april 30, 2007 memorandum to: george a. wilson, branch chief

April 30, 2007

MEMORANDUM TO: George A. Wilson, Branch Chief Electrical Engineering Branch

Division of Engineering Office of Nuclear Reactor Regulation

FROM: Nitin Patel /RA/ Electrical Engineering BranchDivision of Engineering

Office of Nuclear Reactor Regulation

SUBJECT: RESOLUTION OF THE INDUSTRY COMMENTS FROM NUCLEAR UTILITY GROUP EQUIPMENT QUALIFICATION ONPROPOSED REVISION TO STANDARD REVIEW PLAN (SECTION 3.11, “ENVIRONMENTAL QUALIFICATION OFMECHANICAL AND ELECTRICAL EQUIPMENT”

(TAC NO MD1887)

The Electrical Engineering Branch has reviewed the comments provided by the industry

group Nuclear Utility Group Equipment Qualification (NUGEQ) by letter dated

February 09, 2007 on Standard Review Plan (SRP) 3.11. The SRP 3.11 was revised to

incorporate the appropriate NUGEQ comments and issued on March 28, 2007 (ML063600397).

The Resolution of NUGEQ comments is provided in the enclosure.

Enclosure: As stated

CONTACT: Nitin Patel, DE/EEEB (301) 415-3201

April 30, 2007

MEMORANDUM TO: George A. Wilson, Branch Chief Electrical Engineering Branch

Division of Engineering Office of Nuclear Reactor Regulation

FROM: Nitin Patel /RA/ Electrical Engineering Branch Division of Engineering

Office of Nuclear Reactor Regulation

SUBJECT: RESOLUTION OF THE INDUSTRY COMMENTS FROM NUCLEAR UTILITY GROUP EQUIPMENT QUALIFICATION ON PROPOSED REVISION TO STANDARD REVIEW PLAN (SECTION 3.11,“ENVIRONMENTAL QUALIFICATION OF MECHANICAL AND ELECTRICAL EQUIPMENT” (TAC NO MD1887)

The Electrical Engineering Branch has reviewed the comments provided by the industry

group Nuclear Utility Group Equipment Qualification (NUGEQ) by letter dated

February 09, 2007 on Standard Review Plan (SRP) 3.11. The SRP 3.11 was revised to

incorporate the appropriate NUGEQ comments and issued on March 28, 2007 (ML063600397).

The Resolution of NUGEQ comments is provided in the enclosure.

Enclosure: As stated

DISTRIBUTION: C. Nguyen S. Koeinick

ADAMS ACCESSION No: ML071200288

OFFICE DE/EEEB BC:EEEB

NAME N. Patel G. Wilson

DATE 04/25/07 04/30/07

OFFICIAL RECORD COPY

ENCLOSUREPage 1 of 55

Resolution of NUGEQ Comments on SRP Section 3.11, Rev. 3, 2007 (ML062180004)Prepared April 04, 2007

No. NUGEQ Comment NUGEQ Recommended Change NRC Staff Resolution Changes Made to SRP 3.11

I. Progressive Deterioration of SRP 3.11 Guidance

The NUGEQ after careful review has concludedthat both the 1996 and the recent (2006) drafts ofSRP 3.11 represent a progressive deteriorationwith respect to establishing clear, concise,unambiguous guidance to applicants andreviewers that is both internally consistent andconsistent with other regulatory (e.g., SRP andregulatory guide) guidance. We question theability of the SRP 3.11 2006 proposed revision(“Proposed Revision”) to support an efficient,effective, stable regulatory review process in thatit fails to adequately reflect either current practiceor to appropriately and clearly addressconsideration of new or revised standards. Thecomments herein address many of the problemswith this SRP. However, one major difficulty withthe existing SRP is inadequate guidanceregarding the fundamental regulatory basis forthis SRP section and its failure to clearly identifymajor differences in expectations among thevarious classes of affected equipment (i.e., harshenvironment electrical, harsh environmentmechanical, and mild environment electrical andmechanical).

SRP 3.11 1981 clearly and appropriately makesan introductory, high level statement that theinformation presented in SAR Section 3.11 andreviewed by the NRC is intended to assureconformance with General Design Criterion(GDC) 4. The subsequent revisions obfuscatethis high level propose by hiding GDC 4 and 10

1) The NUGEQ recommendsselective changes to the SRP 3.11introductory language to helpframe the guidance in subsequentsections. This change does notresolve problems with otherconfusing and contradictorylanguage, but it should helpapplicants and reviewers to placesubsequent language inperspective. Replace the secondparagraph in I. AREAS OFREVIEW with the following.

“The review will be performed toassure conformance with theenvironmental design basisrequirements of 10 CFR Part 50,Appendix A, General DesignCriterion 4 which states, in part,that “Structures, systems, andcomponents important to safetyshall be designed to accommodatethe effects of and to be compatiblewith the environmental conditionsassociated with normal operation,maintenance, testing, andpostulated accidents, includingloss-of-coolant accidents.” Thereview will assure conformancewith the applicable portions ofother relevant regulations,including 10 CFR 50.67, 10 CFRPart 50, Appendix A, General

1) Agree

The comment wasincorporated with minorrewording and GDC 2was added for reasonsprovided in response tocomment no. II

1) The 2nd paragraph ofSection I AREAS OFREVIEW revised to read asfollows:

“The review will beperformed to assureconformance with theenvironmental design basisrequirements of 10 CFR Part50, Appendix A, GeneralDesign Criterion 4 whichstates, in part, that"Structures, systems, andcomponents important tosafety shall be designed toaccommodate the effects ofand to be compatible with theenvironmental conditionsassociated with normaloperation, maintenance,testing, and postulatedaccidents, includingloss-of-coolant accidents."The review will assureconformance with theapplicable portions of otherrelevant regulations,including 10 CFR Part 50,Appendix A, General DesignCriteria 1, 2 and 23; 10 CFRPart 50, and Appendix B,Quality Assurance CriteriaIII, XI, and XVII. The review


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CFR 50.49 in a list of other applicable butsecondary (with respect to environmentalqualification) regulations (e.g., GDC 1, 2, 4, and23; and Appendix B, Quality Assurance CriteriaIII, XI, and XVII). This obfuscation is compoundedin the 2006 draft that adds a significant amount ofredundant, unnecessary, and often incorrectverbiage regarding compliance with each ofthese individual regulations. See for example thegenerally unhelpful new information provided in“Technical Rationale” beginning on page 3.11-12.Specific information regarding the confusingguidance associated with GDC 2 is provided inour comment - Qualification for NaturalPhenomena – (GDC 2).

Similarly, revisions subsequent to 1981 confusethe significant differences in regulatoryrequirements and expectations regarding themethodologies and documentation used toestablish GDC 4 compliance for differentequipment classes (i.e., harsh environmentelectrical, harsh environment mechanical, andmild environment electrical and mechanical). The1981 version attempted to address theseimportant distinctions by establishing two majorsubsections, Harsh Environment and MildEnvironment, in SRP 3.11, Section II, AcceptanceCriteria. The current version has eliminated theseimportant subsections and hides these importantdifferences in a few items (e.g., #18 and #19)within a larger list of 22 items.

Design Criteria 1 and 23; 10 CFRPart 50, and Appendix B, QualityAssurance Criteria III, XI, and XVII.The review also assuresconformance to Section 50.49 of10 CFR which contains specificrequirements regarding theenvironmental qualification ofelectrical equipment important tosafety that is located in a harshenvironment. For mechanicalequipment located in a harshenvironment, compliance with theenvironmental provisions of GDC 4is generally achieved bydemonstrating that thenon-metallic parts/components aresuitable for the postulatedenvironmental conditions. Forelectrical and mechanical deviceslocated in mild environments,compliance with the environmentalprovisions of GDC 4 is generallyachieved and demonstrated byproper incorporation of all relevantenvironmental conditions into thedesign process, including theequipment specification. Reviewsto determine compliance withrelated requirements for (1)dynamic and seismic qualificationof electrical and mechanicalequipment, (2) protection ofelectric and mechanical equipmentagainst other natural phenomenaand external events, (3) functionalqualification of mechanicalequipment, (4) equipment

also assures conformance to Section 50.49 of 10 CFRwhich contains specificrequirements regarding the environmental qualification ofelectrical equipmentimportant to safety that is located in a harshenvironment.

For mechanical equipmentlocated in a harsh environment, compliancewith the environmentalprovisions of GDC 4 isgenerally achieved bydemonstrating that thenon-metallicparts/components aresuitable for the postulateddesign basis environmentalconditions.

For electrical and mechanicaldevices located in mildenvironments, compliance with the environmentalprovisions of GDC 4 isgenerally achieved and demonstrated by properincorporation of all relevantenvironmental conditions into the design process,including the equipmentspecification.

Reviews to determinecompliance with related


Page 3 of 55

survivability for beyond designbasis hydrogen burns, and (5)qualification of digitalinstrumentation and controlequipment are described in otherSRP sections.”

requirements for (1) dynamicand seismic qualification ofelectrical and mechanicalequipment, (2) protection of electric and mechanicalequipment against othernatural phenomena and external events, (3)functional qualification ofmechanical equipment, (4) equipment survivability forbeyond design basishydrogen burns, and (5)qualification of digitalinstrumentation and controlequipment located in mildenvironment are describedin other SRP sections.”

II Qualification for Natural Phenomena - (GDC 2)

Proposed SRP 3.11 appears to containnumerous examples of confusing andcontradictory guidance. Time constraints preventa thorough review of this SRP section and itsrelationship to other SRP sections and SRPreview activities. However, SRP 3.11 guidanceon qualification for natural phenomena providesinsight and one example of such confusion.

According to SRP 3.11 - “Protection ofmechanical and electrical equipment againstother natural phenomena and external events isaddressed in other SRP sections, as describedunder Review Interfaces in this subsection.”(emphasis added) (pg 3.11-3) (The NUGEQnotes that “other” is undefined and can only be

1) NUGEQ agrees with the pg3.11-3 statement that “Protectionof mechanical and electricalequipment against other naturalphenomena and external events isaddressed in other SRP sections.”The other SRP 3.11 text related toGDC 2 should be deleted asmisleading. This includes thefollowing: page 3.11-5 item #5;3.11-13 item #5; and 3.11-19 initem #4.

1) Disagree

The EnvironmentalQualification Rule, 10CFR 50.49, (b)(ii)addresses naturalphenomena and statesthe following:

“(ii) Design basis eventsare defined as conditionsof normal operation,including anticipatedoperational occurrences,design basis accidents,external events, andnatural phenomena forwhich the plant must be

1) No changes made basedon this comment.


Page 4 of 55

understood by carefully reviewing changes fromdraft 1996 version. In that version the priorsentence – now deleted – discusses seismic anddynamic qualification. So “other” means - otherthan seismic and dynamic. However, the onlynatural phenomena or external event currentlyidentified in Review Interfaces is a reference toSRP 3.10 for seismic and dynamic qualification.“Other” natural phenomena are not discussed.

The design basis for protection against naturalphenomena - GDC 2 - indicates that naturalphenomena include earthquakes, tornadoes,hurricanes, floods, tsunami, and seiches. It alsorequires component designs to considerappropriate combinations of normal/accidentconditions with natural phenomena effects. Anumber of SPR sections relate to naturalphenomena, including 3.3.1 Wind Loadings, 3.3.2Tornado Loadings, 3.4.1 Flood Protection, and3.5.1.4 Missiles Generated by NaturalPhenomena. In contrast even the 1996 draft SRP3.11 identifies SRP sections relate to naturalphenomena as including 3.4.1, 3.5.1.1, 3.5.2,3.6.1, and 5.4.11.

Since SRP 3.11 appropriately states that otherSRP sections address natural phenomena onewould conclude that SRP 3.11 would not containrelated acceptance criteria. Unfortunately, SRP3.11 Section II ACCEPTANCE CRITERIAspecifically cites - 10 CFR Part 50, Appendix A,General Design Criterion 2, “Design Bases forProtection Against Natural Phenomena.” (pg3.11-3) Further acceptance criteria amplificationis provided under SRP Acceptance CriteriaTechnical Rationale which states in Item 5 (this isall new language not contained in 1996 version):

2) This is a simplified and slightlydistorted (it includes “i.e.,environmental qualification” that isnot in GDC 2) version of the GDC2 text without the phenomenaexamples - earthquakes,tornadoes, hurricanes, floods,tsunami, and seiches

designed to ensurefunctions (b)(1)(I) (A)through © of this section.”

In addition, GDC 2 ismentioned in RG 1.89,Revision 1. Therefore,the staff considers GDC 2an appropriate referencefor SRP 3.11.

2) Agree

Removed “(i.e.,environmentalqualification)”

2) Technical rationale, Item 4 revised to read as follows:

GDC 2, ‘Design Bases forProtection Against NaturalPhenomena,’ requires thatcomponents important tosafety be designed towithstand the effects ofnatural phenomena such asearthquakes, tornadoes,hurricanes, floods, tsunami,and seiches without loss ofcapability to perform theirsafety function.

GDC 2 is applicable to thissection since the designbases for componentsimportant to safety mustconsider the effects of themost severe naturalphenomena anticipated forthe site, together with normaland accident plant operating


Page 5 of 55

“Compliance with 10 CFR Part 50, Appendix A,General Design Criterion 2 (GDC 2), “DesignBases for Protection Against NaturalPhenomena,” requires that componentsimportant to safety be designed to withstand theeffects of natural phenomena without loss ofcapability to perform their safety function. Thedesign bases for these components mustconsider the effects of the most severe naturalphenomena anticipated for the site, together withnormal and accident plant operating conditions(i.e., environmental qualification) and theimportance of the safety function to beperformed.”

This is a simplified and slightly distorted (itincludes “i.e., environmental qualification” that isnot in GDC 2) version of the GDC 2 text withoutthe phenomena examples - earthquakes,tornadoes, hurricanes, floods, tsunami, andseiches. The new SRP 3.11 text then states:

“Equipment important to safety must be able toperform their design safety functions under allanticipated operating conditions, which includesnormal environmental conditions, anticipatedoperational occurrences, and accident andpost-accident environmental conditions. Theenvironmental qualification process described bythe various documents, regulations, regulatoryguides, and industry standards cited inSubsection II of this SRP section provides amethod of demonstrating that equipment will beable to perform acceptably during all anticipatedoperating conditions, even after being degradeddue to exposure to service conditions during itsqualified life. Meeting GDC 2 provides assurancethat appropriate combinations of the effects of

3) The NUGEQ also suggests theaddition of clarifying text underReview Interfaces to make clearthat protection of mechanical andelectrical equipment against othernatural phenomena and externalevents is addressed in othersubsections of SRP Section 3.This text could be incorporatedinto item #1 on page 3.11-3 orprovided as a new item.

3) Agree

conditions and theimportance of the safetyfunction to be performed. Components in the scope ofthis section that are subjectto environmental design andqualification must considernatural phenomena as part ofthe environmental conditionsevaluated.

