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MONTHYEARML24023A0392024-01-22022 January 2024 NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118 ML23355A1972023-12-14014 December 2023 NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements ML23219A1672023-10-25025 October 2023 Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23270B9002023-09-27027 September 2023 NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079 ML23268A0102023-09-22022 September 2023 NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors ML23241A8612023-08-25025 August 2023 Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels ML23236A4992023-08-24024 August 2023 Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023 ML23256A1622023-08-0101 August 2023 Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025 ML23206A0292023-07-24024 July 2023 Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23143A1232023-06-22022 June 2023 NRC Fee Waiver Request for Draft NEI 23-01 ML23200A1662023-05-30030 May 2023 NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program ML23116A0732023-05-25025 May 2023 Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03 ML23135A7332023-05-0909 May 2023 NEI Comments on NRC Safety Culture Program Effectiveness Review ML23110A6752023-04-18018 April 2023 04-18-23_NRC_Fee Waiver for NEI 23-03 ML23110A6782023-04-18018 April 2023 Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse ML23107A2302023-03-31031 March 2023 NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking ML23138A1662023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23083B4622023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23060A3272023-03-0101 March 2023 NEI, Wireless Cyber Security Guidance ML23060A2142023-03-0101 March 2023 NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0 ML23023A2752023-01-23023 January 2023 Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents ML22348A1122023-01-17017 January 2023 Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7 ML22353A6082023-01-11011 January 2023 U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33) ML22349A1012022-12-12012 December 2022 LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage ML22336A0372022-11-16016 November 2022 Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML22321A3152022-11-16016 November 2022 NEI Letter with Comments on Significance Determination Process Timeliness Review ML22298A2262022-10-25025 October 2022 Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022 ML22298A2302022-10-17017 October 2022 Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description ML22207B6512022-07-26026 July 2022 NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations ML22195A1662022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A0202022-07-13013 July 2022 07-13-22 NRC Fee Exemption Request for NEI 21-05 Review ML22195A0672022-07-13013 July 2022 Fee Exemption Request for Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases ML22159A2772022-06-28028 June 2022 Response Letter to Richard Mogavero for Fee Exemption for the Nuclear Regulatory Commission Review Ad Endorsement of NEI 15-09, Revision 1 ML22153A2782022-06-0202 June 2022 Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022 ML22154A2962022-06-0202 June 2022 LTR from R. Mogavero to M. Sampson Dated Jun 2 2022 Endorsement of NEI 15-09 Cyber Security Event Notifications Rev 1 Dated May 2022 ML22152A2712022-06-0101 June 2022 Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1 ML22143A9362022-05-20020 May 2022 May 13, 2022, Public Meeting on Draft Regulatory Issue Summary Operational Leakage, 87 Fed. Reg. 2361 (Jan. 14, 2022) (Docket Id NRC-2021-0173) ML22110A1752022-05-0303 May 2022 NRC Response to the Nuclear Energy Institute April 1, 2022, Letter, Regarding the Nrc'S CUI Implementation Plan ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 ML22110A1782022-04-0101 April 2022 April 1, 2022, Letter from NEI Regarding Nrc'S Controlled Unclassified Information Program Implementation ML22048A5812022-02-16016 February 2022 NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations ML22019A2922022-01-12012 January 2022 NEI, Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ML21343A2922021-12-0808 December 2021 NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology ML21337A3802021-12-0303 December 2021 NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1 ML21319A3522021-11-10010 November 2021 NRC NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10, Dated November 10, 2021 ML21306A3652021-10-29029 October 2021 NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7) ML21342A1682021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021 ML21342A2032021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021 ML22081A2002021-10-29029 October 2021 NEI Backfitting Concerns with NRCs Developing Position on Protection of Dry Storage Systems from Natural Phenomena During Short Term Operations 2024-01-22
