ML19025A307

NEI Presentation Re January 31 Digital I_C Public Meeting

ML19025A307
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/28/2019
From:	Nuclear Energy Institute
To:	Division of Licensing Projects
Paige J, NRR/DLP, 415-1474
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ML19025A311 -Pkg.	List: ML19025A307 ML19025A308 ML19025A310 ML19029B200
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Download: ML19025A307 (14)

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©2018 Nuclear Energy Institute NEI DI&C Working Group Digital I&C Strategy January 31, 2019 NRC Public Meeting

©2018 Nuclear Energy Institute 2 Incorporate defined boundaries Apply risk

-informed insights Leverage robust design processes Capitalize on international operational experience and standards Overarching Principles

©2018 Nuclear Energy Institute 3 Identify desired outcomes Identify barriers to progress Propose solutions to overcome barriers Summary Discussion topics

©2018 Nuclear Energy Institute 4 Utilities successfully design, develop, implement, and license digital upgrades to protection and control systems to support plant modernization and improve plant safety and reliability What does the end look like?

©2018 Nuclear Energy Institute 5 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: *Deterministic solutions to mitigate the potential for CCF

• Outdated and not aligned with current DI&C technology Barrier #1

- Common Cause Failure (CCF)

©2018 Nuclear Energy Institute 6 Revise BTP 7-19 to be consistent with the concepts and scope of CCF treatment as described in Revision 4, a more risk

-informed and graded approach Develop a Digital I&C Policy that reflects a more risk

-informed and graded approach to safety Employ concepts from the EPRI Digital Engineering Guide, which leverages principles from International Electrotechnical Commission (IEC) Standards Solution #1

- CCF

©2018 Nuclear Energy Institute 7 Solution #1

- Potential Solutions to CCF Safety Related (Protection)

Safety Related (Non-Protection)

Non-Safety Related Short Term Industry Guidance Standardized Digital Design Process EPRI Technical Guidance Standardized Digital Design Process EPRI Technical Guidance RIS 2002-22 Supp. 1 Standardized Digital Design Process EPRI Technical Guidance RIS 2002-22 Supp. 1 Short Term NRC Review Guidance BTP 7-19, Revision 4 Concepts RIS 2002-22 Supp. 1 No Changes Needed Long Term Industry Guidance Standardized Digital Design Process NEI YY-XX link to EPRI Technical Guidance Standardized Digital Design Process NEI YY-XX link to EPRI Technical Guidance Standardized Digital Design Process NEI YY-XX link to EPRI Technical Guidance Long Term NRC Review Guidance Approval of NEI YY-XX Develop DI&C Commission Policy Content of RIS 2002-22, Supp. 1 Captured as Durable Guidance No Changes Needed

©2018 Nuclear Energy Institute 8 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 Barrier #2

- Software Development Standards and Guidance

©2018 Nuclear Energy Institute 9 Consider guidance from international standards associated with safety-related software development Revise BTP 7

-14 to follow a graded and risk

-informed approach that is flexible (i.e., not constrained to prescriptive adherence)

Leverage digital I&C operating experience from the international nuclear community (e.g., Électricité de France)

Solution #2 - Software Development Standards and Guidance

©2018 Nuclear Energy Institute 10 Chapter 7 of the Standard Review Plan (SRP) has fragmented and incomplete review guidance for I&C system architectures Barrier #3

- I&C System Architecture Development

©2018 Nuclear Energy Institute 11 Consider international guidance related to the design and development of I&C system architectures Employ concepts from the EPRI Digital Engineering Guide (DEG) Solution #3 - I&C System Architecture Development

©2018 Nuclear Energy Institute 12 Insufficient guidance on limited functionality I&C devices Barrier #4

- Limited Functionality I&C Devices

©2018 Nuclear Energy Institute 13 Consider international guidance associated with limited functionality I&C devices Solution #

4 - Limited Functionality I&C Devices

©2018 Nuclear Energy Institute 14 Strategy is outcome oriented Proposed solutions overcome barriers Leverage international successes in DI&C Alignment with NRC initiatives and principles Summary