UNITED STATES

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

February 25, 2016 

MEMORANDUM TO: Victor M. McCree 

 Executive Director for Operations 

FROM: Annette L. Vietti-Cook, Secretary /RA/ 

SUBJECT: STAFF REQUIREMENTS – SECY-15-0106 – PROPOSED RULE: 

INCORPORATION BY REFERENCE OF INSTITUTE OF 

ELECTRICAL AND ELECTRONICS ENGINEERS STANDARD 

603-2009, “IEEE STANDARD CRITERIA FOR SAFETY 

SYSTEMS FOR NUCLEAR POWER GENERATING STATIONS” 

(RIN 3150-AI98) 

The Commission has disapproved staff's recommendation to publish for comment in the Federal 

Register the proposed rule: Incorporation by Reference of Institute of Electrical and Electronics 

Engineers Standard 603-2009, “IEEE Standard Criteria for Safety Systems for Nuclear Power 

Generating Stations,” at this time. 

The staff should develop an integrated strategy to modernize the NRC's digital instrumentation 

and control (l&C) regulatory infrastructure. The staff should provide the plan, with proposed 

implementation milestones, to the Commission within 90 days from the date of this SRM. In 

developing a draft plan, the staff should engage in public workshops and meetings with the 

relevant IEEE standards setting committee, digital I&C vendors, licensees, and any other 

external stakeholders to reach a common understanding of the digital I&C regulatory 

challenges, priorities, and potential solutions to address them. After developing the plan, the 

staff should continue to provide for meaningful participation by stakeholders. Along with the 

plan, the staff should present any policy issues that are ripe for Commission consideration, 

enabling the Commission to address these issues before rulemaking proceeds, especially 

where there is significant disagreement on the optimal approach. 

The staff’s plan should consider the broader context of digital l&C regulatory challenges and 

include all related activities being pursued by the staff, including incorporation of IEEE Std. 603-

2009 into 10 CFR 50.55a, updates to the policy on common-cause failure in SRM- SECY-93-

087, and development of guidance for 10 CFR 50.59 evaluations of digital l&C upgrades. 

 

The staff’s plan should be guided by the following high level principles: 

The staff's plan should include the establishment of a senior management steering committee to 

oversee resolution of digital l&C regulatory challenges. 

Any new or revised requirements addressed in the action plan should be performance-based 

rather than prescriptive.
Digital l&C safety requirements should be technology neutral, however, guidance should be 

tailored if necessary. In addition, the same requirements should apply to operating and new 

reactors. 

Guidance should focus on acceptable approaches to complying with requirements and may 

include specific technology-focused provisions. If only one approach is acceptable to the staff 

to ensure safety based on current understanding, and this approach is appropriately technologyneutral and performance-based, then it should be included in a requirement rather than in 

guidance. 

NRC requirements and guidance should not pose an unnecessary impediment to advancement 

in nuclear applications of digital technology. 

cc: Chairman Burns 

 Commissioner Svinicki 

 Commissioner Ostendorff 

 Commissioner Baran 

 OGC 

 CFO 

 OCA 

 OPA 

ODs, RAs, ACRS, ASLBP (via E-Mail)