ML18204A315
| ML18204A315 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/2018 |
| From: | Luis Betancourt, David Rahn NRC/NRO/DEI/ICE, NRC/NRR/DE/EICB |
| To: | |
| Paige J | |
| Shared Package | |
| ML18204A313 | List: |
| References | |
| Download: ML18204A315 (30) | |
Text
Digital I&C Integrated Action Plan Revision 3 Status & Update Plans David Rahn, NRR/DE/EICB Luis Betancourt, NRO/DEI/ICE IAP Public Meeting July 25, 2018
Agenda
- Introductions/Opening
- NRC Staff Considerations for Possible Broader Modernization Efforts under MP #4B
- Input from Stakeholders on Needs and Priorities
- Comments from the Public
- Action Item Summary/Next Steps 2
Commission Direction Informing the IAP (From Staff Requirements Memoranda [SRM] for SECY-15-0106 & SECY-16-0070)
- Develop an integrated strategy under the oversight of a senior management steering committee to modernize the DI&C regulatory infrastructure
- Engage stakeholders to identify common priorities, problems, and potential solutions to address them
- New or revised requirements should be performance-based, rather than prescriptive
- Focus on acceptable approaches to comply with the requirements
- Requirements should be technology-neutral; Guidance for specific technologies should be tailored if necessary
- Same requirements should apply for operating and new reactors
- Evaluate potential policy issues; present any issues that are ripe for consideration to Commission prior to any rulemaking 3
Premise for NRC Digital I&C Activities In general, implementation of digital I&C technology can provide dependability and safety benefits.
Notably, digital technology can be designed to provide continuous diagnostic information to plant operators on the integrity of its internal systems operation and its availability. However, implementation of digital I&C technology may introduce potential hazards such as software common cause failure (CCF) or failures introduced as result of interconnectivity.
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NRC Focus
- Issuance of regulatory products which support near-term upgrade and initial licensing needs identified by industry:
- Clear expectations for regulatory acceptability of modifications performed under 10 CFR 50.59
- Clear guidance and expedited approval of license amendment requests
- Clear expectations for applicants for new reactor licenses and new digital I&C platforms 5
Status & Plans for IAP Revision 3 MP Status Path Forward to be documented in IAP Rev. 3 Staff will continue to support workshops and MP#1A develop training materials for inspection staff RIS issued on (RIS 2002-22, (See MP#1D below). MP#1A will be relocated into May 31, 2018.
Supplement 1) a new Appendix in the IAP titled, "Completed Work.
Awaiting industry submittal of revised NEI 16-16 regarding design attributes for addressing CCF, MP#1B This activity is expected late Fall or Winter, 2018. This guidance (NEI 16-16) ongoing. is an NRC priority and NRC may initiate its own guidance if revised NEI 16-16 is not timely submitted.
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Status & Plans for IAP Revision 3 MP Status Path Forward to be documented in IAP Rev. 3 Staff work is nearing completion on SECY CCF Info SECY Paper to paper for ensuring consistent application of MP#1C be issued by policy in SRM/SECY 93-087. MP#1C will be September 2018 relocated into a new Appendix in the IAP titled, "Completed Work" Follow-up activities Relocate the workshop and training activities from the issuance of MP#1D from MP#1A into a new sub-MP titled, RIS-2002-22, MP#1D: RIS Workshops Supplement 1 NRC Staff and NEI have resumed work after MP#2 issuance of RIS 2002-22 Supp. 1. Concepts (NEI 96-07 This activity is ongoing.
from the RIS to be incorporated and other Appendix D) issues addressed.
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Status & Plans for IAP Revision 3 MP Status Path Forward to be documented in IAP Rev. 3 Staff/NEI/EPRI work to continue work to This activity is MP#3 identify appropriate, effective, and consistent ongoing.
certification process.
Draft ISG Rev 2 to be issued by July 31, 2018, MP#4A-1 This activity is and targeted for issuance as final at end of (ISG-06) ongoing.
2018.
Add new sub-MP under MP#4A. The activities MP#4A-2 (BTP 7-19 Not Started of BTP 7-19 (same as Appendix A, Item (xi))
Update) (New) will be transitioned here.