[Table view] Category:Report
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Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021 ML21342A1682021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021 ML21274A0312021-10-0101 October 2021 NRC Draft Detailed Comments Related to NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology ML21278A4722021-09-30030 September 2021 NEI 20-07, Rev. Draft, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems ML21257A2352021-08-19019 August 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email Exchange Between Nrc and NEI Draft Pages from NEI-20-05 Rev. E ML21250A3782021-08-0202 August 2021 NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors SAR Content for Applicants Using the NEI 18-04 Methodology ML21130A5962021-05-31031 May 2021 NEI, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5972021-05-31031 May 2021 NEI 20-07, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21125A2842021-05-0505 May 2021 Transmittal of NEI 20-09: Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-Light Water Reactor Standard ML21110A0662021-04-20020 April 2021 Nei'S Comparison Table Between NEI 20-07 Sdos and NRC RGs and Endorsed IEEE Stds R2 ML21085A5552021-03-25025 March 2021 NEI 20-09 -Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR PRA Standard, March 2021 ML21089A0902021-03-18018 March 2021 NEI Comments on Renewal of Performance Indicators Information Collection, March 18, 2021 ML21049A0572021-03-0202 March 2021 Rulemaking: Proposed Rule: NRC Markup of NEI-20-05 Draft B Comments on Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Performance Criteria of 10 CFR 73.55(a)(7) ML20339A4852020-11-23023 November 2020 NEI 20-09 - NRC Comments Resolved November 2020 ML20322A3392020-11-17017 November 2020 NEI ROP White Paper Modification of the Description of Unplanned Scrams with Complications for Nov 18 2020 ROP Public Meeting ML21050A0902020-08-31031 August 2020 Staff Detailed Comments - NEI 20_07 Draft Revision B -February 2021 ML20245E1472020-08-31031 August 2020 Attachment 1 - NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel ML20245E5612020-08-31031 August 2020 Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems ML20302A1152020-08-24024 August 2020 NEI 20-09 - Nlwr PRA Peer Review Rev1 August 2020 ML20211L7142020-07-24024 July 2020 Industry Position Regarding Safety Margin: Dispositioning Degraded or Failed Management Measures Above and Beyond Regulatory Requirements, and Meeting Performance Criteria; Follow Up to May 6, 2020 Letter on Smarter Program Inspection Prior ML20155K6852020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20154K5662020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20129J8592020-05-31031 May 2020 NEI 96-07, Appendix D Revision 1, Draft M, May 2020 ML20129J8582020-05-30030 May 2020 NEI 96-07, Appendix D, Revision 1, Draft M, May 2020 with Redline Strike ML20141L7882020-05-20020 May 2020 NEI - Comments on Draft Micro-Reactor Applications COL-ISG-029, Environmental Considerations Associated with Micro-Reactors ML20139A1902020-05-14014 May 2020 05-14-20 Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Safety-Related and Important-to-Safety Functions ML20134J0332020-05-13013 May 2020 Submittal of Response to Request for Additional Information (RAI) for NEI 14-05A, Revision 1, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services ML20135H1682020-05-13013 May 2020 Request for NRC Endorsement of NEI 96-07, Appendix D, Rev 1 2023-06-06
[Table view] Category:Miscellaneous
MONTHYEARML23129A0282023-05-0202 May 2023 20230502, NEI Issues for Event Notification Implementation Workshops ML22297A2482022-10-20020 October 2022 NEI Comments on 10-20-2022 CCF Meeting Feedback and Comments ML23072A0632022-09-30030 September 2022 (Draft) NEI White Paper Remediation of Vulnerabilities Identified in CDAs - 08302022R0 ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 ML22019A2922022-01-12012 January 2022 NEI, Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21089A0902021-03-18018 March 2021 NEI Comments on Renewal of Performance Indicators Information Collection, March 18, 2021 ML20141L7882020-05-20020 May 2020 NEI - Comments on Draft Micro-Reactor Applications COL-ISG-029, Environmental Considerations Associated with Micro-Reactors ML20100G9032020-03-31031 March 2020 NEI 15-03, Rev. 3, Licensee Actions to Address Nonconservative Technical Specifications ML20038A1952020-02-0606 February 2020 NEI Dic Comments on BTP 7-19 Revision 8 to Support Feb 11 2020 Public Meeting ML19312B1022019-10-15015 October 2019 NEI Letter to A. Kock Industry Proposal 2 - Smarter Program for Fuel Cycle Facilities; Follow Up to September 25, 2019 Public Meeting in Preparation for Subsequent Fall 2019 Meetings ML19239A0162019-08-27027 August 2019 NEI Comments on IMC 0609, Appendix a and Attachment 1 August 2019 ML19226A3342019-08-14014 August 2019 (NEI) - Comments on