Meeting GDC-2 providesassurance that appropriatecombinations of the effects ofnormal and accidentconditions with the effects ofthe natural phenomena areconsidered in meeting theenvironmental design andqualification requirements.”

3) The following textincorporated in ReviewInterfaces Item 10 C:

“The design bases forprotection of mechanical andelectrical equipment againstnatural phenomena andexternal events, are reviewed

under appropriatesubsections of SRP Section3 (e.g., 3.3.1, 3.3.2, 3.4.1,


Page 6 of 55

normal and accident conditions with the effects ofthe natural phenomena are considered in theenvironmental qualification process.”

The only reference here to natural phenomenaand GDC 2 involves the “combination” of effects.The NUGEQ is unaware – absent a detailedreview – of any further guidance in “the variousdocuments, regulations, regulatory guides, andindustry standards cited in Subsection II” relatedto such natural phenomena (except seismic) orthe combination of such phenomena with plantenvironmental conditions. The NUGEQ believesthat compliance with GDC 2 is achieved byintegrating its requirements into the design of theplant and affected SSCs and this is adequatelyaddressed in other SRP sections. If the plantdesign does not adequately protect theequipment from such natural phenomena thenthe equipment could be qualified for theanticipated environmental conditions.

In summary, the NUGEQ agrees with the pg3.11-3 statement that “Protection of mechanicaland electrical equipment against other naturalphenomena and external events is addressed inother SRP sections.” The other SRP 3.11 textrelated to GDC 2 should be deleted asmisleading. This includes the following: page3.11-5 item #5; 3.11-13 item #5; and 3.11-19 initem #4. The NUGEQ also suggests the additionof clarifying text under Review Interfaces to makeclear that protection of mechanical and electricalequipment against other natural phenomena andexternal events is addressed in other subsectionsof SRP Section 3. This text could be incorporatedinto item #1 on page 3.11-3 or provided as a newitem.

3.5.1.1, 3.5.1.4, 3.5.1.5, and3.5.2). SRP Section 3.10includes seismic anddynamic qualification ofmechanical and electricalequipment.”


Page 7 of 55

III Qualification for Combustible Gas Control

Proposed SRP 3.11 in numerous locationserroneously references 10 CFR 50.34 (f)(2)(ix) asthe regulatory basis for combustible gas controlrequirements for future reactors. The appropriateregulatory basis is 10 CFR 50.44©.

SRP 3.11 also erroneously indicates in SpecificAcceptance Criterion #17 (page 3.11- 10) that –“The environmental qualification program mustensure that equipment that is necessary forachieving and maintaining safe shutdown of theplant, and maintaining containment integrity, willperform its safety function during and after beingexposed to the environmental conditions resultingfrom the release of hydrogen generated by theequivalent of a 100% fuel-clad metal-waterreaction . . . .” The 50.44 rulemaking makes clearthat its Equipment Survivability language, forexisting plants in 50.44(b)(3) and future plants in50.44(c)(3), does not apply environmentalqualification criteria and does not requirecompliance with § 50.49 where standards for theenvironmental qualification program areestablished. Specifically -

SECY-03-0127, “FINAL RULEMAKING —RISK-INFORMED 10 CFR 50.44,“COMBUSTIBLE GAS CONTROL INCONTAINMENT” states that:

“The NRC’s requirements for future reactorspreviously specified in §50.34(f)(2)(ix) have beenreworded for conciseness but without materialchange and relocated to §50.44(c)(2) toconsolidate the combustible gas controlrequirements in §50.44 for easier reference.”

The following changes to SRP3.11 are recommended in order tomake clear that (1) qualification to§ 50.49 is not required for beyonddesign basis accidentenvironments and the associatedhydrogen generation and (2) theapplicable hydrogen controlregulatory basis for new plants is50.44 and not 50.34.

1) Delete reference to50.34(f)(2)(ix) on 3.11-1

2) Delete all of ACCEPTANCECRITERIA #1 on 3.11 -5,

3) Delete all of item #17 on3.11-10,

4) Delete all of item #1 on 3.11-12,

5) Delete two references to 50.34on 3.11-18 (1st paragraph and inCOL paragraph), and

6) Delete all of REFERENCE #1on 3.11-19.

7) Add a new item under ReviewInterfaces which reads as follows:

“Review of equipment functionalperformance during and afterbeing exposed to theenvironmental conditions resultingfrom the release of hydrogen

1 )Agree

2) Agree

3) Agree

4 )Agree

5) Agree

6) Agree

7) Agree

1) Recommended deletionmade.



4) Recommended deletion made.



7) Recommended additionincorporated as a new itemunder Review Interfaces item11.


Page 8 of 55

(SECY page 20)

The SECY discussion further clarifies thatsystems, structures, and components provided tomeet the provisions of 50.44(c)(2) are intended tomeet a survivability standard and notqualification.1 Specifically, “Structures, systems,and components (SSCs) provided to meet thisrequirement must be designed to providereasonable assurance that they will operate inthe severe accident environment for which theyare intended and over the time span for whichthey are needed. Equipment survivabilityexpectations under severe accident conditionsshould consider the circumstances of applicableinitiating events (such as station blackout orearthquakes) and the environment (includingpressure, temperature, and radiation) in whichthe equipment is relied upon to function.” Also,“Because these requirements address beyonddesignbasis combustible gas control, SSCsprovided to meet these requirements need not besubject to the environmental qualificationrequirements of § 50.49; quality assurancerequirements of 10 CFR Part 50, Appendix B;and redundancy/diversity requirements of 10CFR Part 50, Appendix A.” And finally, “Guidancesuch as that found in Appendices A and B of RG1.155, “Station Blackout,” is appropriate forequipment used to mitigate the consequences ofsevere accidents.” (SECY page 54)

generated by the equivalent of a100% fuel-clad metal-waterreaction, as stated in 10 CFR50.44©, is performed in SRPSection 6.2.5.”

8) We also recommend that theversion of SRP 6.2.5 provided asAttachment 6 to SECY- 03-0127be modified to make clearer that asurvivability standard and notcompliance with 10 CFR 50.49 isused to establish reasonableassurance of operability of SSCs.This can be accomplished bydeleting in three locations thewords “qualification test” or“qualification program” andreplacing with “test” or “program”as appropriate. Additional SRP6.2.5 guidance may also beappropriate to accurately reflectthe provisions of § 50.44 and theinformation in SECY-03-0127.Suggested text could include thefollowing:

“Structures, systems, andcomponents (SSCs) provided tomeet 50.44© must be designed toprovide reasonable assurance thatthey will operate in the severeaccident environment for whichthey are intended and over thetime span for which they areneeded. Equipment survivabilityexpectations under severeaccident conditions should

8) Disagree

This is beyond the scopeof SRP 3.11. Refer to RG1.7 “Control ofCombustible GasConcentrations inContainment”

8) No changes made as aresult of this comment.


Page 9 of 55

consider the circumstances ofapplicable initiating events (suchas station blackout orearthquakes) and the environment(including pressure, temperature,and radiation) in which theequipment is relied upon tofunction. Because theserequirements address beyonddesign-basis combustible gascontrol, SSCs provided to meetthese requirements need not besubject to the environmentalqualification requirements of §50.49; quality assurancerequirements of 10 CFR Part 50,Appendix B; andredundancy/diversity requirementsof 10 CFR Part 50, Appendix A.Guidance such as that found inAppendices A and B of RG 1.155,“Station Blackout,” is appropriatefor equipment used to mitigate theconsequences of severeaccidents.”

IV Definition of Environmental Qualification

Item 2 page 3.11-2 states: “Section 3.11 of theSAR is reviewed to determine whether therequired environmental qualification of allequipment important to safety will be, or hasbeen adequately demonstrated. The term“environmental qualification” means verification ofdesign, limited to demonstrating that electrical or

The NUGEQ recommends thefollowing changes to SRP 3.11 toproperly characterize thesedifferences for harsh and mildequipment and environmentaldesign and environmentalqualification.

1) Revise Item 2 page 3.11-2 to 1) Agree 1) The following text added


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mechanical or digital instrumentation and controlequipment are capable of performing their safetyfunction under significant environmental stressesresulting from design basis events in order toavoid common-cause failure.” This text is basedon similar language in Regulatory Guide 1.89Rev. 1 which is limited to electrical equipment inharsh environments. Although this SRPstatement is generally appropriate for electricaland mechanical equipment in a harshenvironment, it is not appropriate for electrical ormechanical equipment in mild environments. Inaddition, SRP 3.11 expands this language toinclude “all equipment important to safety.”

Regarding mild environment equipment thestatement is incorrect since (1) there are nosignificant environmental stresses resulting fromdesign basis events (e.g., LOCA) for equipmentin a mild environment, (2) environmentalqualification for mild environment equipment andcompliance with GDC 4 is generally achievedand demonstrated by proper incorporation of allrelevant environmental conditions into the designprocess, including the equipment specification,and (3) the avoidance of environmentally-inducedcommon-cause failures is critical for harshconditions but is not relevant for mildenvironment conditions.

The Commission in CLI-80-21 stated that“fundamental to NRC regulation of nuclear powerreactors is the principle that safety systems mustperform their intended function in spite of theenvironment which may result from postulatedaccidents. Confirmation that these systems willremain functional under postulated accidentconditions constitutes environmental

read: “Section 3.11 of the SAR isreviewed to determine whether therequired environmental design andqualification of all equipmentimportant to safety will be, or hasbeen adequately demonstrated.The term “environmentalqualification” means verification ofdesign, limited to demonstratingthat electrical or mechanical orinstrumentation and controlequipment are capable ofperforming their safety functionunder significant environmentalstresses resulting from designbasis events (i.e., harshenvironments) in order to avoidcommon-cause failure.Environmental designrequirements apply to allequipment important to safety.”

2) Page 3.11-6 paragraphbeginning “The generalrequirements . . .”: Revise phrase(2) to read as follows: “(2) theenvironmental qualification ofequipment located in a harshenvironment shall bedemonstrated by appropriate

2) Agree

to Areas of Review Item 2:

“Section 3.11 of the SAR isreviewed to determinewhether the requiredenvironmental design andqualification of all equipmentimportant to safety will be, orhas been adequatelydemonstrated. The term"environmental qualification"means verification of design,limited to demonstrating thatelectrical or mechanical orinstrumentation and controlequipment are capable ofperforming their safetyfunction under significantenvironmental stresses (i.e.,harsh environments)resulting from design basisevents in order to avoidcommon-cause failure. Environmental designrequirements apply to allequipment important tosafety. (i.e., both mild andharsh environments)."

2) Item (2) in the paragraphon page 3.11-6 beginning“The general requirements...” reworded as follows:

“(2) the environmentalqualification of equipmentlocated in harsh environment


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qualification.2 (emphasis added) This perspectivewas reaffirmed by the Commission in itsStatement of Policy on EnvironmentalQualification.3 The policy further states that “Thisprinciple is incorporated in the Commission’sexisting General Design Criteria One and Four 10CFR Part 50, Appendix A.”

Based on these Commission statements andrelated technical considerations, including theuse of tests and analysis to demonstratecompliance, the NUGEQ concludes that the term“environmental qualification” is appropriatelylimited to equipment that must function underaccident environmental conditions and should notbe applied to equipment in mild environments.For mild environment equipment it is moreappropriate to state that the equipment perGDC-4 is designed to accommodate and becompatible with postulated environmentalconditions and not use the terms “environmentalqualification” or ‘environmental qualificationprogram” for mild environment equipment.

The NUGEQ recommends the following changesto SRP 3.11 to properly characterize thesedifferences for harsh and mild equipment andenvironmental design and environmentalqualification.

Revise Item 2 page 3.11-2 to read: “Section 3.11of the SAR is reviewed to determine whether therequired environmental design and qualificationof all equipment important to safety will be, or hasbeen adequately demonstrated. The term“environmental qualification” means verification ofdesign, limited to demonstrating that electrical ormechanical or instrumentation and control

testing and analyses; and . . .”

3)Delete last sentence.Alternatively revise to differentiatebetween environmental design (forall equipment) and environmentalqualification (hash environmentequipment only).

3) Disagree

In response to comment 2above, the revisedwording in Item (2) in theparagraph on page 3.11-6beginning “The generalrequirements...” makesclear the differentiationbetween environmentaldesign (for all equipment)and environmentalqualification (harshenvironment equipmentonly). No further changesneeded.

shall be demonstrated byappropriate testing andanalyses;”



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equipment are capable of performing their safetyfunction under significant environmental stressesresulting from design basis events (i.e., harshenvironments) in order to avoid common-causefailure. Environmental design requirements applyto all equipment important to safety.”

Page 3.11-16 paragraph beginning “The generalrequirements . . .”: Revise phrase (2) to read asfollows: “(2) the environmental qualification ofequipment located in a harsh environment shallbe demonstrated by appropriate testing andanalyses; and . . .” Delete last sentence.Alternatively revise to differentiate betweenenvironmental design (for all equipment) andenvironmental qualification (hash environmentequipment only).

V. Confusing use of the term - EnvironmentalQualification Program

The proposed SRP 3.11, in particularly the newtext, lavishly uses the term “environmentalqualification program”. The NUGEQ believes theexcessive use of this term contributes toconfusing SRP 3.11 guidance.4 The term“environmental qualification program” is mostappropriately applied to the program required by10 CFR 50.49. The term should not be used torepresent those other activities described in SRP3.11 that are used to demonstrate thatmechanical and electrical equipment aredesigned to be compatible with andaccommodate the effects of applicableenvironmental conditions not associated withharsh environments. These activities are integralto the design process and associateddocumentation and do not represent an ongoing

The NUGEQ recommends that

1) SRP 3.11 be revised to limit useof the term “environmentalqualification program” to activitiesassociated with 10 CFR 50.49compliance. The term“environmental qualification”should replace “environmentalqualification program” if theactivities are associated withqualification of mechanical andelectrical equipment located in aharsh environment.

2) For equipment in a mildenvironment neither“environmental qualification” nor“environmental qualificationprogram” should be used; the

1) Agree

2) Agree

1) Appropriate revisions made to use the term“environmental qualification”to refer to activitiesassociated with equipmentlocated in a harshenvironment, and the term“environmental design” torefer to activities associatedwith equipment located in amild environment.

2) Appropriate changesmade to use the term“environmental design” torefer to activities associatedwith equipment in a mild


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program. Of course, regulations applicable todesign and the design process assure that therequirements apply, as appropriate, to equipmentmodifications or replacement.

appropriate term for this mildenvironment equipment would be“design” or “environmental design”.The most appropriate term for allthe activities addressed by SRP3.11 would be “environmentaldesign and qualification.”

environment.

