ML20236Y518

Forwards Safety Evaluation of TR-107330, Generic Requirements Spec for Qualifying Commerically Available PLC for Safety-Related Applications in Npps

ML20236Y518
Person / Time
Issue date:	07/30/1998
From:	Essig T NRC (Affiliation Not Assigned)
To:	Naser J ELECTRIC POWER RESEARCH INSTITUTE
Shared Package
ML20236Y520	List: ML20236Y518 ML20236Y526
References
PROJECT-669 NUDOCS 9808120276
Download: ML20236Y518 (3)

Text

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M*h p i UNITED STATES g j hUCLEAR REGULATORY COMMISSION o WASHINGTON, D.C. enmas mi s'*****/ July 30, 1998 Mr. Joseph Naser Manager, Instrumentation and Control Energy Conversion Division Electric Power Research Institute 3412 Hillview Venue PO Box 10412 Palo Alto, CA 94303 SUBJECT- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ELECTRIC POWER RESEARCH INSTITUTE (EPRI) TOPICAL REPORT, TR-107330, FINAL REPORT, " GENERIC REQUIREMENTS SPECIFICATION FOR QUALIFYING A COMMERCIALLY AVAILABLE PLC FOR SAFETY-RELATED APPLICATIONS IN NUCLEAR POWER PLANTS" Dear Mr. Naser.

By letter dated January 9,1998, EPRI submitted topical report TR-107330, Final Report,

" Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in Nuclear Power Plants," dated December 1996, for staff review. EPRI submitted an amendment letter dated 4/24/98 to address some additional quality assurance issues. The staff has completed the review of the non-proprietary topical report and the amendment letter dated 4/24/98 and prepared the enclosed safety evaluation report approving TR-107330 as modified by letter of 4/24/98.

l TR-107330 presents a requirements specification for generically qualifying a commercially available PLC for safety-related applications. The goal of this requirements specification is to l define the essential, critical technical characteristics that must be included as part of a PLC design for use in a range of safety applications. System and software development and quality processes are addressed in t..,s specification primarily by references to published standards i

and guidelines.

The TR-107330 guidance provides for some flexibility in the Weific methods for performing the verification activities involved in qualifying a PLC consistent with staff requirements. Licensees referencing TR-107330 for a proposed digital modification should document the qualification process such that there are descriptions and justifications for the methods selected which will support the use of the specific PLC product in a safety-related application. Because the term "PLC" is used by various manufacturers to label digital equipment with capabilities that vary from relatively simple to very ccmplex, care should be exercised to assure that the TR-107330 3 guidance is not used to attempt to qualify equipment beyond the intended scope.

Based on the review of TR-107330 and the 4/24/98, EPRI letter the staff concludes that TE-107330 contains acceptable requirements spnitation guidelines for licensees use in hb Df 9'0']

procuring a particular vendor's PLC for use in safety system applications. Use of the TR-  !

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Joseph Naser 2- July 30, 1998 107330 approach when designing digital modifications will provide licensees with a requirements specification that will enable the PLC design to meet the requirements of 10 CFR Part 50 as identified in section 1 of this SER and the guidance of SRP, Chapter 7

" Instrumentation and Controls" conceming digital instrumentation and control systems.

While the staff finds TR-107330, as modified by the 4/24/98 EPRI letter, acceptable, it should be noted that TR-107330 provides only gc::eric requirements for pre-qualifying commercial PLCs for use in safety-related applications. For a plant specific PLC application, the staff '

review will ensure that the PLC requirements specification has in fact been followed and that the system design meets all of the applicable regulations and guidance as provided in 10 CFR Part 50 and in SRP Chapter 7, for the specific application proposed. This includes a number of plant specific concems such as diversity, EMI/RFI, separation criteria, and maintenance training that must be satisfied before the PLC system design can be found acceptable in a plant specific safety system design. For plant specific applications, the licensee is responsible for determining whether the specific design incorporating the PLC can be i implemented without prior NRC staff approvalin accordance with the requirements of 10 CFR 50.59. NRC staff approval of EPRI TR-107330 does not provide this determination.

l If you have any questions regarding this safety evaluation report, please contact Jim Stewart at (301) 415-2824, e-mail: Jcs1@nrc. gov, i Sincerely,

1. 'L/

homas Essig, Acting Chief

! Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 669 l

Enclosure:

Safety Evaluation .

cc: See next page i

1 i

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Jos:ph Nis;r -2 July 30, 1998 approach when designing digital modifications will provide licensees with a requirements specification that will enable the PLC design to meet the requirements of 10 CFR Part 50 as identified in section 1 of this SER and the guidance of SRP, Chapter 7, " Instrumentation and Controls" conceming digital instrumentation and control systems.

While the staff finds TR-107330, as modified by the 4/24/98 EPRI letter, acceptable, it should be noted that TR-107330 provides only generic requirements for pre-qualifying commercial PLCs for use in safety-related applications. For a plant specific PLC application, the staff review will ensure that the PLC requirements specification has in fact been followed and that the system design meets all of the applicable regulations and guidance as provided in 10 CFR Part 50 and in SRP Chapter 7, for the specific application proposed. This includes a number of plant specific concems such as diversity, EMI/RFl, separation criteria, and maintenance training that must be satisfied before the PLC system design can be found acceptable in a plant specific safety system design. For plant specific applications, the licensee is responsible for determining whether the specific design incorporating the PLC can be implemented without prior NRC staff approvalin accordance with the requirements of 10 CFR 50.59. NRC staff approval of EPRI TR-107330 does not provide this determination.

If you have any questions regarding this safety evaluation report, please contact Jim Stewart at (301) 415-2824, e-mail: Jes1@nrc. gov.

Sincerely, Melinda Malloy for/

Thomas Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 669

Enclosure:

Safety Evaluation cc: See next page DISTRIBUTION:

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DOCUMENT NAME:G:UHWi\EPRI-PLC.SER l OFC PGEB:DRPM (1 PGEB:DRPM 6 DRCf;l:HICS E l PGEB:DRPM l NAME b okyw y J h el M ku l

DATE -7J30/98 7 ad98 7 /5d198 7 8d98 C = COVER E = COVER & ENCLOSURE N = NO COPY i

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