Draft Interim Staff Guidance on the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept ML19261B9552019-08-0101 August 2019 Miscellaneous Material Related to DG-1353 on Licensing Basis for Non-LWRs ML19142A0712019-05-20020 May 2019 NEI 07-07 Rev 1, Industry Groundwater Protection Initiative - Final Guidance. ML18324A7772018-11-0909 November 2018 (NEI)- Summary of Information Provided at the October 17, 2018 Public Meeting Association with Implementation of Open Phase Isolation Systems - ML18271A111 ML18275A1212018-10-0101 October 2018 Letter from Nuclear Energy Institute Endorsement of Iso/Iec 17025: 2017, General Requirements for the Competence of Testing and Calibration Laboratories. ML18268A1142018-09-20020 September 2018 Industry Initiative on Open Phase Condition, Revision 2 ML18260A0012018-09-14014 September 2018 September 14, 2018, Update to NEI 17-06 ML18180A3132018-03-16016 March 2018 NEI Recommendations for NRC Regulatory Tranformation Initiative ML17268A0362017-09-30030 September 2017 NEI 17-02, Revision 1, Tornado Missile Risk Evaluator (TMRE) Industry Guidance Document ML17249A0952017-09-30030 September 2017 NEI 12-04, Revision 1, Draft a, Guidelines for 10 CFR 72.48 Implementation. ML17234A6152017-08-31031 August 2017 NEI 13-10, Revision 6, Cyber Security Assessment. ML17230A3532017-08-0404 August 2017 Anchor Darling Double Disc Gate Valve Industry Resolution Plan 8-4-2017 Update ML17212A6352017-07-31031 July 2017 07-20-17 NEI 0809 Addendum 4 Attachment 2 ML17209A7352017-07-14014 July 2017 Anchor Darling Double Disc Gate Valve Industry Resolution Plan ML17137A0192017-05-17017 May 2017 NEI 96-07 Appendix D Draft Revision 0 - Proposed Revisions - May 16, 2017 Redline ML17137A0202017-05-17017 May 2017 NEI 96-07 Appendix D Draft Revision 0 - Proposed Revisions - May 16, 2017 ML17136A1522017-05-16016 May 2017 Draft of NEI 06-11 Revision 2, Managing Personnel Fatigue at Nuclear Power Reactor Sites) for Discussion at NRC Public Meeting on 2017-June-15 ML17269A0012017-05-16016 May 2017 NEI 96-07, Appendix_D with Hsi Edits from 9/19/2017 - 9/21/2017 Meeting ML17121A4302017-05-0101 May 2017 Industry Comments on the Draft Implementation Plan ML17044A0272017-02-0101 February 2017 February 1, 2017, NEI / Industry Input to Modernization Plan No. 3 - Scope of 3rd Party Certification for Commercial Grade Digital Equipment ML12200A3752012-08-31031 August 2012 Comments on Nuclear Energy Institute 96-07, Appendix C: Guideline for Implementation of Change Control Processes for New Nuclear Power Plants Licensed Under Title 10 of the Code of Federal Regulations, Part 52, Revision 0C ML1208000722012-03-20020 March 2012 Letter NEI 96-07 App C Rev. 0C NRC Comments ML0928904002009-09-30030 September 2009 NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, Revision 3 ML0724204472007-08-0606 August 2007 White Paper Testing of Dynamic Soil Properties for Nuclear Power Plant COL Applications ML0520900382005-07-20020 July 2005 Attachment for the Summary of July 20, 2005 Meeting Between NRC and NEI, Cipims/Itaac Verification Demonstration Program, Phase I Report, Revision 0 ML15084A2091998-01-28028 January 1998 Letter to Mr. Modeen, NEI NRC Staff Views on Clarifications Contain in Nei'S July 22, 1997 on Severe Accident Management ML18263A0401996-01-0101 January 1996 One Year Without a Disposal Site for Low-Level Radioactive Waste - Lessons Learned from the Barnwell Closure to 31 States 7/1/94 - 6/30/95 (Enclosure to Comments Submitted on DSI-4, DSI-5, DSI-7, DSI-9, DSI-12, DSI-13, DSI-14, DSI-21, DSI-G 2023-05-02
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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 April 8, 2022 Mr. Eric J. Benner Director, Division of Engineering and External Hazards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Digital Instrumentation and Control Common Cause Failure Policy Considerations Project Number: 689
On behalf of the Nuclear Energy Institutes (NEI) 1 members, we provide the attached white paper, Digital Common Cause Failure Policy Considerations, for NRC staff consideration while addressing a potential expansion to the existing policy documented in SRM/SECY-93-087. The SRM/SECY-93-087 policy was influenced based on the state of digital instrumentation and control technology in the early 1990s. Specific concerns were provided in SECY-91-292 and reaffirmed in SECY-93-087 that led to the use of diversity alone to overcome digital common cause failure. The NRC concerns that contributed to the creation of the SRM/SECY-93-087 policy have been addressed and no longer apply to the technical environment 30 years later. Research has shown that modern analysis techniques (e.g., hazards analysis, reliability analysis, etc.)
effectively address digital common cause failure. These techniques are used in non-nuclear industries (e.g.,
automotive, aviation, chemical processing, and defense industries) in safety critical applications.
