ML20085K171

Forwards Implementation Plan for Emergency Response Data Sys.Plans Call for Incorporation of Sys Into Replacement Main Plant Computer Sys to Be Installed at Third Refueling Outage

ML20085K171
Person / Time
Site:	Seabrook
Issue date:	10/28/1991
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-91173, NUDOCS 9110300184
Download: ML20085K171 (26)

Text

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Nes Hampshire Yhhk(h Ted C. Feigenbaum PacWdent and Chief Enecutive Officer NYN 91173 October 28, 1991 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk Referenceo (a) Facility Operating License No. NI'F 86, Docket No. 50 443 (b) NilY Letter NYN 90012 dated January 12,1990, ' Response to Generic 1, citer 8915

• T. C. Feigenbauen to USNRC (c) Emergency Response Data System Rule [10 CFR 50.72 (a)(4), and 10 CFR 50, Appendix E, Section Vlj (d) NilY Letter NYN 91155 dated September 24, 1990. " Completion of License Condition 2.C.(3), iluman Factors Engineering," T. C.

Feigenbaum to USNRC

Subject:

Emergency Response Data System (ERDS)

Gentlemen:

This letter provides the impleir.cntation plan for the Emergency Response Data System (ERDS) at Seabrook Station pursuant to 10 CFR $0, Appendix II,Section VI.4,a.

Additionally, in accordance with 10 CFR 50.12, this letter requests a schedular exemption from the requirement of 10 CFR 50.72, Appendix E, Section VI, Paragraph 1.d. to complete implementation of the ERDS by February 13, 1993.

Enclosure 1 to this letter provides the plan for implementation of the ERDS at Scabrook Station, This plan calls for incorporation of the ERDS into the replacement hiain Plant Computer System (hiPCS) to be installed at the third refueling outage of Seabrook Station. NilY believes that this it, the most cost effective method of implementing the ERDS at Seabrook Station, incorporating the ERDS into the replacement hiPCS hns been planned since the initial NilY response to Generic Letter 8915. In this response [ Reference (b)] dated January 12 1990, NIIY indicated a willingness to voluntarily participate in the ERDS Project und to implement the ERDS concurrently with replacement of the h1PCS at the third refueling outage of Seabrook Station. This outage is currently scheduled to begin htarch 1994, llowevct, the final ERDS Rule requires the complete implementation of the ERDS by February 13, 1993, t

9110300104 YlIU' I/

PDR ADOCK OTO p' } Q [' "4

' / _ .tompshire Yankee Division of Public Service Company of New Hampshire ,

j EO. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521 1

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United States Nuclear Regulatory Commission New llampshire Yankee Attention: Document Control Desk October 28, 1991 Since it would be impractical to replace the MPCS by 1ebruary 13, 1993, compliance with the rule would require Seabrook Station to implement the EltDS by temporary incans.

A ternporary fillDS would result in ext a er sts and might not 1 c capable of transmitting timely data to the NitC. A temporary tiltDS would depend upon the currently installed MPCS for input data. As reported to the NitC in Reference (d), the currently installed MI'CS is heavily. loaded. A temporary !!!tDS dependent on this MPCS might act be capable of providing timely data to th: NitC during a significant plant travaient and would subsequently require upgrading or replaccinent at extra cost.

To avoid the difficulties described above, NilY requests that it be authorized to-complete implementation of the EltDS at Seabrook Station prior to restart following the third refueling outage of Seabrook Station, but no later than December 1,1994. Enclosuse :' to this letter requests a schedular exemption from the implementation deadline required by the EltDS rule. If granted, this exemption would providc temporary relief to permit

-incorporation of the ERDS into the replacement MPCS.

NilY concludes that the granting of this exemption request is authorized by law, would not present an undue risk to the public health nnd safety and is consistent with the common defense and security. Shoold you have any further questions rc6arding this matter, please contact Mr. Terry L. Ilarpster, Director of Licensing Services, at (603) 474 9521, extension 2765.

