ML20237D745
| ML20237D745 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1998 |
| From: | Christina Antonescu NRC (Affiliation Not Assigned) |
| To: | Mcknight J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-XX.XXX, TASK-*****, TASK-RE NUDOCS 9808270199 | |
| Download: ML20237D745 (41) | |
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4 August 24,1998 MEMORANDUM TO : Jim'McKnight Document Control Desk (DCD) t FROM:
Christina Antonescu, P. Manager Control, Instrumentation and Human Factor Branch, DST Office of Nuclear Regulatory Office
SUBJECT:
Request to Release Documents to the Public Enclosed (transmitted earlier) is a Summary of a public meeting and conference call that I would like to make available to the public. The public meeting was held on July 23,1998 ( Meeting Number 1998-0671) to discuss public comments on the draft regulatory guide DG-1029. A teleconference call was held on August 6,1998, as a follow-up to July 23,1998 public meeting. I
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would like to make this Summary available to the public! Please don't forget to include Attachments 1,2,3 and 4.
Ifyou have any questions please call me at 415-6792 until August 26,1998 and afterwards please call John Calvert at 415-6323. I will return back in the office on September 21,1999 I
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1 Public Meeting on Comments to DG-1029 Commencement of Public Meeting A public meeting was held in the morning of July 23,1998 and extended in the afternoon, at Two White Flint North, Rockville, Maryland, to discuss public comments on draft regulatory guide DG-1029, Guidelinesfor Evaluating Electromagnetic and Radio-Frequency Interference in Safety-RelatedInstrumentation and Control Systems. Prior to the meeting letter announce ments were sent out to all respondents to DG1029. This meeting was held at the request of the i
Nuclear Energy Institute (NEI) and was attended by representatives of the U.S. Nuclear Regulatory Commission (NRC), NEI, Electric Power Research Institute (EPRI), several utilities i
that operate nuclear power plants, Westinghouse (W), Characterization Engineering Services Inc.
(CIIAR) and the Oak Ridge National Laboratory (ORNL). See Attachment I for attendance list.
Christina Antonescu (NRC) began the meeting by welcoming the guests and stating that NRC encouraged interaction among the nuclear industry representatives and the public on issues of common concern. Ms. Antonescu pointed out that the NRC staff had developed a draft response to the public comments on DG-1029 and that this response was undergoing internal review.
Since the staff response to the public comments was predecisional, the specific comments and responses could not be discussed in detail. However, Ms. Antonescu suggested that discussions should focus on general technical issues with an effort to identify any additional concerns that should be considered. To provide a starting point for discussions, Ms. Antonescu proposed that ORNL, which provided the contractor support to assist NRC Office of Nuclear Regulatory Research in developing the technical basis for electromagnetic compatibility (EMC) guidance, describe the technical basis for the EMI/RFI operating envelopes presented in DG-1029.
Presentation of the technical basis for the DG-1029 ooerating envelones
- Richard Wood of ORNL presented the rationale for each electromagnetic operating envelope
- described in DG-1029. The technical basis for all of the EMI/RFI operating envelopes in DG-1029 begins with Military Standard (MIL-STD) 461 test limits corresponding to the electromagnetic environment in military ground facilities. The electromagnetic conditions in military ground facilities werejudged to be comparable to that of nuclear power plants based on general layout and equipment type considerations. Nuclear power plant emissions data were l
used to confirm the adequacy of the EMI/RFI operating envelopes. From the MIL-STD starting _
point, susceptibility envelopes were adjusted to account for plant emissions data available from the site surveys reported in NUREG/CR-6436 and in EPRI TR-102323. Adjustments to the emissions envelopes were based on providing adequate margin with the susceptibility envelopes.
Finally, when changes to the operating envelopes were motivated by tecimical considerations, consistency among the envelopes for comparable test criteria from similar suites of test methods (e.g., between MIL-STD 461D and MIL-STD 461C or between the DG-1029 and the Safety Evaluation Report (SER) on EPRI TR-102323) was factored into the adjustments.
