed. well understood. The removal of the references is of no regulatory consequence. The Regulatory Analysis section was issued as a separate document (ML17188A397). No change to the RG is warranted.

EPRI General (4) The NRC has removed the reference to The NRC staff agreed in part with the comment.

NUREG-0800 Standard Review Plan for the NUREG 0800 is active and identifies relevant Review of Safety Analysis Reports for Nuclear guidance against which the staff can conduct a Power Plants. This NUREG is still active; it is review. This RG is identified in Chapter 7 of somewhat disturbing that this tie no longer NUREG 0800 so the relationship is direct and 19

Commenter Section of DG-1333 Specific Comments NRC Resolution exists. There are indications that the General unchanged from that point of perspective and Design Criteria (GDC) is still considered implicit from the perspective of the RG.

applicable, but are not directly tied by reference. Nevertheless, NUREG-0800 Chapter 7 is now included in the identification of related guidance. Regarding the GDC, specific relevant GDC are cited in the RG (pg. 2).

The following bullet was added to the Related Guidance subsection of Section B:

• NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 7, Instrumentation and Controls, identifies electromagnetic compatibility among the acceptance criteria for safety-related I&C systems (Ref. 5).

EPRI General (5) The NRC has added to the requirements as The NRC staff agreed in part with the comment.

well. Electrostatic Discharge testing is a new ESD testing is new to the RG. The basis for the requirement that was not part of RG 1.180 change is described in ORNL/SPR-2016/108 Rev.1. (ML16112A369) and ORNL/SPR-2015/254 (ML17199A005). Thus, no change to the RG is warranted.

EPRI General (6) The 8 dB margin requirement for exclusion The NRC staff disagreed with the comment. The zones continues to be applied with no basis for the margin was established in the SER documented technical basis, especially with the and remains unchanged. The SER has not been removal of the SER for the EPRI Guide. withdrawn. The lack of a reference to the SER in the RG does not affect its regulatory standing.

No change to the RG is warranted.

20

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI General (7) The proposed revision discusses a number of The NRC staff disagreed with the comment. The occasions where blended standards (US and basis for the no mixing and matching provision IEC) are considered acceptable, but the NRC was established early in the development of the position of maintaining testing in either the technical basis for the first versions of the RG identified U.S. military standard or the (see NUREG/CR-6431, NUREG/CR-6782 and international standards - without mixing and other cited technical basis documents). No matching - continues to be documented without change to the RG is warranted.

technical basis.

EPRI (pg. 1) (8) First time electrostatic discharge is added The NRC staff disagreed with the comment. The to the requirements. I can find no reference or basis for including ESD testing is described in specific technical basis for this addition ORNL/SPR-2016/108 (ML16112A369) and ORNL/SPR-2015/254 (ML17199A005). Thus, no change to the RG is warranted.

EPRI Table 1 (9) Can MIL-STD-461G CS118 also be used as No change to the RG was made. The NRC staff an acceptable method for ESD testing? has not reviewed MIL-STD-461G CS118. It was issued very late in the development of the technical basis for revision of the RG and was not considered necessary given the availability of the longstanding guidance in IEC 61000-4-2.

EPRI Section C.1 (10) Recommend reducing the 8 decibel margin The NRC staff disagreed with the comment. The (pg. 10) requirement. This margin requirement is one of basis for the margin was established in the SER 1st paragraph the primary obstacles to implementing and remains unchanged. It is noted that 2nd sentence enhancements to the stations. It essentially applicants and licensees are free to propose imposes a 250% margin on exclusion distances. alternate methods for compliance with the Based upon changes to EMI regulations in other Commission's regulations. No change to the RG federally regulated industries like aviation and is warranted.

communications, this margin needs to be critically examined. The research, experience, and improvements in devices can easily be used to justify the reduction of the 250% margin.

EPRI (pg. 10) (11) The use of 10 V/m electric field The NRC staff disagreed with the comment. An (maximum) is listed but no basis provided. The example of how the margin could be applied is 8 dB margin is applied (no technical basis). given using 10 V/m. This value is based on the 21

Commenter Section of DG-1333 Specific Comments NRC Resolution There is no discussion about potential variations radiated electric field operating envelope for in the E-M field nor the possibility of equipment susceptibility. If a different maximum field qualified for higher or lower environments. strength is justified, then that value would apply. Again, the basis for margin is long established and its use is consistent across all regulatory guidance (including the SER on the EPRI guide). No change to the RG is warranted.

EPRI Section C.1 (12) The basis for an 8 dB margin should be The NRC staff disagreed with the comment. The (pg. 10) provided. basis for the margin was established in the SER on the EPRI guide and remains unchanged. No change to the RG is warranted.

EPRI Page 10 - C.1 (13) References to a radiated electric field The NRC staff agrees in part with the comment.

operating envelope of 10 V/m (140 dB/m) For clarity, the wording was changed to the should be clarified to read "a radiated electric following.

field susceptibility limit of 10 V/m (140 dBV/m)" "For the operating envelope of 10 V/m (140 dB

µV/m) associated with radiated electric field susceptibility,"

EPRI Page 10 - C.1 (14) Top paragraph of this page identifies 4 V/m The NRC staff agreed with the comment. The as 132 dB/m but should be 132 dBuV/m units were changed in the cited text to dBV/m.

EPRI Page 10 - C.1 (15) Definition of Pt related to the minimum The NRC staff agreed in part with the comment.

exclusion distance is described as "the effective However, the power is radiated, not conducted.

radiated power of the EMI/RFI transmitter (in The sentence in the RG was changed as follows.

Watts), but should be described as "the peak conducted power of the EMI/RFI emitter (in "the peak radiated power of the EMI/RFI Watts)" emitter (in Watts)"

EPRI Page 10 - C.3 (16) The name of the section would make more The NRC staff disagreed with the comment.

sense to be EMC Emissions Testing. Instead of While the proposed change would be rigorously using the acronym "EMI/RFI". Then substitute correct, the existing term has been consistently "EMC" for "EMI/RFI" throughout the section. used in current and prior guidance and is maintained to avoid confusion about whether 22

Commenter Section of DG-1333 Specific Comments NRC Resolution the guidance has changed its purpose. No change was made to the RG.

EPRI Page 10 - discussion of (17) The gain value in the equation should be The NRC staff disagreed with the comment. The exclusion zones shown as numerical gain - a numerical gain of 1 gain is a numerical value. It was not intended for an isotropic radiator is 0 dB gain (using this for the gain to be interpreted as a value in would result in the distance going to zero). decibels. However, to reduce the apparent confusion, the term "(dimensionless)" was removed from the definition.

EPRI Page 11 - C.3, Table 2 (18) In the introductory discussion of MIL- The NRC staff disagreed with the comment. The STD-461G, there should be a more detailed operating envelopes (limits) for the MIL-STD discussion of which Limits are chosen for the tests are customized to reflect the nuclear power specific test criteria. Each section should plant environment established through plant identify specifically which limits are chosen measurements. The basis for the limits is perhaps with a brief explanation of why they are captured in the cited reference documents applicable to the Nuclear Power Plant containing the technical basis information.

environment. Many of the limits appear to be Repeating this information after many of these customized, but there is no discussion of this in envelopes (limits) have been in effect for 15 the DG. References to other documents to years is considered unnecessary. No change to support the test criteria is difficult to follow. the RG is warranted.

