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Street cred has no place in guidelines for nuclear power stations
The UK Government recently gave the go ahead to build a new nuclear power station in the UK. On Friday I spotted the document COMPUTER BASED SAFETY SYSTEMS published by the UK’s Office for Nuclear Regulation.
This document does a good job of enumerating all of the important software engineering issues in short, numbered, sentences, until sentence 54 of Appendix 1; “A1.54 The coding standards should prohibit the following practices:-“. Why-o-why did the committee of authors choose to stray from the approach of providing a high level overview of all the major issues? I suspect they wanted to prove their street cred as real software developers. As usually happens in such cases the end result looks foolish and dated (1970-80s in this case).
The nuclear industry takes it procedures a lot more seriously than most other industries, which means some poor group of developers are going to have to convince a regulator with minimal programming language knowledge that they are following this rather nebulous list of prohibitions.
What does the following mean? “5 Multiple use of variables – variables should not be used for more than one function;”. It could be read to mean no use of global variables, but is probably intended to cover something like the role of variables idea.
How is ‘complicated’ calculated in the following? “9 Complicated calculation of indexes;”
Here is my favorite: “15 Direct memory manipulation commands – for example, PEEK and POKE in BASIC;”. More than one committee member obviously had a BBC Micro or Sinclair Spectrum as a teenager.
What should A1.54 say? Something like: “A coding guideline document listing the known problematic areas of the language(s) used along with details of how to handle each area will be written. All staff will be given training on the use of these guidelines.”
The regulator needs to let the staff hired following A1.4 do their job: “A1.4 Only reputable companies should be used in all stages of the lifecycle of computer based protection systems. Each should have a demonstrably good track record in the appropriate field. Such companies should only use staff with the appropriate qualifications and training for the activities in which they are engaged. Evidence that this is the case should be provided.”
After A1.54 has been considerably simplified, A1.55 needs to be deleted: “A1.55 The coding standards should encourage the following:-“. Either require it or not. I suspect the author of “6 Explicit initialising of all variables;” had one of a small number of languages in mind, those that support implicit initialization with a defined value: many don’t, illustrating how language specific coding guidelines need to be.
Following the links in the above document led to: Verification and Validation of Software Related to Nuclear Power Plant Instrumentation and Control which contained some numbers about Sizewell B I had not seen before in public documents: “The total size of the source code for the reactor protection functions, excluding comments, support software for the autotesters and communications to other systems, is around 100 000 unique lines. A typical processor contains between 10 000 and 40 000 lines of source code, of which about half are typically from common functions, and the remainder form application code. In addition to the executable code, the PPS incorporates around 100 000 lines of configuration and calibration data per guardline associated with the reactor protection functions.”
Trying to sell analysis tools to the Nuclear Regulatory Commission
Over the last few days there has been an interesting, and in places somewhat worrying, discussion going on in the Safety Critical mailing list about the US Nuclear Regulatory Commission. I thought I would tell my somewhat worrying story about dealing with the NRC.
In 1996 the NRC posted a request for information for a tool that I thought my company stood a reasonable chance of being able to meet (“NRC examines source code in nuclear power plant safety systems during the licensing process. NRC is interested in finding commercially available tools that can locate and provide information about the following programming practices…”). I responded, answered the questions on the form I received and was short listed to make a presentation to the NRC.
The presentation took place at the offices of National Institute of Standards and Technology, the government agency helping out with the software expertise.
From our brief email exchanges I had guessed that nobody at the NRC/NIST end knew much about C or static analysis. A typical potential customer occurrence that I was familiar with handling.
Turned up, four or so people from NRC+one(?) from NIST, gave a brief overview and showed how the tool detected the constructs they were interested in, based on test cases I had written after reading their requirements (they had not written any but did give me some code that they happened to have, that was, well, code they happened to have; a typical potential customer occurrence that I was familiar with handling).
Why did the tool produce all those messages? Well, those are the constructs you want flagged. A typical potential customer occurrence that I was familiar with handling.
Does any information have to be given to the tool, such as where to find header files (I knew that they had already seen a presentation from another tool vendor, these managers who appeared to know nothing about software development had obviously picked up this question from that presentation)? Yes, but it is very easy to configure this information… A typical potential customer occurrence that I was familiar with handling.
I asked how they planned to use the tool and what I had to do to show them that this tool met their requirements.
We want one of our inspectors to be able turn up at a reactor site and check their source code. The inspector should not need to know anything about software development and so the tool must be able to run automatically without any options being given and the output must be understandable to the inspector. Not a typical potential customer occurrence and I had no idea about how to handle it (I did notice that my mouth was open and had to make a conscious effort to keep it closed).
No, I would not get to see their final report and in fact I never heard from them again (did they find any tool vendor who did not stare at them in disbelief?)
The trip was not a complete waste of time, a few months earlier I had been at a Java study group meeting (an ISO project that ultimately failed to convince Sun to standarize Java through the ISO process) with some NIST folk who worked in the same building and I got to chat with them again.
A few hours later I realised that perhaps the question I should have asked was “What kind of software are people writing at nuclear facilities that needs an inspector to turn up and check?”
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