Regulatory Guide 1.168
| ML003740098 | |
| Person / Time | |
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| Issue date: | 09/30/1997 |
| From: | Office of Nuclear Regulatory Research |
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| References | |
| DG-1054 RG-1.168 | |
| Download: ML003740098 (8) | |
September 1997 U.S. NUCLEAR REGULATORY COMMISSION
REGULATORY GU
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE 1.168 (Draft was DG-1 054)
VERIFICATION, VALIDATION, REVIEWS, AND AUDITS FOR
DIGITAL COMPUTER SOFTWARE USED IN SAFETY SYSTEMS
OF NUCLEAR POWER PLANTS
A. INTRODUCTION
In 10 CFR Part 50, "Domestic Licensing of Pro duction and Utilization Facilities," paragraph 55a(a)(1)
requires, in part, that systems and components be de signed, tested, and inspected to quality standards com mensurate with the safety function to be performed. 1 Criterion 1, "Quality Standards and Records," of Ap pendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 requires, in part, 1 that a qual ity assurance program be established and implemented in order to provide adequate assurance that systems and components important to safety will satisfactorily per form their safety functions. Appendix B, "Quality As surance Criteria for Nuclear Power Plants and Fuel Re processing Plants," to 10 CFR Part 50 describes criteria that must be met by a quality assurance program for systems and components that prevent or mitigate the consequences of postulated accidents. In particular, be sides the systems and components that directly prevent or mitigate the consequences of postulated accidents, the criteria of Appendix B also apply to all activities af fecting the safety-related functions of such systems and components, such as designing, purchasing, installing, t ln this regulatory guide, many of the requirements have been paraphrased;
see 10 CFR Part 50 for the full text IDE
testing, operating, maintaining, or modifying. A spe cific requirement is contained in 10 CFR 50.55a(h),
which requires that reactor protection systems satisfy the criteria of IEEE Std 279-1971, "Criteria for Protec tion Systems for Nuclear Power Generating Stations." 2 Paragraph 4.3 of IEEE Std 279-19713 states that quali ty of components is to be achieved through the specifi cation of requirements known to promote high quality, such as requirements for design, inspection, and test.
In Appendix B,1 "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"
to 10 CFR Part 50, many of the criteria contain require ments closely related to the activities of verification and testing. Criterion I, "Organization," of Appendix B, in describing the establishment and execution of a quality assurance program, specifies that applicants must (a) assure that an appropriate quality assurance program is established and effectively executed and (b)
2Revision 1 of Regulation Guide 1.153, "Criteria for Safety Systems," en dorses IEEE Std 603-199 1, "Criteria for Safety Systems for NuclearPow er Generating Stations," as a method acceptable to the NRC staff for satis fying the NRC's regulations with respect to the design, reliability, qualifi cation, and testability of the power, instrumentation, and control portions of the safety systems of nuclear power plants.
31EEE publications may be obtained from the IEEE Service Center, 445 Hoes Lane, Piscataway, NJ 08854.
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verify, such as by checking, auditing, and inspection, that activities affecting safety-related functions have been correctly performed. Criterion II, "Quality Assur ance Program," of Appendix B states, in part, that activ ities affecting quality must be accomplished under suit ably controlled conditions. Controlled conditions include the use of appropriate equipment, suitable envi ronmental conditions for accomplishing the activity, and assurance that all prerequisites for the given activi ty have been satisfied. It also states, in part, that the pro gram must take into account the need for verification of quality by inspection and test. Criterion III, "Design Control," of Appendix B requires, in part, that design control measures provide for verifying or checking the adequacy of design. Criterion XI, "Test Control,"
requires, in part, that a test program be established to ensure that all testing required to demonstrate that structures, systems, and components will perform sat isfactorily in service is identified and performed in accordance with written test procedures that incorpo rate the requirements and acceptance limits contained in applicable design documents. Finally, Criterion XVIII, "Audits," requires, in part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assur ance program and to determine the effectiveness of the program.
This regulatory guide endorses IEEE Std 1012-1986,3 "IEEE Standard for Software Verification
- /
and Validation Plans," and IEEE Std 1028-1988,3
"IEEE Standard for Software Reviews and Audits."
