ML19072A206
| ML19072A206 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/2019 |
| From: | Steven Arndt NRC/NRR/DE/EICB |
| To: | |
| Rahn D | |
| Shared Package | |
| ML19063A0007 | List: |
| References | |
| Download: ML19072A206 (16) | |
Text
2018 International Congress on Advances in Nuclear Power Plants Use of IEC and Other Alternative Standards in NRC Reviews Steven A. Arndt Sr. Technical Advisor
Presentation Outline
- Project introduction / Background
- NRC Transformation Team
- Relationship with the Digital I&C Integrated Action Plan
- Issues to be addressed
- Project plan and upcoming activities NPIC&HMIT 2019
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Background===
- Most countries look to one of two sources as the basis for their regulations
- The US Code of Federal Regulation Title 10 - Energy
- Part 50 Licensing
- Some other section in title 10 also apply
- IAEA Safety Standards NS-R, GSR and SSR series documents
- NS documents are being updated to GSR or SSR documents IAEA requirements are not mandatory, but
- Some states adopt, other states are inspired by them NPIC&HMIT 2019
Background (continued)
- Within the current US regulatory structure
- IEEE 603-1991 is incorporated by reference into 10 CFR 50.55(a)h and serves as the primary regulation
- Regulatory Guides endorse standards (in most cases IEEE standards) as one acceptable way to meet the regulation Other ways may be acceptable However there is some project risk associated with not following endorsed standards NPIC&HMIT 2019
NRC Transformation Team
- The team gathered and analyzed innovation techniques and ideas from a variety of sources
- The objective was to gain a working knowledge of the mechanisms and methodologies used for successful transformations in other organizations
- Develop concepts, strategies to begin transformation initiatives with a emphasis on regulating new technologies
- Recommended a cultural framework to foster future innovation and transformation
- One major recommendation with to develop a new regulation to define high-level performance-based I&C safety design principles and associated regulatory guidance NPIC&HMIT 2019
Digital I&C Integrated Action Plan
- MP4 - Assessment for Modernization of the I&C Regulatory Infrastructure
- MP 4A included tactical activities to support improvements to the regulatory infrastructure (ISG-06).
- MP 4B includes broader strategic activities to address longer-term improvements.
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Issues to be Addressed
- Concern that relying on the IEEE suite of standards (and associated Regulatory Guides) may be less effective and efficient than other possible paths
- Concern that the IEEE software development standards as implemented in the software Regulatory Guides (RG 1.168, etc.)
may be overly restrictive
- Without additional guidance licensees and applicants may be reluctant to use 10 CFR 50.55(a)Z alternative requests NPIC&HMIT 2019
10 CFR 50.55(a)z Alternatives to Codes and Standards Requirements Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety.
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There are Two Main Standards Frameworks for Nuclear Electrical and I&C
- IEEE Nuclear Power Engineering Committee
- The top level IEEE standard for NPP safety systems (IEEE 603) is part of US Nuclear Regulatory Commission regulations (Incorporated By Reference (IBR))
- IEC Subcommittee 45A
- IEC takes IAEA safety standards, as the basis for their standards
- 45A belongs to Technical Committee 45 which includes nuclear instruments (TC45) and radiation protection instruments (45B)
- Thus
- USNRC requirements are an important framework element for IEEE
- IAEA safety standards are an important framework element for IEC NPIC&HMIT 2019
Harmonization of IEC and IEEE Standards
- Efforts to develop dual logo standards or endorse IEC standards directly
- Completed IEC 60780/IEEE 323 Environmental qualification dual logo IEC 63147/IEEE 497 Post accident monitoring dual logo IEC 61000 on EMI/RFI endorsed by NRC
- In progress IEC 60980/IEEE 344 Seismic qualification dual logo IEC 62566 HDL being considered for endorsement by NRC IEC 63113 Spent Fuel Pool Instrumentation dual loge work in progressing Possible new dual logo for IEC 61266 on Classification Possible new dual logo for IEC 63160 on CCF system analysis and diversity NPIC&HMIT 2019
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Project Objectives
- The NRC staff has determined that the most significant concern with the current digital systems regulatory infrastructure is that the endorsement of specific IEEE standards in certain Regulatory Guides (RG 1.152, RG 1.168, etc.) is overly restrictive and other means for demonstrating compliance with the requirements of IEEE Std. 603-1991, are needed
- The scope will be to evaluate the endorsement of IEC standards for development of software, HDL programmed devices and embedded digital devices through a Regulatory Guide as another acceptable way of meeting the current regulations in 10 CFR 50.55(a)h.
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Practical Considerations
- Lessons learned has shown that stakeholder engagement is critical to the success
- With the large number of IEC standards, it would likely be more effective to look at only one specific set of the IEC 61513 suite
- Project will require significant interactions with IEEE and IEC to ensure their support and cooperation NPIC&HMIT 2019
Stakeholder Engagement
- NRC would like to work with an industry working group
- Help identify a subset of the suite of IEC standards that would be of most use to industry
- Provide early feedback on NRC strategy for endorsement
- Provide feedback on overlaps, gaps and possible challenges to endorsement
- Table top/example review
- The NRC would like to use a specific system or platform to evaluate the new process to ensure the guidance is practical and well understood
- The NRC would like to make a selection as soon as possible
- The review will be done over the course of a few months, so will need to be appropriately scoped NPIC&HMIT 2019
Proposed Project Plan
- Public meeting to engage stakeholders (Jan 31, 2019)
- Formalize project plan and select IEC standards to include (Feb 2019)
- Select system or platform for example review (April 2019)
- Coordinate with IEEE and IEC (April 2019)
- Develop possible solutions to identified challenge associated with endorsement of IEC standards (June 2019)
- Complete example review (Oct 2019)
- Brief ACRS (Nov 2019)
- Publish draft guidance for public comment (Nov 2019)
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Path Forward
- Continue with the preparation work
- Work with OGC to determine appropriate guidance document
- Identify a subset of the suite of IEC standards
- Develop a NRC project plan and subset of IEC standards
- Assess industry support
- Solicit pilot application
- Begin coordination with IEEE and IEC NPIC&HMIT 2019