Additionally, risk-insights are effective at better informing decisions when addressing digital common cause failure. A risk-informed approach to digital common cause failure allows for the risk significance of individual plant functions to be considered when designing the digital system so that more protection is designed in for those functions of higher risk significance.
Digital I&C technology applications are imperative to the safe and reliable long-term operation of nuclear power plants. This technology is intended to replace obsolete instrumentation and control systems with 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 April 8, 2022 Page 2 highly reliable equipment offering improved system functional capabilities (e.g., increased accuracy, no setpoint drift, automation, self-testing and diagnostic capabilities, and data availability to plant staff). The prescribed use of diversity has introduced significant system complexity and cost barriers to replacing the existing systems due to the additional equipment, engineering and maintenance costs associated with implementing diverse systems. Included in the attached white paper, NEI members provide the following recommended principles that should be incorporated into the expanded policy. The new, expanded policy should:
- Allow for risk-informed performance-based approaches to ensure applicants focus on the most risk-significant functions and to provide flexibility in meeting established system performance criteria.
- Consider the full plant defense-in-depth strategy to prevent, mitigate or respond to a digital common cause failure.
- Allow for the use of modern hazards and/or reliability analysis techniques to examine the system for unsafe conditions and identify appropriate system requirements to prevent systematic failures.
- Expand the ability to use design techniques (in addition to diversity) to prevent or mitigate a digital common cause failure in accordance with GDC 22.
The following is an example of an expanded policy based on the considerations detailed above:
- 1. The applicant shall assess the impact of the proposed digital instrumentation and control Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) on the plants defense-in-depth systems and procedures to demonstrate that vulnerabilities to digital common cause failures have been adequately addressed.
- 2. In performing the assessment, the vendor or applicant shall identify each digital common cause failure that could adversely impact a safety function using risk-informed hazards and/or reliability analysis techniques.
- 3. Commensurate with the risk significance of each identified digital common cause failure, the applicant shall demonstrate adequate measures to address the identified digital common cause failure that could adversely impact a safety function. The measures may include non-safety systems or components if they are of sufficient quality to reliably perform the necessary functions and with a documented basis that the measures are unlikely to be subject to the same common cause failure.
The measures may also include monitoring and manual operator action to complete a function.
The principles provided are supported by industry research, applied in non-nuclear safety critical applications, and aligned with NRC staff direction to risk-inform regulation where appropriate. Please contact me at adc@nei.org or (202) 439-3698 should you have any questions or concerns.
Mr. Eric Benner April 8, 2022 Page 3 Sincerely, Alan Campbell
Attachment:
Digital Common Cause Failure Policy Considerations c: Jeanne Johnston (NRR/DEX/ELTB)
Samir Darbali (NRR/DEX/ELTB)
Bhagwat Jain (NRR/DEX/ESEB)
NRC Document Control Desk
WHITE PAPER Digital Common Cause Failure Policy Considerations Prepared by the Nuclear Energy Institute April 8, 2022
© NEI 2022. All rights reserved. nei.org
April 8, 2022 Acknowledgements This document was developed by the Nuclear Energy Institute. NEI acknowledges and appreciates the contributions of NEI members and other organizations in providing input, reviewing, and commenting on the document.
NEI Project Lead: Alan Campbell Notice Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.
© NEI 2022. All rights reserved. nei.org 1
April 8, 2022 Digital Common Cause Failure Policy Considerations Common cause failures (CCF) have the potential to introduce failure modes that defeat redundancy.
CCF can exist in all systems, including those using analog technology. Traditionally the potential for CCF is minimized through the application of special treatments, such as quality assurance and testing, maintenance, etc. NRCs current policy relative to CCF in digital systems, developed 30 years ago, is unique in that it requires that CCF is assumed to occur, and diversity is the only means of mitigating the failure. The purpose of this white paper is to provide the NRC with information related to a potential expanded policy for digital CCF. The policy considerations described within this document are intended to address digital common cause failure in both Light Water Reactor (LWR) designs, as well as non-LWR designs. Non-LWR designs developing a risk-informed performance-based design and licensing basis use different terminology for terms such as safety function and safety-significant, and have different regulatory requirements.