IEEE Std 1012-1986, with the exceptions stated in the Regulatory Position, describes a method acceptable to the NRC staff for complying with parts of the NRC's regulations for promoting high functional reliability and design quality in software used in safety systems. 4 In particular, the method is consistent with the pre viously cited General Design Criteria and the criteria for quality assurance programs in Appendix B, as applied to software verification and validation. The cri teria of Appendices A and B apply to systems and related quality assurance processes, and if those sys tems include software, the requirements extend to the software elements. IEEE Std 1028-1988 provides an approach that is acceptable to the NRC staff for carry
4The term "safety systems" is synonymous with "safety-related systems."
The General Design Criteria cover systems, structures, and components
"important to safety." The scope of this regulatory guide is, however, limited to "safety systems," which are a subset of"systems important to safety."
ing out software reviews, inspections, walkthroughs, and audits subject to certain provisions.
In general, information provided by regulatory guides is reflected in the Standard Review Plan (NUREG-0800). The Office of Nuclear Reactor Regu lation uses the Standard Review Plan to review applica tions to construct and operate nuclear power plants.
This regulatory guide will apply to the revised Chapter
7 of the Standard Review Plan.
The information collections contained in this regu latory guide are covered by the requirements of 10 CFR
Part 50, which were approved by the Office of Manage ment and Budget, approval number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information un less it displays a currently valid OMB control number.
B. DISCUSSION
The use of industry consensus standards is part of an overall approach to meeting the requirements of
10 CFR Part 50 when developing safety systems for nuclear power plants. Compliance with standards does not guarantee that regulatory requirements will be met.
However, compliance does ensure that practices accepted within various technical communities will be incorporated into the development and quality assur ance processes used to design safety systems. These practices are based on experience, and they represent industry consensus on approaches used for develop ment of such systems.
Software incorporated into instrumentation and control systems covered by Appendix B will be referred to in this regulatory guide as safety system software.
For safety system software, software verification and validation (V&V), reviews, and audits are important parts of the effort to achieve compliance with the NRC's requirements. Software engineering practices rely, in part, on software V&V and on technical reviews and audits to meet general quality and reliability requirements consistent with Criteria 1 and 21 of Ap pendix A to 10 CFR Part 50, as well as Criteria II, III,
XI, and XVIII of Appendix B. In addition, manage ment reviews and audits of software processes are part of a verification process consistent with Criterion I of Appendix B.
General design verification requirements, but not details of software V&V planning and the conduct of reviews and audits, are described by IEEE Std
7-4.3.2-1993, "Standard Criteria for Digital Comput ers in Safety Systems of Nuclear Power Generating Sta tions," 3 which is endorsed by Revision 1 of Regulatory
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Guide 1.152, "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants," and ASME/
NQA-1-1994, "Quality Assurance Requirements for
)j Nuclear Facility Applications." Two consensus stan dards on software engineering, IEEE Std 1012-1986 (reaffirmed in 1992) and IEEE Std 1028-1988 (re affirmed in 1993), describe the software industry's ap proaches to software verification, validation, review, and audit activities that are generally accepted in the software engineering community. Compliance with these standards helps to meet regulatory requirements by ensuring that disciplined software V&V, review, and audit practices accepted within the software communi ty will be incorporated into software processes applied to safety system software. IEEE Std 1012-1986 de scribes the elements of a software V&V plan and, for software deemed "critical software" by IEEE Std 1012-1986, describes a minimum set of V&V activi ties to be included in the plan. IEEE Std 1028-1988 is a process standard that provides guidance on how to con duct audits, inspections and walkthroughs, and techni cal and management reviews.
Technical reviews, some audits, and software in spections and walkthroughs are focused on the verifica tion and validation of products of the software develop ment process. Management reviews and other audits are focused on ensuring that planned activities are be ing accomplished effectively. Reviews and audits are closely associated with V&V activities since technical reviews and audits are frequently conducted by the V&V organization and because the V&V organization normally participates in management reviews. Because of this close connection of the V&V activity with reviews and audits, IEEE Std 1028-1988 and IEEE Std 1012-1986 are addressed together in this regulatory guide.
