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NEI Presentation Re January 31 Digital I_C Public Meeting
	ML19025A307
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/28/2019
From:	; Nuclear Energy Institute
To:	; Division of Licensing Projects
	Paige J, NRR/DLP, 415-1474
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ML19025A311 -Pkg.	List: ML19025A307; ML19025A308; ML19025A310; ML19029B200;
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	Download: ML19025A307 (14)
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Digital I&C Strategy NEI DI&C Working Group January 31, 2019 NRC Public Meeting

Overarching Principles Incorporate defined boundaries Apply risk-informed insights Leverage robust design processes Capitalize on international operational experience and standards

Discussion topics Identify desired outcomes Identify barriers to progress Propose solutions to overcome barriers Summary

What does the end look like?

Utilities successfully design, develop, implement, and license digital upgrades to protection and control systems to support plant modernization and improve plant safety and reliability

Barrier #1 - Common Cause Failure (CCF)

BTP 7-19 guidance has evolved over the years and expanded the scope of the SRM-SECY-93-087 policy Concerns with SRM-SECY-93-087:

Deterministic solutions to mitigate the potential for CCF

Outdated and not aligned with current DI&C technology

Solution #1 - CCF Revise BTP 7-19 to be consistent with the concepts and scope of CCF treatment as described in Revision 4, a more risk-informed and graded approach Develop a Digital I&C Policy that reflects a more risk-informed and graded approach to safety Employ concepts from the EPRI Digital Engineering Guide, which leverages principles from International Electrotechnical Commission (IEC) Standards

Solution #1 - Potential Solutions to CCF Safety Related Safety Related Non-Safety Related (Protection) (Non-Protection)

Standardized Digital Design Standardized Digital Design Standardized Digital Design Short Term Process Process Process Industry EPRI Technical Guidance EPRI Technical Guidance EPRI Technical Guidance Guidance RIS 2002-22 Supp. 1 RIS 2002-22 Supp. 1 Short Term NRC Review BTP 7-19, Revision 4 Concepts RIS 2002-22 Supp. 1 No Changes Needed Guidance Standardized Digital Design Standardized Digital Design Standardized Digital Design Long Term Process Process Process Industry NEI YY-XX link to EPRI Technical NEI YY-XX link to EPRI Technical NEI YY-XX link to EPRI Technical Guidance Guidance Guidance Guidance Long Term Approval of NEI YY-XX Content of RIS 2002-22, Supp. 1 NRC Review No Changes Needed Develop DI&C Commission Policy Captured as Durable Guidance Guidance

Barrier #2 - Software Development Standards and Guidance Software development standards for safety-related SSCs are not commensurate with safety and not aligned with current technology BTP 7-14 Guidance does not follow a graded and risk-informed approach

Solution #2 - Software Development Standards and Guidance Consider guidance from international standards associated with safety-related software development Revise BTP 7-14 to follow a graded and risk-informed approach that is flexible (i.e., not constrained to prescriptive adherence)

Leverage digital I&C operating experience from the international nuclear community (e.g., Électricité de France)

Barrier #3 - I&C System Architecture Development Chapter 7 of the Standard Review Plan (SRP) has fragmented and incomplete review guidance for I&C system architectures

Solution #3 - I&C System Architecture Development Consider international guidance related to the design and development of I&C system architectures Employ concepts from the EPRI Digital Engineering Guide (DEG)

Barrier #4 - Limited Functionality I&C Devices Insufficient guidance on limited functionality I&C devices

Solution #4 - Limited Functionality I&C Devices Consider international guidance associated with limited functionality I&C devices

Summary Strategy is outcome oriented Proposed solutions overcome barriers Leverage international successes in DI&C Alignment with NRC initiatives and principles

ML19025A307

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