VI References to NUEG-0588

Page 3.11-6 describes NUREG-0588 andreferences its endorsement by CLI 80-21. Whilethe endorsement by CLI 80-21 has somehistorical significance this memorandum andorder was effectively superseded by the issuanceof 10 CFR 50.49. Further, the informationcontained in NUREG-0588 Rev. 1, “Interim StaffPosition on Environmental Qualification ofSafety-Related Electrical Equipment” wasformally identified as interim guidance. TheNUREG abstract states that these interimpositions will be used “until the final positions,currently being developed in rulemaking, areestablished.” A review 10 CFR 50.49 and theaccompanying statements of considerationindicates that the rule grandfathered and limitedthe applicability of certain documents to existingplants in 50.49(k) (i.e., plants previously requiredby the Commission to qualify equipment inaccordance with the DOR Guidelines orNUGEQ-0588 (for comment version) need notqualify the equipment to 50.49). Consequently,qualification for future plants is based on 50.49and not on NUREG-0588.

The use of NUREG-0588 as staff guidance wasalso superseded by the issuance of RegulatoryGuide 1.89 Rev. 1, June 1984, which describes a

Given these considerations werecommend the following changesto SRP 3.11:

1) Delete ACCEPTANCECRITERIA item #1 in its entirety(page 3.11-6). Alternatively movethe NUREG-0588 discussion to aless prominent location (e.g., afterdiscussing Regulatory Guide 1.89)and revise to read as follows:

“NUREG-0588, “Interim StaffPosition on EnvironmentalQualification of Safety- RelatedElectrical Equipment,” Revision 1,July 1981 provides generalinformation applicable to existingplants that may be useful forassessing the compliance of anenvironmental qualificationprogram with 10 CFR 50.49. Forfuture plants Regulatory Guide1.89 provides the principalguidance for implementing therequirements and criteria of 10CFR 50.49 for environmentalqualification of electricalequipment that is important tosafety and located in a harsh

1) Agree 1) Item 1 of SRP AcceptanceCriteria revised to read asfollows:

“NUREG-0588, ‘Interim StaffPosition on EnvironmentalQualification of SafetyRelated ElectricalEquipment,’ Revision 1, July1981 provides staff positionsapplicable to existing plantsfor assessing the complianceof an environmentalqualification program with 10CFR 50.49. For futureplants, Regulatory Guide1.89 provides the principalguidance for implementingthe requirements and criteriaof 10 CFR 50.49 forenvironmental qualification ofelectrical equipment that isimportant to safety andlocated in a harshenvironment. However,certain NUREG-0588


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method acceptable to the NRC staff forcomplying with 10 CFR50.49 with regard toqualification of electric equipment important tosafety. A review of Regulatory Guide 1.89 Rev. 1indicates that the guidance of NUREG-0588 wasnot generically referenced or incorporated.Rather, the regulatory guide only referencesNUGEQ-0588 in discussions of (1) source terms;(2) upgrading on replacement; (3) 50.49(k)limitations; and (4) Value/Impact where the staffessentially states that 50.49 and RegulatoryGuide 1.97 Rev. 1 effectively supersedeCLI-80-21 and the guidance in the DORGuidelines and NUREG-0588. Based on theseconsiderations we believe reference toNUREG-0588 should be deleted in SRP 3.11 andRegulatory Guide 1.89 identified as theapplicable staff guidance regarding compliancewith 50.49.

For future applicants if the staff believes thatcertain useful information and guidance isprovided in NUREG-0588 and not in RegulatoryGuide 1.89 Rev. 1 then it may be appropriate tosuggest that the guidance in Category 1 ofNUREG-0588 may be used if guidance is notprovided in the regulatory guide.

Finally, we note this SRP section discusses bothNUREG-0588 Category 1 and Category 2. TheCategory 2 information was apparently retained(the 1996 draft deleted reference to Category 2)because existing plants use Category 2. We aresomewhat concerned about this stated basis forretaining reference to Category 2. If the NRC staffwants to describe Category 2 then otherenvironmental qualification related documents(e.g., DOR Guidelines, IEB 79-01B and

environment. However, certainNUREG-0588 Category 1guidance may be used if relevantguidance is not provided inRegulatory Guide 1.89. NUREG-0588 includes two sets ofqualification criteria, Category Iand Category II. Category I refersto IEEE Std 323-1974, “IEEEStandard for Qualifying Class 1EEquipment for Nuclear PowerGenerating Stations.” Category Iapplies to plants whoseconstruction permit SERs weredated after July 1, 1974. CategoryII refers to IEEE Std 323-1971, andis not applicable to any futureplants.”

2) Delete reference toNUREG-0588 in the discussion ofseveral regulatory guides in theACCEPTANCE CRITERIA section.Specifically delete the text “. . . andshould be used in conjunction withNUREG-0588 and RegulatoryGuide 1.89, as appropriate . . .”and replace with “. . . and shouldbe used in conjunction withRegulatory Guide 1.89, asappropriate . . .” in the followingitems: #4 (RG 1.40), #5 (RG 1.63),#6 RG 1.73), #9 (RG 1.131), #11(RG 1.156), #12 (RG 1.158), and#14 (RG 1.183).

2) Disagree

The staff notes that thisreference is still used bysome operating reactorsand, as suggested incomment 1 above, itcould be used for certainrelevant guidance. Therefore, the staffconsiders it anappropriate reference forSRP 3.11 and it will beretained.

Category 1 guidance may beused if relevant guidance isnot provided in RegulatoryGuide 1.89. NUREG0588includes two sets ofqualification criteria,Category I and Category II. Category I refers to IEEE Std323-1974, "IEEE Standardfor Qualifying Class 1E Equipment for Nuclear PowerGenerating Stations."Category I applies to plants whose construction permitSERs were dated after July1, 1974. Category II refers toIEEE Std 323-1971, and isnot applicable to any futureplants.



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supplements) applicable to existing plants but notfuture plants should be cited in this SRP section.If the staff determines that SRP 3.11 mustreference the NUREG, then we wouldrecommend limiting the discussion of Category 2to a simple statement that Category 2 does notapply to future plants. If the staff chooses toretain further discussion of Category 2applicability then the SRP should, at a minimum,also reference “Guidelines for EvaluatingEnvironmental Qualification of Class 1E ElectricalEquipment in Operating Reactors” (DORGuidelines) in that that guidance is also retainedunder Section 50.49(k) as potentially applicableto certain existing plants.

VII Confusing Reference and Applicability of IEEEStandards and Regulatory Guides

SPR 3.11 ACCEPTANCE CRITERIA after listingapplicable 10 CFR Sections identifies 22 items,the vast majority of which refer to specificregulatory guides or IEEE standards. Historicallythe NRC has been unable to issue/revise guidesin a timely manner when IEEE standards areissued/revised. As a result virtually all the mostrecent and applicable IEEE standard versions donot have companion regulatory guides. In supportof new reactor applications we anticipate that theNRC may give a higher priority to futureregulatory guide revisions. The IEEE will continueto refine and revise its standards. As a result andgiven the current organization of the SRP 3.11 itwill remain continually out of date.

In order to resolve this problem with out-of-dateregulatory guides and on-going IEEE standardrevisions, the NUGEQ recommends the addition

1) In order to resolve this problemwith out-of-date regulatory guidesand on-going IEEE standardrevisions, the NUGEQrecommends the addition of thefollowing language inACCEPTANCE CRITERIA onpage 3.11-6 immediatelypreceding the 22 items. Thislanguage is based in part onlanguage contained in a recentlyissued regulatory guide (RG 1.97Rev. 4):

“If the NRC staff has endorsed areferenced standard in aregulatory guide, that standardconstitutes an acceptable methodfor use in meeting the relatedregulatory requirement asdescribed in the regulatory guide.If a referenced standard has not

1) Agree 1) The following text added inSection II under SRPAcceptance Criteria as 2nd

para, page 3.11-6appropriately.

“If the NRC staff hasendorsed a referencedstandard in a regulatoryguide, that standardconstitutes an acceptablemethod for use in meetingthe related regulatoryrequirement as described inthe regulatory guide. If areferenced standard has notbeen endorsed in aregulatory guide, licenseesand applicants may considerand use the information inthe referenced standard, if


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of the following language in ACCEPTANCECRITERIA on page 3.11-6 immediately precedingthe 22 items. This language is based in part onlanguage contained in a recently issuedregulatory guide (RG 1.97 Rev. 4):

“If the NRC staff has endorsed a referencedstandard in a regulatory guide, that standardconstitutes an acceptable method for use inmeeting the related regulatory requirement asdescribed in the regulatory guide. If a referencedstandard has not been endorsed in a regulatoryguide, licensees and applicants may considerand use the information in the referencedstandard, if appropriately justified, consistent withcurrent regulatory practice. When a regulatoryguide references an older version of a standard,those portions of the newer version that arematerially the same as the version cited in theregulatory guide or reflect NRC positions in theregulatory guide are appropriately justified by theregulatory guide.”

If adopted this language obviates the need foritem #15 on page 3.11-10. As discussed furtherbelow in examples 1 and 2 the IEEE standardscited in item #15 have either been withdrawn orfocus on functional qualification of equipment inmild environments. The NUGEQ recommendsthat item #15 be deleted.

The following are examples of other problemswith the current referenced guides andstandards.

1. This proposed SRP 3.11 revision includes anew reference - Regulatory Guide 1.30, “QualityAssurance Requirements for the Installation,

been endorsed in a regulatoryguide, licensees and applicantsmay consider and use theinformation in the referencedstandard, if appropriately justified,consistent with current regulatorypractice. When a regulatory guidereferences an older version of astandard, those portions of thenewer version that are materiallythe same as the version cited inthe regulatory guide or reflect NRCpositions in the regulatory guideare appropriately justified by theregulatory guide.”

2) If adopted this languageobviates the need for item #15 onpage 3.11-10. As discussed furtherbelow in examples 1 and 2 theIEEE standards cited in item #15have either been withdrawn orfocus on functional qualification ofequipment in mild environments.The NUGEQ recommends thatitem #15 be deleted.

2) Agree

appropriately justified,consistent with currentregulatory practice.”

2) Item 15 under SRPAcceptance Criteria deleted.


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Inspection, and Testing of Instrumentation andElectric Equipment,” August 1972. We questionthe addition of this30+ year old guide asacceptance criteria for environmentalqualification. While this guide focuses oninstallation and operational QA topics, the only 10CFR Part 50, Appendix B criteria cited in SRP3.11 are design control (III), test control (XI), andQA records (XVII). This guide, which is applicableto all safety-related instrument, control, andelectrical equipment, is not even referenced bythe most recent official versions of SRP 7 andSRP 8. The guide is also not referenced inRegulatory Guide 1.89 Rev. 1 or NUREG-0588.Since the guide is not cited in SRP 7 and SRP 8or in other NRC environmental qualificationguidance, why is being included in SRP 3.11?We recommend deleting this reference. If thestaff retains this reference then it should also beincorporated more broadly in other SRP sections,including SRP 7 and 8.

2. Several of the referenced IEEE standards andcompanion regulatory guides do not apply toequipment in harsh environments. Theseequipment qualification standards focus onfunctional qualification of electrical equipmentand include some provisions for seismicqualification and possibly consideration of mildenvironment conditions. These documentsinclude (1) Regulatory Guide 1.158, “Qualificationof Safety-Related Lead Storage Batteries forNuclear Power Plants” and IEEE 535, (2) IEEEStd 650, “IEEE Standard for Qualification ofClass 1E Static Battery Chargers and Invertersfor Nuclear Power Generating Stations,” and (3)IEEE Std 649, “IEEE Standard for QualifyingClass 1E Motor Control Centers for Nuclear

3) We recommend deleting thisreference [Regulatory Guide 1.30,“Quality Assurance Requirementsfor the Installation, Inspection, andTesting of Instrumentation andElectric Equipment,” August 1972]. If the staff retains this referencethen it should also be incorporatedmore broadly in other SRPsections, including SRP 7 and 8.

4) We recommend that the SRPeither delete reference to thesefunctional qualification standards[RG 1.158, IEEE-535, IEEE-650,IEEE-649] or make clear that theytypically apply to equipment in mildenvironments.

5) We recommend that the SRPeither delete reference to thesestandards [IEEE-381 and IEEE627] or make clear which portionsof these withdrawn standards arenot contained in other guidanceand are considered importantenough to cite in this context.

6) We recommend deletingreference to RG 1.131; referenceto IEEE 383 should be retained.

3) Agree

4) Agree

RG 1.158 and IEEE-535retained for guidance forqualification of batteries, iflocated in harsh(Radiation only)environment.

5) Agree

6) Disagree

RG 1.131 draft retainedfor guidance purposespending issuance of theFinal version.

3) The reference RG 1.30deleted from SRP 3.11,Revision 3.

4) IEEE-649 AND 650deleted.

RG 1.158 and IEEE-535retained for guidance forqualification of batteries, iflocated in harsh (Radiationonly) environment.

5) Reference to IEEE-381and IEEE-627 standardsdeleted.



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Power Generating Stations.” We note that otherregulatory guides and IEEE standards applicableto functional qualification of electrical equipmentare not identified here (e.g., RG 1.9, “Selection,Design, Qualification, and Testing of EmergencyDiesel Generator Units Used as Class 1E OnsiteElectric Power Systems at Nuclear Power Plants”and IEEE 387). We recommend that the SRPeither delete reference to these functionalqualification standards or make clear that theytypically apply to equipment in mildenvironments.

3. Two of the referenced IEEE standards havebeen withdrawn: IEEE 381, “IEEE StandardCriteria for Type Tests of Class 1E Modules Usedin Nuclear Power Generating Stations” and IEEE627, “IEEE Standard for Design Qualification ofSafety Systems Equipment Used in NuclearPower Generating Station”. We recommend thatthe SRP either delete reference to thesestandards or make clear which portions of thesewithdrawn standards are not contained in otherguidance and are considered important enoughto cite in this context.

4. Regulatory Guide 1.131, “Qualification Tests ofElectric Cables and Field Splices forLight-Water-Cooled Nuclear Power Plants,” wasonly issued in draft form (for comment in 1977and proposed revision in 1979). The NRC neverissued a final regulatory guide. The draft guidereferences IEEE 383-1974 which was reaffirmedin 1992. There was a significant revision to theIEEE standard in 2003. We recommend deletingreference to RG 1.131; reference to IEEE 383should be retained.

7) Several regulatory guides citeversions of industry standardswhich have been revised severaltimes since the cited versions.

7) Disagree

The NRC staff has notendorsed all revisions toIEEE standards. TheRegulatory Guidesreference the version ofthe standard that iscurrently endorsed by thestaff.

If the NRC staff hasendorsed a referencedstandard in a regulatoryguide, that standardconstitutes an acceptablemethod for use in meetingthe related regulatoryrequirement as describedin the regulatory guide. Ifa referenced standardhas not been endorsed ina regulatory guide,licensees and applicantsmay consider and use theinformation in the

referenced standard, ifappropriately justified,consistent with currentregulatory practice.