Very tr lhurs, Mdf A44w W Ted ' Feigenlag Enclosures TCP:G K/ tad cc: Mr. Thomas T. Martin Regional Administrator United States Nuclear llegulatory Commission '

Region i 475 Allendale Road King of Prurisia, PA 19406 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of Reactor Projects U.S. Nuclear llegulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, Nil OT874 l

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New ilninpshire Yankee October 28, 1991 liNCI.OSUl(I! 1 to NYN 91173 IIhit!ROl!NCY Rl!SPONSli DATA SYSTilhi (IIltDS) th1P!,11hillNTATION Pl. AN Folt Sl!AllitOOK STATION

EMERGENCY RESPONSE DATA SYSTEM (ERDS)

IMPLEMENTATION PIAN I

TABLE OF CONTENTS I. .. ?!!TRODUCTION

13. IMPLEMENTATION SCIIEDULE III. NilY ERDS SPECIFICATION IV. SITE SURVEY QUESTIONNAIRE (NUREG-1394 REV 1 - APPENDIX B) f P

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EMERGENCY RESPONSE DATA SYSTEM (ERDS)

I. INTRODUCTION The NHY ERDS implomontation plan addresses the items described in NUREG-1394 Rev. 1 (section 3.9). Section 3.9 refers to a proposed schedule, the ERDS Transmission /Rocoption Plan Appendix A which further outlines typical schedule milestones and the DPL/ PAL, the site survey quantionnaire and the administration requirements of section 3.6.

The. proposed schedule is included in section II of this plan.

It is based on the current schedule for the new plant computer system. The specification for this now system already includes a specification for the ERDS datalink (see section III) . NHY plans to update this ERDS specification during the conformance specification process in 1992. The point list will bo expanded and it will include the 12 charactor ERDS CSF paramotor names for each point.

The site survey questionnaire can be found in section IV.

The administration requirements of Section 3.6 relate to ERDS activation and configuration contrc'.. Emergency Responso Procedure ER3.1 (TSC Operations) will be modified to include instructions to activate the ERDS datalink within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the declaration of an Alert or higher omorgency classification level. This procedure will be modified just prior to when ERDS is placed on-line. A Software Configuration Management System has boon specified for the now plant computer and will be used to ensure the integrity of ERDS is maintained.

.The Data Point Library represents.a very significant portion of the overall ERDS effort. The completed DPL will be provided as shown on the schedule. A preliminary DPL (or Point List) has boon provided in section III.

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II. IMPLEMENTATION SCllEDULE NIIY - SBl - ERDS IMPLEMENTATION SCllEDLE Ni!Y RETURNf DPL/ PAL (NOTE) ... DECEMBER 299?

VENDOR DEVELOPS ERDS SOFTWARE ... APRIL 1993 FRELIM.-TRANSMISSION TESTINO ... JUNE 1993 AT FACTORY NRC - 1HSTALL.PilONE LINE AT SB1 ... FEBRUARY 1994 FINAL SOFTWARE TEST ... MARCll 1994 SITE ACCEPTANCE TEST 0 NRC ... APRIL 1994 NifY ERDS ON-LINE ... MAY 1994 NOTE: The planned plant computer database build sequence is ostimated to start in 1992 and tako approximately 8 months to completo. The completed ERDS DPL would be ready towards the end'of this.coquence as shown below:

Auto Transfer of Initial Database to now IIost complete point records (all ficids) for all I/O points '

Defino all NSSS/ BOP calculation points Define Validated Data Points for SPDS Define all' Composed Analog-Points -

Defino' Validated Data Points-for ERDS'and complete DPL Define all Boolean Digital Points

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III. NHY ERDS SPECIFICATION l

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F 39 s.x.t.E 002$ Rev. O F.9 NUCLEAR REGULATORY CONNIS$10N ENERGENCY RESPONSE DATA SYSTEM DATALINK F.9.1 Purpose  :

The purpose nf the ERDS datalink is to electronically transmit information during an emergency directly to the NRC as decalled in NRC Ceneric Letter 99 15 and NL* REC.)i94 Accurate, timely data is required on the following four types of parosacers; o Core and coolant system data o Containment building data o Radioactivity release rates o _ Meteorological data This information is intended to help the NRC keep federal agencies and the media informed of the status of an incident. provide support services while ,

plant operators are implementing emergency operating procedures, and assist trich technical analysis and logistics for protective action recommandations lade to 4 offsite authoritise. The purchaser has conmipted to voluntary compliance and par-icipation in ERDS.  ;

F.9.2 Data Types And Quantities The initial nueuer of date points shall be 70: the maximum number shall be 150.