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Dr. Wood's presentation illustrated the rationale for the operating envelopes for each EMI/RFI test by showing comparative plots of the MIL-STD 461D and 461C test limits, nuclear power plant electromagnetic emissions data, EPRI TR-102323 operating envelopes, and DG-1029 operating envelopes (see Attachment 2). The presentation proceeded with a discussion of the operating envelopes according to test type. First, the operating envelopes for conducted EMI/RFI susceptibility tests in the low frequency band (30 Hz to 50 kHz) and high frequency band (10 kHz to 400 MHz) were presented. This discussion was followed by descriptions of the l
' operating envelopes for radiated EMI/RFI susceptibility tests in the low frequency band (30 Hz to 100 kHz) and high frequency band (10 kHz to 1 GHz). Next, the operating envelopes for conducted electromagnetic emissions tests in the low frequency band (30 Hz to 10 kHz) and high l
frequency band (10 kHz to 10 MHz) were presented. Finally, the operating envelopes for radiated electromagnetic emissions tests in the low frequency band (30 Hz to 100 kHz) and high l
frequency band (10 kHz to 1 GHz) were discussed.
l-During the presentation of the' operating envelopes for the EMI/RFI susceptibility tests, there was l
some discussion about the electromagnetic survey data. First, Jim Shank of Public Service l
Electric and Gas (PSE&G) observed that the EPRI conducted emissions data included measurements around the ac powerline frequency (60 liz) so the relatively high amplitude in the data below 120 Hz is to be expected. Therefore, the determination of margins between the data and susceptibility envelopes in this very low frequency band should account for this consideration. Second, Carl Vitalbo (W) inquired about the differences between the plant I
emissions data measured in the EPRI survey and the plant emissions data measured in the ORNL survey. Dr Wood explained that EPRI's measurements were taken over a limited time period at l
a plant using a spectrum analyzer while ORNL's measurements were taken over an extended time period at a plant using electromagnetic receivers. The significantly longer observation l
I period permitted the capture ofless frequent, higher magnitude events during the ORNL survey while the differences in measurement devices (e.g., detection method and measurement bandwidth) also contributed to the higher magnitude observations of electromagnetic fields by ORNL. Third, it was observed that the plot showing EPRI emissions data for radiated electric fields did not include high magnitude, narrow bandwidth emissions from communications devices. Dr. Wood explained that these field strength contributions were omitted to simplify the plot. In EPRI TR-102323, these emissions were reported to result from specific deliberate action, the sources were clearly identified, and the EPRI guidance addresses such emissions through administrative control (i.e., exclusion zones) rather than as part of the operating envelopes for susceptibility testing.
As part of the discussion on susceptibility testing, Mr. Vitalbo observed that it would be difficult for display devices such as cathode ray tubes (CRTs) to pass radiated susceptibility tests for electric fields if the 10 V/m operating envelope is applied. This issue arises in the guidance l provided by both DG-1029 and EPRI TR-102323. Mr. Vitalbo suggested that radiated E susceptibility requirements for display devices be reconsidered or that a lower envelope be permitted in areas where administrative controls on emissions levels are in place. It was noted that the operating envelopes represent general guidance that encompasses several plant locations
3 without requiring additional plant emissions measurement but the user may providejustification with a valid technical basis to support the use of alternate operating envelopes.
In presenting the operating envelopes for electromagnetic emissions testing, Dr. Wood pointed out that ORNL had erred in adapting the MIL-STD test limits for the low frequency conducted emissions tests. In the MIL-STD, two separate limits are provided for ac-powered equipment based on power consumption level. In developing the technical basis for recommendations on operating envelopes, ORNL had inadvertently omitted the envelope corresponding to low power equipment (< 1 kVA). This oversight could have potentially result in testing conditions where some ac-powered equipment would fail the test by design, as observed in public co:nments on DG-1029. Therefore, ORNL has provided corrected recommendations that are being reviewed I
for use in the Final Regulatory Guide.
The most significant difference between the operating envelopes presented in EPRI TR-102323 j
and those described in DG-1029 occurs in the comparison of emissions envelopes. The discussion concerning these emissions envelopes focused on their technical bases. A common observation in public comments on DG-1029 was that the emissions envelopes in DG-1029 were too restrictive and were based on MIL-STD limits that were designed to protect highly sensitive equipment on military platforms. Mr. Shank stated that the emissions envelopes in EPRI TR-102323 provide sufficient margin below the comparable susceptibility envelopes (20 dB or greater) and account for industrial emissions limits for commercial equipment. These emissions envelopes permit the use of commercial equipment that meet Federal Communications l
Commission (FCC) emissions guidelines while still providing adequate margin to ensure safety.