MP#4A-3 (50.59 Not Started Add new sub-MP under MP#4A. This activity Inspection Training will be started after the completion of MP#2.
and Guidance) (New) 8
Status & Plans for IAP Revision 3 MP Status Path Forward to be documented in IAP Rev. 3 Divide MP#4B into three new sub-MPs:
- Licensing (MP#4B-1),
- Inspection, (MP#4B-2)
This activity MP#4B
- Research (MP#4B-3) is ongoing Appendix A Items (i), and (iii)-(ix) will be incorporated into the scope of MP#4B1 through MP#4B3.
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MP#4B IAP Description Summary Identify actions needed to implement a streamlined, and agile I&C regulatory infrastructure that will ensure safety and security while effectively addressing larger scale digital I&C upgrades to operating reactors and the I&C designs for new and advanced reactors. The outcome will also improve clarity regarding the interrelationships between the regulatory issues, the priorities and sequencing of further improvements, and the supporting research that is needed to accomplish such improvements to meet both objectives.
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Objectives of MP#4B An improved regulatory infrastructure that integrates performance-based and technology-neutral safety engineering concepts, to assist stakeholders in demonstrating the safety and security of I&C systems, and to assist the NRC staff in performing regulatory reviews and I&C system inspections in an efficient, effective, consistent, and risk-informed manner.
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Starting Point:
Baseline Regulatory Framework 12
Planned Scope of MP#4B Assessment
- Three standards IBR in 10 CFR
- NuScale DSRS Chapter 7 50.55a(h): 19 RGs in DSRS Chapter 7 that IEEE Std 279-1968, IEEE Std 279- endorses 17 standards 1971, and IEEE Std 603-1991 3 Generic Communications referenced in DSRS Chapter 7
- SRP Chapter 7 7 NUREGs referenced in DSRS 27 RGs referenced in SRP Chapter 7 Chapter 7 that endorses 32 standards 17 BTPs referenced in SRP Chapter 7
- Other Relevant Documents 7 ISGs (most of them superseded) 3 Generic Communications 27 NUREGs referenced in SRP Chapter 7 11 SECY Papers 14 NUREGs referenced in SRP 14 Topical Reports Chapter 7 3 RILs 52 other documents referenced in SRP Chapter 7 (e.g., EPRI Reports, IEEE, and ISO stds not endorsed) 13
Previously Proposed IAP Appendix A Items for Longer-term Modernization Add/Drop/
App. A Item Path Forward Relocate Drop: This tactical activity was addressed by MP#4A-1 (i.e. ISG-06, Rev 2). The strategic portion for how ISG-06 will be transitioned to durable guidance would be Item (i): Improved Drop part/
covered under MP#4B-1.
Licensing Review Guidance Relocate for Digital I&C Systems part Relocate: The Cyber Security Evaluation in Design Reviews, will be relocated to a new activity under MP#4B titled, Guidance on Architecture Measures 14
Previously Proposed IAP Appendix A Items for Longer-term Modernization Add/Drop App. A Item Path Forward
/Relocate Item (ii): Improvement in Regulatory Consistency Relocate this item into new MP#4A-3, "50.59 Relocate from Licensing to Inspection Training and Guidance."
Inspection Pending the outcome of SRM to SECY Item (iii): IBR of IEEE Std Relocate 0060 (Transformation Team Paper) 603-2018 Relocate this item into MP#4B-1.
Item (iv): Approval of Endorsement of IEEE Relocate this item into MP#4B-3. This item Relocate Standard 7-4.3.2 into an will be led by RESs Regulatory Guide Branch.
RG 15
Previously Proposed IAP Appendix A Items for Longer-term Modernization Add/Drop/
App. A Item Path Forward Relocate This item will be transitioned into MP#4B-3.
Item (v): Embedded Relocate This item was started by a UNR on EDDs.
Digital Devices (EDDs)
(See Slide 20 below)
Item (vi): Holistic Review This item will be transitioned into MP#4B1-of the Regulatory Relocate MP#4B-3.
Infrastructure Item (vii): Improved Guidance for Evaluation of This item will be transitioned into MP#4B-1 Relocate Highly-Integrated Digital and MP#4B-3.
Technologies 16
Previously Proposed IAP Appendix A Items for Longer-term Modernization App. A Item Add/Drop/Relocate Path Forward Item (viii): Consistency and Integration of Multiple This item will be transitioned into Relocate Regulatory Guidance MP#4B-1.
Documents Item (ix): Improved Guidance for Evaluation of This item will be transitioned into Proposed Alternatives to Relocate MP#4B-1.
