ML25111A068
| ML25111A068 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 04/18/2025 |
| From: | Andy Campbell Nuclear Energy Institute |
| To: | Martinez-Navedo T Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML25111A068 (1) | |
Text
Alan Campbell Technical Advisor Phone: 202.439.3698 Email: adc@nei.org April 18, 2025 Tania Martinez-Navedo Director, Division of Engineering of External Hazards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Consolidated Industry Priorities for Digital Instrumentation and Control (DI&C) Regulatory Modernization Project Number: 689
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 appreciates the opportunity to provide consolidated input on NRC activities related to the regulatory framework for digital instrumentation and control (DI&C) system upgrades. This letter synthesizes industry feedback submitted in 2024 and 2025 and communicates the industrys top priorities for resolving longstanding challenges in the licensing of modern DI&C systems.
The nuclear industry strongly supports the NRCs efforts to enhance regulatory clarity and efficiency in this area. To that end, NEI urges the NRC to prioritize the following immediate actions:
- 1. Address Lessons Learned Using DI&C-ISG-06: NEI recommends that the NRC address key lessons learned from the initial uses of DI&C-ISG-06 in areas such as Equipment Qualification (EQ), Vendor Oversight Plans (VOP), and Human Factors Engineering (HFE). These technical areas are critical to successful licensing of DI&C upgrades and require a coordinated, consistent review approach. To support industry deployment, NEI requests completion by December 2025.
- 2. Endorse Risk-Informed Common Cause Failure Methodology in NEI 20-07: The NRC should formally endorse NEI 20-07 when submitted, which provides a performance-based methodology to 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.
Ms. Tania Martinez April 18, 2025 Page 2 Nuclear Energy Institute support implementation of the risk-informed digital common cause failure (CCF) policy articulated in SRM-SECY-22-0076. This guidance represents a generically applicable solution that supports industry adoption of digital safety systems in operating and new reactors. To support industry deployment, NEI requests completion by December 2025.
- 3. Eliminate 10 CFR 50.55a(h): The industry strongly supports the removal of 10 CFR 50.55a(h),
which inhibits the use of modern standards and duplicates numerous criteria in Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants. Eliminating this requirement will reduce unnecessary regulatory burden and enable more efficient implementation of DI&C upgrades without compromising safety. To support industry deployment, NEI requests completion by June 2026.
In addition to the above high-priority items, NEI identifies the following as essential long-term actions to modernize the regulatory infrastructure:
Consolidate Standard Review Plan (SRP) Chapter 7: NEI recommends restructuring and consolidating SRP Chapter 7 to better align with digital technologies and system architectures, reduce redundancy, and improve usability by applicants and reviewers, as described by the industry during the February 19, 2025, public meeting on Advance Act Section 505 and 507 DI&C topics.
Consolidate Human Factors Engineering (HFE) Guidance: The NRC should consolidate HFE staff review guidance (i.e., SRP Chapter 18, NUREG-0700, NUREG-0711, NUREG-1220, NUREG-1764, and NUREG-1852) to improve efficiency, predictability, and timeliness of reviews.
Streamline and Modernize Regulatory Guides: The NRC should review and revise relevant DI&C regulatory guides (e.g., Regulatory Guides 1.168 through 1.173) to reflect current engineering practices, such as systems engineering approaches to digital system design.
These actions are necessary to enhance regulatory clarity, predictability, and efficiency to support deployment of modern DI&C systems. We stand ready to work with the NRC staff to advance these priorities and support their implementation.
Please direct any questions or requests for further information to me at adc@nei.org or 202-439-3698.
Sincerely, Alan Campbell cc:
Patrick Koch (NRR/DEX/ELTB)
Fanta Sacko (NRR/DEX/EICB)