Dr. Wood noted that a review of the underlying technical basis for the MIL-STD limits indicates that the conducted emissions envelopes are based on consideration of power quality, which is a common issue for military platforms and nuclear power plants. In addition, the FCC Class A and i
International Special Committee on Radio Interference (CISPR) Class A emissions limits, which correspond to industrial environments, are comparable in level to the high frequency conducted emissions envelope described in DG-1029. However, the MIL-STD basis for high frequency radiated emissions control is related to protecting sensitive receivers on military platforms.
Therefore, there is technical justification for relaxing that emissions envelope. A comparison with the FCC and CISPR radiated emissions limits for industrial environments appears to be a sound basis for raising the envelope level. ORNL is providing modified emissions envelope recommendations for NRC review and possible use in the Final Regulatory Guide Mr. Vitalbo observed that the plant emissions data exceeded both the DG-1029 and EPRI TR-102323 conducted emissions envelopes in several cases. The question was raised as to whether this indicates that there will be some difficulty in finding commercial equipment that can pass the conducted emissions tests, especially equipment containing a switching power supply. It was noted that the low frequency conducted emissions tests in DG-1029 and EPRI TR-102323 can be exempted in cases where power quality criteria with a valid technical basis are employed. In addition, the high frequency conducted emissions operating envelopes are of comparable level with FCC and CISPR industrial environment emissions limits (which are less restrictive than the
4 FCC and CISPR residential environment emissions limits) so commercial equipment that meet those criteria may be suitable.
Presentation of Nuclear Power Industry Comments on DG-1029 Jim Shank of PSE&G presemed the NEI comments on DG-1029 (see Attachment 3). Mr. Shank described the nuclear power industry acceptance and use of the EMC guidance in EPRI TR-102323. The main concern expressed by NEI regarding DG-1029 is that it is inconsistent with the Safety Evaluation Report (SER) on EPRI TR-102323 that was dated April 17,1996. The most significant differences posed by the draft regulatory guide position are overly conservative emission limits, limitation of testing options to MIL-STD methods, and the applicability of the guidance to replacement equipment. NEl believes that the additional conservatism included in the DG-1029 emissions envelopes is unwarranted. Considering the previous presentation by
. ORNL, Mr. Shank noted that the modifications to the envelopes under consideration by NRC are a welcome development. There is still concern that the guidance in DG-1029 limits testing options to the military standards. The International Electrotechnical Commission (IEC) standards [IEC 801 and IEC 61000] represent widely used methods that the nuclear power industry contends they should be allowed to employ as optional methods. The issue of applicability for DG-1029 involves the coverage of analog and hybrid systems and the potential impact of that position on existing licensing bases. EPRI TR-102323 applies specifically to electromagnetic compatibility of digital equipment. Carl Vitalbo (W) observed that analog electronic components sometimes demonstrate more susceptibility to EMI/RFI and hardening analog equipment could result in much higher costs to the user. NEI concluded that DG-1029 is at variance with EPRI TR-102323 and its application could lead to increased costs with no added safety benefits. Mr. Shanks stated that NEI recommends a revision of DG-1029 to address concerns expressed in public comments and to bring the regulatory guidance more into alignment with the industry developed guidance in EPRI TR-102323.
I Ramesh Shankar (EPRI) stated that a primary motivation for the meeting with NRC staff was to clarify the status of the SER on EPRI TR-102323. There was concern that the regulatory guide signaled a withdrawal of support for the SER position. Matt Chiramal (NRC) reiterated that the SER stands as an acceptable method. Eric Lee (NRC) noted that the regulatory guide is one acceptable method of addressing EMI/RFI while the SER endorses another method that is also acceptable. Mr. Shankar requested that this point be made more strongly in DG-1029 to avoid possible misinterpretation.
Dr. Wood (ORNL) described the anticipated benefits of providing the guidance contained in DG-1029. First, the draft regulatory guide endorses an updated standard (IEEE 1050-1996) that corrects some previous errors and is more user friendly. Second, DG-1029 accounts for additional technical evidence developed in the intervening time since the issuance of the SER.
l As an example, the plant emissions data taken in the ORNL survey provide greater confidence t
that the susceptibility envelopes adequately characterize the general electromagnetic environment at selected locations in U.S. nuclear power plants. Therefore, the responsibility of the user in
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applying these envelopes for a particular plant is more clearly defined in terms of an area of installation assessment to identify any unique EMI/RFI emissions sources. Third, the draft regulatory guide provides additional clarity on some EMC issues. For example, DG-1029 j
presents operating envelopes that are tailored for the specific test methods (i.e., are given in the i
proper measurement units over the frequency ranges that correspond to specific tests) so the user l
is not required to convert the envelopes to different units based on key assumptions or to justify l
the application of test methods in extended frequency bands. In addition, guidance on the types of documented evidence that are acceptable is given in DG-1029.