IEEE Std 603-1991 and IEEE Std 7-4.3.2-1993, which are endorsed by Revision 1 of Regulatory Guide
1.153 and Revision 1 of Regulatory Guide 1.152, respectively, do not provide for classification, although the foreword to IEEE Std 7-4.3.2-1993 recommends the addition of grading to future versions of IEEE Std 603. This regulatory guide is based on current standards and describes methods acceptable for any safety system software. Within the framework of the acceptable methods described by this regulatory guide, certain V&V activities are required. For smaller, less complex systems or components, these activities should require
>
less effort. Additionally, the applicant or licensee deter mines how the required activities will be implemented, commensurate with the item's importance to safety.
The benefits of this approach are that the concepts ad dressed in the standard are applied within the context of safety system development while the applicant or licensee has flexibility in implementation.
C. REGULATORY POSITION
The requirements specified in IEEE Std 1012
1986Property "IEEE" (as page type) with input value "IEEE 1012</br></br>1986" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. provide an approach that is acceptable to the NRC
staff for meeting the requirements of 10 CFR Part 50
and the guidance given in Revision 1 of Regulatory Guide 1.152, "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants," as they apply to the verification and validation of safety system software, subject to the exceptions listed below in Regulatory Positions 1 through 8 and 11.
IEEE Std 1028-1988 provides an approach accept able to the NRC staff for carrying out software reviews, inspections, walkthroughs, and audits, subject to the exceptions listed below in Regulatory Positions 9 through 11. These are often performed in association with V&V or software quality assurance activities.
Except as noted below, the appendices to these stan dards are not covered by this regulatory guide. In this Regulatory Position, the cited criteria are in Appendix B to 10 CFR Part 50 unless otherwise noted.
To meet the requirements of 10 CFR 50.55a(h) and Appendix A of 10 CFR Part 50 as ensured by comply ing with the criteria of Appendix B applied to the verifi cation, validation, reviews, and audits of safety system software, the following exceptions are necessary and will be considered by the NRC staff in the review of submittals from applicants and licensees.
1.
CRITICAL SOFTWARE
IEEE Std 1012-1986 refers to critical and noncriti cal software. It defines the contents of a Software V&V
Plan (SVVP) for all software and, for critical software, identifies a minimum set of software V&V tasks and their inputs and outputs that must be included in the SVVP. Critical software is defined in IEEE Std 1012-1986 to be software whose failure could have an impact on safety or could cause large financial or social loss. For the purposes of this regulatory guide, critical software means software used in nuclear power plant safety systems per footnote 4 of this guide, a narrower set of critical software than that defined in IEEE Std 1012-1986.
2.
SOFTWARE RELUABILITY
In its discussion of component and integration test plans in Table 1, IEEE Std 1012-1986 identifies measurement of software reliability as a criterion for
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determining whether software elements correctly im plement software requirements. The following is noted in Revision I of Regulatory Guide 1.152.
Section
5.15,
"Reliability,"
of IEEE Std
7-4.3.2-1993 states, "When qualitative or quanti tative reliability goals are required, the proof of meeting the goals shall include software used with the hardware." The staff does not endorse the con cept of quantitative reliability goals as a sole means of meeting the Commission's regulations for reliability of the digital computers used in safety systems.
3. INDEPENDENCE OF SOFTWARE V&V
IEEE Std 1012-1986 does not require indepen dence in the performance of software V&V, but the NRC does require independence. Criterion III, "Design Control," imposes an independence requirement for the verification and checking of the adequacy of the design, requiring that those who perform the verification and checking be different from those who accomplish the design. Approaches to performing independent soft ware V&V are described in Revision 1 of Regulatory Guide 1.152. Regardless of the approach selected for a given V&V task, the responsibility for the adequacy of V&V lies with the organization responsible for the in dependent V&V. The person accountable for V&V
must also be independent of the person accountable for the design. This independence must be sufficient to en sure that the V&V process is not compromised by schedule and resource demands placed on the design process. The independent verifiers must be sufficiently competent in software engineering to ensure that soft ware V&V is adequately implemented. Criterion II,
"Quality Assurance Program," states that the program must provide for indoctrination and training of person nel performing activities affecting quality as necessary to ensure that suitable proficiency is achieved and maintained. It is beneficial if the independent verifiers are also knowledgeable regarding nuclear applications.
