ML20216E105

Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys

ML20216E105
Person / Time
Site:	Comanche Peak
Issue date:	04/07/1998
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR7844, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 63FR7844-00006, 63FR7844-6, NUDOCS 9804160089
Download: ML20216E105 (5)

Text

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, Dec o$ 6 3 FR Myg mammm m mme. 2-)7 o g g Log # TXX-98112

- .= File # 10186 r C Ref. # 63FR7844 1UELECTRIC April 7. 1998 c.i m c. n rry r$nc I OBEcer Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555 00001

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

COMMENTS ON DRAFT REGULATORY GUIDE DG 1029. " GUIDELINES FOR EVALUATING ELECTROMAGNETIC AND RADIO-FREQUENCY INTERFERENCE IN SAFETY-RELATED INSTRUMENTATION AND CONTROL SYSTEMS" REF: 1) Federal Register. Volume 63. No. 31. February 17, 1998.

Page 7844. Draft Regulatory Guide: Issuance. Availability Gentlemen:

By Federal Register notice dated February 17, 1998 (Reference 1), the NRC issued for public ccament a draft "egulatory guide (DG-1029) titled

" Guidelines for Evaluating Electromagnetic and Radio-frequency Interference in Safety related Instrumentation and Control Systems."

Comments were requested to be submitted by April 10. 1998. TV Electric has participated in the EPRI Utility EMI/EMC Working group to review the draft guideline and endorses the #ctached working group comments in response to Reference 1.

TV Electric appreciates the opportunity to comment on this draft i regulatory guide and requests that the Commission or NRC staff contact {

Janardan Amin at (254) 897 6469 if there are any questions.  !

l Sincerely, g 41g g 980407 C. L. Terry XX.XXX C PDR By: e491 HOWd 0 gyIII3 1 ry A airs Manager l t

-MJR/jrh 8 U U 8dV Ed61 l Attachmen 3bl303d l COMANCilE PEAK STEAM ELECTRIC STATION P.O. Box 1002 Glen Rose. Texas 76043-1002

l I-TXX 98112 Page 2 of 2 i

L c- E. W. Herschoff. Region IV l

J. I. Tapia, Region IV T. J. Polich, NRR-

! Resident Inspectors, CPSES r

John Butler i Nuclear Energy Institute 1776_I. Street, NW, Suite 400 Washington, DC 20006-3708 i

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( Attachment l EPRI/ Utility Electromaanetic Interference (EMI) Workino Grouc l

Coments on l

l U.S. Nuclear Regulatory Commission Office of Nuclear Regulatory Research l Draft Regulatory Guide DG 1029. " Guidelines for Evaluating Electromagnetic l and Radio Frequency Interference in Safety Related Instrumentation and ,

l Control Systems" j 1.) Page 5. Paragraph 3 Reference to IEEE Std. 473 1985 is not

, appropriate for consideration of relaxing all operating envelopes and in fact it only covers radiated measurements from 10 kHz to 10 Ghz.

I 2.) Page 6. Paragraph 2 Lack of endorsement of IEC Std. 801 is not consistent with the EPRI Report TR 102323 guidance endorsed by the l NRC staff via SER. Improvements and development of these standards i should not preclude their endorsement by the staff.

l 3.) Page 9. Section 3 Although endorsement of MIL STD 461C & 462C l demonstrates the acceptance of equipment previously tested and l evaluated for the effects of EMI/RFI on equipment, this standard was superseded by MIL STD-461D and 462D in January 1993. It should be made clear that new equipment should be tested and evaluated in accordance with the latest revision of the standard. l l

4.) Page 11. Paragraph 2 - DG 1029 states that " Equipment tested under comparable power quality guidance should be exempt from this test."

l It is not clear what constitutes " comparable power quality guidance." Equipment should be exempt from CE101 testing when adequate demonstration for controlling low frequency conducted l emissions by design has been demonstrated. For most applications l

this is a low value added test.

l 5.) Page 11, Figure 4.1 The emissions limit for AC Power Leads is excessively restrictive compared to other standards. No justification was provided for deviation from the less restrictive equipment emissions limits previously endorsed for low frequency conducted equipment emissions via TR 102323 and the newly l established limits from MIL STD 4610. For an endorsement of MIL-STD 461D emissions limits. Figure CE1014 for source voltages above 28 V would be more appropriate and not compromise adequate safety margin.

6.) Page 12. Figure 4.2 No justification was provided for deviation I from the less restrictive equipment emissions limits previously endorsed for highfrequency conducted equipment emissions via TR-102323 and the more restrictive limits proposed from MIL STD-4610.

The previously established safety margin was adequate.

7.) Page 15. Figure 4.5 - No justification was provided fo- deviation from the less restrictive equipment emissions limits previously endorsed for low-frequency radiated equipment emissions vid TR-102323 and the more restrictive limits proposed from MIL-STD 4610.

Equipment should be exempt from RE101 testing when adequate demonstration for controlling low frequency radiated emissions by design has been demonstrated. For most applications this is a low value-added test due to the rapid decline of magnetic fields over short distances.

8.) Page 16. Figure 4.6 - The RE102 equipment emissions limit is excessively restrictive compared to other standards. No justification was provided for deviation from the less restrictive equipment emissions limits previously endorsed for high frequency radiated equipment emissions via TR 102323 and the newly established limits from MIL-STD-461D. The previously established safety margin was adequate when considering the use of administrative controls.

9) Page 16. Paragraph 1 - RS101 is typically a low valua added test with few applications of concern due to the rapid decline of magnetic fields over short distances. The applications of concern should be clearly documented and this test be made optional for equipment outside the applications of concern.

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10.) Pages 18 Although endorsement of MIL STD-461C & 462C demonstrates the acceptance of equipment previously tested and evaluated for the effects of EMI/RFI on equipment, this standard was superseded by MIL-STD-461D and 462D in January 1993. It should be made clear that new equipment should be tested and evaluated in  ;

accordance with the latest revision (Rev. D) of the standard. Both j susceptibility and emissions limits should be comparable to those recommended from MIL STD-461D providing due consideration for differences between the tests. Some differences in acceptable limits were noted.

11.) Pages 26 30 Endorsement of IEEE Stds. C62.41 and C62.45 for surge withstand and electrically fast transients for the waveforms of Table 3 (page 26) was consistent with the endorsement of TR-102323 guidance for the same, however similar testing successfully performed in accordance with applicable IEC standards should be documented as acceptable.

12.) General The future of EMI/RFI testing is in International Electrotechnical Community (IEC) standard 1000 which should be i endorsed by DG 1029. As noted in the conclusion of NUREG/CR-6431 )

the Department of Defense has moved away from the use of MIL-STD 461 l

& 462 and has instead emphasized the purchase of commercial off-the-shelf (C0TS) equipment with applicable commercial EMI/Rrl testing qualifications. For a design guide applicable to future nuclear power plants, endorsement of an industry supported standard like IEC 1000 is highly recommended.  !

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I- 13.) General The extension of this design guide to new analog and hybrid systems of presently operating nuclear power plants planning on upgrading safety elated I&C systems has a significant cost impact. . A cost versu; safety benefit should be developed to justify this impact.

( 14.) General - A clear statement addressing backfit that " grandfathers" l equipment and systems installed priot to the issuance of DG 1029 l needs to be added to this regulatory guide.

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