F.9.2.1 The following specific plant parameters have been identified by the NRC for ERDS transmissiotu

- PRIMARY Pressure COOLANT Temperatures hot leg SYSTEM Temperatures cold leg Temperatures core exit theraocouples Subcooling margin Pressurizer level RCS charging / makeup flow Reactor vessel level (when avellable)

Reactor coolant flow Reactor power SECONDARY Steam generator levels COOLANT Steam generator pressures SYSTEM Main feedwater flows Auxiliary /eaergnacy feedwater flows SAFETY High pressure safety injection flows INJECTION Low pressure safety injection flows Safety injection flows Sorated water storage tank level V ..

F 40 s.x.t.E 0025 Rev )

CCNTAINMENT Containment pressure Containment temperatures Hydrogen concentration Contairment sump levels RADIATION Reactor coolant radioactivity MC.4ITCRING Centairaent radiation level SYSTEM Condenser air removal radiation level Effluent radiation monitors Process radiation monitor levels METECROLOGICAL Vind rpeed Wind direction Atmospheric stability F.9.2.2 The following data points will be used to satisfy ERDS requirements:

Point Point '

A h,c rio tion , h

• • • • • • • • FRIMARY COOL. ANT SYSTEM ********************************

A10l2 PR CHAN 1 PVR PC A0339 RCLPl VIDE RNC HOT LEC TEMP F A0340 RCLP2 WIDE RNC HOT LEG TEMP F A0341 RCLP) WIDE RNG HOT LEG TEMP F A0342 RCLP4 WIDE RNG HOT LEG TEMP F A0363 kCLP1 WIEE RNC COLD LEG TEMP F A0344 RCLP2 VIDE RSC COLD LEG TEMP F A0345 RCLP3 WIDE RNG COLD LEG TEMP F A0346 RCLP4 WIDE RNG COLD LEC TEMP F A0349 RCLPl VIDC RNG HOT LEG PRESS PSIG A0350 RCLP4 WIDE RNG HOT LEG PRESS PSIG C0709 AUCTIONRD HI CAMMAMETRICS PWR LVL PC C0710 AUCTIONRD HI START UP RATE C0718 AUCTIONRD 14 HOT LEG TEMPERATURE F C0719 AUCTIONRD LO COLS LEG TEMPERATURE F C0729 AVERAGE PRESSURIZER LEVEL 1 00731 AUCTIONRD HI THERMOCOUPLE TEMP F C0732 AUCTIONRD LO SUBC00 LING MARCIN F

• • • • • • • • SECONDARY COOLANT SYSTEM ******************************

A0737 50 A UNCOMPENSATED WR LEVEL 1 A0747 SC 8 UNCOMPENSATED VR LEVEL  %

A0757 SG C UNCOMPENSATED VR LEVEL  %

A0727 SG D UNCOMPENSATED VR LEVEL 1 A0778 SG E 11A STM OUTL PRESS PSIG A0779 SG E 118 STM OUTL PRESS PSIG A0780 SC E 11C STM OUTL PRESS PSIG A. _ _ _ _ . _ _ ___ _ - _ _ _ _ _ _ -_____ _ -

L F ' 41 S X 1.E 0025 Rev. O A0781 SC E 110 STM OUTL PRESS PSIC A0793 TV P 32A SUCT HDR FLOW CPM A0794 FW.P 32S SUCT HDR FLOW CPM C0722 TOTAL EFW FLOW HE51/$POS CPM Later 50 A AVC NRLVL t 1.a t e r SC 8 AVC NRLVL t Later 50 C AVC NRLVL t Later SC D AVC NRLVL t Later SC A AVG PRES PSIC Later 50 8 AVC PRES PSIC L4ter SG C AVC PRES PSIC Later SC D AVC PRE'J PSIC C0723 AUCTIONRD HI SG PRESSURE FS!C C0724 AUCT10NRD HI-SC LEVEL 1 C0725 AUCTIONRD Lo SC LEVEL 1