EPRI Section C.3 (19) Recommend clarifying when military The NRC staff disagreed with the comment. The (pg. 10 & 11) standards and IEC standards must be used in RG states Either set of test methods should be 2nd paragraph their entirety and when then can be used in applied in its entirety or in specified next-to-last sentence combination. Currently, these two paragraphs combinations subject to the clarifications and 2nd paragraph 1st seemingly contradict each other in regards to conditions identified in the guidance below.

sentence performing tests entirely using one standard and Subsequently, the RG defines specific when testing can be combined. My guess is that combinations and conditions in which the test a clarifying sentence would be helpful in methods from one standard can be used to removing uncertainty. address coverage gaps in the other set of standards. The guidance is not contradictory. No change to the RG is warranted.

EPRI Page 10 & 11 - C.3 (20) This Table describes RE102 testing from 2 The NRC staff disagreed with the comment. The MHz to 10 GHz where MIL-STD-461G frequency ranges above 1 GHz as specified in describes the test from 2 MHz to 18 GHz. There the draft regulatory guide are identical to those 23

Commenter Section of DG-1333 Specific Comments NRC Resolution is no explanation for the deviation from the existing in the current version of the regulatory MIL-STD-461G frequency range requirement. guide. The applicable frequency ranges from RE102 and RS103 are addressed in technical basis documents (i.e., NUREG/CR-6782) and in Position 6 of RG 1.180, Rev. 1. The applicable frequency ranges specified in the regulatory guide are different from those in the MIL-STD because of differences in the nature and intensity of interference sources of concern. For nuclear power plants, the concern above 1 GHz arises primarily from wireless communications and internally generated noise (which drops off rapidly in the near-field). The MIL-STD guidance addresses military platforms and applications. In the rationale for the tests, it is stated that the intent of RE102 and RS103 are to protect sensitive receivers from interference coupled through the antennas associated with the receiver and to ensure that equipment will operate without degradation in the presence of electromagnetic fields generated by antenna transmissions both onboard and external to the platform, respectively. Sensitive receivers and high-powered transmitters are not generally employed in nuclear plant environments. Thus, the limits and frequency ranges specified in RG 1.180, Rev. 1, were selected to be appropriate to a nuclear plant environment. The 10 GHz upper range for frequency was chosen as reasonable to address the potential threat from portable and fixed transmitters, which generally operate at 900 MHz, 2.4 GHz, and 5.8 GHz. No change to the RG is warranted.

24

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI (pg. 11) (21) test methods (US and IEC) are stated to be The NRC staff disagreed with the comment. The 2nd to last paragraph able to be combined; adds to the confusion basis for the no mixing and matching provision when other comments indicate standards may was established early in the development of the not be combined when looking at threshold technical basis for the first versions of the RG values. Does not appear that there is a technical (see NUREG/CR-6431, NUREG/CR-6782 and basis for requiring one standard approach. other cited technical basis documents).

However, to offer some flexibility for passive emissions testing, the RG defines specific combinations and conditions in which the test methods from one standard can be used to address coverage gaps in the other set of standards. No change to the RG is warranted.

EPRI Page 12 - C.3.1 (22) The power sensitive criteria (limit line The NRC staff disagrees with the comment. The relaxation) in MIL-STD-461G is not shown or limit relaxation referenced in the comment does described in Figure 3.1. not apply to the CE101 limits for military aircraft. The relaxation only applies to the AC limits for submarines and surface ships. No change to the RG was warranted.

EPRI Page 12 - Section 3.1 (23) The curve for the AC power does not The NRC staff disagrees with the comment. The include a relaxation value based upon the limit relaxation referenced in the comment does fundamental current draw. This is in line with not apply to the CE101 limits for military the MIL-STD-461G guidance but will cause aircraft. The relaxation only applies to the AC systems drawing greater than 1 amp of current limits for submarines and surface ships. No to have a much higher likelihood of failing this change to the RG was warranted.

test. I would recommend adopting a limit relaxation factor similar to EPRI TR-102323 Revision 4 guidance or keep the same limit (and relaxation factor) that was in NRC RG 1.180 Revision 1.

EPRI Page 12 - Section 3.1 (24) The curve for the AC power does not The NRC staff disagrees with the comment. The include a relaxation value based upon the limit relaxation referenced in the comment does fundamental current draw. This is in line with not apply to the CE101 limits for military the MIL-STD-461G guidance but will cause aircraft. The relaxation only applies to the AC systems drawing greater than 1 amp of current 25

Commenter Section of DG-1333 Specific Comments NRC Resolution to have a much higher likelihood of failing this limits for submarines and surface ships. No test. I would recommend adopting a limit change to the RG was warranted.

relaxation factor similar to EPRI TR-102323 Revision 4 guidance or keep the same limit (and relaxation factor) that was in NRC RG 1.180 Revision 1.

EPRI Page 12 - Section 3.1, (25) I would recommend putting MIL-STD- The NRC staff agrees in part with the comment.

3.2, 3.3, and 3.4 461G in front of CE101, CE102, RE101, and It is considered to be understood from the Headings RE102 in the headings just for clarity. preceding guidance that the test methods are from the MIL-STD. However, it is recognized that labeling is important. CE101, CE102, and RE102 are shown in the figures. RE101 Operating Envelope was added to Figure 3.3.

EPRI Page 12 and 13 - Section (26) The first paragraph states, "This RG The NRC staff agrees with the comment. The 3.2 CE102 [Section B, provides an acceptable method for qualifying sentence (and an earlier sentence) was modified pg. 5] digital and advanced analog systems for the to add "I&C" between "analog" and "systems" projected electromagnetic environment in nuclear power plants." It's not clear if this guidance should be applied to all electrical and electronic equipment or only advanced analog and digital instrumentation and control (I&C) equipment.

EPRI Page 12 and 13 - Section (27) DG-1333 references performing CE102 The NRC staff agrees in part with the comment.

3.2 CE102 testing from 10 kHz to 2 MHz, however MIL- The frequency range addressed in Section 3.2 STD-461G CE102 specifies this test be was corrected to address an upper range of 10 conducted from 10 kHz to 10 MHz. It's not MHz. The operating envelope plot (Figure 3.2) clear why DG-1333 suggests terminating this was extended from 2 MHz to 10 MHz (@ 73 test at 2 MHz versus 10 MHz. The use of dB) customized testing limits that differ from approved standards is not recommended.

EPRI Section C.3 (pg.13) (28) Recommend reformatting Figure 3.2 and The NRC staff agreed with the comment. The Figures 3.2 and 3.3 Figure 3.3. It seems that Figure 3.2 has a editorial problem resulted from formatting 26

Commenter Section of DG-1333 Specific Comments NRC Resolution second figure overlaid upon it while Figure 3.3 issues associated with Figure 3.3. The is missing. formatting of Figures has been corrected.

EPRI Page 13 - C.3.2 (29) The power sensitive criteria (limit line The NRC staff disagrees with the comment. The relaxation) in MIL-STD-461G is not shown or limit relaxation referenced in the comment does described in Figure 3.2. not apply to the CE101 limits for military aircraft. The relaxation only applies to the AC limits for submarines and surface ships. No change to the RG was warranted.

