ML23188A068
| ML23188A068 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/2023 |
| From: | Ismael Garcia NRC/NSIR/DPCP |
| To: | |
| References | |
| ML23188A055 | |
| Download: ML23188A068 (1) | |
Text
N uclear Ener gy A gencys Consensus Position on Regulator y Inspections of Digital Ins trumentation and Contr ol Sys tems and Com ponents Im por tant to Safety used at N ucl ear P ower P l ants - Inspection Fr amework
Ismael L. Garcia Senior Technical Advisor Cybersecurity and Digital Instrumentation & Control Of fice of Nuclear Security and Incident Response U.S. Nuclear Regulator y Commission (NRC)
Email: Ismael.Garcia@nrc.gov
The information and conclusions presented herein are those of the author only and do not necessarily represent the views or positions of the US Nuclear regulatory Commission. Neither the US Government nor any agency thereof, nor any employee, makes any warranty, expressed, or implied, or assumes any legal liability or responsibility for any third partys use of this information.
Acknowledgements
- The evaluation framework discussed herein was derived from the work performed by the Nuclear Energy Agency (NEA)
Committee on Nuclear Regulatory Activities (CNRA) Working Group on Digital Instrumentation and Control (WGDIC)
- For additional information concerning the NEA/CNRA WGDIC visit: https://www.oecd-nea.org/jcms/pl_21460/working-group-on-digital-instrumentation-and-control-wgdic
2 Outline
- Introduction
- Inspection Framework
- Verification and Validation
- Quality Management
- Configuration Management
- Computer Security
- Requirements and Design
- Implementation and Integration
- Installation and Commissioning
- Operation and Maintenance
- Closing Remarks/Take-aways
3 Introduction
- Regulatory inspections provide assurance that activities, performed by the inspectee, comply with applicable laws, regulations, and conditions of authorization
- The inspection framework discussed herein applies to all digital I&C systems important to safety, both hardware and software
4 Inspection Framework
V er if ic a tio n & Va lid at io n Q ua lity M a na g em e nt Co nf igu ra ti on M an ag em en t Co mp ute r S ec u ri ty
R e qu ire m en ts Op e ra tio n &
M ain te na nc e
I ns ta lla tio n &
Co mmi ss ion in g De s ign
Integration
I mpl em e nta ti on
5 Inspection Framework -
Verification and Validation
- The Regulatory Body (RB) verify whether the inspectee performed a comprehensive assessment to verify that the essential properties of the system properly satisfy the requirements
6 Inspection Framework -
Quality Management
- The RB should verify that the inspectee has a suitably accredited quality management system
- The RB should verify that the inspectee provides sufficient evidence on the implemented processes
7 Inspection Framework -
Configuration Management
- The RB should verify that procedures are implemented by the inspectee to establish a hardware and software baseline at the completion of each lifecycle phase
- The RB should verify that procedures are implemented by the inspectee to establish access control to the configuration management platform
8 Inspection Framework -
Computer Security
- The RB should leverage the evaluation guidance documented in WGDIC CP -08, Impact of Cyber Security Features on Digital I&C Systems Important to Safety, available via the CNRA WGDIC website
9 Inspection Framework -
Requirements and Design
- The Regulatory Body (RB) should verify that the inspectee has a process for identifying, specifying, and tracing the requirements throughout the I&C system lifecycle
- The requirements include those derived from plant level to the overall I&C architecture
- The design is developed with an understanding of the origin for the safety requirements
- The design takes into account best practices on cybersecurity
10 Inspection Framework -
Implementation and Integration
- Procedures are established and implemented for compliance with coding rules, methods, and standards
- Software implementation activities are completed in accordance with a documented implementation plan
- Verify that the inspectee provides sufficient evidence of the integrated software-and hardware-development processes is well documented, understood, and questioned
11 Inspection Framework -
Installation and Commissioning
- The RB should assess the system installation testing activities of the I&C system lifecycle by verifying that
- There are provisions documented in procedures for modifications to the hardware or software made during installation
- Adequate installation testing has been performed
- The RB should verify the installation inspection performed by an inspectee
- The RB should verify that the inspectee ensures that commissioning test coverage is sufficient, both in terms of functionality and physicality
12 Inspection Framework -
Operation and Maintenance
- The documentation for the methods, plan, and deployment of the digital I&C system hardware and software
- The assumptions used for equipment qualification are maintained
- The procedures have been established for managing ageing and obsolescence of the digital I&C equipment
- The RB should verify that the inspectee has a defined and implemented program for systems important to safety periodic examination, inspection, maintenance and/or tests
13 Closing Remarks/Take-Aways
- There may be different approaches for achieving the stated objective
- The approach taken should be justified for suitability for the important to safety application
- The methodology discussed herein is not to be construed as a requirement or regulation
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