ML17053A010

NEI - Di&C Rifg Regulatory Framework - Big Picture (for NRC r1)

ML17053A010
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/27/2017
From:	Nuclear Energy Institute
To:	Joseph Holonich Licensing Processes Branch (DPR)
Holonich J
References
Download: ML17053A010 (10)

Text

DI&C Regulatory Framework Big Picture Concepts & Issues NEI DI&C RIFG February 28, 2017

• Rockville, MD 1

Key Concepts/Issues

• There are three key big picture concepts that need to be addressed to improve the digital instrumentation & controls (DI&C) regulatory framework:

- Inappropriate Treatment of Digital as Special

- Excessive and Unnecessary Complexity

- Practical Application of Regulatory Guidance 2

Treatment of Digital as Special

• Design and Licensing Process Interaction

- Recommended Principles/Goals

• The licensing process for DI&C projects should be fundamentally consistent with that used for projects involving other disciplines (e.g., electrical, analog I&C).

• The licensing process for DI&C projects should focus on review of the regulatory required design attributes.

• Execution of later project phases (e.g., implementation, testing) should be addressed via the inspection process.

3

Treatment of Digital as Special

• Digital Equipment Quality

- Recommended Principles/Goals

• Quality of out of the box digital equipment (hardware and base software) is not a concern unique to nuclear; quality of digital equipment application to plant SSCs is a concern unique to nuclear.

• Regulatory guidance should not reinvent the wheel on out of the box digital equipment quality; it should rely on industry standards.

4

Excessive/Unnecessary Complexity

• Industry Guidance Documents

- Recommended Principles/Goals

• For a given topical area, there should be one guidance document written primarily for licensees and one guidance document written primarily for NRC staff.

• These licensee and NRC staff guidance documents should be fundamentally consistent.

• There should be a minimum of different guidance document types (e.g., RG, NUREG, RIS, ISG, SER, etc.)

across the various DI&C topical areas.

5

Excessive/Unnecessary Complexity

• NRC Staff Endorsement of Industry Standards

- Recommended Principles/Goals

• With few exceptions, nuclear specific standards should be endorsed without exceptions, caveats, etc., to prevent the RG process from undermining achievement of industry consensus.

• Endorsement of non-nuclear standards should account for the need to tailor application of these standards to nuclear industry processes and practices (i.e., a verbatim compliance approach may not work).

6

Excessive/Unnecessary Complexity

• NRC Staff Endorsement of Industry Standards

- Computer Engineering Standards Trend

• IEEE software engineering standards have been/are being revised to take a systems engineering approach.

• EPRI research is investigating application of a systems engineering approach to nuclear DI&C projects.

• NRC staff endorsements of these standards have lagged behind, and a standard taking a systems engineering approach has not yet been endorsed.

7

Excessive/Unnecessary Complexity

• Operating Plant vs. New Build Guidance

- Recommended Principles/Goals

• The same DI&C regulatory guidance documents should be used for both operating plants and new builds, with differences in guidance specified only when necessary.

• If separate guidance documents are deemed necessary, then their regulatory goals should be fundamentally consistent.

8

Practical Application of Guidance

• Clarity and Level of Detail

- Recommended Principles/Goals

• Two different technically competent engineers should be able to obtain similar results when applying regulatory guidance to their designs.

• Competent engineers should be able to apply regulatory guidance to their designs with reasonable confidence that competent NRC staff will reach similar conclusions regarding design acceptability.

9

Practical Application of Guidance

• Generic vs. Licensee Specific Documents

- Recommended Principles/Goals

• All DI&C related regulatory guidance should be available in generic publications.

• Regulatory guidance should not exist solely in a licensee specific document.

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