Regulatory Guides and Standards Item (x): Improved Process This item will be dropped from for Digital I&C Topical Drop the IAP.
Report Evaluations 17
Previously Proposed IAP Appendix A Items for Longer-term Modernization App. A Item Add/Drop/Relocate Path Forward Item (xi): Improvements to This activity will be transitioned Relocate SRP BTP 7-19 into MP#4A-3 18
New Research Activities Item Description Path Forward The objective of this research is to provide support in developing the This activity will be incorporated Risk-Informed technical basis for into MP#4B-3. A UNR was Reviews of I&C integrating risk insights into created to initiate this effort.
the regulatory framework for I&C systems and components.
The objective of this research is to develop a This activity will be incorporated Technical Basis and technical basis for into MP#4B-3. A UNR was Recommendations acceptance criteria for created to initiate this effort.
to Address CCF evaluating the CCFs in DI&C systems and components.
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New Research Activities Item Description Path Forward The objective of this Embedded Digital research is to develop a This activity will be incorporated Devices and technical basis to support into MP#4B-3. A UNR was Emerging guidance to review (and/or created to initiate this effort.
Technology dedicate) EDDs and emerging technologies 20
Proposed New Activity to be Considered Item Description Path Forward Develop guidance that includes review areas at the This activity will be incorporated overall I&C architecture into MP#4B-3. The Cyber Guidance on level, and leverage MDEP Security Evaluation in Design Architecture DICWG-09, Common Reviews, from IAP Appendix A Measures Position on Safety Design Item (i) will be relocated into this Principles and Supporting activity.
information for the Overall I&C Architecture.
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NRC Transformation Team Maintain an Awareness of SECY 18-0060 Recommendations
- Rulemaking: High-level performance-based I&C safety design principles
- Address future versions of IEEE Std. 603 into regulatory guidance
- Development Processes reviewed under Quality Assurance Program 22
IAP Schedule
- Issue Revision 3 to IAP: October 2018
- Annual Commission Paper: October 2018
- Commission Meeting: October 2018 23
Questions?
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Input from Stakeholders on Needs and Priorities 25
Backup Slides 26
Status Summary
- Making progress on Integrated Action Plan (IAP) activities
- Focused so far on developing regulatory products to support near-term upgrade needs identified by industry
- First implementable result targets lower safety-significant safety-related upgrades under 10 CFR 50.59 (i.e., RIS supplement) and work on NEI 96-07, Appendix D
- Next priorities - revise licensing process (ISG-06, Rev. 2) and issuance CCF Info SECY Paper
- Staff is increasing its efforts under MP#4B to identify and pursue broader modernization of the regulatory infrastructure (initiated in October 2017) 27
MP#1C Implementing Commission Policy on CCF in DI&C
- Staff will update guidance documents to ensure the Commission policy in SRM to SECY-93-087 continues to be consistently applied and address evolving DI&C technologies by better articulating the following principles:
- Licensees and applicants should continue to address CCFs due to software
- A D3 analysis for RTS and ESFAS to address CCF concerns continues to be required. This analysis can be either a best estimate (i.e., using realistic assumptions) or a design basis analysis
- Clarify the use of a graded approach for a D3 analysis for less safety critical systems
- Clarify the use of alternate means to address CCF concerns
- Clarify the use of certain design attributes to address CCF concerns 28
Acronyms ACRS: Advisory Committee on Reactor EDD: embedded digital device Safeguards ET: emerging technology APR1400: Advanced Power Reactor EPRI: Electric Power Research Institute 1400 ESFAS: engineered safety features ARS: advanced review standard actuation system BTP: branch technical position FAT: factory acceptance test CCF: common cause failure GDC: general design criteria CGD: commercial grade dedication HW: hardware DI&C: digital instrumentation and IAP: integrated action plan control I&C: instrumentation and control DRS: design review standard IBR: incorporated by reference DSRS: design-specific review standard IEEE: Institute of Electrical and IEC: International Electrotechnical Electronics Engineers Commission 29
Acronyms ISG: interim staff guidance RIL: research information letter ISO: International Organization For RIS: Regulatory Information Standardization Summary LAR: licensee amendment request RPS: reactor protection system MP: modernization plan SAT: site acceptance test NEI: Nuclear Energy Institute SIL: safety integrity level NRC: U.S. Nuclear Regulatory SRM: Staff Requirements Commission Memorandum QA: quality assurance Std: standard RG: regulatory guides SW: software TR: technical report 30