ML17053A010
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| 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.
10