EPRI Page 13 - C.3.4 (30) This section describes RE102 testing from The NRC staff disagreed with the comment. The 2 MHz to 10 GHz where MIL-STD-461G frequency ranges above 1 GHz as specified in describes the test from 2 MHz to 18 GHz. There the draft regulatory guide are identical to those is no explanation for the deviation from the existing in the current version of the regulatory MIL-STD-461G frequency range requirement. guide. The applicable frequency ranges from RE102 and RS103 are addressed in technical basis documents (i.e., NUREG/CR-6782) and in Position 6 of RG 1.180, Rev. 1. The applicable frequency ranges specified in the regulatory guide are different from those in the MIL-STD because of differences in the nature and intensity of interference sources of concern. For nuclear power plants, the concern above 1 GHz arises primarily from wireless communications and internally generated noise (which drops off rapidly in the near-field). The MIL-STD guidance addresses military platforms and applications. In the rationale for the tests, it is stated that the intent of RE102 and RS103 are to protect sensitive receivers from interference coupled through the antennas associated with the receiver and to ensure that equipment will operate without degradation in the presence of electromagnetic fields generated by antenna transmissions both onboard and external to the platform, respectively. Sensitive receivers and 27

Commenter Section of DG-1333 Specific Comments NRC Resolution high-powered transmitters are not generally employed in nuclear plant environments. Thus, the limits and frequency ranges specified in RG 1.180, Rev. 1, were selected to be appropriate to a nuclear plant environment. The 10 GHz upper range for frequency was chosen as reasonable to address the potential threat from portable and fixed transmitters, which generally operate at 900 MHz, 2.4 GHz, and 5.8 GHz. No change to the RG is warranted.

EPRI Page 13 - Section 3.4 (31) Remove the word "emissions" after "2MHz The NRC staff agreed in part with the comment.

First Sentence to 10 GHz". The editorial problem resulted from formatting issues associated with Figure 3.3. The formatting of the Figure has been corrected. The wording in question now reads as follows:

from 2 MHz to 10 GHz. It is applicable for emissions EPRI Page 14 (32) separation from equipment sensitive to The NRC staff disagrees with the comment.

magnetic fields needs a definition or a technical This condition for omission of the test methods basis. has been in place as stated for more than 20 years. No change to the RG is warranted.

EPRI Section 3.5 (33) I do not believe that power quality controls The NRC staff disagreed with the comment.

(pg. 14) should be used to justify removed testing Regarding CE102, the MIL-Std states that "The 2nd Paragraph requirements from 10 kHz to 150 (or 450) kHz. basic concept in the lower frequency portion of First, most sites do not have well documented the requirement is to ensure that the EUT does power quality controls in place to be able to use not corrupt the power quality (allowable voltage the exemption properly. Second, the traditional distortion) on the power buses present on the frequency range for power quality is considered platform" while "At higher frequencies, the to be up to the 40th harmonic or 2.4 kHz for 60 CE102 limit serves as a separate control from Hz systems. These controls will not address DC RE102 on potential radiation from power leads".

power supplies and other power converters with Thus, the lower frequency band is directly switching harmonics in the frequency range of related to power quality issues. It should be 50 kHz to 100 kHz. New equipment typically noted that the electrical power systems of a fails to meet the CE102 requirements within this nuclear power plant are outside the scope of the 28

Commenter Section of DG-1333 Specific Comments NRC Resolution range. This was also a gap in the previous RG RG. This issue can be further considered as part when using exemptions. of subsequent investigation of power quality practices which is outside the scope of this RG.

No change to the RG is warranted.

EPRI (pg. 15) (34) Again, discussion of unrestrained mixing The NRC staff disagreed with the comment. The last paragraph and matching of standards with no basis. In basis for the no mixing and matching provision addition, there is no supporting discussions for was established early in the development of the using actual field measurements (E-M technical basis for the first versions of the RG environment) and matching them to (see NUREG/CR-6431, NUREG/CR-6782 and susceptibility values that may be lower than 10 other cited technical basis documents). No V/m. change to the RG is warranted.

EPRI Section C.3.6 (35) FCC 47 CFR Part 15 Class A (and B) The NRC staff agreed in part with the comment.

(pg. 15) requirements have been removed from the entire FCC certification can be credited in lieu of document. No basis for removal; these levels additional emissions testing for non-safety-apply to many of the unlicensed radiators being related I&C systems over the frequency ranges used today. covered by the certification. However, in the case of safety-related I&C systems, credit for this testing should be fully documented and available for review. The following paragraph was added to Section C.3.6 and the appropriate reference added:

Finally, Federal Communications Commission (FCC) certification for Class A or Class B devices under 47 CFR 15 may be credited over the frequency ranges covered by certification testing in lieu of additional testing for non-safety-related I&C systems. In order to take credit for FCC certification for safety-related I&C systems, test data and documentation equivalent to the information identified in Regulatory Position 7 should be maintained and be available for review.

EPRI Section C.3.6 (36) Recommend keeping the alternative option The NRC staff agreed in part with the comment.

(pg. 15) of using FCC Part 15 Class A. In the majority FCC certification can be credited in lieu of 29

Commenter Section of DG-1333 Specific Comments NRC Resolution of evaluations, non-safety-related components additional emissions testing for non-safety-are justified using this alternative option related related I&C systems over the frequency ranges to FCC Part 15, Class A. Most non-safety- covered by the certification. However, in the related vendors will not perform separate testing case of safety-related I&C systems, credit for in accordance with military standards and IEC this testing should be fully documented and standards. However, they will provide a available for review. The following paragraph certificate of conformance with FCC Part 15 was added to Section C.3.6 and the appropriate Class A. Without this option, Licensees will reference added:

have to perform unnecessary testing which will Finally, Federal Communications Commission provide no additional benefit to nuclear safety. (FCC) certification for Class A or Class B devices under 47 CFR 15 may be credited over the frequency ranges covered by certification testing in lieu of additional testing for non-safety-related I&C systems. In order to take credit for FCC certification for safety-related I&C systems, test data and documentation equivalent to the information identified in Regulatory Position 7 should be maintained and be available for review.

EPRI Page 15 - Section 3.6 (37) For the CE101, I suggest changing it to The NRC staff agreed with the comment. The First Paragraph "plant has power quality controls in place and suggested wording was adopted and the the equipment won't impose more than 5% THD sentence was changed as follows:

(see conditions in the CE101 test guidance)."

"plant has power quality controls in place and the equipment won't impose more than 5% THD (see conditions in the CE101 test guidance)."

EPRI Page 15 - Section 3.6 (38) I suggest not allowing a CE102 test The NRC staff agreed with the comment. The First Paragraph exemption up to 450kHz based upon power omission criteria for the lower frequency band quality controls. In addition, it is not discussed of CE102 (here and in Section 3.2) was changed regarding the FCC testing beginning at 450 kHz. to an upper frequency bound of 150 kHz. Figure So if used, it would seem more natural to 3.5 was changed to reflect the adjustment.

exempt it from 10 kHz to 150 kHz since that is where the IEC testing begins.

30

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Section 3.6 (39) Do not allow for the exemption of The NRC staff disagreed with the comment.

(pg. 15) frequencies from 10 kHz to 150 (or 450) kHz Regarding CE102, the MIL-Std states that "The 2nd Paragraph based upon power quality controls. This will basic concept in the lower frequency portion of miss a major source of excessive emissions the requirement is to ensure that the EUT does from switch-mode power supplies and AC-DC not corrupt the power quality (allowable voltage or DC-DC converters. distortion) on the power buses present on the platform" while "At higher frequencies, the CE102 limit serves as a separate control from RE102 on potential radiation from power leads".