• =****** S A F E 7Y I NJ ECT IO N * * * * * * * * * ** * * *** * * * * * * * * * * * * * * * * * * *- e *

• A0510 8 INJ TK.6 CHC HDR FIDW CPM A0622 CHG FMP DISCH HDR FLOW CPM A060e CHC PMP DISCH HDR PRESS P$10 A0950 RH E.9A DISCH FLOW CPM A0952 RH E.98 DISCH FLOW CPM A0511 SI P 6A DISCH PRESS PSIC A0512 St.P.6A DISCH FLOW CPM A0513 St.P 68 DISCH PRESS PSIC A0514 SI P 68 DISCH FLOW CPM A0923 CSS P.9A DISCH PRESS PSIC A0925 CBS P 98 DISCH PRESS PSIC i A0921 RWST TX 8 LVL. KCAL A0920 SPRAY ADD TX.13 LVL CAL 4 C0727- AVC CONTAINKEt'T SLDC LEVEL FT C0804 $1 SICNAL RECEIVED N/A C0806 CONTM RECIRC SWAPOVER INITIATED . N/A l

C0807 RRR PUKf5 ON N/A C0808 RHR VALVES OPEN N/A C0809 RECIRCULATION FLOW CPM l o

• • • • • • • • CuNTAINNENT *******************************************

ll A0930L CONTN SUMP TX.10A OVFL LVL FT h A0931 CONTN SUMP TK.108 OVFL LVL Fr C0726 AVC CONTAINMENT PRESSURE PSIC C0 7 2 !, ' AUCTIONRD HI POST ACCIDENT MONITOR R/HR L C0764- CONTAINNENT AVC AIR TEMP DEC F C0819 AUCTIONPD HI NYDROCCN CONCENTRATION I I

L l ******** RAD I ATION MONITOR ING SYST EM *************** * * * ** ** * * * *

• L 1AM106 CA CnNTM POST LOCA TRN A R/HR l 1AN107 CA CONTM POST LOCA IRN 8 R/HR l- 1N0222 CA PLANT VENT LO RANCE CAS UC!/CC INO223 CA PLANT VENT MID RANCE CAS UCI/CC 1N0224 CA PLANT VENT HI RANCE CAS UCI/CC 1

4 F . 42 S.X 1.E.002$ Rev. ?

1CC225 CA PLANT VENT DISCH RATE . UCI/SEC 1CMact CA MAIN STEAM LINE LOOP ell MR/HR 1CM802 CA MAIN STEAM LINE LOOP d4 MR/HR 1CM80) CA KAIN STEAM LINE LOOP (/2 KR/KR

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1CM806 CA MAIN STEAM LINE LOOP //3 MR/HR INC21! CA PLANT VENT LO RANCE CAS KR/HR 1NC218 CA P! WIT VENT HI RANCE CAS MR/HR INC222SF SF PLANT VENT L0 RANCE CAS SCFM

• • • • • • • • METEOROLOG I CAL D AT A * * ** * * * * ** ** * * * * * * * ** * * * * * * * * * * * * *

• C0783 LOWER WIND SPEED MPH C0784 UPPER VIND S12ED MPH C078$ LOWER VIND DIRECTION 0f0 C0786 UPPER VIND DIRECTION DFC LATER AIR STA31L17Y CLASS ...

F 9.3 Transmission Frequency Data transmission will be manually initiated if the plant is placed on Alert or higher status. Data shall initially be transmitted every 15 seconds,

=however the capability shall exist to modify the transmission frequency over the range of 15 -to 60 seconds via CRT display interaction.

F.9.4 Interface Hardware The ERDS system requires a coamunication port, a dialup line (funded by tFA NRC). and a modem. Thai CPU at the NRC end is expected to be a DEC MICROVAX 3600 = The following hardwcre will be supplied by the NRC for use by the MPCS:

all other hardwara shall be provided by the MPCS supplier, o Codex 2234 moden -

V.22 2400 bps, asynchronous, autodtalins, auto.

answer. error correcting. using the AT command set, F.9.5 Interface Protocol ERDS illi use XON/XOFF to stop, resume, or suspend data transmission f rom the sitei Communication parameters are:

o Eight data bits

t. o One stop bit

! 'o Parity a none '

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L l-F.9.6 Nessage Structure F.9.4.1 Transmission Steps '

4. . Site-shall'une autodial capability to initiate a link request in ASCII using:

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'A ,, ,,. -,y ,w-- ,--.wnm-m +v --,, , . . --vw -,,w ~- w = , e

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F . 43 s.x 1.E.002$ Rev. O o Three character site designator (581) o Se vord LINK o