4. DESIGN CHANGES
IEEE Std 1012-1986, in paragraph 3.7.2, requires a description in the SVVP of the criteria for determin ing the extent to which a V&V task must be reper formed following a change to an input of the task. The criteria described in the SVVP must be consistent with Criterion III, "Design Control," which requires that de sign changes be subject to design control measures commensurate with those applied to the original de sign. In addition, IEEE Std 1012-1986 includes cost and schedule as possible criteria for determining the ex- tent of re-performance of V&V tasks. Such cost and schedule criteria, if used, must be commensurate in im portance with the cost and schedule criteria that applied to verification of the original design. Any use of these criteria must be consistent with the requirement of 10
CFR 50.57(a)(3) that there be reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.
5.
CONFORMANCE OF MATERIALS
Criterion III, "Design Control," states that measures are to be established for the selection and re view for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components. Criterion VII, "Control of Purchased Material, Equipment, and Services," states that measures are to be established to ensure that purchased material, whether purchased directly or through con tractors and subcontractors, conform to the procure ment documents. In its discussion of V&V during the operation and maintenance phase of the software life cycle, IEEE Std 1012-1986 (in paragraph 3.5.8) pro vides requirements and guidance for retrospective V&V of software that was not verified under the stan dard. The use of this guidance for the acceptance of pre existing (e.g., commercial off-the-shelf) critical soft ware not verified during development to the provisions of this regulatory guide or its equivalent is not en dorsed. Revision 1 of Regulatory Guide 1.152 provides information on the acceptance of pre-existing software.
Additional detailed information on acceptance pro cesses is available in EPRI TR-106439, "Guideline on Evaluation and Acceptance of Commercial Grade Dig ital Equipment for Nuclear Safety Applications" (Octo ber 1996). 5
6. QUALITY ASSURANCE
Criterion I identifies the quality assurance func tions of (a) assuring that an appropriate quality assur ance program is established and effectively executed and (b) verifying, such as by checking, auditing, and in specting, that activities affecting the safety-related functions have been correctly performed. Criterion XVII requires that sufficient records be maintained to furnish evidence of activities affecting quality. Criteri on III requires that design changes be subject to design
511ectric Power Research Institute documents may be obtained from the EPRI Distribution Center, 207 Coggins Drive, P.O. Box 23205, Pleasant Hill, CA 94523. EPRI TR-106439 is also available for inspection or copying for a fee in the NRC Public Document Room at 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555-0001; telephone
(202)634-3273;
fax
(202)634-3343.
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control measures commensurate with those applied to the original design. In addition to the requirements of IEEE Std 1012-1986 (in paragraph 3.7.4) regarding control procedures, any V&V materials necessary for the verification of the effectiveness of the V&V pro grams or necessary to furnish evidence of activities af fecting quality must be maintained as quality assurance records. Those materials necessary for the reverifica tion of changes must be maintained under configura tion management. 6
7.
TOOLS FOR SOFITWARE DEVELOPMENT
Tools used in the development of safety system software should be handled according to IEEE Std
7-4.3.2-1993, "Standard Criteria for Digital Comput ers in Safety Systems of Nuclear Power Generating Sta tions," as endorsed by Revision 1 of Regulatory Guide
1.152. IEEE Std 7-4.3.2-1993 states that "V&V tasks of witnessing, reviewing, and testing are not required for software tools, provided the software that is pro duced using the tools is subject to V&V activities that will detect flaws introduced by the tools." If this cannot be demonstrated, the provisions of this Regulatory Guide 1.168 are applicable.
8.