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5. The only referenced regulatory guides whichcite current IEEE standard versions areRegulatory Guide 1.63, “Electrical PenetrationAssemblies in Containment Structures forNuclear Power Plants (IEEE 317 1983 wasreaffirmed in 2003) and Regulatory Guide 1.156,“Environmental Qualification of ConnectionAssemblies for Nuclear Power Plants,” November1987 (IEEE 572-1985 was reaffirmed in 2004).Several regulatory guides cite versions ofindustry standards which have been revisedseveral times since the cited versions. RegulatoryGuide 1.73, “Qualification Tests of Electric ValveOperators Installed Inside the Containment ofNuclear Power Plants” January, 1974 endorsesIEEE 382-1972. The cited version wassuperceded by both 1985 and 1996 (reaffirmed in2004) versions. Regulatory Guide 1.89 Rev. 1,“Environmental Qualification of Certain ElectricEquipment Important to Safety in Nuclear PowerPlants” endorses IEEE 323-1974. There havebeen two subsequent revisions, 1983 (reaffirmedin 1996) and 2003, to this critically importantqualification standard. We anticipate that theNRC will issue a RG 1.89 revision in the nearfuture. The above NUGEQ proposed languageaddresses this problem of reference to out ofdate versions of IEEE 323.

VIII New SRP 3.11 Positions Since 1996 DraftVersion

The following comments discuss four newtechnical positions in the proposed revision thatdo not appear in the 1996 draft, the 1981 version

1) Based on these considerationswe recommend that this item[Section III Review Procedures –Item #4] be deleted. If deemednecessary, additional reviewerguidance regarding possible

1) Agree 1) The referenced item # 4deleted and the text movedto the Review Interfacessubsection item 10.B fromReview Procedure. Deletedreference ASME Std QME-1.


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of SRP 3.11, or meet the NRC’s own criteriaregarding new SRP technical positions. Asubsequent comment - SRP 3.11 RevisionControl and Justification for Changes – discussesthe staff’s apparent failure to adhere to itsprocedure (LIC-200) for updating, reviewing, andissuing revised SRP sections.

1. Section III Review Procedures – Item #4. Item#4 is unnecessary, confusing, redundant, andambiguous regarding which NRC reviewersevaluate valve actuator functional performanceand related temperature effects. We recommendthat this item be deleted in its entirety. Item #4states: “In addition to the evaluation of fullenvironmental qualification, potential degradationof the operating performance of mechanical andelectrical equipment under adverseenvironmental conditions needs to be addressedby the applicant and reviewed by the NRC staff.”This item identifies an example (ambienttemperature effects on motor torque), states thatthe industry has developed related butunidentified guidance regarding “degradedperformance,” identifies SRP3.9.6 as a source ofguidance for pumps and valves, and observesthat the NRC will be reviewing ASME standardQME- 1, “Qualification of Active MechanicalEquipment Used in Nuclear Power Plants,” forpossible acceptance.

This new Review Procedure guidance isconfusing at best with much of the discussionunrelated to specific review procedures. What is“full environmental qualification” and why does itnot consider “potential degradation of theoperating performance of mechanical andelectrical equipment under adverse

ambient temperature effects onactuated valves can be added toSRP 3.9.6 and should be theresponsibility of that section’sreviewers.

2) Based on LIC-200 this [SectionII Acceptance Criteria – Item #2 –flooding above the flood level. Item#4] should be identified as a newstaff position or the text should bedeleted. We recommend deletingthis text and integrating thisguidance into the planned revisionto Regulatory Guide 1.89.

2) Disagree

The information providedin this paragraph relatedto flooding above theflood level is based onpast operatingexperience. It is providedas clarification andguidance in meeting therequirements of IEEEStd.-323. For example,components insideelectrical enclosures

The text was revised asfollows:

SRP 3.9.6 includes functionaldesign and qualification ofpumps, valves, and dynamicrestraints at a nuclear powerplant. The review includesthe potential impact ofadverse environmentalconditions on activemechanical and electricalequipment. For example,electric motors mightproduce less torque underhigh temperature conditionsthan under ambientconditions, which couldimpact their capability tooperate their individualpumps or valves.

2) This item is retained andrefer to item 3) below forclarification.


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environmental conditions?” What is the specificindustry guidance that is being identified?5 Whyisn’t the guidance in SRP3.9.6, and associatedstaff review, sufficient to address Item #4concerns regarding environmental effects onfunctional performance of pumps, valves, andsnubbers? Shouldn’t the concerns andassociated guidance expressed in this item bethe responsibility of the SRP3.9.6 reviewersusing information from SRP 3.11 regarding theapplicable environmental conditions? Why is thestaff identifying its future consideration of ASMEQME-1 in a Review Procedures section? We notethat although several versions of ASME QME-1have existed for some time, the NRC has notpreviously used or formally reviewed theguidance of this standard for use on any existingor proposed plants.

Although this item should be deleted, we interpretthe possible intended meaning of the item (basedon other SRP 3.11 guidance) to be that “fullenvironmental qualification” for mechanicalequipment is generally limited to determining thesuitability of materials, parts, and equipment, withemphasis on “soft parts” (i.e., gaskets, seals,lubricants, diaphragms). This perspective isadequately addressed in item #18 – page3.11-11. Further, we interpret the item to meanthat other activities necessary to support thefunctional capability of such equipment underdesign basis conditions are described andevaluated under other SRP 3 subsections,particularly 3.9.6. This perspective is adequatelyaddressed in item #12 – page 3.11-5. Regardingambient temperature effects on MOV electricmotors, this is addressed during design,environmental qualification of electric actuators,

3) On a technical level this itemalso inappropriately requiresenclosure drain holes to drain “anyaccumulated water” for allenclosures where wateraccumulation is possible. It wouldbe more appropriate to revise thelast sentence in the operativeparagraph to read: “Equipment insuch locations, whose design issuch that water accumulation ispossible, should have measures topreclude such accumulation (e.g.,enclosure drain holes) or theaffected equipment should bequalified for the anticipatedsubmergence.”

4) Given these considerations IN98-21 and referenced documents

subjected tosubmergence due waterand moisture intrusion.This standard does notrepresent a newqualification requirement,and the staff does notconsider this informationto be a change in thequalificationrequirements. Refer to10 CFR 50.49 (e)(6) andRG 1.89 position C.3.a.Consequently, this doesnot represent a new staffposition.

3) Agree

4) Agree

3) The last sentence of Item2 on page 3.11-7 revised asfollows:

The reviewer should confirmthat equipment in suchlocations, whose design issuch that water accumulationis possible, should havemeasures to preclude suchaccumulation (e.g.,enclosure drain holes) or theaffected equipment shouldbe qualified for theanticipated submergence.

4) The 3rd paragraph of Item2 on page 3.11-7 related to


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and functional qualification of actuator/valveassemblies (see SRP 3.9.6 provisions regarding“ambient temperature”). Further, this guidance,regarding possible torque effects of ambienttemperature, applies to reviews conducted underSRP 3.9.6 and not SRP 3.11. We agree that theenvironmental qualification of electricalequipment, such as motors, and the applicationof that information to plant equipment, such asactuated valves, must consider possibleenvironmental degradation of the equipment’sperformance characteristics (e.g., motor torqueand cable resistance). However, such guidancealready exists in the SRP and referenceddocuments and item #4 only adds confusion.

Based on these considerations we recommendthat this item be deleted. If deemed necessary,additional reviewer guidance regarding possibleambient temperature effects on actuated valvescan be added to SRP 3.9.6 and should be theresponsibility of that section’s reviewers.

2. Section II Acceptance Criteria – Item #2 –flooding above the flood level. Item #4 (page3.11-7) includes new SRP guidance regardingflooding above the flood level based on operatingexperience in Information Notice 89-63. On aprocedural level and according to LIC-2006, newstaff guidance based on operating experience(including experience based on NRC genericletters and bulletins) should be classified as anew staff position with associated ACRS andCRGR reviews. However, the SRP 3.11transmitting memorandum states that SRP 3.11contains no new guidance.7 Based on LIC-200this should be identified as a new staff position orthe text should be deleted. We recommend

do not call into question “overlyaccelerated aging” and this SRP3.11 paragraph [Section IIAcceptance Criteria – Item #2 –overly accelerated aging. Item #4]should be deleted or some othersupportable basis documents citedto support this concern (overlyaccelerated aging). Finally and asa practical matter, we note that theonly NRC reviewer guidanceprovided here regarding overlyaccelerated aging is to evaluatequalification test results “whileconsidering the specific applicationand set of environmentalconditions under which theequipment must operate.” This is ameaningless generic platitude withno relevant guidance regardingoverly accelerated aging. TheNUGEQ disagrees with thisguidance.

5) The NUGEQ recommendsdeleting this paragraph [Section IIAcceptance Criteria – Item #2 –integrated HRRM system testing.Item #4] or revising it to accuratelyreflect the referenced documentsand subsequent evaluations.

5) Agree

IN 98-21 deleted.

5) The 4th paragraph of Item2 on page 3.11-7 related IN97-45 for HRRMs deleted.


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deleting this text and integrating this guidanceinto the planned revision to Regulatory Guide1.89.

On a technical level this item also inappropriatelyrequires enclosure drain holes to drain “anyaccumulated water” for all enclosures wherewater accumulation is possible. It would be moreappropriate to revise the last sentence in theoperative paragraph to read: “Equipment in suchlocations, whose design is such that wateraccumulation is possible, should have measuresto preclude such accumulation (e.g., enclosuredrain holes) or the affected equipment should bequalified for the anticipated submergence.”

3. Section II Acceptance Criteria – Item #2 –overly accelerated aging. Item #4 (page 3.11-7)includes new SRP guidance regarding “overlyaccelerated aging” based on operatingexperience in Information Notice 98-21.

On a procedural level and according to LIC-200,new staff guidance based on operatingexperience (including experience based on NRCgeneric letters and bulletins) should be classifiedas a new staff position with associated ACRS andCRGR reviews. However, the SRP 3.11transmitting memorandum states that SRP 3.11contains no new guidance. Based on LIC-200this should be identified as a new staff position orthe text should be deleted. We recommenddeleting this text and integrating this guidanceinto the planned revision to Regulatory Guide1.89. On a technical level this item incorrectlyconcludes that the performance problems citedIN 98-21 were due to overly accelerated aging ofthe test specimens during the original


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qualification. IN 98-21 does state that the testspecimens were “aged more slowly” in theNRC-sponsored research but never concludesthat this aging methodology was responsible forthe reported performance problems. The IN doesindicate the Sandia testing raises potential issuesfor connectors that exhibit low/marginal insulationresistance values or were not subjected todielectric withstand tests. A detailed 1998NUGEQ review of the Sandia testing referencedin the IN indicated that many performanceproblems may have been caused by testanomalies, including possible unplannedsubmergence of the test specimens, anddifferences between the testsequence/configuration used by Sandia andthose used during the vendor qualification tests.In addition, for several specimens the Sandiaaging conditions, based on an Arrheniusanalysis, exceeded those in the vendorqualification tests. Given these considerations IN98-21 and referenced documents do not call intoquestion “overly accelerated aging” and this SRP3.11 paragraph should be deleted or some othersupportable basis documents cited to support thisconcern (overly accelerated aging). Finally andas a practical matter, we note that the only NRCreviewer guidance provided here regarding overlyaccelerated aging is to evaluate qualification testresults “while considering the specific applicationand set of environmental conditions under whichthe equipment must operate.” This is ameaningless generic platitude with no relevantguidance regarding overly accelerated aging. TheNUGEQ disagrees with this guidance.

4. Section II Acceptance Criteria – Item #2 –integrated HRRM system testing. Item #4 (page


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3.11-7) includes new SRP guidance regardingthe need for integrated qualification testing ofhigh-range radiation monitors (HRRM) togetherwith the cables and containment penetrationpigtails based on operating experience inInformation Notice 97-45 and its supplement.Again, on a procedural level and according toLIC- 200, new staff guidance based on operatingexperience (including experience based on NRCgeneric letters and bulletins) should be classifiedas a new staff position with associated ACRS andCRGR reviews. However, the SRP 3.11transmitting memorandum states that SRP 3.11contains no new guidance. Based on LIC-200this should be identified as a new staff position orthe text should be deleted. We recommenddeleting this text and integrated this guidance intothe planned revision to Regulatory Guide 1.89.

On a technical level this guidance incorrectlyconcludes that a lack of integrated testingresulted in spurious changes in HRRM outputduring environmental transients. IN 97- 45Supplement 1 reports on the transient thermaleffects to HRRM output that are due to inherentcharacteristics of certain coaxial cable styles.This phenomenon, based on the IN andsubsequent EPRI research, is affected by cablelength and the rate of ambient temperaturechange. The phenomenon is NOT related to anabsence of integrated qualification testing.Further, IN 97-45 describes a second issue -HRRM cable moisture intrusion during a LOCAsimulation that migrated to the cable connectorand caused partial shorting – that is notdiscussed in SRP 3.11. The IN suggests that theabsence of integrated testing of thecable/connector or adequate consideration of the


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plant cable/connector physical layout may havecontributed to this moisture migration problem.Regarding this second phenomena cable styleswhich preclude significant intrusion/migration orcable/connector designs which prevent moisturemigration into the connector are methods ofaddressing this potential deficiency. The NUGEQrecommends deleting this paragraph or revising itto accurately reflect the referenced documentsand subsequent evaluations.

IX 50.49 Exemption for Reg. Guide 1.97 and OtherReferences to Reg. Guide 1.97

Both draft 1996 and draft 2007 SRP 3.11 containerroneous guidance regarding the need for anexemption from 10 CFR 50.49(b)(3) for plantsthat use RG1.97 Rev.3 or Rev.4. Theperpetuation of this erroneous guidance is anexample of the problem with the NRC concluding,absent detailed public review, that the 1996 draftrepresents current accepted staff practice.

The proposed SRP 3.11 states:

“For new applications, the staff may accept anexemption from the requirement of 10 CFR50.49(b)(3) to qualify certain types ofpost-accident monitoring equipment inaccordance with Revision 2 to Regulatory Guide1.97, if the applicant commits to conformancewith the latest revision of Regulatory Guide 1.97,which meets the underlying purpose of the 10CFR 50.49 rule.” (pg 3.11-17)

This statement is incorrect. A licensee may takeexception to the Regulatory Guide, but the Guideis not a requirement for which an exemption

1) The NUGEQ recommendsdeleting REVIEW PROCEDURESitem #3 on page 3.11-17. If theNRC concludes that additionalguidance is warranted then wesuggest the following in lieu of item#3:

“For new applications, the 10 CFR50.49(b)(3) requirement to qualifycertain types of post-accidentmonitoring (PAM) equipmentlocated in a harsh environmentapplies to those instrumentsidentified as requiring suchqualification based on theapplicant’s submittal and the NRCreview thereof, including thereview conducted under SRPChapter 7. The regulatoryrequirements in 10 CFR50.49(b)(3) do not dictatecompliance with the guidance inRevision 2 to Regulatory Guide1.97, and applicants and licenseesmay justify exceptions to theprovisions of that guide.”

1) Agree 1) Section III REVIEWPROCEDURES, Item 3revised to read as follows:

“For new applications, the 10CFR 50.49(b)(3) requirementto qualify certain types ofpost-accident monitoring(PAM) equipment located ina harsh environment appliesto those instrumentsidentified as requiring suchqualification based on theapplicant’s submittal and theNRC review thereof,including the reviewconducted under SRPChapter 7. The regulatoryrequirements in 10 CFR50.49(b)(3) reference theguidance in Revision 2 toRegulatory Guide 1.97.”