.x 2 ' site date and cirne in the format MM/DD/VY/hh:aus: ss o a < Cit >

b. .DS will respond in ASCII with; o Three character site designator (SBL) 1 o The.' word ACCEPTED or DEN!ED o a <CR) ]i c,

• . ten the ERDS is ready to receive data, it will send an initiate cessale in ASCII using: '

o Three character site designator (581) ,

o - The word TNITIATE o a (CR>

' d, Upon receipt of the initiate message. -the MPCS shall begin transmission of data at a (for example) 15 second race. The d6ta string shall consist

-of:

o Header that contains the three character site desi5nator (551). and  !

date and time in. the forma MM/DD/YY/hh:sse: sr o Data packet sequenced with point identifier, value. and quality tag o Trailer containing the checksum value of the data packet and a <CR> .

- ei '*

. hen the site or ERDS wishes . to terminate the connection, an ASCII sessage shall be sent, The message shall:contain:

o' Three character site designator (581) o The word TERMINATE o a <CR>

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. f. If a site is inadvertently terminated, (due to loss or communications

or receipt of corninate_ message), and' che incident is still underway.

the site shall reconnect . vich the. EADS by radialing and using . the -

following request message in ASCII:

o 3ree. character site designator ($81) -

o The word RECONNECT .

o The local site time and date in the format MH/DD/W/hh:mm:ss <

o a <CR>

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F 44 S.X 1 E.0025 Rev 0 F.9.6.2 Data Format F.9.6.2.1 Delimiters 1

The folloving dolimiters have been defined: j l

o Field delimiter (*)

o Dataset delimiter (\) l o Carriage return (<CR>)

F.9.6.2.2 Datastream Values-

a. The link request shall be in ASCII as described above with each field separated by a fin'..d delimiter and the request terminated with a dataset delimiter.

Example: 581* LINK +01/12/89/11:48: 50\<CR>

b. The ERDS response will be in ASCII as described above with each field separated by a field delimiter and the response terminated with a dataset

• delimiter.

Example: S81* ACCEPTED \<CR)

c. '*

. hen .the ERDS is ready to receive data, it vill respond in ASCII as described above with each field separated by a field delimiter and :he response scryinated with a dataset delimiter.

Example: 581* INITIATE \<CR)

d. The datastream shall be in ASCII and shall consist of three parts, i.e.

header, data, and trailer, as described above with each field separated by a field delimiter and each of the three parts separated by a dataset delimiter.

Example: Header . 581*01/12/89/11:50:30\

Data - 821CP004* 0.1234+00*3* .. '

(for each parameter)\

Trailer (checksum value) 0000056000\<CR> <

e. The point identifier may be up to 12 characters in_ length, f, The value may be up to 20 characters in length,

g. The following quality tags shall_ be generated by the MPCS:

b

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9 -- - +- . -,yy&e.--.y- .-g 4.+ y9 eg

i T . 45 s.X 1.E.0025 Rev. 0 N INDICATOR DESCRIPTION coed 0 Value is within range for discrete points, or input points are within range for composed points.

Off scan 1 Point is currently out of. service, 3 Suspect 2 Value is not bad, yet should not be considered good. This quality will occur primarily on et;mposed values, when there are enough good inputs  ;

to make the calculation, but, a bad quality on i other inputs may make the resule questionable.

Bad 3 Value is not within tolerance for discrete points. -

or calculation of a composed point may not be mads due to the qualities of its inputs, l'nknown 4 'lo quality indicator available.

Operator S Value has been manually entered, cverridin5 ':h*

Entered discreto or composed.value.

High Alarm 6 Value is in high alarm.

I.ow Alarm 7 Value is in low alarm, t

h. The checksum which accompanies each update set shall be an integer value calculated by summing each of the bytes of the transmission, up to (and .

including) the dataset delimiter that follows the body of the update set.

- The body of the update set is the portion containing the parameter, value, and quality -indications; the trailer portion contains the checksua. This integer checksun value shall then be encoded into the

• update set as a ten. digit value, lef t. padded with zeros as required to fill the ten. digit field. The calculatton of the checksua shall be independent of the format of the transmission (ASCII / EBCDIC); ic is simply the sum of the transmitted bytes.

F.9.7~ Link Failure Detection The MPCS shall be able to detect the failure of the link to the NRC; i f.nk failure. thall generate a system event message.