Thus, the lower frequency band is directly related to power quality issues. It should be noted that the electrical power systems of a nuclear power plant are outside the scope of the RG. This issue can be further considered as part of subsequent investigation of power quality practices which is outside the scope of this RG.

No change to the RG is warranted.

EPRI Page 15 - Table 4 (40) CISPR Class A removed, and average No change made to the RG. No change values removed. Quasi-peak values from Table requested. The CISPR Class A limits are no 5 also changed. longer used (above 1 GHz is not covered). The limits from IEC 61000-6-4 are now used.

EPRI Page 15 - Table 5 (41) Table 5 provides the limits at 10 meters for The NRC staff disagreed with the comment. The frequencies less than 1 GHz and 3 meters for IEC standard gives equivalent limits depending frequencies above 1 GHz. I suggest stating that on the test method used. It is considered these emissions can be collected in an Open unnecessary to document all of the test method Area Test Site (OATS), within a 10 meter semi- variations covered within the standard since the anechoic chamber, or within a 3 meter semi- equivalent limits are readily evident. No change anechoic chamber with the limits adjusted to the RG is warranted.

accordingly based upon free space propagation.

EPRI Page 16 - C.4 (42) The name of the section would make more The NRC staff disagreed with the comment.

sense to be EMC Susceptibility Testing. Instead While the proposed change would be rigorously of using the acronym "EMI/RFI". Then correct, the existing term has been consistently substitute "EMC" for "EMI/RFI" throughout the used in current and prior guidance and is section. maintained to avoid confusion about whether 31

Commenter Section of DG-1333 Specific Comments NRC Resolution the guidance has changed its purpose. No change was made to the RG.

EPRI Section C.4 (43) Clarification of the following statement The NRC staff disagreed with the comment.

(pg. 16) should be added to address if ESD and Surge ESD is covered in C.6 (with only IEC) and are included in what is being considered the Surge Withstand is covered in C.5 (with the scope of susceptibility testing: "Regardless of IEEE and IEC test methods being essentially which susceptibility testing program is chosen, interchangeable - basically identical). No either set of test methods should be applied in change was made to the RG.

its entirety, without selective application of individual methods (i.e., no mixing and matching of test methods)."

EPRI Section C.4 Table 6 (44) Table 6 describes the CS114 testing from The NRC staff disagreed with the comment. The (pg. 16) 10 kHz to 30 MHz where MIL-STD-461G 30 MHz to 200 MHz frequency band is omitted describes the testing from 10 kHz to 200 MHz. because it is covered by RS103 testing (per There is no explanation for the deviation from MIL-STD). The rationale is given in cited the MIL-STD-461G frequency range technical basis documents and the MIL-STD.

requirement. No change to the RG was warranted.

EPRI Section C.4 (45) no mix and match of standards. No basis. The NRC staff disagreed with the comment. The (pg. 16) basis for the no mixing and matching provision 2nd paragraph was established early in the development of the technical basis for the first versions of the RG (see NUREG/CR-6431, NUREG/CR-6782 and other cited technical basis documents). No change to the RG is warranted.

EPRI Page 16 through 30 - (46) Surge is handled in a confusing manner The NRC staff disagreed with the comment. The Sections 4 & 5 between sections 4 and 5. CS116 is not included CS115 and CS116 tests are only identified for in section 5 but is in section 4. IEC surge signal lines. The IEEE standard specifically standards are covered in both. IEEE surge defines its application as being for AC power standard is only in Section 5. lines. The organization of the guidance is maintained from the prior version of the RG. No change to the RG is warranted.

EPRI Page 18 - C.4.1.2 (47) there is no indication of the acceptable The NRC staff disagreed with the comment. As operating class (A, B, C, etc.) when discussing is the case for all qualification testing, the 32

Commenter Section of DG-1333 Specific Comments NRC Resolution IEC standards. Need to define if safety-related acceptance criteria depends on the equipment devices need to be Class A (normal operation specification and the function being performed.

before, during, and after event), Class B (normal It is not appropriate for the RG to specify operation before and after, may not operate generic acceptance criteria. No change to the during event), or Class C (normal before, may RG was warranted.

need manual action to reset after). One assumes that Class D / E (essentially failed during / after event) are not acceptable.

EPRI Page 18 - C.4.1.2 (48) This section describes the CS114 testing The NRC staff disagreed with the comment. The from 10 kHz to 30 MHz where MIL-STD-461G 30 MHz to 200 MHz frequency band is omitted describes the testing from 10 kHz to 200 MHz. because it is covered by RS103 testing (per There is no explanation for the deviation from MIL-STD). The rationale is given in cited the MIL-STD-461G frequency range technical basis documents and the MIL-STD.

requirement. No change to the RG was warranted.

EPRI Page 18 and 19 - Section (49) The proposed CS114 testing limit The NRC staff disagrees with the comment.

4.1.2 represents a customized testing level not found Customized testing levels are allowed in the in MIL-STD-461G. The technical bases for the MIL-STD and can be specified based on the CS114 testing limit is believed to be flawed as unique conditions for the application.

reported in EPRI report 1016158 "Review of Additionally, the defined levels in the MIL-STD High-Frequency Conducted Susceptibility apply to specific military platforms so there is Limits." The primary concern is the plant data no imperative to force their application to other reported at 150 kHz that resulted in and required platforms. ORNL/SPR-2015/485 the use of a customized testing limits that differs (ML17199A004) documents the basis for the from approved standards, which is not CS114 operating envelope in the RG. No recommended. Additional testing should be change to the RG was warranted.

performed as required to determine if endorsement of one of the MIL-STD-461G Figure CS114 limit curves is possible.

EPRI Page 2 - Related (50) not clear why this is not simply included as There is no change to the RG. This organization Guidance pointers to the References section, there is no is consistent with the RG style adopted by NRC.

real detail provided 33

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Page 2 - under (51) first bullet starting Criterion III; The NRC staff disagreed with the comment.

Applicable Regulations appears to refer to GDC which does not apply to These criteria are cited in RG 1.180, Rev. 0 and all plants (especially older sites). Also appears Rev. 1. No change to the RG was warranted.

to invoke the need to provide and maintain sufficient records. Was unable to find this as a direct correlation to Rev.1.

EPRI Page 20 (52) Table 11 is new. Do not believe there is an No change to the RG is made. No change equivalent US standard. requested.

EPRI Page 21 (53) Table 15 is updated. (need to verify curves No change to the RG is made. No change for CS114 are correct for Figure 4.2) requested.

EPRI Section C.4.2 (54) Recommend revising the title of Table 13 The NRC staff agreed with the comment. The (pg. 21) to use "MIL-STD-461G" instead of "MIL-STD- identification of the standard in Table 13 has Table 13 461E". been corrected to MIL-STD-461G.

EPRI Section C.4.2 (55) Top paragraph has an erroneous "f" placed The NRC staff agreed with the comment. The (pg. 21) prior to IEC 6100-4. extraneous f has been removed from the cited text.

EPRI Page 17 - Table 7 (and (56) there is no indication of the acceptable The NRC staff disagreed with the comment. As more) operating class (A, B, C, etc.) when discussing is the case for all qualification testing, the IEC standards. Need to define if safety-related acceptance criteria depends on the equipment devices need to be Class A (normal operation specification and the function being performed.

before, during, and after event), Class B (normal It is not appropriate for the RG to specify operation before and after, may not operate generic acceptance criteria. No change to the during event), or Class C (normal before, may RG was warranted.

need manual action to reset after). One assumes that Class D / E (essentially failed during / after event) are not acceptable.