Applicants and licenseesmay use the later revisions ofRegulatory Guide 1.97 ,when appropriate.


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would be required.

As a matter of law reference to a separatedocument, standard, or other information in aregulation does not, by itself, codify orincorporate the reference as a legal requirement.Such information is only incorporated byreference if the Director of the Federal Registerhas approved the incorporation in accordancewith 5 U.S.C. 552(a) and 1 C.F.R. Part 51. Thiswas not done in this instance and RegulatoryGuide 1.97 is not included in the NRC’s MaterialApproved for Incorporation by Reference (see 10C.F.R. “Material Approved for Incorporation byReference).8 In fact, the NRC previouslyrecognized the status of Regulatory Guide 1.97as guidance, even though identified in a footnotein 10 C.F.R. §50.49. Specifically, in 1984 as aresult of discussions between the NUGEQ andthe NRC legal and technical staff, the NRCclarified its interpretation of the legal significanceof footnote 4 to 50.49(b)(3). In a subsequentlyissued EQ SER9 the NRC recognized that alicensee can provide justification for not includingwithin the scope of 10 CFR 50.49(b) RegulatoryGuide 1.97, Rev. 2, Category 1 and 2 variableslocated in a harsh environment. Further, theacceptability of these justifications would bedetermined by the staff as part of its review forconformance with Regulatory Guide 1.97. ThatEQ SER concludes that such an approach foridentifying equipment within the scope of 10 CFR50.49(b)(3) is in accordance with therequirements of that paragraph.

The NUGEQ recommends deleting REVIEWPROCEDURES item #3 on page 3.11-17. If theNRC concludes that additional guidance is

2) Incorporate specific reference topost-accident monitoring (PAM) inReview Interfaces item #5 page3.11-4. For example, the firstsentence would be revised to read:“The adequacy of the design,installation, inspection, and testingof instrumentation and controls,including the post-accidentmonitoring (PAM) equipmentidentified in 50.49(b)(3), isreviewed as part of the licensingreview under SRP Chapter 7.”(emphasis added)

3) Delete reference to RegulatoryGuide 1.97 on page 3.11-2 item1.F. The revised text reads:“Certain post-accident monitoringequipment, as described in 10CFR 50.49(b)(3).”

2) Agree

3) Disagree

The regulatoryrequirements in 10 CFR50.49(b)(3) reference theguidance in Revision 2 toRegulatory Guide 1.97. Therefore, RG 1.97 is anappropriate reference forpost-accident monitoringequipment in SRP 3.11.(For operating plants)See Item 3 under Review

2) Review Interface Item 3revised to read as follows:

“Review of the adequacy ofthe design, installation,inspection, and testing ofinstrumentation and controls,including the functionaldesign and qualification ofdigital instrumentation andcontrol equipment located ina mild environment and thepost-accident monitoring(PAM) equipment identifiedin 10 CFR 50.49 (b) (3), isperformed under SRPChapter 7. Qualificationguidance of digital I&Cequipment located in a mildenvironment is alsoaddressed in RegulatoryGuide 1.209.

3) No changes made as aresult of this comment.


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warranted then we suggest the following in lieu ofitem #3:

“For new applications, the 10 CFR 50.49(b)(3)requirement to qualify certain types ofpost-accident monitoring (PAM) equipmentlocated in a harsh environment applies to thoseinstruments identified as requiring suchqualification based on the applicant’s submittaland the NRC review thereof, including the reviewconducted under SRP Chapter 7. The regulatoryrequirements in 10 CFR 50.49(b)(3) do notdictate compliance with the guidance in Revision2 to Regulatory Guide 1.97, and applicants andlicensees may justify exceptions to the provisionsof that guide.”

In any event, the NUGEQ understands that thisquestion was raised in a meeting with AREVAheld on November 29, 2006, and, as reflected inthe NRC Staff’s summary of that meeting, datedJanuary 28, 2007, the NRC acknowledged thatan exemption would not be required. Rather, thelicensee may take exceptions to the RegulatoryGuide which will be reviewed by the NRC on acase-by-case basis.

The NUGEQ further notes that the applicant’spost-accident monitoring (PAM) program, asaccepted by the NRC, including review applyingSRP Chapter 7, and not Regulatory Guide 1.97(directly), defines which PAM devices should bequalified to 50.49(b)(3). This is particularly truefor Regulatory Guide 1.97 Rev. 4 which does notdefine specific instruments in PAM categories. Inthis regard the NUGEQ recommends thefollowing:

4) Delete ACCEPTANCECRITERIA item #8 on page 3.11-8which describes Regulatory Guide1.97 as part of the SRP 3.11acceptance criteria for PAMinstruments.

5) Delete REVIEW PROCEDURESitem #3 on page 3.11-17 (seediscussion above regarding 50.49footnote).

6) Delete REFERENCE Item #35which references RegulatoryGuide 1.97.

Procedures

4) Disagree

The regulatoryrequirements in 10 CFR50.49(b)(3) reference theguidance in Revision 2 toRegulatory Guide 1.97.RG 1.97 providesguidance on I&Cequipment that needs tobe qualified for harshenvironment as requiredby 10 CFR 50.49(b)(3).

New applicants may usethe later revisions of theRG when appropriate.See response to item 1above and 2nd para underSRP Acceptance Criteria.

5) Agree

6) Disagree

The regulatoryrequirements in 10 CFR50.49(b)(3) reference theguidance in Revision 2 toRegulatory Guide 1.97.

4) No changes made basedon this comment. This is item7 in Acceptance Criteriasection.

5) Section III REVIEWPROCEDURES, Item 3 willbe replaced as discussed incomment 1 above.



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Incorporate specific reference to post-accidentmonitoring (PAM) in Review Interfaces item #5page 3.11-4. For example, the first sentencewould be revised to read: “The adequacy of thedesign, installation, inspection, and testing ofinstrumentation and controls, including thepost-accident monitoring (PAM) equipmentidentified in 50.49(b)(3), is reviewed as part of thelicensing review under SRP Chapter 7.”(emphasis added)

Delete reference to Regulatory Guide 1.97 onpage 3.11-2 item 1.F. The revised text reads:“Certain post-accident monitoring equipment, asdescribed in 10 CFR 50.49(b)(3).”

Delete ACCEPTANCE CRITERIA item #8 onpage 3.11-8 which describes Regulatory Guide1.97 as part of the SRP 3.11 acceptance criteriafor PAM instruments.

Delete REVIEW PROCEDURES item #3 on page3.11-17 (see discussion above regarding 50.49footnote).

Delete REFERENCE Item #35 which referencesRegulatory Guide 1.97.

RG 1.97 is an appropriatereference for SRP 3.11for qualification of post-accident monitoringequipment. RG 1.97 isused in other SRPsections.

X. Digital Instrument and Control Equipment

1. The proposed SRP 3.11 revision has addedthe word “digital’ before virtually all textoccurrences of “instrumentation and control”.Although there will a significant amount of digitalI&C devices and systems in future reactors, thischange incorrectly limits the SRP 3.11 guidanceto only digital instrumentation and control. It

1) Page 1 AREAS OF REVIEW –paragraph 1: Replace “digitalinstrumentation and control” with“instrumentation and control” andfootnote as follows: “the use of theterm instrumentation and control inthis section unless otherwisestated has applicability to all typesof instrumentation and control

1) Agree 1) The first sentence ofSection I AREAS OFREVIEW revised to read asfollows:

“...(mechanical, electrical,and instrumentation andcontrol (I&C), including digitalI&C)...”


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would be more appropriate to establish early inthe text that use of the term “instrumentation andcontrol” unless otherwise clarified hasapplicability to all types of instrumentation andcontrol equipment, including digital and analogdevices. Subsequent use of digital and analogwould then imply that the applicable guidance islimited to that specific type of device.

Page 1 AREAS OF REVIEW – paragraph 1:Replace “digital instrumentation and control” with“instrumentation and control” and footnote asfollows: “the use of the term instrumentation andcontrol in this section unless otherwise stated hasapplicability to all types of instrumentation andcontrol equipment, including digital and analogdevices.”

Page 2 – delete both occurrences of “digital”.

Page 4 – delete 2 occurrences of “digital” andretain the one “digital” reference in the sentence“Guidance for the qualification of digitalinstrumentation and control equipment located inboth mild and harsh environment is also providedin SRP Chapter 7.”

Page 9 – retain the one “digital” reference in thesentence “Guidance for the qualification of digitalinstrumentation and control equipment located inboth mild and harsh environment is also providedin SRP Chapter 7.”

2. In the Page 4 and 9 sentences cited above -“Guidance for the qualification of digitalinstrumentation and control equipment located inboth mild and harsh environment is also providedin SRP Chapter 7.” It is important to recognize

equipment, including digital andanalog devices.”

2) Page 2 – delete bothoccurrences of “digital”.

3) Page 4 – delete 2 occurrencesof “digital” and retain the one“digital” reference in the sentence“Guidance for the qualification ofdigital instrumentation and controlequipment located in both mild andharsh environment is also providedin SRP Chapter 7.”

4) Add the following to ReviewInterfaces:

“13. The functional design andqualification of digitalinstrumentation and controlequipment is addressed in SRPChapter 7.”

5) If the title and scope of theregulatory guide [DG-1142,Guidelines for EnvironmentalQualification of Safety RelatedComputer-Based Instrumentationand Control Systems in NuclearPower Plants] focus onenvironmental qualification ratherthan functional qualification ofdigital systems, then theanticipated regulatory guide shouldbe referenced in SRP 3.11.

2) Agree

3) Agree

4) Agree

5) Agree

2) The requested deletionmade.

3) The requested changes made.

4) The Review Interface item3 revised as discussed inresponse to comment IX-2.

5) Reference to RG 1.209,which is the RegulatoryGuide corresponding to DG-1142 added.


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that the term qualification has a broader meaning(i.e., functional qualification) than environmentalqualification. This distinction may be lost absentsome clarifying language. It also appearsappropriate to identify “qualification of digitalinstrumentation and control equipment” as anadditional item in the SRP section on ReviewInterfaces. The NUGEQ recommends adding thefollowing to Review Interfaces:

“13. The functional design and qualification ofdigital instrumentation and control equipment isaddressed in SRP Chapter 7.”

3. The NRC has published and receivedcomments, including those provided by theNUGEQ, on DG-1142, Guidelines forEnvironmental Qualification of Safety RelatedComputer-Based Instrumentation and ControlSystems in Nuclear Power Plants. However,there is no reference to this anticipated regulatoryguide in SRP 3.11. If the title and scope of theregulatory guide focus on environmentalqualification rather than functional qualification ofdigital systems, then the anticipated regulatoryguide should be referenced in SRP 3.11.

XI. Maintenance Rule and Acceptance Criteria forMild Environment Equipment

In ACCEPTANCE CRITERIA page 3.11-11, item#19 presents guidance on environmentalqualification of electrical and mechanicalequipment located in mild environments. Theguidance in the second paragraph includes thediscussion of a “well-supportedmaintenance/surveillance program,” a “preventive

1) Delete the language in thesecond paragraph [ACCEPTANCECRITERIA page 3.11-11, item #19]and replace with the following:

“Compliance with 10 CFR 50.65,“Requirements for monitoring theeffectiveness of maintenance atnuclear power plants,” andassociated guidance in Regulatory

1) Agree 1) The 2nd paragraph of Item15, in Section IIACCEPTANCE CRITERIAmodified to read as follows:

“A well-supportedmaintenance/surveillanceprogram, in conjunction witha good preventivemaintenance program, is


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maintenance program” and periodic reviews ofmaintenance records. The language in thisparagraph originally appeared in the 1981revision of SRP 3.11 before promulgation of 10CFR 50.65, “Requirements for monitoring theeffectiveness of maintenance at nuclearpowerplants,” and associated industry and NRCguidance (e.g., Regulatory Guide 1.160 andNUMARC 93-01). The maintenance ruleeffectively encompasses this SRP 3.11 guidance,including considerations associated with periodicmaintenance, monitoring, and periodicevaluations. Consequently, the guidanceprovided in SRP 3.11 is redundant, outdated, andpotentially at odds with 50.65 (e.g., the SRP 3.11guidance specifies a periodic review at leastevery 18 months while 50.65 specifies at leastevery 24 months).

We recommended that the language in thissecond paragraph be deleted and replaced withthe following:

“Compliance with 10 CFR 50.65, “Requirementsfor monitoring the effectiveness of maintenanceat nuclear power plants,” and associatedguidance in Regulatory Guide 1.160 are sufficientto provide reasonable assurance thatenvironmental considerations established duringdesign are maintained on a continuing basisduring operation.”

It may also be appropriate to identify 10 CFR50.65 and Regulatory Guide 1.160 in theACCEPTANCE CRITERIA and REFERENCESsections.

Guide 1.160 are sufficient toprovide reasonable assurance thatenvironmental considerationsestablished during design aremaintained on a continuing basisduring operation.”

2) Identify 10 CFR 50.65 andRegulatory Guide 1.160 in theACCEPTANCE CRITERIA and

2) Agree

sufficient to ensure thatequipment that meets thedesign/purchasespecifications is qualified forthe designed life. Compliance with 10 CFR50.65, "Requirements formonitoring the effectivenessof maintenance at nuclearpower plants," andassociated guidance inRegulatory Guide 1.160 aresufficient to providereasonable assurance thatenvironmental considerationsestablished during designare reviewed every refuelingoutage and maintained on acontinuing basis to ensurethat the qualified design lifehas not been reduced bythermal, radiation, and/orcyclic degradation resultingfrom unanticipatedoperational occurrences orservice conditions. Modification to thereplacement program and/orreplacement of equipmentshould be based on thereview ofmaintenance/surveillancedata.”

2) The requested referencesadded. 10 CFR 50.65 asreference 7 and RG 1.160 as


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REFERENCES sections. reference 30.

XII Out of Date References

SRP 3.11 Section VI REFERENCES identifies anumber of retired or out-of-date standards. Thiscreates confusion regarding which standards andversions should be used by licensees. NUGEQcomment - Confusing Reference and Applicabilityof IEEE Standards and Regulatory Guides –contains recommendations intended to limitconfusion regarding applicable IEEE standards.

The NUGEQ has annotated the following SRP3.11 references with [bracketed bold text] toclarify the revision status of these standards. TheNRC should consider similar information in theSRP.

9. IEEE Std 317-1983 (reaffirmed 1992), “IEEEStandard for Electric Penetration Assemblies inContainment Structures for Nuclear PowerGeneration Stations,” Institute of Electrical andElectronics Engineers (endorsed by RegulatoryGuide 1.63). [reaffirmed in 2003]

10. IEEE Std 323-1974, “IEEE Standard forQualifying Class 1E Equipment for NuclearPower Generating Stations,” Institute of Electricaland Electronics Engineers (endorsed byRegulatory Guide 1.89 and NUREG-0588).[revised in 1983 and 2003]

11. IEEE Std 334-1971, “IEEE Trial-Use Guidefor Type Tests of Continuous-Duty Class 1

1) The NUGEQ has annotated thefollowing SRP 3.11 references with[bracketed bold text] to clarify therevision status of these standards.The NRC should consider similarinformation in the SRP.