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IV. SITE SURVEY QUESTIONNAIRE '

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6 APPENDIX B ERDS COMMUNICATIONS DESCRIPTION AND SURVEY QUESTIONNAIRE L

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1. Contacts Note: Please proside name, title, mailing address, ar i phone ntimber.

A. Survey Coordinator (l.c., contact for .ater clarification of questionnaire answer;).

Mich..el l'esaresi Senior 1:ngineer New Ilam;ishire Yankee l'.0. 11ox 300 Seabrook Nil 03874 1-603-474-9574 x4422 B. Computer 1lardware Specialist (s):

(l.a t e r)

C, Systems Software Specialist (s):

(La t e r)

D. Application level Software Specialist (s):

(Later)

E. Telephone Systems Specialist (s):

(Later) i l

NUltl:0-1394, llev.1 11 - 2 l

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III. Selection Of Data Feeders A. How many data feeders are there (six rnaimum)?

One - Main Plant Computer System (MPCS)

B. Identify the selected data feeders and provide the following for each:

(1) a short description of the categories of data points it will provide (e.g., met, rad. or plant data points, by unit) and (2) the rationale for selecting it if ancther system can also provide its ca:rgories of data points.

The MPCS will supply all of the requested data (e.g. met. rad, plant data).

The MPCS is the main repository for the data requested. Radiation data is transmitted to the MPCS every 30 seconds. A Westinghouse RVLIS system sends data to the MPCS approximately every five seconda.

C, Which data feeder is the site time determining feeder? This should be the feeder which is providing the majority of the data points.

The MPCS will be the site time determining feeder for the ERDS data.

l B-7 NUREG-1394. Rev.1 C _ _ __

4-IV. Data Feeder Information Note: A new Section IV must be filled out for each feeder system selected.

General Questions

1. Identification of Data Feeder

a. What is the name in local parlance given to this data feeder (e.g., Emergency Response Information System)? Please give both the acronym and the words forming it.

MPCS - Main Plant Computer System

b. Is this the site time determinir.g feed."

Yes

c. How often will this feeder transmit an update set to the ERDS (in seconds)?

Once every 15 seconds

2. Ilardware/ Software Environment

a. Identify the manufacturer and model number of the data feeder hardware.

TBD

b. Identify the operating system.

TBD c, What method of timekeeping is implemented on this iceder system (Daylight Savings, Standard, Greenwich)?

TBD i

i d. In what time zone is this feeder located?

TBD NUREG-1394. Rev.1 B-8 L

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3. Data Communication Details

a. Can this data feeder provide asynchronous serial data communication (RS-232 C) with full modem control?

Yes

b. Will this feeder transmit in ASCI! ct EBCDIC?

ASCII

c. Can this feedei transmit at a serial baud rate of 2400 bps? If not, at what baud rate can it transmit?

Yes

d. Does the operating system support XON/XOFF flow control?

Yes i 1, Are any problems foreseen with the NRC using XON/XOFF to control the trans.

mission of data?

No

e. If it is not feasible to reconfigure a serial port for the ERDS linkup (i.e.. change the baud rate, parity, etc.), please explain why. .

f. Do any ports currently exist for the ERDS linkup?

Yes

1. If not,is it possible to add additional ports?

i B-9 NURSG-1394. Rev.1 A . - - . .. - - - - - - -..

2, if yes. will the port be used solely by the ERDS or shared with other non-emergency time users? Give details.

The port will be used solely by tho I:RDS.

4. Data feeder Physkal Entironment and Matagement

a. Where is the data feeder located in terms of the TSC. EOF. and control room?

In the computer room (Control Ituilding,- 1: lev. 75'). which fu adjacent to the control room and the TSC. The 1:0F Jn located in Newington, N.ll, approximately 15 miles-from the site,

b. Is the data feeder protected from loss of supply of electricity?

Yen, it is supplied f rom an TIPS ut it .

c. Is there a human operator for this data feeder?

l Yes.

1. If so how many hours a day is the feeder attended?

One 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> shifI per day. Monday throu;;h Friday by computer personnel. The ERDS datalink can be activated by non-computer pornonnel during; of f-hours.

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NUREG-1394. Rev. I 11-10

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New lintupshire Yanker -

October 28, 1991 i

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TJr'(.,QSJt)UW 7 to NYN 911'7,3, Ill!OUEST FOlt A SClil!DUI Alt I!XEMPTION FltOM-TIIU ltEQUlitEMENTS OF

.10 CFil 50, APPENDIX :1, SECTION VI.4al.