EPRI Page 21 - C.4.2, Table (57) The limit for CS116 is indicated as 5A, but The NRC staff disagreed with the comment The 15 does not indicate if this value is detail on the test waveform is contained in the peak/RMS/average. This entry should be MIL-STD and does not require repeating in the described as peak which matches the criteria in RG. However, the expression of the guidance MIL-STD-461G Figure CS116-2. has been changed in response to another comment (PC-3 #16) 34

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Page 21 - Table 13 (58) Table 13 should reference MIL-STD-461G The NRC staff agreed with the comment. The instead of MIL-STD-461E identification of the standard in Table 13 has been corrected to MIL-STD-461G.

EPRI Page 21 and 22 - Table (59) DG-1333 recommends CS116 testing to 5 The NRC staff disagreed with the comment. The 15 A. EPRI TR-102323 does not endorse CS116 CS116 test is not offered as an alternate to IEC because the MIL-STD-461 CS116 damped 61000-4-5 for surge withstand testing of power sinusoidal wave test represents coupled and not lines. However, it is adopted as an alternative unidirectional energy. The slower rise time and for the less extreme testing of signal lines. No longer duration result in a less challenging change to the RG was warranted.

test than the combination wave test (IEC 61000-4-5). Thus the CS116 is not recommended as an alternate to the IEC 61000-4-5 test.

EPRI Page 22 (60) Table 16 is revised but essentially the No change to the RG is made. No change same. Table 17 has higher values than Rev.1. requested.

Table 18 was revised for RS103 from 1 GHz to 10 GHz. Table 19 was revised from 1 GHz to 6 GHz.

EPRI Page 22 - Table 17 (61) The IEC 61000-4-12 Level 3 voltage is The NRC staff agreed with the comment. The 4 2kV for line to ground and not 4 kV. 4 kV is kV limit was changed to the correct value of 2 the Level 4 test voltage. kV.

EPRI Page 22 - Table 18 (62) Table 18 should reference MIL-STD-461G The NRC staff agreed with the comment. The instead of MIL-STD-461E editorial change was made to the RG.

EPRI Page 23 (63) Section 4.3.2 requires an electric field level The NRC staff disagreed with the comment. The of 10 V/m up to 10 GHz with no technical basis, technical basis for the limit is given in but there appears to be some flexibility in NUREG/CR-6782 and MIL-STD. No change to providing additional definition of acceptable the RG was warranted.

levels in the test plan.

EPRI Section C.4.4 (64) Clarification of the following statement The NRC staff disagreed with the comment.

(pg. 24) should be added to address if ESD and Surge ESD is covered in C.6 (with only IEC) and are included in what is being considered the Surge Withstand is covered in C.5 (with the scope of susceptibility testing: "Regardless of IEEE and IEC test methods being essentially which susceptibility testing program is chosen, 35

Commenter Section of DG-1333 Specific Comments NRC Resolution either set of test methods should be applied in interchangeable - basically identical). No its entirety, without selective application of change was made to the RG.

individual methods (i.e., no mixing and matching of test methods)."

EPRI Page 27 (65) Table 23 no longer includes Category C No change to the RG is made. No change is Exterior levels. requested.

EPRI Page 27 - Section 5.1 (66) Is the Ring Wave test only applicable to ac The NRC staff disagreed with the comment. The power leads? Are DC leads not to be tested? practices in IEEE Std C62.41.1, C62.41.2, and C62.45 only apply to AC power leads. The prior versions of the RG only addressed surge on AC power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-12 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

EPRI Page 28 - Section 5.2 (67) Is the Combination Wave test only The NRC staff disagreed with the comment. The applicable to ac power leads? Are DC leads not practices in IEEE Std C62.41.1, C62.41.2, and to be tested? C62.45 only apply to AC power leads. The prior versions of the RG only addressed surge on AC power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-5 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

EPRI Page 29 (68) Section 5.3 removed the requirement to use No change to the RG is made. No change is a frequency up to 10 times the base frequency requested.

above 1 GHz (acceptable).

36

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Page 29 - Section 5.3 (69) Is the EFT test only applicable to ac power The NRC staff disagreed with the comment. The leads? Are DC leads not to be tested? practices in IEEE Std C62.41.1, C62.41.2, and C62.45 only apply to AC power leads. The prior versions of the RG only addressed surge on AC power leads because this was the phenomenon of concern. The issue for DC power leads was considered to be properly attributed to power supplies as a power quality concern. Thus, while IEC 61000-4-4 applies to AC and DC power leads, the RG only specifies its application for AC power leads. No change to the RG was warranted.

EPRI Section A (70) Recommend deleting the reference to RG The NRC staff disagreed with the comment.

(pg. 3) 1.89. RG 1.89, "Environmental Qualification of Electromagnetic conditions are identified as 5th bullet Certain Electric Equipment Important to Safety relevant service conditions and EMC testing is for Nuclear Power Plants" is listed in the included in the testing sequence within current "Related Guidance". However, the RG does not EQ standards. Therefore, the inclusion of RG address EMI specifically. Traditionally EQ 1.89 is appropriate given the consensus scope of does not include EMI which is why it has its EQ. No change to the RG was warranted.

own separate Regulatory Guide.

EPRI Page 30 - Section 6 (71) Is the MIL-STD-461G CS118 test an No change to the RG was made. The NRC has acceptable substitute for the IEC 61000-4-2 not reviewed MIL-STD-461G CS118. It was ESD test? issued very late in the development of the technical basis for revision of the RG and was not considered necessary given the availability of the longstanding guidance in IEC 61000-4-2.

EPRI Page 30 and 31 (72) New section 6 for Electrostatic discharge No change to the RG is made. No change is testing. Values identified are 8 kV for direct requested.

contact discharge and 15 kV for indirect air discharge. Assumes very low humidity but doesnt define a value; also assumes the use of synthetic fabrics but provides no technical basis.

37

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Page 31 - Section 7 (73) Suggest referencing MIL-STD-461G No change was made to the RG. The suggestion section 6.3 which points to DI-EMCS-80200 for would require adoption of an unreviewed the Electromagnetic Interference Test Report. standard/document (DI-EMCS-80200). The RG does not prohibit this format from being used.

EPRI Page 31 Section 7 (74) [here is where the admin controls over No change was made to the RG. There was no Documentation EMI / RFI sources is called out for those change requested.

looking for a procedural reference] -

requirements for organized, understandable, and traceable documentation that can be audited.

(Note this was in Rev.1) Added 5.6 Resolution of anomalies (good thing).

EPRI Section B (75) Recommend that either the "Reason for The NRC staff disagreed with the comment. The (pg. 5) Revision" or "Background" sub-sections endorsement of EPRI TR-102323, Rev. 0/1, has address why the NRC no longer endorses EPRI not been withdrawn. The RG has never TR-102323. It has been the key document for endorsed the EPRI guide and it is not necessary the nuclear industry for EMI for many years and to reference it. No change was made to the RG.

there needs to be a clear reason why this version of the RG is silent on the document.

EPRI Section B (76) Recommend providing a reference that The NRC staff disagreed with the comment.