1) Disagree

NRC policy is to performa detailed staff review ofindustry standards beforeendorsing thosestandards as anacceptable method ofmeeting regulations. While NRC is aware thatvarious standards havebeen revised, the latestrevisions are not alwaysendorsed by the staff forvarious reasons, includingunacceptable content. However, in certaininstances, standards thathave not been endorsedby the staff may containuseful information andmay be used as referencedocuments. Thereferences cited are forstandards that have beenendorsed, and areacceptable to the staff tomeet the requirements forwhich they were intended,or for standards that maybe useful as referencedocuments. Therefore,referencing a version of a



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Motors Installed Inside the Containment ofNuclear Power Generating Stations,” Institute ofElectrical and Electronics Engineers (endorsedby Regulatory Guide 1.40). [revised in 1974,reaffirmed in 1980, revised in 1994]

12. IEEE Std 381-1977 (reaffirmed 1984), “IEEEStandard Criteria for Type Tests of Class 1EModules Used in Nuclear Power GeneratingStations,” Institute of Electrical and ElectronicsEngineers. [withdrawn in 1994]

13. IEEE Std 382-1972, “IEEE Trial-Use Guidefor Type Test of Class 1 Electric Valve Operatorsfor Nuclear Power Generating Stations,” Instituteof Electrical and Electronics Engineers. (asendorsed by Regulatory Guide 1.73.) [revised in1985 and 1996 and reaffirmed in 2004]

14. IEEE Std 383-2003, “IEEE Standard for TypeTest of Class 1E Electric Cables and FieldSplices for Nuclear Power Generating Stations,”Institute of Electrical and Electronics Engineers(endorsed by Regulatory Guide 1.131).[reaffirmed in 1992 and revised in 2003]

15. IEEE Std 535-1986, “IEEE Standard forQualification of Class 1E Lead Storage Batteriesfor Nuclear Power Generating Stations,” Instituteof Electrical and Electronics Engineers.[reaffirmed in 1994 and revised in 2006]

16. IEEE Std 572-1985, “IEEE Standard forQualification of Class 1E Connection Assembliesfor Nuclear Power Generating Stations,” Instituteof Electrical and Electronics Engineers (endorsedby Regulatory Guide 1.156). [reaffirmed in 1992and 2004]

2) The NUGEQ recommendsdeleting this reference toRegulatory Guide 1.131,“Qualification Tests of ElectricCables, Field Splices, andConnections forLight-Water-Cooled Nuclear PowerPlants”

3) SRP 3.11 Section VIREFERENCES for a number ofregulatory guides identifies theendorsed version of the applicableIEEE standard, such as “(thisguide endorses IEEE Std382-1972)”. It may be moreappropriate to delete thisinformation since subsequentregulatory guide revisions arelikely to endorse more recentversions, thus rendering the SRP3.11 information obsolete. If theendorsed version text was deletedthen the reference would not beobsolete when the regulatoryguides are revised.

standard that has beensuperceded by a revisiondoes not necessarilyconstitute an out of datereference. Instead, itrepresents the latestversion of the standardthat has been endorsedby the staff.

2) Disagree

RG 1.131 draft retainedfor guidance purposespending issuance of theFinal version.

3) Disagree

(See response tocomment 1 above.)




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17. IEEE Std 627-1980 (reaffirmed 1991), “IEEEStandard for Design Qualification of SafetySystems Equipment Used in Nuclear PowerGenerating Station,” Institute of Electrical andElectronics Engineers. [withdrawn]

18. IEEE Std 649-1980, “IEEE Standard forQualifying Class 1E Motor Control Centers forNuclear Power Generating Stations,” Institute ofElectrical and Electronics Engineers. [revised in1991, reaffirmed in 1999 and 2004, and revisedin 2006]

19. IEEE Std 650-1979, “IEEE Standard forQualification of Class 1E Static Battery Chargersand Inverters for Nuclear Power GeneratingStations,” Institute of Electrical and ElectronicsEngineers. [revised in 1990 and 2006]

SRP 3.11 Section VI REFERENCES identifiesRegulatory Guide 1.131, “Qualification Tests ofElectric Cables, Field Splices, and Connectionsfor Light-Water-Cooled Nuclear Power Plants”and indicates that this guide endorses IEEEE383-2003. To our knowledge the NRC has neverformally issued RG 1.131. According to the NRCwebsite the For Comment version was publishedAugust 1977 and Proposed Revision 1, waspublished August 1979 (which is beingreferenced by the SRP). No similarly named draftguide was identified on the website. Based onthis information the NUGEQ concludes that noneof the available draft versions could haveendorsed IEEEE 383- 2003 which was published20+ years after these draft versions. The NUGEQrecommends deleting this reference.

SRP 3.11 Section VI REFERENCES for a


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number of regulatory guides identifies theendorsed version of the applicable IEEEstandard, such as “(this guide endorses IEEE Std382-1972)”. It may be more appropriate to deletethis information since subsequent regulatoryguide revisions are likely to endorse more recentversions, thus rendering the SRP 3.11information obsolete. If the endorsed version textwas deleted then the reference would not beobsolete when the regulatory guides are revised.

XIII Environmental Qualification for Radiation HarshConditions

It is currently a common and accepted practice toqualify in accordance with 10 CFR 50.49 certainelectrical equipment in ‘Radiation Only’ harshconditions using analysis of radiation testinformation (i.e., partial test data) combined withappropriate consideration of margin and agingeffects for nonmetallic components/materials.This methodology meets 10 CFR 50.49(f)(4) andis similar to the material evaluations conductedfor mechanical equipment in harsh environments(see Item # 18 on page 3.11-11). The staffrecognized and accepted this practice asconsistent with its position in cases wheresufficient documentation is available to precludethe need for a type test.10

The NUGEQ recommends the addition of thefollowing new paragraph on page 3.11-10 to Item#14.

“Environmental qualification for electricalequipment located in a ‘Radiation- Harsh’environment (i.e., locations where radiation is theonly harsh environmental condition) can be

1) Add the following newparagraph on page 3.11-10 to Item#14.

“Environmental qualification forelectrical equipment located in a‘Radiation- Harsh’ environment(i.e., locations where radiation isthe only harsh environmentalcondition) can be accomplished inaccordance with 10 CFR50.49(f)(4) using analysiscombined with radiation testinformation (i.e., partial test data)and appropriate consideration ofmargin and aging effects fornonmetallic components/materialswhen sufficient documentation isavailable to preclude the need fora type test.

1) Agree

This is now item # 12.

1) The following newparagraph added to SectionII ACCEPTANCE CRITERIA,Item #12.

“Environmental qualificationfor electrical equipmentlocated in a ‘Radiation harsh'environment (i.e., locationswhere radiation is the onlyharsh environmentalcondition) can beaccomplished in accordancewith 10 CFR 50.49(f)(4)using analysis of test data(from identical materials)combined with radiation testinformation (i.e., partial testdata), and appropriateconsideration of margin andaging effects for nonmetalliccomponents/materials whensufficient documentation isavailable to preclude theneed for a type test.”


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accomplished in accordance with 10 CFR50.49(f)(4) using analysis combined withradiation test information (i.e., partial test data)and appropriate consideration of margin andaging effects for nonmetalliccomponents/materials when sufficientdocumentation is available to preclude the needfor a type test.

XIV Environmental Qualification as an OperationalProgram

Item #20 on page 3.11-11, Item #11 on page3.11-15, and Item #6 on page 3.11-17 discussCOL operational programs and requiredmilestones. The NUGEQ has not evaluated thespecific criteria used to determine ifenvironmental qualification is considered anoperational program. However, SECY-05-0197Attachment 1 lists operational programs identifiedby NEI. The attachment indicates that NEIidentified “Equipment Qualification” as such aprogram with the applicable regulation as 50.49.NEI has incorrectly named this program as“equipment” qualification; 50.49 and relatedguidance are for “environmental” qualification ofcertain electrical equipment located in a harshenvironment. Importantly, SECY-05-0197 makesclear that the “operational” environmentalqualification program is limited to 10 CFR 50.49.

NEI and the SECY recognize that the applicableregulation for this operational program is 50.49.There are no other operational programsidentified in the SECY for seismic qualification,equipment qualification, mechanical equipmentqualification, or for environmental qualification ofequipment (electrical or mechanical) in mild

1) Item #20 revised to read:

“For COL applicants, in addition tothe meeting the acceptancecriteria for the program elementsdescribed above, acceptableimplementation milestones mustbe identified for operationalprograms. An acceptableimplementation milestone for the10 CFR 50.49 environmentalqualification program for certainelectrical equipment located in aharsh environment is to have allqualification requirements metprior to the loading of fuel.

2) Item #11 – last sentencerevised to read:

“The 10 CFR 50.49 environmentalqualification program for certain

1) Agree

This is item # 16.

2) Agree

This is item # 10.

1) Item 16, on page 3.11-10revised to read as follows:

“For COL applicants, inaddition to meeting theacceptance criteria for the program elements describedabove, acceptableimplementation milestonesmust be identified foroperational programs. Anacceptable implementationmilestone for the 10 CFR50.49 environmentalqualification program forelectrical, and I&C equipment located in a harshenvironment is to have allqualification requirementsmet prior to the loading offuel. Implementation isrequired by a licensecondition.

2) Technical Rationale, Item10, last sentence revised toread as follows:

“The 10 CFR 50.49


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environments. Based on these considerations theNUGEQ assumes the operative text regardingthe need for a 50.49 operational program is in50.49(a) which states:

“Each holder of or an applicant for a license for anuclear power plant, other than a nuclear powerplant for which the certifications required under §50.82(a)(1) have been submitted, shall establisha program for qualifying the electric equipmentdefined in paragraph (b) of this section.”(emphasis added).

In addition, it appears that these SRP 3.11 items,particularly Item #11 on page 3.11-15, incorrectlyconclude that all the environmental qualificationactivities described in SRP 3.11 are elements ofthis operational program. This appears contraryto the SECY and NEI information that limits theoperational program to 10 CFR 50.49environmental qualification. Based on theseconsiderations the NUGEQ recommends revisingitem #20, item #15, and item #6 as follows:

Item #20 revised to read:

“For COL applicants, in addition to the meetingthe acceptance criteria for the program elementsdescribed above, acceptable implementationmilestones must be identified for operationalprograms. An acceptable implementationmilestone for the 10 CFR 50.49 environmentalqualification program for certain electricalequipment located in a harsh environment is tohave all qualification requirements met prior tothe loading of fuel.

Item #11 – last sentence revised to read:

electrical equipment located in aharsh environment was identifiedas an operational program in thatmemo.”

3) Item #6 - first paragraph revisedto read:

“For a COL application, the staffreviews the description of the 10CFR 50.49 environmentalqualification program for certainelectrical equipment located inharsh environments and theproposed implementationmilestones.”

3) Agree

This is item # 5.

environmental qualificationfor electrical and I&Cequipment located in a harshenvironment was identifiedas an operational program inthat memo.”

3) Item 5 of ReviewProcedures revised to readas follows:

“For a COL application, thestaff reviews therequirements of the 10 CFR50.49 environmentalqualification program forelectrical and I&C equipmentlocated in harshenvironments and theproposed implementationmilestones.”


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“The 10 CFR 50.49 environmental qualificationprogram for certain electrical equipment locatedin a harsh environment was identified as anoperational program in that memo.”

Item #6 - first paragraph revised to read: “For a COL application, the staff reviews thedescription of the 10 CFR 50.49 environmentalqualification program for certain electricalequipment located in harsh environments and theproposed implementation milestones.”

XV. Central Environmental Qualification File

SRP 3.11 in numerous locations providesguidance on qualification records and files,including a “central file”. Collectively thisguidance generally reflects current industrypractice and staff positions associated with 10CFR 50.49 records/files but uses incorrectterminology and does not accurately reflect suchpractices and positions for mild environmentequipment or mechanical equipment in harshenvironments.

For electrical equipment located in a harshenvironment, 10 CFR 50.49(d)11 requires a list ofcovered electric equipment and an auditable filethat includes accident-related environmentalconditions, electrical characteristics, andequipment performance specifications. The listand file must be kept current and retained in anauditable form throughout the plant life. Nosimilar regulatory requirements exist for mildenvironment equipment or mechanical equipmentin harsh environments. The most applicablerequirement is 10 CFR Part 50, Appendix B,Criterion XVII, Quality Assurance Records. It is

1) Item 4B page 3.11-3: Replace“An audit of the applicant’s centralfile, including a review of thedocumentation provided in the fileto demonstrate tangible evidenceof qualification.” with “An audit ofthe applicant’s records, including areview of the documentation usedto demonstrate tangible evidenceof qualification.”

1) Agree 1) Item 4B on page 3.11-3revised appropriately to readas follows:

“An audit of the applicant'srecords, including a review ofthe documentation providedin the file to permitverification of theenvironment design andqualification for allmechanical, electrical andI&C equipment covered bythis SRP section. The staff'sreview is performed todetermine (1) properimplementation of criteriaestablished in the CP review,and (2) adequateenvironmental design andqualification for all electrical,mechanical and I&Cequipment covered by thisSRP section.”


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reasonable to infer for this equipment thatsufficient environmental design and qualificationrecords must be retained in an auditable form tofurnish evidence that this equipment,, pursuant toGDC 4, is designed to accommodate the effectsof and to be compatible with applicableenvironmental conditions.

In contrast, SRP 3.11 appears to make nodistinction between the record requirements forany of these classes of equipment (harshelectrical, harsh mechanical, and mild electrical/mechanical). Its guidance appears to specify acentral file for all classes of equipment. This isinconsistent with applicable regulations andguidance, including 50.49 and Regulatory Guide1.89 Rev.1. SRP 3.11 Item 4B page 3.11-3discusses an applicant’s central file whichcontains tangible evidence of “environmentalqualification for all mechanical and electricalequipment covered by this SRP section.”(emphasis added) Similarly Item #2 on page 16discusses the staff audit of “the qualification filesat the applicant’s central storage location.”Importantly, although a central file was specifiedin the proposed 50.4912 it was removed in thefinal rule. The SOC accompanying the final ruledescribed this change as follows:

Issue: The requirement for a central file shouldbe deleted since it is not cost effective and hasno safety benefit. Response: The Commissionagrees. This requirement has been subject todifferent interpretations. A record of qualificationmust be maintained in an “auditable form” but notnecessarily in a central file for the entire periodduring which the covered item is installed in anuclear power plant. Record keeping requirement

2) Item 2 page 3.11-16: Delete “,and maintained at a centrallocation,” in 2nd paragraph.

