ML20155C692

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Audit Rept for Audit Conducted on 981006-09 on Implementation of GL 98-01, Year 2000 Readiness of Computer Sys at Npps
ML20155C692
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 10/27/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20155C680 List:
References
GL-98-01, GL-98-1, NUDOCS 9811020318
Download: ML20155C692 (17)


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i U.S. NUCLEAR REGULATORY COMMISSION t

1 OFFICE OF NUCLEAR REACTOR REGULATION (NRR)

AUDIT REPORT l

ON IMPLEMENTATION OF GENERIC LETTER (GL)18-01

" YEAR 2000 READINESS OF COMPUTER SYSTEMS AT NUCLEAR POWER PLANTS" Docket Nos:

50-325,50 324 License No:

DPR-71, DPR 62 Licensee:

Carolina Power & Light Company (CP&L)

Facility:

Brunswick Steam Electric Plant Units 1 & 2 Location:

Highway 87 N Southport, NC 28461 Dat es:

October 6 9,1998 Audit Team Members:

Matthew Chiramal, NRR Caswell Smith, DRS, Region 11 Michael Waterman, NRR Approved by:

Jared Wermiel, Chief Instrumentation and Controls Branch Office of Nuclear Reactor Regulation i

i 9811020318 981027 Enclosure PDR ADOCK 05000324 G

PDR

EXECUTIVE

SUMMARY

From October 6 through 9,1998, the NRC staff conducted an audit of the Year 2000 (Y2K) readiness program at the Brunswick Steam Electric Plant, Units 1 & 2, (Brunswick)in accordance with the audit plan (Attachmant 1) for this activity. The purpose of the audit was to (1) assess the effectiveness of the Car'; lina Power and Light Company (CP&L) (the licensee) programs for achieving Y2K readiness, including continued safe operation of the plant as well

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as compliance with applicable NRC regulations and license conditions with respect to the,

l potential Y2K problems, (2) evaluate Y2K program implementation to assure that the licensee's schedule is in accordance with NRC Generic Letter (GL) 98-01 guidelines for achieving Y2K readiness by July 1999, and (3) assess the licensee's contingency plans fo: addressing risks associated with potential events resulting from Y2K problems. The audit team reviewed i

selected licensee documentation regarding the Brunswick Y2K readiness program and I

conducted interviews with the cognizant licensee personnel. The results of this audit and subsequent audits at other selected plants will be used by the staff to determine the need for additional action, if any, on Y2K readiness for nuclear power plants.

Based on the staff's assessment and evaluation of the Brunswick Y2K readiness program, the following observations were made:

1.

CP&L has a common Y2K project implementation plan which establishes the scope and control of the Nuclear Generation Group (NGG) Year 2000 Readiness Program at CP&L's three nuclear power stations (Brunswick, Robinson, and Shearon Harris) and two engineering divisions. The plant-specific NGG Year 2000 Readiness Program Project Implementation Plan for the Brunswick Nuclear Plant is comprehensive and incorporates the major elements of the nuclear power industry Y2K problem guidance contained in Nuclear Energy Institute (NEI)/ Nuclear Utilities Software Management Group (NUSMG) 97-07, " Nuclear Utility Year 2000 Readiness."

2.

The Brunswick Y2K readiness program is receiving appropriate management support and oversight.

3.

The licensee began the formal Brunswick Y2K readiness program in September 1997, developed the plant inventory by December 1997, completed the initial assessment phase in March 1998, and is scheduled to complete the detailed assessment phase in December 1998. The licensee has established a tightly controlled schedule in order to meet the June 1999 Y2K readiness date established by the program. (The one exception in meeting the readiness schedule is the installation and integrated system testing of the modified, Y2K compliant digital feedwater control system application in Brunswick Unit 1. The licensee plans to take a forced outage on Unit 1 sometime in the Fall of 1999 to accomplish this activity.) The Y2K readiness schedule appears to be achievable because of the dedicated effort at this site, the fact that the licensee has already begun modification of major critical computer systems, and the licensee has received support via information sharing with the Boiling Water Reactor Owners Group, EPRI and CDSV, the utility alliance with Duke Energy, South Carolina Electric & Gas, and Virginia Power.

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The licensee has started the Brunswick Y2K contingency planning. The licensee is using the nuclear industry guidance in NEl/NUSMG 98-07, Nuclear Utility Year 2000 Readiness Contingency Planning," for this effort and is in the process of integrating l

contingency planning in the next revision of the Brunswick Year 2000 Readiness Project implementation Plan. With proper integration of this effort in the project implementation

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plan and schedule, the licensee should be able to complete this effort by July 1999 with l

the exception of some required testing.

i 5.

The licensee is accepting vendor certifications for embedded components including l

those in high priority mission critical systems without conducting additional confirmatory testing at the plant site. This approach is based upon the licensee's reliance on and ccnfidence in its established vendor qualification program and resulting approved vendor / supplier list. The audit team acknowledged that the decision on whether to perform additional embedded component susceptibility testing is based on the licensee's determination of the importance of the affected system and knowledge of the item, prior i

experience with the vendor, and other relevant infonr,9 tion obtained.