(pg. 5) supports the claim in the first paragraph of There have been several research investigation 1st paragraph subsection "Background" that states "However, in the cited technical basis references and other the electronic architecture used with these project reports that support the statement. It is a technologies may be more sensitive to the valid statement. No change to the RG was nuclear power plant EMI/RFI environment than warranted.

existing I&C systems." If there is no research to support this claim, then recommend removing the statement.

EPRI Section B (77) Recommend deleting "recent". This The NRC staff agreed with the comment. The (pg. 5) wording is a holdover from the RG version that word "recent" was deleted from the cited 3rd paragraph was issued 15 years ago. Therefore, the word sentence.

3rd sentence "recent" no longer seems appropriate.

EPRI Section B (78) Recommend revising to remove the The NRC staff disagreed with the comment. The (pg. 5) statement "and non-safety-related I&C system emissions from non-safety-related systems and 38

Commenter Section of DG-1333 Specific Comments NRC Resolution th 4 paragraph whose failure can affect safety functions". The components can affect safety-related systems 2nd sentence wording is inconsistent with the title for the and functions. Controlling emissions from all regulatory guide which limits the guidance to new I&C systems is necessary to ensure that the "Safety-Related Instrumentation and Control operating envelopes (limits) remain valid. No Systems". The wording is inconsistent with the change to the RG is warranted.

title and involves expanding the scope of the guidance.

EPRI Page 5 - End of Second (79) This RG says it applies to digital and The NRC staff disagreed with the comment. The paragraph advanced analog systems. This should also guidance does not automatically apply to encompass simply replacement analog systems maintenance of existing I&C systems such as like-for-like modules. Can this (replacement/refurbishment with like-for-like guidance also be applied to electrical parts). Section D of the RG provides clear equipment? guidance regarding when this RG applies and how previously-established acceptable methods of compliance with regulations are treated. The scope of the equipment covered by the RG is limited to I&C systems. While the EMC practices in the RG can apply to electrical equipment, the full range of applicable practices and limits have not been identified for this guide. No change to the RG was warranted.

EPRI Page 5 (and more) (80) The use of advanced analog systems The NRC staff disagreed with the comment The needs some further technical basis or definition usage is consistent with prior versions of RG.

(term carried from Rev.1). The comment An extensive technical basis provided in cited electronic architecture used with these and other NUREG/CRs. No change to the RG is technologies may be more sensitive needs to warranted.

either be removed or provided with a technical basis - it appears to be the opinion of the author when using may be in the discussion.

EPRI Page 5 through 7 - (81) Discussion in last paragraph noting close The NRC staff disagreed with the comment The Section B proximity installations of non-safety equipment usage is consistent with prior versions of RG.

to safety-related equipment - needs to be further An extensive technical basis provided in cited defined or a technical basis provided. and other NUREG/CRs. No change to the RG is warranted.

39

Commenter Section of DG-1333 Specific Comments NRC Resolution EPRI Page 5 through 7 - (82) R.G. 1.180 Rev. 1 included a paragraph The NRC staff disagreed with the comment. The Section B documenting an endorsement of TR-102323 staff acceptance of EPRI TR-102323, Rev. 0/1, as an acceptable alternate approach. This as an acceptable method is not withdrawn nor is paragraph should be put back in R.G. 1.180 the EMC testing for any previously installed systems affected by this revised RG. Section D Rev. 2 to provide flexibility and make it of the RG provides clear guidance regarding clear TR-102323 is an acceptable method when this RG applies and how previously-for qualifying digital I&C equipment for established acceptable methods of compliance commercial nuclear licensees to they can with regulations are treated. Regarding whether choose either option. the revised RG mentions the EPRI guide, it is important to recognize that RG 1.180 has never endorsed any version of EPRI TR-102323. The reference to the SER and EPRI guide in prior versions of the RG occurred in the Discussion section (Section B) and served as background information providing context. This discussion was not considered necessary for this revision since the RG itself has been in use for almost 20 years so context should be well understood. No change to the RG is warranted.

EPRI Page 6 (83) the comment that the RG adjusts The rationale and technical support for changes frequency ranges when appropriate, and relaxes in the operating envelopes are described in the operating envelopes could use further referenced technical basis documents identified elaboration. Is the technical reference for such in Section B. Thus, no change to the RG is relaxation provided for those cases, and if so, warranted.

how?

EPRI Page 6 (84) Why are MIL STD and IEEE standards The NRC staff disagreed with the comment.

locked into specific versions while the IEC Given that substantial changes in the test standards are not? It would be preferred that methods and associated guidance can occur as none of them are locked in, and the latest these standards undergo revision (e.g.,

versions of all are what should be used. substantial changes in guidance transitioning between MIL-STD 461C + 462 and 461D +

462D), blind endorsement of future versions of any standard poses the risk that the effectiveness 40

Commenter Section of DG-1333 Specific Comments NRC Resolution of the endorsed method may be compromised by unreviewed changes. Consequently, the endorsements are limited to reviewed versions of the standards. Consequently, Therefore, NRC made no changes to the RG.

EPRI Page 7 (85) top full paragraph; implies that technical The NRC staff disagreed with the comment. The bases / documentation for planned locations background in the Discussion section provides needs to be prepared and maintained. information, not regulatory positions. The relevant regulatory position (in RP 1) occurs in the third paragraph of that position, which addresses the need to assess the electromagnetic environment at the point of installation and confirm that the operating envelopes maintain the margin above the expected environment. No change to the RG is warranted.

EPRI (86) It seems incomplete that the section titled No change was made to the RG. The current "Harmonization with International Standards" version of IEC 62003 is not considered adequate does not discuss IEC 62003 for endorsement so no harmonization was occurred.

EPRI (87) Revision 1 of the Reg Guide supported the No change to the RG was made. The IEEE use of IEEE 473 for EMI/RFI site surveys. This standard 473 was cited in the Discussion section standard has been withdrawn since it was of Revision 1 of the RG. It has never been outdated. It is currently going through the endorsed as part of the regulatory guidance.

revision process. While that could not be Future review and endorsement of the standard endorsed, it would be good to include a can be considered when it is reissued.

discussion on the use of in-situ EMI/RFI site surveys when allowing the use of modified or different electromagnetic operating envelopes.

EPRI Section C.1 (88) first of multiple instances where the 8 dB The NRC staff disagreed with the comment. The (pg. 8) margin is invoked. No technical basis for the basis for the margin was established in the SER margin is provided. and remains unchanged. It is noted that applicants and licensees are free to propose alternate methods for compliance with the 41

Commenter Section of DG-1333 Specific Comments NRC Resolution Commission's regulations. No change to the RG is warranted.

EPRI Page 8 (89) The following paragraph is confusing; The NRC staff disagreed with the comment. It is discusses multiple methods for equipment unclear to which paragraph the comment refers.

testing (physical configurations) which all However, the paragraph on testing configuration appear to be acceptable. The discussion offers relief from the interpretation of the prior continues with what appears to be permanent guidance that all possible configurations must record requirements for testing of I&C systems, be tested. The examples are given to illustrate including an indication of control of the E-M the concept of worst case for establishing environment. The top of Pag 9 includes a bounding configurations. The subsequent laundry list of items to be controlled. paragraph essentially repeats prior guidance from RG 1.180, Rev. 1, which has been in place for 15 years. No change to the RG was warranted.