The earlier presentation by ORNL on the rationale for the operating envelopes presented in DG-l 1029 had identified most of the concerns regarding the perceived conservatism in the electromagnetic emissions envelopes. Mr. Shank stated that this issue was the primary factor in i
the expressed concern over compliance costs. Again, the participants in the meeting expressed l
the hope that the NRC proposed modifications to those envelopes that are under consideration by NRC would alleviate those concerns.
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The issue of flexibility in the selection of testing standards was discussed. The public comments from NEI had taken issue with the absence ofIEC 801 from the regulatory position in DG-1029.
Dr. Wood explained that IEC 801 still contains draft parts and is therefore not a final standard.
For this reason, IEC 801 was not included as part of DG-1029. In addition, IEC 61000 was not included as part of DG-1029 because it has not yet been reviewed by NRC. It was noted that the absence of an endorsement ofIEC 801 or IEC 61000 in DG-1029 does not preclude their use, j
l The SER position describes an acceptable method that includes IEC 801 as an option. In j
l addition, the user of the guidance from DG-1029 is free to employ IEC 801 or IEC 61000 instead
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i of the MIL-STD test methods provided technical justification for their equivalence is provided.
l Mr. Shank stated that endorsement ofIEC 61000 would be most valuable and he encouraged I
NRC to evaluate that standard in the near term. John Butler (NEI) requested clarification on the term " consensus." Dr. Wood stated that, in this context, " consensus" was intended to describe de jure standards that have been balloted and approved by their governing body In the case ofIEC 801, there remains some parts that are still in draft form and are unlikely to receive approval since the entire standard has been superseded by IEC 61000. Since the MIL-STD methods are l
developed and approved by an exclusive board, it was agreed that perhaps " finalized" or i
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" balloted" would be more appropriate than " consensus." A final comment concerning IEC 801 was made by Mr. Vitalbo concerning experience with that testing standard. Mr. Vitalbo stated that IEC 801 parts 2,3, and 4 are stable, useful metho' while the draft parts ofIEC 801 (parts 5 and 6) are not practical because of their cumbersome, confusing procedures.
Applicability of DG-1029 beyond new digital systems was also discussed. The expressed concern over applicability is twofold. First is the issue of whether the expense of providing a
" bulletproof" ccmponent to modify an existing system is justified when the full system is still potentially vulnerable (or at least has not been qualified by EMI/RFI testing) since electromagnetic compatibility was not part ofits original licensing basis. Second is the question of whether applying the guidance to all safety-related modification (digital, analog, or hybrid)
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6 will require more extensive modifications to the system so that the full system demonstrates electromagnetic compatibility. It was agreed that the term " upgrade" might lead to uncertainty about the range of application of DG-1029. NRC is considering a change in wording to
" modification" rather than " upgrade" to clarify that replacement parts are not included in this guidance. Mr. Shankar stressed the concern about modifications to existing systems which do not include EMI/RFI as part of their licensing basis. John Calvert (NRC) noted that General Design Criterion (GDC) 4 of Appendix A in the Code of Federal Regulations (CFR) Title 10,
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Part 50 reycires that systems be designed to be compatible with environmental service conditions, which include die ambient electromagnetic environment at nuclear power plants.
Therefore, while EMI/RFI may not have been specifically addressed in previous guidance, it is part of the licensing basis through GDC 4. Mr. Vitalbo suggested that an exemption to parts and pieces of upgrades be considered for inclusion in DG-1029. He gave regulatory position 6 of I
Regulatory Guide 1.89 as an example which gives exemption for replacement equipment installed ifit required significant plant modification. Mr. Shankar suggested that a transition plan be developed for informing the licensees that EMC issues apply to safety-related analog i
equipment as well as digital equipment. Mr. Shankar asked if DG-1029 constituted the only acceptable method for evaluating analog modifications. Mr. Chiramal stated that it seemed l
reasonable for the EPRI TR-102323 approach to be used for analog equipment as well.
