ML20046C819
| ML20046C819 | |
| Person / Time | |
|---|---|
| Issue date: | 07/02/1993 |
| From: | Pulsifer R Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9308120231 | |
| Download: ML20046C819 (7) | |
Text
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E UNITED STATES
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NUCLEAR REGULATORY COMMISSION s,,, (/
t WASHINGTON, D.C. 20555-0001 y
July 2,1993 ORGANIZATION: NUCLEAR MANAGEMENT AND RESOURCES COUNCIL (NUMARC)
SUBJECT:
MEETING
SUMMARY
- DISCUSSION OF NRC MARKUP 0F NUMARC DRAFT DOCUMENT " GUIDELINE FOR LICENSING DIGITAL I&C UPGRADES" On June 23, 1993, a meeting was held at NRC Headquarters in Rockville, Maryland, to discuss the June 2, 1993, NRC markup of the NUMARC draft document entitled " Guideline for Licensing Digital I&C Upgrades."
Meeting participants included representatives of NUMARC, various utilities and consultants, and employees of the NRC's Office of Nuclear Reactor Regulation (NRR).
A list of attendees is enclosed.
NUMARC stated the prime reason for this meeting was to discuss the NRC markups to understand the reasoning behind them.
NUMARC asked why a threshold was needed. The NRC said that a threshold was desired to indicate those Analog to Digital (A/D) changes that would probably need NRC review before implementation.
This does not alleviate the responsibility or authority of the licensee to perform a 10 CFR 50.59 evaluation in every case, nor does it predetermine the outcome of that evaluation.
NUMARC indicated that they received about twenty five comments on the draft document.
Some of the comments dealt with 1) needing examples of complex systems, 2) dosument should focus on systems vs component failure modes, 3) commercial grade items should be more specifically addressed and 4) address the difference in handling complete Reactor Protection System upgrade vs a minor upgrade modification to a safety system.
Several items were discussed regarding the markups:
The safety significance of the upgrade will determine if the item is above or below the threshold.
This could be a major system upgrade to a minor instrument change. An unreviewed safety question (USQ) determination requires NRC review and approval before implementation.
An NRC review is not required because the upgrade just involves digital equipment but a review is required because of the uncertainties associated with the more complex software, i.e., testing, electromagnetic interference (EMI), and verification and validation (V&V) lead to an USQ.
This document will not use the word "shall" because it is only a guideline for licensee use.
9308120231 930702 1
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Good EMI data is not available.
Knowledge of the EMI environment in which the upgraded equipment is expected to operate should be obtained as well as its effect on other equipment.
l Dedication of commercial grade software for complex systems is difficult. Verification and validation of source codes may be necessary. There needs to be a high degree of confidence that the product will perform as intended and that no unintended functions will occur.
It is difficult to quantify software probabilities.
NRC would probably reduce review time needed for similarly approved.
devices or upgrades that reference previously approved designs, such as by a topical report. The NRC would then focus on plant specific ' issues, such as environmental effects and operating experience.
NUMARC stated that after their review and resolution of the NRC and industry comments on the draft document the final guideline should be ready by fall.
ORIGINAL SIGNED BY:
Robert M. Pulsifer, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
List of attendees 0FFICE PD111r3:LA:DRPW PDIII-3:PM:DBS)I HICB NAME MRuskrk.
RPulsifdr JMauck D DATE'
/ / $ 93 7 / 2 /93 7 / :t/93 0FFICE PDIII-3:PD:DRPW NAME JHhn /s DATE 7 / 7 /93 Document Name: Duanearn\\A-D. SUM i
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July 2, 1993
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DISTRIBUTION E
Central file i
r NRC PDR PDIII-3 r/f TMurley/Miraglia i
JPartlow JRoe BBoger JZwolinski JHannon RPulsifer Ploeser (8-H3)
CLittle (P-351)
JStewart (8-H-3)
CDoutt (8-H-3)
JGallagner (8-H-3)
JJoyce (8-H-3)
FAllenspan (10-A-19)
GScarfo (MNBB-3206)
RKarsch (MNBB-3206)
JWermeil (10-D-24) l JMauck (8-H-3)
RGallo (10-D-22)
- MRushbrook 0GC EJordan (MNBB-3206)
GGrant (17-G-21)
EGreenman,RIII ACRS (10)
SMays (P-315)
DWheeler (12-G-18)
DCoe (P-315)
cc: NUMAC MPR Associates MPR Associates ATTN: Jess Betlack ATTN: Bob Fink 320 King Street 320 King Street Alexandia, Virginia 22314 Alexandia, Virginia 22314 EPRI Scott Wingate ATTN:
Ray Torok NUS Safety & Licensing P. O. Box 10412 910 Clopper Rd.
Palo Alto, California 94303 Gaithersburg, Maryland 20878-1399 Tony Pietrangelo Mr. David Reigel NUMARC GE Nuclear Energy 1776 Eye Street, NW 175 Curtner Avenue Suite 300 MK 236 Washington, DC 20006-3706 San Jose, California 95125 Dave Modeen Mr. Hector Barbeito NUMARC Bechtel PWR Corporation 1775 Eye Street, NW 9801 Washington Blvd.