6.

The audit team identified an area of inconsistency in tre implementation of Y2K l

susceptibility testing in reviewing some of the testing that has been completed, the audit team found (in high priority applications) that different licensee business units use a variation of the test guidance.

The audit team concludes that the NGG Y2K testing effort would benefit from additional communication between business units or additional training to ensure consistent application of the test procedure guidelines. The licensee stated that aggressive actions to address this issue at the NGG level have been initiated.

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REPORT DETAILS

1.0 INTRODUCTION

The objectives of the Brunswick Units 1 and 2 plant-specific CP&L NGG Y2K Reediness Program audit were to:

1.

Assess the effectiveness of the CP&L (the licensee) program for achieving Y2K readiness including continued safe operation of the plant as well as compliance with applicable NRC regulations and license conditions with respect to the potential Y2K

problems, 2.

Evaluate Y2K program implementation to assure that the licensee's schedule is in accordance with NRC Generic Letter (GL) 98-01 guidelines for achieving Y2K readiness by July 1999, and, 3.

Assess the licensee's contingency plans for addressing risks associated with potential events resulting from Y2K problems.

The audit was conducted in accordance with the established audit plan outline (Attachment 1) which was based in part on the guidance and requirements contained in the following documents:

1 GL 98-01, " Year 2000 Readiness of Computer Systems at Nuclear Power Plants" e

Licensee Response (s) to GL 98-01 e

Plant technical specifications and license terms and conditions e

Applicable NRC regulations e

NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness" e

NEl/NUSMG 98-07," Nuclear Utility Year 2000 Readiness Contingency Planning" e

Prior to the audit at the plant site, the audit team obtained and reviewed the CP&L Year 2000 Program implementation Plan (Document Number 3 listed in Attachment 2).

The audit process started with an entrance meeting attended by the CP&L NGG Year 2000 Project Manager (PM), the Brunswick Nuclear Plant site Y2K Coordinator and other site personnel, and members of the audit team. Attachment 3 is a list of the attendees. The PM and members of the project team described the project organization, the project plan and its implementation, and the project status and ongoing activities.

l-l l Following the meeting, the audit team spent the rest of the audit reviewing the project plan and its associated procedures, the plan implementation products (documents and data bases) and interacting with the project manager and project team members. The documents reviewed are i

listed in Attachment 2.

2.0 BRUNSWICK Y2K PROJECT DESCRIPTION 1

2.1 Project Oroanization I

The Brunswick Steam Electric Plant (BSEP) Site Coordinator for Y2K readiness is Gil Manacsa.

Mr. Manacsa reports to Eric Northeim, who is the project manager (PM) for the CP&L NGG Year 2000 Readiness Project, of which BSEP is one'of three CP&L plant sites that use the l

NGG project implementation plan. The BSEP Y2K readiness project site sponsor is Bo Lindgren. The BSEP Y2K readiness project has 12-15 full-time equivalent persons, divided among approximately 20 staff. The PM has overall responsibility for the project and reports to the Manager of the CP&L Nuclear IT Group, who reports in tum to Tom Walt (Project Sponsor),

L Department Manger for Operations and Environmental Support Department. Tom Walt reports to Scotty Hinnant, Chief Nuclear Officer, CP&L.

Brunswick participates with other organizations that are addressing the Y2K effort. The licensee has been involved with the BWR Owners Group, the alliance with Duke Power Company, South Carolina Electric & Gas, and Virginia Power (The CDSV Nuclear Exchange Program), and is a participant in the EPRI Embedded System Program.

2.2 Proiect Plan The Brunswick plant-specific Year 2000 Project implementation Plan (Item 5 of Documents Reviewed ) was developed by the licensee to establish the scope and control of the plant program consistent with a common plan (Item 3 of Documents Reviewed) which is applied uniformly at the three CP&L nuclear power plant sites, and in the two CP&L corporate engineering divisions. The audit team reviewed Rev. 3 of the CP&L NGG common plan, dated September 4,1998. Revision 4 of this plan is to be issued in October,1998. The CP&L NGG Project implementation Plan is based on the guidance provided in NEl/NUSMG 97-07, which was endorsed by the NRC in NRC Generic Letter 98-01 as guidance which presents one approach for achieving Y2K readiness. The audit team's review confirmed that the NGG Year 2000 Project Implementation Plan is based on the guidance contained in NEl/NUSMG 97-07.

l The NGG Year 2000 Project implementation Plan consists of the following phases: the Study l

Phase, which comprises the elements of Awareness and initial Assessment; the l

Implementation Phase, which contains the elements of Detailed Assessment, Testing, l

Remediation, and Validation; and the Contingency Planning Phase. The project implementation plan also includes requirements for quality assurance, regulatory considerations, and documentation.

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. 2.2.1 Awareness At Brunswick, the formal Y2K Study Phase of the Y2K program was initiated in August 1997.

