ML21278A471
| ML21278A471 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 09/30/2021 |
| From: | Andy Campbell Nuclear Energy Institute |
| To: | Eric Benner Office of Nuclear Reactor Regulation |
| Govan T | |
| Shared Package | |
| ML21278A470 | List: |
| References | |
| NEI 20-07, Rev. D | |
| Download: ML21278A471 (2) | |
Text
ALAN CAMPBELL Technical Advisor, Generation and Suppliers 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8011 adc@nei.org nei.org September 30, 2021 Mr. Eric Benner Director, Division of Engineering and External Hazards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI 20-07, Draft D, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems Project Number: 689
Dear Mr. Benner:
The Nuclear Energy Institute (NEI)1, on behalf of its members, submits the attached document, NEI 20-07, Guidance for Addressing Software Common Cause Failure in High Safety-significant Safety-related DI&C Systems to the U.S. Nuclear Regulatory Commission (NRC) staff for review. NEI 20-07 establishes the guidance for a performance-based methodology, based on other safety industry recognized practices, to eliminate the potential for common cause failure in high safety-significant safety-related DI&C system during system design. NEI 20-07 is directly linked to Branch Technical Position (BTP) 7-19, Revision 3, Guidance for the Evaluation of Defense-in-Depth and Diversity to Address Common Cause Failure Due to Latent Defects in Digital Safety Systems. In particular, Section B.3.1.3 of BTP 7-19, Use of Alternate Methods to Eliminate the Potential for Common-Cause Failure from Further Consideration, provides an option to leverage an NRC-approved methodology that incorporates various defensive measures to limit the potential for a common-cause failure. NEI 20-07 is intended to provide an alternate method in accordance with the guidance from BTP 7-19, Section B.3.1.3.
Please contact me at adc@nei.org or (202) 439-3698 should you have any questions or concerns regarding NEI 20-07 or other related matters. We look forward to discussing the contents of this document with you.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Mr. Eric Benner September 30, 2021 Page 2 Sincerely, Alan Campbell Attachment c:
Samir Darbali (NRR/DEX/ELTB)
Wendell Morton (NRR/DEX/EEEB)
Tekia Govan (NRR/DRO/IRAB)
Michael Waters (NRR/DEX/EICB)
Jeanne Johnston (NRR/DEX/ELTB)