EPRI Section C.1 (90) Recommend revising to remove the The NRC staff disagreed with the comment. The (pg. 8) statement "and non-safety-related systems and emissions from non-safety-related systems and 2nd paragraph components whose operation can affect safety- components can affect safety-related systems 4th sentence related system or component functions". The and functions. Controlling emissions from all wording is inconsistent with the title for the new I&C systems is necessary to ensure that the regulatory guide which limits the guidance to operating envelopes (limits) remain valid. No "Safety-Related Instrumentation and Control change to the RG is warranted.

Systems". The wording is inconsistent with the title and involves expanding the scope of the guidance.

EPRI Section C.1 (91) Recommend reducing the 8 decibel margin The NRC staff disagreed with the comment. The (pg. 8) requirement. This margin requirement is one of basis for the margin was established in the SER 3rd paragraph the primary obstacles to implementing and remains unchanged. It is noted that enhancements to the stations. It essentially applicants and licensees are free to propose imposes a 250% margin on exclusion distances. alternate methods for compliance with the Based upon changes to EMI regulations in other Commission's regulations. No change to the RG federally regulated industries like aviation and is warranted.

communications, this margin needs to be critically examined. The research, experience, 42

Commenter Section of DG-1333 Specific Comments NRC Resolution and improvements in devices can easily be used to justify the reduction of the 250% margin.

EPRI Section C.1 (92) The basis for an 8 dB margin should be The NRC staff disagreed with the comment. The (pg. 8) provided. basis for the margin was established in the SER 3rd paragraph on the EPRI guide and remains unchanged. No change to the RG is warranted.

EPRI Page 8 - C.1 3rd (93) "implemented as part of installation, The NRC staff agreed with the comment. The Paragraph maintained, and controlled." should be changed sentence was changed as follows.

to "implemented and controlled through installation and maintenance practices." "...implemented during installation and then maintained and controlled" EPRI Page 9 (94) Table 1 has changed from Rev.1 to include The NRC staff disagreed with the comment. The a General EMC Program. There are no Table was made complete to conform to current standards or other requirements listed - this RG style conventions. Thus, Regulatory appears to be a significant expansion in the RG. Positions 1 and 7 were described. No change to Electrostatic discharge testing is also new the RG was warranted.

(values discussed later) and appear significant.

Documentation was not previously listed in the table but was discussed elsewhere in Rev.1.

EPRI Pages 10 and 11 (95) references to the EPRI Guide from Rev.1 The NRC staff disagreed with the comment. The have been removed (with no explanation). staff acceptance of EPRI TR-102323, Rev. 0/1, as an acceptable method is not withdrawn nor is the EMC testing for any previously installed systems affected by this revised RG. Section D of the RG provides clear guidance regarding when this RG applies and how previously-established acceptable methods of compliance with regulations are treated. Regarding whether the revised RG mentions the EPRI guide, it is important to recognize that RG 1.180 has never endorsed any version of EPRI TR-102323. The reference to the SER and EPRI guide in prior versions of the RG occurred in the Discussion 43

Commenter Section of DG-1333 Specific Comments NRC Resolution section (Section B) and served as background information providing context. This discussion was not considered necessary for this revision since the RG itself has been in use for almost 20 years so context should be well understood. No change to the RG is warranted.

EPRI Pages 12 and 13 - C.3.2 (96) Table 2 of DG-1333 describes the CE102 The NRC staff agrees with the comment. The test from 10 kHz to 10 MHz which aligns with frequency range addressed in Section 3.2 was the range in MIL-STD_461G. The CE-102 corrected to address an upper range of 10 MHz.

testing is described in section 3.2 over the range The operating envelope plot (Figure 3.2) was of 10 kHz to 2 MHz where the MIL-STD-461G extended from 2 MHz to 10 MHz (@ 73 dB) test range is 10 kHz to 10 MHz. There is no explanation for the deviation from the MIL-STD-461G frequency range requirement.

EPRI Section C.3 (97) DG-1333 should include an endorsement The NRC staff agreed in part with the comment.

for FCC 47 CFR Part 15 Class A (and B) FCC certification can be credited in lieu of requirements. additional emissions testing for non-safety-related I&C systems over the frequency ranges covered by the certification. However, in the case of safety-related I&C systems, credit for this testing should be fully documented and available for review. The following paragraph was added to Section C.3.6 and the appropriate reference added:

Finally, Federal Communications Commission (FCC) certification for Class A or Class B devices under 47 CFR 15 may be credited over the frequency ranges covered by certification testing in lieu of additional testing for non-safety-related I&C systems. In order to take credit for FCC certification for safety-related I&C systems, test data and documentation equivalent to the information identified in 44

Commenter Section of DG-1333 Specific Comments NRC Resolution Regulatory Position 7 should be maintained and be available for review.

EPRI General (98) IEC Specifications not readily available for This comment requires no NRC action.

review. They are costly as obtained from the IEC. Did not review specifics for IEC testing.

SNC Section A (1) Comment: The NRC staff disagreed with the comment.

(pg. 3) RG 1.89, "Environmental Qualification of Electromagnetic conditions are identified as 5th bullet Certain Electric Equipment Important to Safety relevant service conditions and EMC testing is for Nuclear Power Plants" is listed in the included in the testing sequence within current "Related Guidance". However, the RG does not EQ standards. Therefore, the inclusion of RG address EMI specifically. Traditionally EQ 1.89 is appropriate given the consensus scope of does not include EMI which is why it has its EQ. No change to the RG was warranted.

own separate Regulatory Guide.

Proposed Resolution:

Recommend deleting the reference to RG 1.89.

SNC Section B (2) Comment: The NRC staff disagreed with the comment. The (pg. 5) EPRI TR-102323 has been the key document endorsement of EPRI TR-102323, Rev. 0/1, has for the nuclear industry for EMI for many years not been withdrawn. The RG has never and there needs to be a clear reason why this endorsed the EPRI guide and it is not necessary version of the RG is silent on the document. to reference it. No change was made to the RG.

Proposed Resolution:

Recommend that either the "Reason for Revision" or Background" sub-sections address why the NRC no longer endorses EPRI TR-102323.

SNC Section B (3) Comment: The NRC staff disagreed with the comment.

(pg. 5) There have been several research investigation 1st paragraph Proposed Resolution: in the cited technical basis references and other Recommend providing a reference that supports project reports that support the statement. It is a the claim in the first paragraph of subsection 45

Commenter Section of DG-1333 Specific Comments NRC Resolution "Background" that states "However, the valid statement. No change to the RG was electronic architecture used with these warranted.

technologies may be more sensitive to the nuclear power plant EMI/RFI environment than existing I&C systems." If there is no research to support this claim, then recommend removing the statement.

SNC Section B (4) Comment: The NRC staff agreed with the comment. The (pg. 5) This wording is a holdover from the RG version word "recent" was deleted from the cited 3rd paragraph that was issued 15 years ago. Therefore, the sentence.

3rd sentence word "recent" no longer seems appropriate.

Proposed Resolution:

Recommend deleting "recent".

SNC Section B (5) Comment: The NRC staff disagreed with the comment. The (pg. 5) The statement "and non-safety-related I&C emissions from non-safety-related systems and 4th paragraph system whose failure can affect safety components can affect safety-related systems 2nd sentence functions" is inconsistent with the title for the and functions. Controlling emissions from all regulatory guide which limits the guidance to new I&C systems is necessary to ensure that the "Safety-Related Instrumentation and Control operating envelopes (limits) remain valid. No Systems". The wording is inconsistent with the change to the RG is warranted.

title and involves expanding the scope of the guidance.