V&V TASKS
Table 2 of IEEE Std 1012-1986 lists optional V&V
)/
tasks. These are further described in the appendix (which is for information only) to IEEE Std 1012-1986. These tasks are intended to provide a tai loring capability by allowing tasks to be added to the minimum set for critical software. Exception is taken to the 'optional' status of some tasks on this list; they are considered by the NRC staff to be acceptable methods for meeting the requirements of Appendices A and B to
10 CFR Part 50 as applied to software, regardless of whether they are performed by the V&V organization.
The following tasks are considered by the NRC staff to be part of the minimum set of V&V activities for criti cal software unless they are (1) incorporated into other V&V tasks in the SVVP or (2) performed outside the software V&V organization as part or all of the duties of some other organization.
8.1 Configuration Management Configuration management (CM), and software configuration management in particular, are not option al functions, but are identification and control functions considered to be mandatory under Criterion VIII,
6See the guidance in Regulatory Guide
1.169, "Configuration Management Plans for Digital Computer Software Used in Safety Sys tems of Nuclear Power Plants."
"Identification and Control of Materials, Parts, and Components," as applied to software. The same per sonnel who perform the V&V functions may perform the software configuration management functions.
8.2 Audits Criteria III, "Design Control," and XVIII, "Au dits," require the performance of audits. These audits include functional audits, in-process audits, and physi cal audits for software. These audits are commonly considered to be the responsibility of the software qual ity assurance organization and the configuration man agement organization, but they may be handled by the V&V organization. If so, the audits should be described in the SVVP. An acceptable method of conducting these audits is described in IEEE Std 1028-1988.
8.3 Regression Analysis and Testing Criterion III, "Design Control," requires that design changes be subject to design control measures commensurate with those applied to the original design. Regression analysis and testing following the implementation of software modifications is a neces sary element of the V&V of software changes. It is con sidered by the staff to be part of the minimum set of software V&V activities for critical software.
8.4 Installation and Checkout Testing Criterion XI, "Test Control," requires that the test program include, as appropriate, proof tests prior to installation, pre-operational tests, and operational tests.
The user of IEEE Std 1012-1986 must identify in the SVVP which tests will be performed to meet Criterion XI.
8.5 Test Evaluation
.Test evaluation, an optional task described in the Appendix to IEEE Std 1012-1986, calls for confirma tion of the technical adequacy of test materials such as plans, designs, and results. The evaluation of these ma terials is necessary for consistency with Criterion II,
"Quality Assurance Program," in its requirement for controlled conditions and with Criterion XI, "Test Con trol," in its requirement for the evaluation of test results.
8.6 Evaluation of User Documentation Table 2 of IEEE Std 1012-1986 includes User Documentation Evaluation as an optional V&V task.
The requirements of Criterion III, "Design Control,"
for verifying and checking the design apply to software documentation, including user documentation.
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9. CLARIFICATIONS
Criterion III, "Design Control," requires measures, such as the performance of design reviews, to be pro vided for verifying or checking the adequacy of the design, and Criterion II, "Quality Assurance Program,"
requires activities affecting quality to be accomplished under suitably controlled conditions. Criterion V,
"Instructions, Procedures, and Drawings," requires activities affecting quality to be directed by written instructions, procedures, and drawings that include ac ceptance criteria for determining that these activities are successfully accomplished. IEEE Std 1028-1988 contains a mix of verbs (such as "will," variants of "to be," or verbs used in the present tense (as described be low)), and it may not be clear whether the usage is in tended to be a requirement of the standard or a state ment of fact. In this regulatory guide, the following are considered to be conditions for audits and reviews.
9.1 The responsibilities and prerequisites of sections
3.1 and 3.2 and the minimum process description template of section 3.3 of IEEE Std 1028-1988.
9.2 Anything with the terms "must," "required,"
"shall," "minimum requirements," "is responsible for," "will ensure," "is to (or 'is not allowed to'),"
"minimum input,"
"necessary input,"
"is conducted when," "reports that identify (or
'contain')," "output is," or variations of any of these terms.
9.3 The responsibilities, minimum inputs, entry and exit criteria, procedures, and auditability of items described in sections 4 through 8 of IEEE Std 1028, unless the IEEE Std 1028-1988 phraseology indicates a recommended or optional item.