i Open Discussions Following the presentations, the general issues common to many of the public comments received on DG-1029 were reviewed by Ms Antonescu in the afternoon open discussion. These issues consisted of the following: (1) comparison of DG-1029 and the SER on EPRI TR-102323; i
(2) prescriptiveness of DG-1029; (3) scope of application for DG-1029 guidance, including existing plants vs. new plants, definition of upgrade, testing at the plant site, additional site measurements, and coverage of analog and hybrid equipment; (4) DG-1029 position on other testing options; (5) endorsement of MIL-STD 461C; (6) rationale for DG-1029 EMI/RFI operating envelopes; (7) rationale for DG-1029 power surge test levels; (8) limiting practices endorsed in DG-1029; (9) documentation identified in DG-1029; (10) cost / impact of DG-1029; and (11) additional guidance suggested by commentors for DG-1029, including extending EMI/RFI operating envelopes above 1 GHz, addressing signal line susceptibility, and power quality and power systems. In many instances, previous discussions during the meeting had identified NEI's concerns on specific issues. However, there were some additional points brought up in the subsequent discussions.
Regarding cost concerns arising from the guidance in DG-1029, Jim Shank (PSE&G) stated that main issues involve the conservative emissions limits, the perceived lack of flexibility in selecting testing methods from the international standards bodies, and the inclusion of analog equipment under the EMI/RFI guidar ce. Mr. Shank stated that the restrictive limits for emissions were the primary cost concern. However, with the proposed modifications everybody agreed that this concern is being addressed.
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7 The discussion on the need for additional site measurements brought agreement that both the SER and DG-1029 positions are intended to sufficiently characterize the ambient electromagnetic conditions at nuclear power plants that no additional measurements would be required in most instances. Mr. Shank stated that NEI's interpretation of the SER position is that the EPRI TR-102323 limits can be applied as long as the user determines that the installation site contains the same or similar types of equipment as that present in the seven plants that participated in the EPRI survey. Ramesh Shankar (EPRI) asked that the data from the ORNL survey be made available, perhaps via the internet. Ms Antonescu (NRC) provided a copy of NUREG/CR-6436, which reports the ORNL data, to Mr. Shankar and reminded the attendees
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i that this document was publicly available.
t Wrap-up Ms. Antonescu (NRC) and Mr. Shankar (EPRI) summarized the important benefits of this type of exchange between the NRC and the nuclear power industry. Mr. Shankar stated four resolution items for NRC attention that result from this meeting. First, the electromagnetic emissions envelopes presented in DG-1029 v,ill be brought more into alignment with those in EPRI TR-102323. Mr. Shankar was encouraged by the potential modifications under NRC consideration. Second, the discussion in DG-1029 will emphasize greater flexibility in the use of l
other standards for demonstrating electromagnetic compatibility. Third, a stronger statement on the acceptability of continued usage of the EPRI TR-102323 approach will be added to DG-1029. Fourth, plant emissions data from the ORNL survey of electromagnetic conditions at nuclear power plants will be made available to the industry. Ms. Antonescu identified L
NUREG/CR-6436 as the primary source for accessing this data and stated that efforts will proceed to make the summary data available on the internet.
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8 Public Teleconference on Comments to DG-1029 A teleconference was held on August 6,1998, as a follow-up to the July 23,1998 public meeting to discuss public comments on draft regulatory guide DG-1029, Guidelinesfor Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and ControlSystems. The primary focus of this conversation was proposed modifications to the EMI/RFI operating envelopes presented in DG-1029. Participants were Christina Antonescu, John Calvert, Joel Kramer, and Eric Lee of the U.S. Nuclear Regulatory Commission (NRC),
Ramesh Shankar of Electric Power Research Institute (EPRI), Carl Yoder of Baltimore Gas and Electric (BGE), and Richard Wood of the Oak Ridge National Laboratory (ORNL). Ms.
Antonescu reviewed the four resolution items identified by Ramesh Shankar from the public meeting on July 23. Efforts are being made to resolve items 2 and 3. Items 2 and 3 involved
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wording changes to DG-1029 that would emphasize greater flexibility in the use ofintemational standards to demonstrate electromagnetic compatibility (EMC) and that would more strongly state that continued usage of EPRI TR-102323 was still acceptable. Ms. Antonescu stated that those wording changes were under review and should be finalized soon. Item 4 involved accessibility of the plant emissions data from the ORNL survey of electromagnetic conditions at nuclear power plants. Ms. Antonescu had previously provided NUREG/CR-6436 to Mr. Shankar to fulfill this action. Item I concerned modifications to the electromagnetic emissions envelopes presented in DG-1029 so that they would be more in alignment with the emissions envelopes presented in EPRI TR-102323. Ms. Antonescu had previously forwarded plots of proposed modifications to the envelopes from ORNL to Mr. Shankar (see Attachment 4 and 5). Mr. Wood discussed the rationale behind the proposed modifications to the emissions envelopes.