SRM/SECY-93-087 provides the NRC policy on CCF in digital systems. Within this policy, the NRC provides guidance to:
- assess the defense in depth and diversity of the proposed digital system,
- demonstrate adequate diversity for each postulated common-mode failure (or common cause failure) for each event evaluated in the nuclear power plants accident analysis,
- provide a diverse means of accomplishing safety functions, if the postulated common-mode failure (or common cause failure) could disable a safety function, and
- provide diverse displays and controls in the main control room for manual, system-level actuation of critical safety functions.
The SRM/SECY-93-087 policy was influenced by NRC staff understanding of the state of digital instrumentation and control technology in the early 1990s. Specific concerns were provided in SECY 292 and reaffirmed in SECY-93-087 that led to the use of diversity as the sole means to overcome digital common cause failure. In these SECY papers, the NRC describes the following concerns:
- Lack of digital I&C experience in nuclear applications
- Absence of requirements and standards related to digital-specific design aspects; and
- Lack of guidance and standards related to software development processes.
In the past 30 years, these concerns have been addressed by numerous industries resulting in mature design and software development practices and increased application of digital I&C technology. US and international standards organizations (e.g., Institute of Electrical and Electronics Engineers (IEEE),
International Electrotechnical Commission (IEC), and International Society of Automation (ISA)) have developed guidance for the full lifecycle of digital I&C technology and have created robust processes to update these standards. Many of these standards have been endorsed by the NRC for use in nuclear safety-related applications or accepted by NRC in project-specific reviews (e.g., Safety Evaluations for
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April 8, 2022 Triconex 1, RadICS 2, and TXS 3). Digital I&C technology has been used in numerous nuclear non-safety applications and has been implemented in a limited way within safety-related applications. Many licensees have determined that digital non-safety control system upgrades have significantly decreased turbine-related initiating events. One utility reported that for BWR Digital Feedwater, BWR Turbine Controls, and PWR Turbine Controls upgrades the sites reduced the associated SCRAM rates by 95%,
83%, and 74%, respectively. Outside of the nuclear power generation industry, digital I&C technology is used extensively in safety applications in industries such as automotive, aviation, chemical processing, and defense. As such, risk and hazards analysis techniques have matured to support these safety critical applications. When applied appropriately, modern hazards analysis techniques have been proven effective by researchers and practitioners in identifying systematic failures (including common cause failures). In essence, the NRC concerns that contributed to the creation of the SRM/SECY-93-087 policy 30 years ago have been addressed rigorously in numerous industries and reliance on diversity alone as a means of protecting against common cause failure is no longer needed.
Beyond the SRM/SECY-93-087 policy, diverse systems are not required within 10 CFR Parts 50 and 52.
The interpretation of General Design Criterion 22, Protection system independence, summarized in NUREG-0800 Branch Technical Position (BTP) 7-19 is too narrow. It states that for high safety significant safety-related SSCs, GDC 22 requires functional diversity, to the extent practical. In fact, GDC 22 states: Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function. GDC 22 requires design techniques to prevent the loss of the protection function, not functional diversity.
Limiting design techniques to only functional diversity, as stated in BTP 7-19, or in component (i.e.,
equipment) design diversity does not fulfill the intent of GDC 22. As a result, no rulemaking would be needed to allow the use of other measures to protect against common cause failure.
In addition, reliance on diversity alone would not reduce the likelihood of a malfunction in the I&C system in all cases. Research of nuclear power plant events concludes that the leading contributing factor to those events was system requirements errors (both I&C and non-I&C system requirements). 4 Implementing diversity may not always be effective in addressing system requirements errors. For example, if the same design requirements are used for the safety system and the diverse system, the same incorrect design functions will be designed into both systems and verified and validated as correct.