• EMEltGENCY lt!!SPONSE DATA SYSTEM" Folt SEAni(OOK STATION

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.1 ENCL.USUR E 2 to NYN.9117),

i This Enclosure provides information in support of a request for a schedular exemption -

pursuant ' to 10 CFR 50.12, " Specific- Exemptions," from . a requirement of 10 CFR 50, _

l J Appendix E,Section VI for Seabrook Station. Specifically, an exemption is requested from  ;

the requirement of 10 CFR 50, Appendix E.Section VI.4.d. that implamentation of the i Emtrgency Response Data System (ERDS) be complete by February 13, 1993. NHY requesta that it be authorized to complete implenientation of the ERDF at Seabrook Station prior to restart following the'(Fird refueling outage of Seabrook Station, but no later than Deceraber 1,1994 This schedular exemption would permit implementation of the ERDS concurrently with replacement of the Main' Plant Computer System (MPCS). The purpose of _this schedu!ar exemption request is permit the- implementation- of a cost effective ERDO at Seabrook Station on a schedule compatible with that of the MPCS replacement project. l l

Justification of this schedular exemption request is based upon an evaluation of the merits )

and circumstances of the request against the individua! criteria of 10 CFR 50.12 as discussed - )

below i

10 CFR 50.'t2 (a) Criteria: l The Commission may grant exemptians from the require.nents of the regulations in 10 CFR -Part 50. . Such exemptions must be authorized by law, must not present an undue risk to the public hea'th and safety, and must be consistent with the common i

defcase and security.

Evaluation:

1. The requested exemption a-C the activities which would be permitted under it are authorized by law. Pi.hlir wice Company of New Hampshire (PSNH),

actin;; for itself and as ager.t and representative of eleven other utilities, is currently authorized to operate Scabrook Station puisuant to License No. NPF-86, which was issued in accordance with the Atomic Energy Act as amended.

New Hampshire Yankee (NHY) is _the Division of PSNH responsible for the operation of Seabrook Station. If the requested exemption is granted, no other prohibition of law would exist in this regard to preclude licensed activitics-

2. The re pested exemotion will not present an undue risk to the public health, and st i ty, Delaying implementation of the ERDS at Seabrook Station for the requested period beyond the deadline date specified by the rule would have a negligible impact the public health and safety. The responsibility for protection of public health and safety in ti e event of an accident at Seabrook ,

Station rests with PSNH,- the licensee. _ Implementation of the ERDS neither

.:hanges this responsibility nor affects- PSNH's ability to carry it out.- The primary purpose of the ERDS is to enhance the ability of the NRC to monitor the PSNH (NIIY) actions carried out in the event of an emergency at Seabrook Statien.

During the period covered by the requested schedular exemption, these is a low probability of an emergency occurring er Seabrook Station of the type for which the rule would require, activation of the ERDS. In neeparation for such 1

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an emergency, NilY has implemented procedures for transfer of information to the NRC. These procedures were de.cloped by experts in emergency pieparedncas, demonstrated to be effective in drills and graded exercises since 1HUI and have been judged by the NRC to be neceptable. The El'.DS will supplement, but not replace, the existing vol:e transmission of information over the Emcipency Notification System (l!NS) in the event of an emergency,

3. The requested excmption will not impact the common defense and t.ccurity.

.HL2R_3 Pal f ni (?) Sruk Shntstantrh:

(1) Appilcation of the regula'bm in the pa, *

,. circumstanccs cor+Ilicts with other retles or requirements o. ino Commisamn.

Evaluatinn: NilY hus not identified a conflict between the requirements of the EltDS P.alc and any other rule or regulation.

(11) Application of the regulation in the particular circumstunees would not serve the undeilying purpose of the rule or is t;t necessary to achieve the underlying purpose of the rule.

Evaluallunt The Commission has stated that the objective of the final rule is to ensure timely and effective implementation of the ERDS. The purpose of the !!RDS is to provide the NRC with timely and accurate values of a limited set of parameters that describe selected pinnt conditions. A temporary ERDS at Scabrook Station will obtain data from the currently istulled, heavily-loaded MPCS. It is highly probable that, during significant plant transients, the MPCS will miss data scans. The councque af missed data scans is that the temporary HRl" may transmit untimely unia to the WitC. Thus, a temporary ERDS at Scabrook Station may not serve an nnderlying purpose of t h,: rule: to iraut.mit timely data to-the NRC.

