ML24351A017
| ML24351A017 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 12/13/2024 |
| From: | Andy Campbell, David Rahn Nuclear Energy Institute |
| To: | Barwell O NRC/OCFO |
| References | |
| NEI 20-07 | |
| Download: ML24351A017 (1) | |
Text
Alan Campbell Technical Advisor Phone: 202.739.8011 Email: adc@nei.org December 13, 2024 Owen Barwell Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Supplement to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems Project Number: 689
Dear Mr. Barwell,
On October 31, 2024, the Nuclear Energy Institute (NEI)1, on behalf of its members, submitted a fee exemption request2 for NEI 20-07, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems. NEI 20-07 is intended to guide licensees in developing license applications to deploy digital I&C systems while meeting the provisions established by the Commission in SRM-SECY-22-0076, Staff Requirements - SECY-22-0076 - Expansion of Current Policy on Potential Common-Cause Failures in Digital Instrumentation and Control Systems. This letter is intended to provide supplemental information in support of the NRC staffs review of the fee exemption request submitted on October 31, 2024.
In its letter to NEI dated October 25, 20233, the NRC granted a fee exemption for pre-submittal activities acknowledging the potential benefits to fill a gap in existing NRC regulatory guidance for addressing common cause failure (CCF) within highly safety-significant DI&C safety systems. During pre-submittal meetings, NEI and the NRC staff made meaningful progress towards developing industry guidance for 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. Owen Barwell December 13, 2024 Page 2 Nuclear Energy Institute addressing the potential effects of common cause failure (CCF) in DI&C systems and identified future activities intended to build regulatory confidence in the proposed methodology.
In the same letter granting the fee exemption, the NRC raised concerns regarding the use of proprietary markings on the previously submitted version, NEI 20-07 Rev. E. NEI agrees to submit future versions of NEI 20-07 as a non-proprietary report. As a result, future versions of NEI 20-07 will be available to NEI and NRC stakeholders within the public domain and support generic regulatory improvements to the DI&C regulatory infrastructure.
NEI believes that the effort to improve the licensing process for highly safety-significant safety-related DI&C systems constitutes the exact type of generic regulatory improvement envisioned by 10 CFR 170.11.
NRC efforts conducted while reviewing NEI 20-07 will result in generic regulatory improvements and facilitate licensing of DI&C systems.
Please contact me at adc@nei.org or (202) 439-3698 should you have any questions or concerns.
Sincerely, Alan Campbell C:
David Rahn (NRR/DEX/ELTB)
Michael Marshall (NRR/DORL/LPL1)
Jason Paige (NRR/DEX/ELTB)
Fanta Sacko (NRR/DEX/EICB)
Eric Benner (NRR/DEX)
NRC Document Control Desk