Additionally, aviation industry experts have identified that system complexity from diverse systems has contributed to errors leading to aircraft accidents. 56 Alternatively, modern hazards analysis techniques (e.g., Systems-Theoretic Process Analysis) are effective in the identification of potential design errors that could lead to the failure of system functions. To determine their effectiveness, researchers have provided digital I&C system designs to engineering teams to implement modern hazards analysis techniques. 7 The engineering teams were unaware of defects in these system designs that either led to digital events or were identified in late project stages. Using these modern hazards analysis techniques, the engineering teams successfully identified the design errors earlier in the design process or 1
Final Safety Evaluation for the Triconex Topical Report, April 20, 2012. ADAMS Accession Number ML120900899 2
Safety Evaluation by the Office of New Reactors and the Office of Nuclear Reactor Regulation AREVA NP Topical Report ANP-10272 Software Program Manual for Teleperm XS Safety Systems, July 5, 2011. ADAMS Accession Number ML111801119 3
RadICS Final NONPROPRIETARY SE and Transmittal Letter, July 31, 2019. ADAMS Accession Number ML19134A193 4 EPRI Report 3002005385, Severe Nuclear Accidents: Lessons Learned for Instrumentation, Control and Human Factors. December 2015 5 Malmquist, Shem, Nuclear Regulatory Commission Regulatory Information Conference, T7 - Hazard Analysis for Nuclear Automation:
Defeating Digital Demons March 8, 2022 6 Elias, Bart, Cockpit Automation, Flight Systems Complexity, and Aircraft Certification: Background and Issues for Congress October 3, 2019.
R45939 https://crsreports.congress.gov 7 Thomas, John, System Integration Approach to Safety-Security presented at IAEA Technical Meeting on Instrumentation and Control, and Computer Security for Small Modular Reactors and Microreactors, February 24, 2022.
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April 8, 2022 sufficiently addressed the design errors when traditional defense-in-depth and diversity failed to address them effectively.
The use of diversity and modern hazards analysis techniques are not mutually exclusive concepts; rather, these tools are complementary to achieving safe utilization of digital I&C technology. Diversity is an important measure that may be used when implementing digital I&C technology; however, use of diversity should be based on an engineering approach that identifies where diversity is necessary.
Additionally, digital common cause failures should not be viewed without the context of the defense-in-depth posture of the plant. All defense-in-depth elements (i.e., plant systems and procedures) should be accounted for in preventing common cause failure and mitigating its effects.
Risk insights applied during digital I&C system development processes lead to better system function allocation between components, better understanding of the impacts of system architectural decisions, and can inform the use of measures to prevent or mitigate a potential common cause failure based upon risk significance. Utilizing risk-informed practices associates specific SSC with their risk significance. In doing so, design techniques to prevent or mitigate digital common cause failure can be informed by the risk-significance allowing engineering, maintenance, and operation teams to improve decision-making based on potential impacts to the nuclear power plant.
Prescribing the use of diversity as the only solution for addressing potential digital common cause failure unnecessarily impedes the use of todays digital I&C technology that can improve safety in nuclear power plants. This technology is intended to replace obsolete instrumentation and control systems with highly reliable equipment offering improved system functional capabilities (e.g., increased accuracy, no setpoint drift, automation, self-testing and diagnostic capabilities, and data availability to plant staff).
The prescribed use of diversity introduces unnecessary complexity that has introduced significant system complexity as well as cost barriers to replacing the existing systems due to the additional equipment, engineering and maintenance costs associated with implementing diverse systems. By allowing other methods beyond diversity to address common cause failure will enable the deployment of this safer technology at an accelerated pace.
Based on the information described above, NEI members have developed the following recommendations to be considered in the expansion of common cause failure policy. The new, expanded policy should:
- Allow for risk-informed performance-based approaches to ensure applicants focus on the most risk-significant functions and to provide flexibility in meeting established system performance criteria.
- Consider the full plant defense-in-depth strategy to prevent to the degree practicable, mitigate or respond to a digital common cause failure.
- Allow for the use of modern hazards and/or reliability analysis techniques to examine the system for adverse conditions and identify appropriate system requirements to prevent systematic failures.
- Expand the ability to use design techniques (in addition to diversity) to prevent to the degree practicable or mitigate a digital common cause failure in accordance with GDC 22.
The following is an example of an expanded policy based on the considerations detailed above:
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April 8, 2022
- 1. The applicant shall assess the impact of the proposed digital instrumentation and control Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) on the plants defense-in-depth systems and procedures to demonstrate that vulnerabilities to digital common cause failures have been adequately addressed.
- 2. The vendor or applicant shall identify each digital common cause failure that could adversely impact a safety function using risk-insights, and hazards and/or reliability analysis techniques.
- 3. The applicant shall demonstrate commensurate with the risk significance of each identified digital common cause failure adequate measures to address the identified digital common cause failure that could adversely impact a safety function. The measures may include non-safety systems or components if they are of sufficient quality to reliably perform the necessary functions and with a documented basis that the measures are unlikely to be subject to the same common cause failure. The measures may also include monitoring and manual operator action to complete a function.
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