10. TABLE 1 IN IEEE STD 1028-1988 In Table 1 in IEEE Std 1028-1988, the word 'in clude' in the column heading means representative but not exhaustive. Table 1 relates quality assurance processes to quality assurance objectives, adds 'test'
for completeness, and matches key processes to quality assurance objectives. In so doing, it does not provide an exhaustive list of all process and objective relation ships. In particular, the relationship of testing to verifi cation is not indicated, but this relationship is added by this regulatory guide.
11. OTHER CODES AND STANDARDS
Various sections of IEEE Std 1012-1986 and IEEE Std 1028-1988 reference other industry codes and stan dards. These references to other standards should be treated individually. If a referenced standard has been incorporated separately into the NRC's regulations, licensees and applicants must comply with that stan dard as set forth in the regulation. If the referenced stan dard has been endorsed in a regulatory guide, the stan dard constitutes a method acceptable to the NRC staff of meeting a regulatory requirement as described in the regulatory guide. If a referenced standard has been nei ther incorporated into the NRC's regulations nor en dorsed in a regulatory guide, licensees and applicants may consider and use the information in the referenced standard, if appropriately justified, consistent with cur rent regulatory practice
D. IMPLEMENTATION
The purpose of this section is to provide informa tion to applicants and licensees regarding the NRC
staff's plans for using this regulatory guide. No back fitting is intended or approved in connection with the issuance of this guide.
Except in those cases in which an applicant or licensee proposes an acceptable alternative method for complying with the specified portions of the NRC's regulations, the methods described in this guide will be used in the evaluation of submittals in connection with applications for construction permits and operating licenses. This guide will also be used to evaluate sub mittals from operating reactor licensees who propose system modifications that are voluntarily initiated by the licensee if there is a clear nexus between the pro posed modifications and this guidance.
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BIBLIOGRAPHY
2 Hecht, H., A.T. Tai, K.S. Tso, "Class 1E Digital Sys tems Studies," NUREG/CR-6113, USNRC, October
1993.1 Hecht, H., et al., "Verification and Validation Guide lines for High Integrity Systems," NUREG/CR-6293, USNRC, March 1995.1 Institute of Electrical and Electronics Engineers, "Stan dard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations," IEEE Std
7-4.3.2-1993.
Lawrence, J.D., "Software Reliability and Safety in Nuclear Reactor Protection Systems,"
NUREG/
CR-6101 (UCRL-ID-117524, Lawrence Livermore National Laboratory), USNRC, November 1993.1 ICopies may be purchased at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328 (telephone
(202)512-2249); or from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161. Copies are available for inspection or copying for a fee from the NRC Public Document Room at 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop L.-6, Washington, DC 20555-0001;
telephone (202)634-3273; fax (202)634-3343.
Lawrence, J.D., and G.G. Preckshot, "Design Factors for Safety-Critical Software,"
NUREG/CR-6294, USNRC, December 1994.1 Seth, S., et al., "High Integrity Software for Nuclear Power Plants: Candidate Guidelines, Technical Basis and Research Needs," NUREG/CR-6263, USNRC,
June 1995.1 USNRC, "Criteria for Digital Computers in Safety Systems of Nuclear Power Plants," Regulatory Guide
1.152, Revision 1, January 1996.2 USNRC, "Standard Review Plan," NUREG-0800,
February 1984.1
2Single copies of regulatory guides may be obtained free of charge by writing the Office of Administration, Printing, Graphics and Distribu tion Branch, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001; orby fax at (301)415-5272. Copies are available for in spection or copying for a fee from the NRC Public Document Room at
2120 L Street NW, Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555-0001; telephone (202)634-3273;
fax (202)634-3343.
REGULATORY ANALYSIS
A separate regulatory analysis was not prepared for this regulatory guide. The regulatory analysis prepared for Draft Regulatory Guide DG-1054, "Verification, Validation, Reviews, and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants," provides the regulatory basis for this guide. A
copy of the regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555-0001; phone
(202)634-3273; fax (202)634-3343.
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