Proposed Resolution:

Recommend revising to remove the statement "and non-safety-related I&C system whose failure can affect safety functions".

SNC Section C.1 (6) Comment: The NRC staff disagreed with the comment. The (pg. 8) The statement " and non-safety-related systems emissions from non-safety-related systems and 2nd paragraph and components whose operation can affect components can affect safety-related systems 4th sentence safety-related system or component functions" and functions. Controlling emissions from all is inconsistent with the title for the regulatory new I&C systems is necessary to ensure that the guide which limits the guidance to "Safety-46

Commenter Section of DG-1333 Specific Comments NRC Resolution Related Instrumentation and Control Systems". operating envelopes (limits) remain valid. No The wording is inconsistent with the title and change to the RG is warranted.

involves expanding the scope of the guidance.

Proposed Resolution:

Recommend revising to remove the statement "and non-safety-related systems and components whose operation can affect safety-related system or component functions".

SNC Section C.1 (7) Comment: The NRC staff disagreed with the comment. The (pg. 8) The 8-decibel margin requirement is one of the basis for the margin was established in the SER 3rd paragraph primary obstacles to implementing and remains unchanged. It is noted that last sentence enhancements to the stations. It essentially applicants and licensees are free to propose imposes a 250% margin on exclusion distances. alternate methods for compliance with the Based upon changes to EMI regulations in other Commission's regulations. No change to the RG federally regulated industries like aviation and is warranted.

communications, this margin needs to be critically examined. The research, experience, and improvements in devices can easily be used to justify the reduction of the 250% margin.

Proposed Resolution:

Recommend reducing the 8 decibel margin requirement.

SNC Section C.1 (8) Comment: The NRC staff disagreed with the comment. The (pg. 10) The 8-decibel margin requirement is one of the basis for the margin was established in the SER 1st paragraph primary obstacles to implementing and remains unchanged. It is noted that 2nd sentence enhancements to the stations. It essentially applicants and licensees are free to propose imposes a 250% margin on exclusion distances. alternate methods for compliance with the Based upon changes to EMI regulations in other Commission's regulations. No change to the RG federally regulated industries like aviation and is warranted.

communications, this margin needs to be critically examined. The research, experience, 47

Commenter Section of DG-1333 Specific Comments NRC Resolution and improvements in devices can easily be used to justify the reduction of the 250% margin.

Proposed Resolution:

Recommend reducing the 8 decibel margin requirement.

SNC Section C.3 (9) Comment: The NRC staff disagreed with the comment. The (pg. 10 & 11) These two paragraphs seemingly contradict each RG states Either set of test methods should be 2nd paragraph other in regards to performing tests entirely applied in its entirety or in specified next-to-last sentence using one standard (military or IEC) and when combinations subject to the clarifications and 2nd paragraph 1st testing can be combined. A clarifying sentence conditions identified in the guidance below.

sentence would be helpful in removing uncertainty. Subsequently, the RG defines specific combinations and conditions in which the test Proposed Resolution: methods from one standard can be used to Recommend clarifying when military standards address coverage gaps in the other set of and IEC standards must be used in their entirety standards. The guidance is not contradictory. No and when then can be used in combination. change to the RG is warranted.

SNC Section C.3 (pg.13) (10) Comment: The NRC staff agreed with the comment. The Figures 3.2 and 3.3 It seems that Figure 3.2 has a second figure editorial problem resulted from formatting overlaid upon it while Figure 3.3 is missing. issues associated with Figure 3.3. The formatting of Figures has been corrected.

Proposed Resolution:

Recommend reformatting Figure 3.2 and Figure 3.3.

SNC Section C.3 (11) Comment: The NRC staff disagreed with the comment.

The proposed revision implies that licenses must Section D of the RG provides clear guidance use and adhere to the CISPR 16 tests referenced regarding when this RG applies and how in IEC 61000-6-4 when not testing to MIL- previously-established acceptable methods of STD-461. Currently, IEC 61000-6-4 compliance with regulations are treated.

incorporates the test methods of both CISPR 16 Therefore, NRC made no changes to the RG.

and CISPR 11 by reference. Because CISPR 11 was the only one referenced in IEC 61000-6-4 prior to 2006, the proposed guidance implies licensees will have to retest a considerable 48

Commenter Section of DG-1333 Specific Comments NRC Resolution number of legacy components in inventory without gaining any safety benefit. This effort would not only be very costly to licensees, but would likely delay beneficial modifications.

Proposed Resolution:

Recommend removing the explicit reference to only CISPR 16, or adding a statement that permits licensees to utilize components currently tested to older EMI/RFI certifications.

SNC Section C.3.6 (12) Comment: The NRC staff agreed in part with the comment.

(pg. 15) For the majority of evaluations, non-safety- FCC certification can be credited in lieu of related components are justified using this additional emissions testing for non-safety-alternative option related to FCC Part 15, Class related I&C systems over the frequency ranges A. Most non-safety-related vendors will not covered by the certification. However, in the perform separate testing in accordance with case of safety-related I&C systems, credit for military standards and IEC standards. However, this testing should be fully documented and they will provide a certificate of conformance available for review. The following paragraph with FCC Part 15 Class A. Without this option, was added to Section C.3.6 and the appropriate Licensees will have to perform unnecessary reference added:

testing which will provide no additional benefit Finally, Federal Communications Commission to nuclear safety. (FCC) certification for Class A or Class B devices under 47 CFR 15 may be credited over Proposed Resolution: the frequency ranges covered by certification Recommend keeping the alternative option of testing in lieu of additional testing for non-using FCC Part 15 Class A. safety-related I&C systems. In order to take credit for FCC certification for safety-related I&C systems, test data and documentation equivalent to the information identified in Regulatory Position 7 should be maintained and be available for review.

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Commenter Section of DG-1333 Specific Comments NRC Resolution SNC Section C.4.2 (13) Comment: The NRC staff agreed with the comment. The (pg. 21) identification of the standard in Table 13 has Table 13 Proposed Resolution: been corrected to MIL-STD-461G.

Recommend revising the title of Table 13 to use "MIL-STD-461G" instead of "MIL-STD-461E".

SNC General (14) Comment: The NRC staff disagreed with the comment. The In many instances, Licensees have not staff acceptance of EPRI TR-102323, Rev. 0/1, committed to RG 1.180 but do refer to EPRI as an acceptable method is not withdrawn nor is TR102323 in their procedures and analyses. the EMC testing for any previously installed The proposed version of the Regulatory Guide systems affected by this revised RG. Section D no longer mentions EPRI TR102323. The of the RG provides clear guidance regarding Licensees and their contractors heavily when this RG applies and how previously-reference and use EPRI TR102323. established acceptable methods of compliance with regulations are treated. Regarding whether Proposed Resolution: the revised RG mentions the EPRI guide, it is Recommend not deleting any reference or important to recognize that RG 1.180 has never mention of EPRI TR102323. endorsed any version of EPRI TR-102323. The reference to the SER and EPRI guide in prior versions of the RG occurred in the Discussion section (Section B) and served as background information providing context. This discussion was not considered necessary for this revision since the RG itself has been in use for almost 20 years so context should be well understood. No change to the RG is warranted.

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