Suite 300 Gaithersburg, Maryland 20878 Washington, Oc 20006-3706 Commonwealth Edison Company ATTN:
Richard Blauw 125 S. Clark - Room 422 Chicago, Illinois 60603 Bechtel PWR Corporation ATTN:
Kevin Graney 9801 Washingtonian Blvd.
Gaithersburg, Maryland 20878 Mr. Michael Hellums TVA 1101 Market Street Chattonooga, Tennessee 37401 Mr. Gerry von Noordennan Northeast Utilities P.O. Box 270 Hartfield, Connecticut 06141-0270 Mr. Lloyd Heckle Duke Power 2086 High Pines Rock Hill, South Carolina 29732 i
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ANALOG TO DIGITAL MEETING ATTENDANCE June 23, 1993 NRiE ORGANIZATION TELEPHONE Robert Pulsifer NRR/PD III-3 (301) 504-3016 Kevin Graney SERCH Licensing-Bechtel (301) 417-8823 Hector Barbeito SERCH Licensing-Bechtel (301) 417-8142 Scott Wingate NUS (301) 258-2565 Cliff Doutt NRR/HICB (301) 504-2847 Paul Loeser NRR/HICB (301) 504-2825 Jerry Mauck NRR/HICB (301) 504-3248 Duke Wheeler NRC/0ED0 (301) 504-1717 Bruce Boger NRR (301) 504-1004 Robert Gallo NRR (301) 504-2548 Doug Coe NRC/ACRS (301) 492-8972 Steven Mays NRC/ACRS (301) 492-7904 John Hannon NRR/DRPW (301) 504-1389 Tony Pietrangelo NUMARC (202) 872-1280 Bob fink MPR Associates (703) 519-0200 Ray Torok EPRI (415) 855-2776 Dave Modeen NUMARC (202) 872-1280 Dave Reigel GE Nuclear (408) 925-2094 Jess Betlack MPR Associates (703) 519-0200 Richard Blauw Commonwealth Edison Co. (312) 394-8893 Gerry van Noordennen Northeast Utilities (203) 665-3288 Lloyd Heckle-Duke Power (704) 382-3730 Mike Hellums TVA (615) 751-2695 l
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Memo Dated July 6,1993 i
REVISED OUTLINE OF DIGITAL UPGRADE LICENSING GUIDELINE 1.
INTRODUCTION
1.1 Background
1.2 Purpose j
Provide guidance for:
Actions to be taken in the design and implementation process to ensure that digital upgrade issues are adequately addressed in this process, and i
How to address the digital upgrade issues when performing 10CFR50.59 evaluations of digital upgrades.
4 Intent is that this guidance will assist utilities in:
Performing and documenting 10CFR50.59 evaluations for digital upgrades that are to be performed under the 50.59 regulation, and Expediting the licensing review process for digital upgrades that are not performed under the 50.59 rule but require prior NRC review and -
approval.
i 1.3 Scope
.j Document is intended primarily to address digital upgrades to safety systems.
However, much of the guidance also is applicable to upgrades in nonsafety systems
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and can be applied by the utility as appropriate for those upgrades.
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Document applies to large and small digital upgrades -- from the simple i
replacement of an analog meter with a microprocessor based instrument up to the complete changeout of a Reactor Protection System with a new digital system.
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9f4FP 1.4 Content i
The guideline describes the design and implementation process and how the digital upgrade issues are addressed at various steps in the process. References are made to industry standards, guidelines, EPRI reports, regulatory requirements, and other documents as appropriate for addressing the issues. Also, supplementalirlaterialis provided in selected areas where existing standards or guidelines do not exist or need to be supplemented to adequately address the issues.
Describe each section's contents...
2.
DEFINITIONS AND TERMINOLOGY 3.
DESIGN, SPECIFICATION AND IMPLEMENTATION PROCESS Start with NSAC-105 modification design processflow chart Old 4.5 Design, Specification and implementation Process Discuss importance offailure modes evaluation as part of design, specifcation, implementation, testing and verification process Old 4.1.1 Software Design and Quality Assurance - beef up mention of software configuration control Old 4.4 Commercial Grade item Dedication Cover " system diversity" issue here (ATWS rule) i 4.
LICENSING PROCESS AND 10CFR50.59 Old 3. Eristing Licensing Process and 10CFR50.59 Old 5. Supplemental Guidance for 10CFR50.59 Evaluations of Digital Upgrades May include revised flow chart (old Figure 2) on evaluating software failures from standpoint of USQ determination, if needed 5.
ADDITIONAL GUIDANCE FOR ADDRESSINb DIGITAL UPGRADE ISSUES Failure analysis System based
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Cover software, intemipts, lock-ups, etc. including software common mode or
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common causefailure 2-
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Cover hardware, wear-out failures, etc.
Probability assessments -- qualitative and quantitative Engineeringjudgment Some aspects of commercialgrade item dedication covered here, at least in sense that you havi less information on failure modes, dealing with this Defense in depth (draw more on IEEE P-7-4.3.2)
Environmentalincluding EMI Reference EPRI Guide Leave in Table 1 Give 2 options (delete middle one in present draft)
Leave in ESD Add emissions (Carl)
Human element Human factors, MMI or HMI (old 4.3, in failure modes context)
Training 6.
REFERENCES j
APPENDIX A - Digital I&C Upgrade Examples and Case Studies
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