3) In the 3rd paragraph replace“applicant’s qualification file” with“applicant’s qualification file orrecords” and replace “audit thequalification files at the applicant’scentral storage location” with “auditthe applicant’s qualification files

2) Agree

3) Agree

2) 2nd paragraph, Item 2 onpage 3.11-14 revised to readas follows:

“At the time of the OLapplication, the reviewerconfirms that completerecords are retained at afacility in an auditable andreadily accessible form,which describe theenvironmental design andqualification method used forall mechanical, electrical,and I&C equipment insufficient detail to documentthe degree of compliancewith the requirementsdiscussed herein. Thereviewer also confirms that,thereafter, such records willbe updated and maintainedcurrent as equipment isreplaced, tested, orotherwise qualified.”

3) 3rd paragraph in Item 2revised to read as follows:

“To confirm the extent towhich the equipment meetsthe requirements ofSubsection II, the staff audits


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of 10 CFR Part Appendix B must be met. Certainrecords can be kept at the vendor’s shop.”

In addition to the central file problem, the SRP isunclear regarding differences in the types ofrecords that apply to the different equipmentclasses. The following summarizes currentaccepted industry practice and NRC staffpositions regarding such records.

For electrical equipment in a harsh environmentcompliance with 50.49 requires an equipment listand qualification files that include the informationspecified in 50.49(d)(1), (2), and (3).

For mechanical equipment in a harshenvironment compliance with the GDC 4requirement that the design of equipment becompatible with and accommodate the effects ofapplicable environmental conditions, includingaccident conditions, is generally achievedthrough the evaluation of non-metalliccomponents/parts (e.g., seals, gaskets,lubricants, fluids for hydraulic systems, anddiaphragms). Appropriate documentation of thisevaluation in accordance with 10 CFR Part 50,Appendix B, Criterion XVII, Quality AssuranceRecords, is necessary. However, environmentalqualification files, per se, are not required formechanical equipment in a harsh environment.13

For electrical and mechanical equipment in a mildenvironment compliance with the GDC 4requirement that the design of equipment becompatible with and accommodate the effects ofapplicable environmental conditions is generallyachieved through incorporation of the appropriateenvironmental conditions into the design and

and records.” the environmental designand qualification files andrecords, and conducts aplant site review. Forselected equipment, the staffreviews the test procedureand test results, andexamines the equipmentconfiguration and mounting,and then determines whetherthe test or analysisreferenced demonstratescompliance with theestablished criteria. Thestaff may require thatcomponent evaluationworksheets for all equipmentbe submitted to the staff. After the visit, the applicantmay be required to submitcertain selected documentsand reports for further staffreview. If the staff hasreviewed an applicant'senvironmental design andqualification files and recordsfor a previous application,they may elect not to requirethe applicant to submit all thequalification summary datasheets, but instead elect toaudit the environmentaldesign and qualification filesand records.”


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procurement specifications. Appropriatedocumentation of the proper incorporation ofenvironmental conditions in accordance with 10CFR Part 50, Appendix B, Criterion XVII, QualityAssurance Records, is necessary. However,environmental qualification files, per se, are notrequired.

To resolve SRP inconsistency with Commissionguidance regarding a central file and to provideappropriate guidance regarding differences in thetype of records among the equipment classes,the NUGEQ recommends the following:

Item 4B page 3.11-3: Replace “An audit of theapplicant’s central file, including a review of thedocumentation provided in the file to demonstratetangible evidence of qualification.” with “An auditof the applicant’s records, including a review ofthe documentation used to demonstrate tangibleevidence of qualification.”

Item 2 page 3.11-16: Delete “, and maintained ata central location,” in 2nd paragraph. In the 3rdparagraph replace “applicant’s qualification file”with “applicant’s qualification file or records” andreplace “audit the qualification files at theapplicant’s central storage location” with “auditthe applicant’s qualification files and records.”

Implementation page 3.11-19: Replace “Eachplant is required to have a completeenvironmental qualification file that demonstratescompliance with this review plan (or usesestablished bases for alternate requirements)before submittal of an OL application.” With“Each plant is required to have completeenvironmental qualification records, including an

4) Implementation page 3.11-19:Replace “Each plant is required tohave a complete environmentalqualification file that demonstratescompliance with this review plan(or uses established bases foralternate requirements) beforesubmittal of an OL application.”With “Each plant is required tohave complete environmentalqualification records, including anenvironmental qualification file for10 CFR 50.49 equipment, thatdemonstrate compliance with thisreview plan(or uses establishedbases for alternate requirements)before submittal of an OLapplication.”

4) Agree 4) The 2nd last paragraph ofSection VIMPLEMENTATION revisedto read as follows:

“Each plant is required tohave completeenvironmental design andqualification records,including an environmentalqualification file for 10 CFR50.49 equipment, thatdemonstrate compliance withthis review plan (or usesestablished bases foralternate requirements)before submittal of an OLapplication.”


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environmental qualification file for 10 CFR 50.49equipment, that demonstrate compliance with thisreview plan(or uses established bases foralternate requirements) before submittal of an OLapplication.”

XVI. Environmental Qualification for MechanicalEquipment in a Harsh Environment\

The NUGEQ disagrees with the statement in Item#1 on page 3.11-6 that the NUREG- 0588“criteria are general in nature and can also beapplied to mechanical equipment.” We assumethe observation was intended to be limited tomechanical equipment in harsh environments buteven in this limited case the guidance inNUREG-0588 Category 1 is inappropriate. Themost relevant NUREG-0588 guidance forqualification of mechanical equipment in harshenvironments relates to acceptable methods forestablishing accident environmental conditions.However, much of this guidance is supercededby similar guidance in Regulatory Guide 1.89Rev. 1. Most of the other NUREG-0588 guidance,including qualification methods anddocumentation are not applicable to the materialevaluation that establishes environmentalqualification for mechanical equipment in a harshenvironment. As correctly stated elsewhere inSRP 3.11 (see Item #18 on page 3.11-1114),equipment qualification for mechanical equipmentin a harsh environment is generally limited to anevaluation of those materials that are sensitive toenvironmental effects (e.g., seals, gaskets,lubricants, fluids for hydraulic systems, anddiaphragms). In summary, such an evaluationidentifies nonmetallic subcomponents, applicableenvironmental conditions, and evaluates the

1) Delete the following sentence inItem #1 on page 3.11-6: “Thesecriteria are general in nature andcan also be applied to mechanicalequipment.”

2) The NUGEQ recommendsdeleting the following sentence inthe first paragraph of Item #2 onpage 3.11-7: “Although specificallywritten for Class 1E electricequipment, IEEE Std 323 isconsidered applicable to theenvironmental qualification of othertypes of equipment.”

1) Agree

2) Agree

1) See changes made toresolve comment VI - 1. SeeSRP Acceptance Criteria 1.

2) The requested deletionmade. See SRP AcceptanceCriteria 2.


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environmental effects on the material/componentcapabilities. Further, the NRC’s position set forthin its evaluation of a current operating plant’sapproach regarding elimination of a separateprogram for environmental qualification ofmechanical equipment in harsh environmentsand provides appropriate direction for clarificationof this SRP discussion, and in particular theconclusion that “maintaining compliance withGDC-4 through the Procurement, Maintenanceand Surveillance Programs … would beacceptable….”15

The NUGEQ recommends deleting the followingsentence in Item #1 on page 3.11-6: “Thesecriteria are general in nature and can also beapplied to mechanical equipment.”

The NUGEQ questions the meaning of the term“other types of equipment” in the followingstatement on page 3.11-7: “Although specificallywritten for Class 1E electric equipment, IEEE Std323 is considered applicable to the environmentalqualification of other types of equipment.” If by“other types of equipment” the NRC meansmechanical equipment then we disagree with theusefulness of this statement within the SRP 3.11context. The NUGEQ believes that this SRPstatement may have originated when there wasless consensus regarding the methods used toaddress environmental considerations formechanical equipment. Today for both harsh andmild environment mechanical equipment there isa well defined process described in SRP 3.11and approved in recent SERs includingNUREG-1793, “Final Safety Evaluation ReportRelated to Certification of the AP1000 StandardDesign.” As noted elsewhere in these comments


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this involves evaluating the capabilities ofnon-metallic materials/parts for mechanicalequipment in harsh environments and integratingapplicable environmental conditions into thedesign and procurement specifications formechanical equipment in mild environments.IEEE 323 1974 contains little applicable guidanceregarding these activities.

The NUGEQ recommends deleting the followingsentence in the first paragraph of Item #2 onpage 3.11-7: “Although specifically written forClass 1E electric equipment, IEEE Std 323 isconsidered applicable to the environmentalqualification of other types of equipment.” TheNUGEQ disagrees with this statement andrecommends that it be deleted.

XVII Confusing Review Interface Guidance

The NUGEQ recognizes that the staff mustestablish its own review interfaces, and thatthose interfaces may change over time as aresult of, for example, agency reorganization.However, a quick review indicates that much ofthe guidance related to the review interfacesappears to lack sufficient clarity to assureadequately defined review responsibilities thatwould allow for a timely and efficient reviewprocess. Accordingly, we provide thesecomments for the staff’s consideration and urgeclarity in this area in order to facilitate the reviewprocess.

1) Review Interface items : #8 and#10 contain no reference to otherSRP sections.

1) Agree

Item 8 is now item 6 andprovided interfacereference to SRP section9.4.5. Item 10 is now initems 8 and 9 and SRPsection referencesprovided as 15.0.3 and6.5.2 respectively.

1) Review Interface Item 8 revised to delete reference toI&C equipment and sensinglines, and incorporated intoReview Interface Item 6 (seeresolution to comment XVII-3).

Review Interface Item 10separated into items 8 and 9and provided reference SRPSections 15.0.3 and 6.5.2.


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In sum, the NUGEQ believes a significant amountof the staff reviewer guidance in SRP 3.11Review Interface is confusing, contradictory, andpotentially misplaced. According to LIC200 theReview Interface should describe how other SRPsections interface with this section and how theevaluations are related to each other. Further, thespecific acceptance criteria and reviewprocedures are to be contained in the referencedSRP sections. According to LIC200, specificguidance for review of the contents of SRP 3.11should be contained in III. REVIEWPROCEDURES. This LIC200 guidance clearlyindicates that all Review Interface items mustreference other SRP sections and all SRP3.11reviewer guidance should be in III. REVIEWPROCEDURES. The following are examples ofproblems in SRP 3.11, principally in ReviewInterface. Note - the NUGEQ has not hadsufficient time to thoroughly comment on thistopic.

1. Review Interface items : #8 and #10 contain noreference to other SRP sections.

2. A review Interface item does not exist for (1)protection of electric and mechanical equipmentagainst other natural phenomena and externalevents and (2) equipment functional performanceduring and after exposure to conditions resultingfrom a 100% fuel-clad metal-water reaction. Bothitems are outside the scope of SRP 3.11:

3. Several Review Interface items (#3, #4, #5, #6,and #7) specify that specific system reviewsunder other SRP sections (e.g., instrument andcontrols in SRP 7) confirm that: (1) the SARidentifies each item of equipment described in

2) A review Interface item does notexist for (1) protection of electricand mechanical equipment againstother natural phenomena andexternal events and (2) equipmentfunctional performance during andafter exposure to conditionsresulting from a 100% fuel-cladmetal-water reaction. Both itemsare outside the scope of SRP 3.11:

2) Agree 2) The following new ReviewInterface items added:

Item 10.C. The design basesfor protection of mechanicaland electrical equipmentagainstnatural phenomena andexternal events, are reviewedunder appropriatesections of SRP Chapter 3(e.g., 3.3.1, 3.3.2, 3.4.1,3.5.1.1, 3.5.1.4, 3.5.1.5, and3.5.2). SRP Section 3.10includes seismic anddynamic qualification ofmechanical and electricalequipment.

Item 11. “Review of theadequacy of equipmentfunctional performanceduring and after beingexposed to theenvironmental conditionsresulting from the release ofhydrogen generated by theequivalent of a 100%fuel-clad metal-waterreaction, as stated in 10 CFR50.44 ©, is performed underSRP Section 6.2.5.”

(See response to commentIII - 7)


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Subsection I, Item 1, of this SRP section, (2) thevalidity of the descriptions of anticipatedoperational occurrences, and normal, accident,and post-accident environments provided in theSAR for this equipment, and (3) the acceptabilityof the values provided in the SAR for the lengthof time that the equipment is required to operateunder accident environments. However, itappears that the review procedures in thesereferenced sections do not specify such reviews.We base this conclusion on a review of SRP6.5.2 (referenced in item #7) which contains nodiscussion or confirmation of anticipatedoperational occurrences, environmentalconditions, SAR identification of each equipmentitem in SRP 3.11 Subsection I #1, or equipmentrequired operating times. NUGEQ notes that SRP3.11 III. REVIEW PROCEDURES, Items #1 and#2 suggest that the SRP 3.11 reviewers (primaryand secondary) do “review” the SRP 3.11identification of normal, accident, andpost-accident environmental conditions;anticipated operational occurrences; requiredoperating time; and chemical, submergenceconditions and verify that the system list,including the equipment list, is consistent withSubsection I, Item 1. The NUGEQ recommendsthat the NRC resolve this confusing guidanceabout who does these reviews and under whatSRP section. It may be appropriate to deleteReview Interface items #3, #4, #5, #6, and #7and include statements in REVIEWPROCEDURES, Items #1 and #2 that thereviewers of other SRP sections (list applicablesections) are consulted regarding certain topics(list topics).

4. Review Interface item #3 specifies that review

3) The NUGEQ recommends thatthe NRC resolve this confusingguidance about who does thesereviews and under what SRPsection. It may be appropriate todelete Review Interface items #3,#4, #5, #6, and #7 and includestatements in REVIEWPROCEDURES, Items #1 and #2that the reviewers of other SRPsections (list applicable sections)are consulted regarding certaintopics (list topics).

4) The NUGEQ questions why thecontainment and containmentsystem reviewers are responsiblefor confirming the location of allelectrical and mechanicalequipment (both inside andoutside containment) within thescope of SRP 3.11. The NUGEQrecommends that the NRC resolvethis apparently confusingguidance. It may be appropriate todelete this portion of Interface Item#3 and include guidance inREVIEW PROCEDURES,regarding confirming the locationof all electrical and mechanicalequipment (both inside andoutside containment) within thescope of SRP 3.11, including theneed to consult reviewers of otherSRP sections (list sections).

3) Agree

4) Disagree

The comment correctlynotes that ReviewInterface item 3 specifiesthat review under SRPSections 6.2.1 - 6.2.6“confirms that the SARidentifies the location ofeach equipmentdescribed in Section I,Item 1, of this SRPsection. The correctinterpretation is that thereviewer confirms that thenecessary information iscontained in the SAR. Itdoes not mean that thecontainment andcontainment systemreviewers are responsiblefor confirming the locationof all electrical and

3) The guidance in ReviewInterfaces 1-12 revised toprovide a clearer descriptionof the reviews performed.

4) Review Interface Item 1revised for clarity as follows:

“Review of the adequacy ofthe design, installation,inspection, and testing ofcontainment systems isperformed under SRPSections 6.2.1 through6.2.6.”