The rcplacement MPCS vill incorporate a greatly incrensed capability over that of the existing MPCS to supply calculated and'other conditioned data loi the ERDS and will be capable of meeting the time interval requirements of the rule. Tnus, the replacement MPCS will incorporate an ERDS which in capable of meeting the underlying purpoac of the _ rule.

(111) Compliance would result in undue hardship or other costs that are significantly in execss of those contemplated when the regulation was adopted, or that are s

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significantly in exct if those incurred by others similarly situated.

Evaluatinn: NilY plans to incorporate the ERDS into the upgraded MPCS planned for the third refuc)ing outage of Seabrook Station. A temporary ERDS, would requite the purchase of a dedicated personal computer (PC) and development of data feed software to interface the PC with the existing MPCS and the computers at the NRC. Training and procedurcr. would also be seguired. Later, when the MPCS is replaced, new data feed software as well as revised procedures and additional training would be required. Even considering the no cost software which the NRC has committed to supply for 2

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interface between the PC and the NRC computers, the additional cost of implementing the temporary ERDS at Seabrook Station to meet the schedule of the rule may be as high as $50,000.

As detailed in the implementation plan forwarded as Enclosure 1 te this letter, the sequence to develop the data bue for the replacement MPCS is scheduled to start in 1992. Development of the ERDS Data Point Library (DPL) is scheduled to be completed towa'rds the end of P ? -ight month sequence, in order to meet the February 1993 deadline of the rule, the data base development sequence for the MPCS would be impacted by the redirection of resources to develop a DPL for the temporary ERDS. Significant revisions would be required to the DPL and other software to later ine'rporate the ERDS into the replacement MPCS.

While NHY. does not consider the costs _ and duplicative effont, mentioned above to represent undue hardships, it is nevertheless in the public interest to operate as effici ntly as possible, consistent with safety. Therefore, through this exemption request, NHY seeks the schedular flexibility to implement a cost effective ERDS at Scabrook Station on a schedulu compatlie with that of the MPCS replacement project.

(iv) The exemption would result in benefit to the public health' and safety that compensates for any decrease in safety that may result from the grant of the exemption.

Evaluation: There is a negligible decrease in safety associated with granting NHY the requested exemption. The rationale for this conclusion was presented in the evaluation of item No, 2 under 10 CPR 50.12 (a) Criteria (above).

There is- negligible benefit to the public health and safety resulting from granting the exemption. The exemption would allow relief from the rule at Seabrook Station to permit implementation o' a cost effective ERDS on a schedule compatible with that of replacing the MPCS. The exemption would -

serve the public interest primarily by avoiding the extra costs associated wl.th implementing a' temporary ERDS for the sole purpose of meeting the deadline date. of the rule and then upgrading or replacing it at the time of- MPCS replacement.

(v) The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation.

I Evaluation: The exemption would - provide temporary relief from the-

' implementation completion date of February 13, 1993. The exemption would permit NHY to incorporate the ERDS, as planned, into the replacement MPCS to be installed prior to startup following the third refueling outage of Seabrook Station. Thb. cutage is currently scheduled -to begin in March 1994. It would not be practical to accelerate the schedule for MPCS replacement.

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l With regard to good faith efforts to implement the rule, NIIY, in a January 1990 response to Generic Letter 89-15, indicated a willingness to voluntarily 3

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participate in the ERDS Project. Prior to this response, NIIY had established plans to replace the MPCS at Seabrook Station during the third refueling outage. Accordingly, the response to Generic Letter 8915 clearly stated the NilY intentlen to include the capability to support ERDS hardware and software requirements as part of the planned MPCS upgrade.

As the NRC was developing the ERDS Ruin. NilY was continuing to plan for replacing the MPCS at the third refueling outage of Scabrook Station.

Documented plans include the capability to support the ERDS as a requirement to be met by the replacement MPCS. Thus, it is well documented that NilY intended and was planning, well prict to effective date of the rule, to incorporate ERDS into the MPCS replacement at the third refueling outage of Se brook Station.

(vi) There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption.

Evaluatinn: NilY has not identified any other material circumstance pertinent to this exemption request.

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