ML17228A985

Comment Supporting Proposal to Issue GL Providing Guidance for Determining When analog-to-digital Replacement Can Be Performed Under Requirements of 10CFR50.59

ML17228A985
Person / Time
Site:	Saint Lucie
Issue date:	01/17/1995
From:	Bohlke W FLORIDA POWER & LIGHT CO.
To:	NRC
References
FRN-59FR52559 59FR52559-00002, 59FR52559-2, GL-95-02, GL-95-2, NUDOCS 9501270137
Download: ML17228A985 (5)

Text

PRIDRIT'Y 2 REGOLRTOIFFBRMBBIII DfSHII!TTONNETEM (RIDE) t ACCES'SION NBR:9501270137 DOC.DATE: 95/01/17 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power 6 Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION BOHLKE,W.H. Florida Power a Light Co.

RECIP.NAME RECIPIENT AFFILIATION NRC No Detailed Affiliation Given P Comment supporting proposal to issue GL providing guidance 'U for determining when analog-to-digital replacement can be R performed under requirements of 10CFR50.59.

DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: F E CENT- R. 01 1 1 NMSS/IMOB T8F5 1 1 OGC/DR 15-B-18 1 1 RES DIR 1 1 RES/DSIR 1 1 RES/PMPDAS 1 1 Y,

EXTERNAL: NRC PDR 02 1 1 p

Q RECIPIENT N

YOTE TO ALL"RIDS" S:

PLEASE HELP US TO REDUCE iVASTE! COYTACTTHE DOCL'AIEi'! COYTROL DESK, ROOii! Pl -37 (EXT. 504-20S3 ) TO ELIikIIYATE YOUR iNAP IE FRO!II DISTRIBl."I'IOY,LISTS FOR DOC!.'h IEYTS YOU DOi "I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7

Florida Power 8c Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 Pf;Pe)@ED Gb7y JAN 17 $ 995 RULES REVIEW'";

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Qtl g s2sg-g Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission l'0/@ay Washington, D.C. 20555-0001 Re: Use of NUMARC/EPRI Report TR-102348, "Guideline on Licensing Digital Upgrades,"

in Determining the Acceptability of Performing Analog-to-Digital Replacements Under 10 CFR 50.59.

59 Fed. Reg. 52559, October 18, 1994 I Re uest for Comments On October 18, 1994 (59 FR 52559), the Nuclear Regulatory Commission (NRC) published for public comment a notice regarding "Use of NUMARC/EPRI Report TR-102348, 'Guideline on Licensing Digital Upgrades,'n Determining the Acceptability of Performing Analog-to-Digital Replacements Under 10 CFR 50.59." The following comments are submitted on behalf of Florida Power and Light Company (FPL), a licensed operator of two nuclear power plant units in Dade County, Florida and two units in St. Lucie County, Florida.

Overall, FPL endorses the proposal to issue a generic letter that provides guidance for determining when an analog-to-digital replacement can be performed under the requirements of 10 CFR 50.59. FPL provides the following additional suggestions and comments as a result of lessons learned from a recent experience at one of its facilities.

Several IEEE standards were not included in Report TR-102348 which are vital to software validation and verification. TR-102348 places all of its emphasis on IEEE Standard 7-4.3.2-1993, and not enough on the importance of the other IEEE standards available.

See the attachment for a listing of those standards that should be included as a necessary part of a digital upgrade.

Additionally, FPL would suggest that the section on clarifications to TR-102348 be amended to include additional statements to the licensees on the significance of software validation and verification. The IEEE Software Standards clearly point out that validation and verification is a process and is not just a test at the end of software development. Statements should be added to the Standards 'regarding the importance of timing and the thoroughness of testing. While TR-102348 addresses items requiring additional guidance in Section 5 (i.e., EMI), it does not discuss issues

~elated to software development and validation and verification.

9501270137 950117 Iu<E NXSC an FPL GrouP comPany

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L-95-18 Page Two FPL has reviewed all the current IEEE standards and has suggested possible revisions to the IEEE Standards Board that would address the importance of timing issues, hidden ambiguities in software specifications, and the intended audience (relative to experience level) for the standard.

FPL appreciates the opportunity to comment on this report.

Very truly yours, W. H. Bohlke Vice President Nuclear Engineering and Licensing WHB/spt Attachment

ATTACHMENT IEEE 829-1983, IEEE Standard for Software Test Documentation IEEE 1008-1987, IEEE Standard for Software Unit Testing.

IEEE 1044-1993, IEEE Standard Classification for Software Anomalies IEEE 1059-1993, IEEE Guide for Software Verification and Validation IEEE 1219-1993, IEEE Software Maintenance Standard.

IEEE 1298-1992, IEEE Software Quality Management System.