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under SRP Sections 6.2.1 - 6.2.6, in addition tothe activities discussed above, “confirms that theSAR identifies the location of each item ofequipment described in Subsection I, Item 1, ofthis SRP section, both inside and outside thecontainment. Inside the containment, the locationmust be specified, whether inside or outside ofthe missile shield for pressurized-water-reactor(PWR) plants, or whether inside or outside of thedrywell for boiling-water-reactor (BWR) plants.”The NUGEQ questions why the containment andcontainment system reviewers are responsiblefor confirming the location of all electrical andmechanical equipment (both inside and outsidecontainment) within the scope of SRP 3.11. Wesuspect that the 1996 SRP 3.11 draft contributedto this problem – it specified SCSB review of thisinformation. The similar 1981 version identifiedthe ASB and CSB as the reviewers of all suchequipment. The NUGEQ recommends that theNRC resolve this apparently confusing guidance.It may be appropriate to delete this portion ofInterface Item #3 and include guidance inREVIEW PROCEDURES, regarding confirmingthe location of all electrical and mechanicalequipment (both inside and outside containment)within the scope of SRP 3.11, including the needto consult reviewers of other SRP sections (listsections).

5. Review Interface Item #11 page 3.11-5represents additional confusing guidance when itspecifies that the organization responsible forreviewing the containment spray system reviewsall the bolting and thread fasteners under SRPSection 3.13 Draft Rev. 0 - April 1996, including“mounting and bolting details equivalent to thoseused for equipment qualification.” Similar

5) The NUGEQ recommendsdeleting Item #11 since harshenvironmental qualificationtypically evaluates and justifiesdifferences in orientation andmounting manner if theequipment’s performance isaffected by these differences andmore detailed considerationsregarding fastener design,materials, and stresses aretypically limited to seismic anddynamic qualification (SRP 3.10).

6) The NUGEQ suggests the NRCconsider dividing this item into twoitems. One would addressenvironments associated with lossof required HVAC systems andanother (if needed) for instrumentsensing line heat tracing (with anappropriate reviewer).

mechanical equipment(both inside and outsidecontainment) within thescope of SRP 3.11.

5) Agree

6) Agree

5) The requested deletionmade. Item # 11 deleted.

6) Review Interface Item 8 revised to delete reference toI&C equipment and sensinglines. (see resolution tocomment XVII-1 & 3).

Item 6 includes interface forloss of ventilation systems.


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guidance on such fasteners first appeared in the1996 SRP 3.11 draft except that a NRC materialsgroup and not the Containment Spray Systemorganization was responsible for the review. The1996 draft of SRP 3.10 on seismic qualificationcontains identical language.

NUGEQ assumes this guidance is limited toequipment in a harsh environment even thoughno such limitation is identified in SRP 3.11. Harshenvironmental qualification typically evaluatesand justifies differences in orientation andmounting manner (e.g., bolts, rivets, welds,clamps) if the equipment’s performance isaffected by these differences. However, moredetailed considerations regarding fastenerdesign, materials, and stresses are typicallylimited to seismic and dynamic qualification.

The referenced SRP 3.13 contains no ReviewInterface guidance regarding fastener reviews insupport of SRP 3.11. The most appropriatereference to equipment is in Review Interfacesand specifies that: “The EMEB reviews issuesrelated to piping, mechanical components, andmechanical and electrical component supports aspart of its primary review responsibility for SRPSections 3.6.1, 3.6.2, 3.9.2, and 3.9.3.”

The NUGEQ recommends deleting Item #11since harsh environmental qualification typicallyevaluates and justifies differences in orientationand mounting manner if the equipment’sperformance is affected by these differences andmore detailed considerations regarding fastenerdesign, materials, and stresses are typicallylimited to seismic and dynamic qualification (SRP3.10).

7) SRP 3.11 contains reviewerguidance (inappropriately) inACCEPTANCE CRITERIA Item#10 page 3.11-9 regardinginstrument sensing line freezeprotection. NUGEQ believes thisguidance should have been inSRP 7 rather than SRP3.11.17.The 1996 reviewer guidance wasto “assure that adequateredundancy and other appropriatemeasures have beenimplemented, to precludeinadvertent effects caused byadverse conditions.” This contrastssignificantly with the ProposedSRP 3.11 which instead specifiesinclusion of the control equipmentin the environmental qualificationprogram. Finally, this significantchange is not highlighted as achange in the proposed SRP 3.11version.

8) Review Interface Items #1, #2,and #12 contain overlappingguidance. The NUGEQ suggeststhe NRC revise these items andestablish separate items for (1)SRP sections responsible forseismic and dynamic qualification,(2) SRP sections responsible forfunctional design of mechanicalequipment, and (3) SRP sectionsresponsible for adverse floweffects and vibration caused byacoustic resonances and

7) Agree

8) Agree

7) Acceptance Criteria Item10 related to instrumentsensing lines deleted.

8) Review Interface Items 1and 2 deleted and combinedin Item 10.


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6. Review Interface Item #8 page 3.11-4 providesconfusing guidance which specifies that theorganization responsible for I&C equipment isresponsible for confirming the environmentaldescriptions resulting from loss of environmentalcontrol systems (heat tracing, ventilation, heating,air conditioning), for those areas that containequipment and instrument sensing lines that relyon heat tracing for freeze protection. No SRPsections are referenced for this item. Thisseemingly illogical guidance (why are the I&Cpersonnel responsible for confirming loss ofHVAC environments) is similar to 1996 draftlanguage and is evidence of problems arisingfrom relying on the 1996 draft as the officialversion.

The original 1981 SRP-3.11 guidance, whichmakes sense, states; “With regard to theenvironments resulting from loss ofenvironmental control systems (ventilation,heating, air conditioning), the ASB will confirmthe description of these environments asprovided in the SAR for those areas whichcontain equipment including electrical control andinstrumentation equipment.” This moreappropriate guidance tasks HVAC knowledgeablereviewers with verifying the environmentalconditions resulting from loss of HVAC systems,with the apparent purpose of using thoseconditions for qualification. The NUGEQ notesthat even this version does not indicate if suchconditions should be considered as part of thedesign for electrical equipment in the area.Although not discussed in SRP 3.11, we assumethat the loss of redundant safety-related HVAC isnot generally considered part of the designbasis.16 Unfortunately, the 1996 revision by

hydrodynamic forces.


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including heat tracing and freeze protection canalso be interpreted to change the entire meaningof the guidance. Now the guidance can be readto apply solely to conditions resulting fromequipment relied on for freeze protection. Themore appropriate intended meaning of the 1981version could be totally lost. Finally, the NUGEQquestions the need to include piping (sensinglines) within the scope of SRP 3.11. The NUGEQsuggests the NRC consider dividing this item intotwo items. One would address environmentsassociated with loss of required HVAC systemsand another (if needed) for instrument sensingline heat tracing (with an appropriate reviewer).

7. Further, regarding instrument sensing linefreeze protection, SRP 3.11 contains reviewerguidance (inappropriately) in ACCEPTANCECRITERIA Item #10 page 3.11-9. This itemindicates that the guidance in a regulatory guideon instrument sensing lines (RG 1.151) containsACCEPTANCE CRITERIA for SRP 3.11. It alsoprovides reviewer guidance (this guidance shouldbe in III. REVIEW PROCEDURES) to confirm thatthe applicant has identified any safety relatedsensing lines that rely on heat tracing andensured that the associated control equipment isincluded in the environmental qualificationprogram. Reference to RG 1.151 in SRP 3.11first appeared in the 1996 draft. NUGEQ believesthis guidance should have been in SRP 7 ratherthan SRP3.11.17 Nonetheless, at least the 1996reviewer guidance was to “assure that adequateredundancy and other appropriate measureshave been implemented, to preclude inadvertenteffects caused by adverse conditions.” Thiscontrasts significantly with the Proposed SRP3.11 which instead specifies inclusion of the


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control equipment in the environmentalqualification program. Finally, this significantchange is not highlighted as a change in theproposed SRP 3.11 version.

8. Review Interface Items #1, #2, and #12contain overlapping guidance. The NUGEQsuggests the NRC revise these items andestablish separate items for (1) SRP sectionsresponsible for seismic and dynamic qualification,(2) SRP sections responsible for functionaldesign of mechanical equipment, and (3) SRPsections responsible for adverse flow effects andvibration caused by acoustic resonances andhydrodynamic forces.

XVIII SRP 3.11 Revision Control and Justification forChanges

As a matter of process clarity and consistency,and recognizing the importance of adequatelydefining the nature of changes to the prior SRPrevision in order to assure proper internal NRCreview, the NUGEQ also evaluated the nature ofthe new and changed staff positions reflected inthis proposed revision of SRP 3.11 andcompared those with what appears to be thecontrolling NRC guidance for SRP revision.

Our review suggests that, contrary to theguidance in LIC200 Rev. 1, “Standard ReviewPlan (SRP) Process”, the proposed SRP 3.11revision only highlights significant changes (but

1) Our review suggests that,contrary to the guidance in LIC200Rev. 1, “Standard Review Plan(SRP) Process”, the proposedSRP 3.11 revision only highlightssignificant changes (but not allchanges) from the prior 1996 draftversion. LIC200 specifies thatchanges from the last formalversion (i.e., 1981) including textfrom the 1996 draft be highlighted

2) The NUGEQ concludes thatthese additions constitute newstaff positions, that the staff shouldrevise statements that SRP 3.11contains no new staff positions,

1, 2, 3) Disagree

LIC-200 is an internalNRC Office Instructionthat, in part, providesguidance to the staff formaintaining andmodifying existing SRPsections, and adding newSRP sections. Thisdocument is revised, asneeded, based onlessons learned toimprove the guidanceprovided and make theSRP revision processmore efficient and

SRP 3.11 was revised basedon these comments asfollows:

NUGEQ reviewed theproposed SRP 3.11 Revision3 and provided commentsand recommended changesby latter dated Feb. 09, 2007.

The necessary changesmade based on NUGEQrecommendationsappropriately throughoutSRP 3.11.


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not all changes) from the prior 1996 draft version.LIC200 specifies that changes from the lastformal version (i.e., 1981) including text from the1996 draft be highlighted. In this proposed SRPsection the staff does not identify and justifychanges between the 1981 and 1996 version.SRP 3.11 in “Description of Changes” page 3.11-A-1 simply states that “This SRP section affirmsthe technical accuracy and adequacy of theguidance previously provided in (Draft) Revision3, dated April 1996 of this SRP.” The NUGEQbelieves this is contrary to the guidance inLIC-200.

Also contrary to LIC-200 the staff has apparentlyconcluded that endorsement of the 1996 draftdoes not represent new staff positions becausethe draft has been used by the staff andstakeholders (e.g., new reactor designcertification reviews and Review StandardsRS-001 and RS-002).18 The NUGEQ questionsthe adequacy of this conclusion particularly withrespect to SRP 3.11. The NUGEQ has notconducted an exhaustive search of availabledocuments to determine the specific cases whereapplicants and the NRC staff have used the 1996draft version of SRP 3.11 in lieu of the last formalversion (Revision 2 in 1981). However, theapplicant and the NRC staff did use SRP 3.11Rev. 2 and not the 1996 draft for the AP1000SER (see NUREG-1793, Vol. 1, page 3-251)which was completed in 2004.19 Further, we donot believe efforts associated with RS-001 andRS-002 involved significant reliance on SRP3.11.20 Setting aside this question about thestatus of the 1996 draft, it appears that the staffhas incorrectly concluded that the proposed SRP3.11s represents no new staff positions since the

and the review and approvalprocess for SRP 3.11 shouldconform with NRC procedures forSRP sections with new staffpositions (i.e., LIC200 Type 2).

3) As described further in our othercomments, the NUGEQ believesthat a number of changes made inthe 1996 draft, that did not benefitfrom close public or regulatoryreview but have now been deemed– contrary to LIC200 - to representcurrent staff positions during theSRP 3.11 update, have contributedto many of the problems with theproposed SRP section.

tractable. The latest SRPrevision processrepresents a similar effortwas initiated in 1996(draft). During the latestSRP revision process, thechanges proposed in1996 were reviewed andmodified as necessary.The intent of the guidancein LIC 200 is to providean effective and efficientSRP revision process, thestaff does not considerthe approach taken to becontrary to the guidancein LIC-200.

Further, the staff does notbelieve that this revisionof SRP 3.11 presents anynew staff positions withregard to the regulationsor requirements forenvironmentalqualification. In theNUGEQ comments citingnew positions, informationwas provided based onoperating experience toclarify and provideguidance on methodsacceptable to the staff inmeeting existingregulations andrequirements, or inimplementing standardsendorsed by the staff,

SRP 3.11 Revision 3 was streamlined and providedclarifications based on theNUGEQ comments.


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1996 version (i.e., SRP 3.11 meets the Type 1definition in LIC200). In the NRC TRANSMITTALmemorandum for the proposed revision to SRP3.11 the staff states; “The staff has determinedthat the changes do not involve any new staffpositions.”21 In NUGEQ comment - New SRP3.11 Positions Since 1996 Draft Version – weidentified several additions to SRP 3.11 since the1996 version. These additions, particularly thosereferencing an Information Notice as the sourcedocument reflect new staff positions since the1996 version. LIC200 when describing Type 2revisions (i.e., new staff positions) indicates thatsuch changes include those derived from sourcedocuments that have not received publiccomment or the appropriate NRC officeapprovals. It states that: “An example of such adocument would be one setting forth operatingexperience.” The NUGEQ concludes that theseadditions constitute new staff positions, that thestaff should revise statements that SRP 3.11contains no new staff positions, and the reviewand approval process for SRP 3.11 shouldconform with NRC procedures for SRP sectionswith new staff positions (i.e., LIC200 Type 2).

As described further in our other comments, theNUGEQ believes that a number of changes madein the 1996 draft, that did not benefit from closepublic or regulatory review but have now beendeemed – contrary to LIC200 - to representcurrent staff positions during the SRP 3.11update, have contributed to many of theproblems with the proposed SRP section. Inmany cases the unreviewed 1996 languageforms the basis for further conflicting anderroneous guidance to applicants and reviewersthat is both internally inconsistent and

such as IEEE Std.-323. Consequently, the staffconsiders these changesto be Type 1 changes inaccordance with theguidance in LIC-200.Additional detail isprovided in the responsesto the specific comments.

The problems identified inthe examples areaddressed in appropriatesections of SRP.311.


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inconsistent with other regulatory guidance.Examples of problems with the SRP 3.11 1996draft include but are not limited to (1) applicableregulatory basis and equipment requirements forbeyond-design-basis hydrogen burnenvironments, (2) applicable SRP sections forreview and guidance regarding GDC 2 andnatural phenomena, (3) 50.49 exemptions fornew revisions of Regulatory Guide 1.97, and (4)incorporation of instrument sensing line freezeprotection and Regulatory Guide 1.151 into thereview scope of SRP 3.11.

april 30, 2007 memorandum to: george a. wilson, branch chief

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