The conducted emissions envelopes ure based on MIL-STD limits. These limits in turn are primarily based on controlling harmonic distortions introduced by equipment to the power distribution system. The technical basis for the limits is to maintain no more than 5% total harmonic distortion on the power distribution system of the military platform with no more than a 3% contribution from a single harmonic. The rationale in the appendix of MIL-STD 461D also states that total harmonic distortion (TliD) that is greater than "5% is above the tolerance of most electronic equipment, induction motors, magnetic devices, and measuring devices." The same equipment are of concern for nuclear power plants. Therefore, the MIL-STD limits provide a sound basis for the DG-1029 envelopes. The exception for the conducted envelopes is the highest frequency band corresponding to CE102 (conducted emissions, power lead, high frequency) from MIL-STD 461 D and CE03 (conducted emissions, power lead, high frequency) from MIL-STD 461C. The MIL-STD rationale indicates that these levels are based on controlling potential radiated EMI that could affect sensitive receivers, which are not normally present in nuclear power plants. Therefore, it was proposed that the levels in the low frequency band of these envelopes remain unchanged while the levels in the higher frequency band are raised for application to nuclear power plants. The proposed changes use the International Special Committee on Radio Interference (CISPR) Class A (i.e., industrial environments) and Federal Communications Commission (FCC) Class A conducted emissions levels as the basis for setting the emissions envelope levels in DG-1029. Thus, it was proposed that each envelope l
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l retain the low frequency slope and levels that are based on power quality consideration but that j
the upper frequency levels be adjusted to encompass the CISPR and FCC limits.
l The radiated emissions envelopes are also based on MIL-STD limits. The operating envelope for low frequency radiated emissions was originally adjusted from its MIL-STD starting point to provide adequate margin with the comparable operating envelope for low frequency radiated susceptibility. It was proposed that this envelope be made consistent in level with the equivalent envelope in EPRI TR-102323. This proposed change contributes to consistency between DG-1029 and EPRI TR-102323 where the technical basis supports it. A review of the MIL-STD rationale for the high frequency radiated emissions limit indicates that the primary intent of the RE102 (radiated emissions, electric field, high frequency) test is to protect sensitive receivers.
However, the levels for the low frequency band (<2 MHz) were based on the levels from CE102 (conducted emissions, power lead, high frequency), which address power quality. Therefore, it was proposed that the levels for the envelopes be raised but that the slope of the lowest frequency band (which is related to the CE102 envelope) be maintained. The proposed changes for the highest frequency component used the CISPR and FCC Class A radiated emissions levels as the basis for setting the DG levels above 25 MHz. Thus, it was proposed that the high frequency radiated emissions envelope corresponding to RE102 retain the low frequency slope at levels comparable with those endorsed in the SER but that the upper frequency levels be set to encompass the CISPR and FCC limits. It was also proposed that the RE02 (radiated emissions, electric field, high frequency) narrowband envelope adopt the RE102 envelope shape and level.
Additional modifications (not shown in the attached plots) to the electromagnetic emissions envelopes in DG-1029 were discussed based on further review by NRC. These potential modifications would completely encompass the FCC and CISPR Class A emissions limits for high frequency radiated emissions and high frequency conducted emissions. Therefore, equipment that passed the FCC or CISPR tests would fulfill the DG-1029 guidance in those l
relevant frequency ranges. However, the user would still need to demonstrate compliance with the emissions envelopes in the frequency ranges not covered by FCC or CISPR.
Carl Yoder (BGE) brought up the issue of the responsibility of the user to confirm the applicability of the operating envelopes to a particular nuclear power plant. In the Safety Evaluation Report (SER) on EPRI TR-102323, the guidance states that the EPRI envelopes can be applied if the electromagnetic environment at the user's plant is similar to the that of the seven l
plants that participated in the EPRI electromagnetic survey. In DG-1029, the guidance states that the user must assess the electromagnetic environment in the area ofinstallation to identify any unique EMI/RFI emissions sources. Mr. Yoder is concerned that utilities might be required to prove that there are nn conditions that could drive that plant's electromagnetic environment outside of that environment modeled by the operating envelope. Eric Lee (NRC) stated that this is not the intent of either guidance. Mr. Yoder requested that wording changes be considered for DG-1029 and the SER on EPRI TR-102323 to avoid misinterpretation of the intent of this guidance. The NRC said that they would consider the merits of the request.
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