ML23115A017

Comment (3) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants

ML23115A017
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/23/2023
From:	Andy Campbell Nuclear Energy Institute
To:	Kenny Nguyen Office of Administration
References
NRC-2022-0143, 88FR14956 00003, DG-1374
Download: ML23115A017 (1)

Text

SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Michael Eudy, Bridget Curran, Mary Neely Comment (3)

Publication Date: 3/10/2023 Citation: 88 FR 14956 QUESTION:

I am consolidating industry comments on DG-1374 to submit during the public comment period. Can you please clarify the intent of the criteria in Section C.b.1.2.2? Are these criteria intended to apply during the design and testing phases of the digital lifecycle? This will help us provide the appropriate feedback/comments.

NRC RESPONSE:

As stated in IEEE Std. 7-4.3.2-2016, if self-diagnostic functions are integrated into the safety system, these functions shall be subject to the same verification and validation (V&V) processes as the safety functions. This standard further states, in part, that for V&V refer to IEEE Std. 1012-2012.

IEEE Std 1012 is a process standard that defines the V&V processes in terms of specific activities and related tasks. This standard states, in part, that the life cycle processes at the system, software, or hardware levels may be conducted in parallel for systems or system elements at the same level. The full set of life cycle processes (system, software, or hardware, as appropriate) are applied to each product.

In the same way, system V&V is applied recursively for each system of the system of interest, and software or hardware V&V is applied to each system element.

DG-1374 (Revision of RG 1.152) endorses IEEE Std. 7-4.3.2-2016 with exceptions and clarifications. With regard to self-diagnostics criteria, DG-1374 provides clarification with supplemental guidance, including Section C.b.1.2.2. This supplemental guidance does not exclude any phase of the safety-related DI&C systems lifecycle, and therefore Section C.b.1.2.2 of DG-1374 should apply throughout the system lifecycle.

From: CAMPBELL, Alan <adc@nei.org>

Sent: Thursday, March 23, 2023 10:15 AM To: Khoi Nguyen <Khoi.Nguyen@nrc.gov>

Cc: Michael Eudy <Michael.Eudy@nrc.gov>

Subject:

[External_Sender] DG-1374 Question

Khoi, I am consolidating industry comments on DG-1374 to submit during the public comment period. Can you please clarify the intent of the criteria in Section C.b.1.2.2? Are these criteria intended to apply during the design and testing phases of the digital lifecycle? This will help us provide the appropriate feedback/comments.

Thanks,

Alan Alan Campbell, PE l Technical Advisor Nuclear Energy Institute 1201 F Street NW, Suite 1100 l Washington, DC 20004 P: 202.739.8011 M: 202.439.3698 nei.org