ML19092A419
| ML19092A419 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/2019 |
| From: | Kenneth Mott NRC/RES/DE |
| To: | |
| Paige J, NRR/DLP/PLPB, 415-1474 | |
| Shared Package | |
| ML19092A39 | List: |
| References | |
| Download: ML19092A419 (8) | |
Text
MP4B Strategic Assessment for Modernization of the NRCs Digital I&C Regulatory Infrastructure DI&C Real World Challenges Ken Mott Modernization Plan 4B Working Group April 4, 2019
Agenda Meeting Objective MP4B - Modernization of the DI&C Regulatory Infrastructure Overview January 31st, 2019, Industry DI&C Listed Barriers Industry Presentation of Real World Examples to Listed Barriers Discussion of Industrys Real World Barrier Examples Discussion of other Identified Potential DI&C Barriers Types of Potential Barriers and Challenges Discussion of Possible Solutions to Industry Barriers Opportunity for Public Comment Action Items Discussion / Closing Remarks 2
Meeting Objective The meeting objective for today:
Create a Consensus List of remaining barriers/challenges to DI&C efficient review that are supported by real world examples. This task will be completed by:
Providing industry the opportunity to submit real world examples to demonstrate their barriers to efficient DI&C regulatory review that were presented at the January 31st, 2019, public meeting Provide industry with the opportunity to describe other potential barriers to efficient DI&C regulatory evaluation Have an open discussion about the real world examples to support common understanding of barriers/challenges Discuss possible solutions to the barriers and associated real world examples 3
MP4B - Overview Broad Assessment for Modernization of DI&C Regulatory Infrastructure The MP4B working group is in the process of a comprehensive assessment of the Digital I&C regulatory infrastructure. This assessment will:
- Focus on the scope identified in the SRM to SECY-15-0106
- Utilize existing agency work that has been completed to avoid duplication of effort and complete assessment in a timely efficient manner
- Seek input from the public and the various stakeholder communities
- Focus first and foremost on guidance change within current DI&C regulatory structure 4
January 31st, 2019, Industry DI&C Listed Barriers 5
- 1) Common Cause Failure:
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
- 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
- 3) I&C System Architecture Development Consider international guidance related to the design and development of I&C system architectures
Discussion of other Identified Potential DI&C Barriers 6
Preliminary List of Other Identified Remaining DI&C Challenges ID Description 1
Efficiency of guidance for HDL programmable devices and similar hardware/firmware 2
Efficiency of guidance for risk informing Digital I&C review 3
Efficiency of a simple method for navigating the regulatory infrastructure 4
Efficiency of guidance and flexibility in the use of D3 assessments 5
DI&C Systems developed for use outside the United States may not conform to US regulatory criteria but may nevertheless be of adequate quality and dependability 6
Concerning Commercial Grade Dedication (CGD)
(It is not clear how CGD applies to complex DI&C systems or to software)
Types of Potential Barriers and Challenges Demonstrating Safety
- Guidance or criteria not commensurate with actual risk
- Alternate ways to demonstrate safety
- Guidance or criteria does not reflect current science or new technologies Regulatory Efficiency
- Written guidance or criteria ambiguous
- NRC implementation & interpretation unclear or inconsistent
- More efficient or quicker ways to demonstrate safety 7
Action Items Discussion /
Closing Remarks 8