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NuclearPlantJournal.com Nuclear Plant Journal, September-October 2016
sites to identify a solution that can be
applied to all. The process generally
begins with the development of detailed
specifications that defines all the system
performance and technical requirements.
We use the specifications to communicate
with prospective vendors. Vendors
will develop conceptual designs that
we evaluate to a structured process to
determine which option best meets our
needs.
Once we have identified the preferred
solution, the funding authorization
process begins and once approved, a
project team is scaled up to implement.
Since we can’t deploy these solutions all
at the same time, we sequence projects
based on where the need is greatest.
While every project is different, a typical
project team is comprised of a Corporate
Digital Engineer, Site Digital Engineer,
Site System Engineers, Project Managers,
A&E design team and equipment
Modernizing the...
vendors. The final design is typically
turned over to the installation team 12
months in advance of the installation.
The project team remains engaged until
the modification is installed, tested and
turned over to operations.
4.
What impact does Cyber Security
have on digital modifications?
The governing regulation is 10
CFR 73.54. The scope of the regulation
includes any asset that performs a
Safety, Important-To-Safety, Security
or Emergency Preparedness (SSEP)
function. The scoping creates a very
large population of assets that must be
evaluated and managed. The industry
and NRC worked for several years to
create a regulatory framework that allows
licensees to manage these assets more
efficiently.
The entire industry has put very
formidable defensive measures in place
to ensure that our digital assets are well
protected from malicious actions. We
continue to build out our program to meet
the full compliance deadline of December
2017. Cyber Security impacts nearly
every aspect of how we conduct business,
including procurement, design, and
maintenance practices. This represents a
body of work that is hard to overstate.
We view DI&C and Cyber Security
as concentric rings around the same
center. We address Cyber Security
requirements as a basic element of any
design change. Standardization helps us
with cyber security compliance because
the solutions we develop can be applied
broadly to all similar systems.
5.
What are the barriers to greater
degrees of modernization?
The largest barrier we face right now
is regulatory. The systems we modernize
today are all non-safety related (NSR).
These modifications are largely done
in accordance with 10 CFR 50.59
and generally do not require a license
amendment to implement.
Moving safety systems into the digital
domain is very different proposition
because this generally requires a license
amendment in accordance with the ISG-6
(Interim Staff Guidance Association with
Digital Instrumentation) process. This
process is very burdensome and lacks the
certainty necessary for a licensee to make