Part of this program phase included the Project Communications Plan, Rev. O, which was completed on December 9,1997. The Communications Plan describes the actions necessary to inform NGG management and employees, and interface with the CP&L corporate Y2K compliance effort and extemat organizations. The Communication Plan prescribes actions for briefing NGG management, educatWg the general population of NGG personnel via departmental newsletters, training parsonnel who are to perform inventory and assessment activities, coordinating Y2K team communications, and reporting of team progress to NGG management.

The audit team reviewed samples of communiques issued from November 1997 to early 1998.

Based on the samples reviewed the audit team considers that CP&L has an effective Y2K awareness program.

The Brunswick Y2K project implementation schedule is provided in Table 1.

2.2.2 Initial Assessment The initial assessment part of the Study Phase of the Brunswick Year 2000 Project started in August 1997 and was completed by March 1998. The completed initial assessment resulted in the identification of an inventory of the software applications and embedded system components at the Brunswick. The tasks of initial assessment included: (1) inventory, (2) categorization, (3) classification, (4) prioritization and, (5) analysis of the initial assessment.

The inventory of potentially impacted applications, computer systems and hardware, and embedded plant systems / components was developed by plant personnel familiar with and responsible for each business unit area using the Year 2000 project scope assessment data sheet which is part of the Project implementation Plan. For software applications, the licensee used the inventory developed for the pinnt software quality assurance manual as means for gaining additional confidence in the completed inventory.

In the identification of embedded systems, the licensee reviewed the procedures and documentation for occurrences of phrases that would indicate the existence of an intemal clock or processor, surveyed the vendors for information on their equipment, performed system walk-downs, and reviewed schematics, program listings, and reference manuals on various instrumentation and control systems. The results of the Brunswick initial assessment of the software applications and embedded items are placed in the Brunswick Y2K Application Checklist and Embedded Component Summary.

The total inventory of potentially affected systems at the Brunswick Nuclear Plant is 736 -

252 software applications and 484 embedded systems / components. Table 2 provides the results of the inventory of software items and Table 4 lists the embedded systems / components. Of the total of identified embedded items,190 items were assigned

. High priority, and 64 of these,High priority items have been certified to be Y2K compliant. Table 5 lists those embedded systems that were reviewed by the audit team.

Prioritization The inventory includes a prioritization of the identified items. The priority is based on the criticality and risk of the functions performed. The licensee used risk assessment methods to prioritize each inventoried item as high, medium, low, or replaced / obsolete. High priority items are those items whose failure could affect nuclear or personnel safety, adherence to regulatory requirements, or loss of plant capacity. Medium priority items are those items whose failure could significantly impair the ability of the licensee to execute major business functions, cause unavailability of Maintenance Rule systems, or could create operator workarounds. Low priority items are those items whose failure could cause inconvenience but would not impair the licensee's ability to perform major business or system functions. Replaced or obsolete items are those items that will be replaced or become obsolete before Y2K problems are encountered. The licensee's prioritization process encompasses the criteria described in NEl/NUSMG 97-07.

Tables 2 and 4 list the prioritization of the inventoried software applications and embedded systems, respectively. Of the 26 High priority software items identified,4 items have been certified Y2K compliant, and 22 items require assessment testing. Table 3 provides a list of high priority software applications at the Brunswick Nuclear Plant.

Analysis ofInitial Assessment The results of the Brunswick initial assessment of the software applications and embedded component items are in the Brunswick Y2K Application Checklist and Embedded Component Summary. The licensee completed the initial assessment phase in March,1998. Analysis of the initial assessment is the final step in the Study Phase. During the analysis of the initial assessment, the licensee evaluated the failure risk of each item as the basis for assigning the priority; recommended the approach / plan for detailed assessment, testing, and remediation; and estimated the detailed assessment /remediation cost. Unless specifically noted otherwise, the licensee did not formally assess and remediate low priority items. Remediation of these items will be done as time and resources permit. Items with a Replaced / Obsolete designation were not assessed and no remediation actions will be taken.

NRC Audit Team Assessment The audit team reviewed in detail 6 of the 26 high priority software applications initial assessment packages identified in Table 3, and 34 of the 484 embedded components identified by the licensee, as identified in Table 5. The reviewed embedded components were designated high priority and were selected from a database print-out provided to the audit team by the licensee. The audit team also reviewed some assessment data of a few items in the medium and low priority categories. Based on its review, the audit team found the initial assessment phase to be appropriate and implemented consistent with the guidelines in NEl/NUSMG 97-07.

. 2.2.3. Detailed Assessment In the Brunswick Year 2000 Readiness Program implementation Plan, the implementation Phase contains the elements of Detailed Assessment, Testing, Remediation, and Validation.

Detailed assessment is performed for all high and medium priority items consisting of vendor evaluation, interface evaluation, spare parts evaluation, training system evaluation, test plans /results, subject matter experts review, and results. Vendor evaluation encompasses evaluation of available manufacturer / developer information (such as contracts, correspondence, vendor manuals, internet listings, and vendor owners groups), communication with vendors using the corporate vendor management program standard vendor questionnaire, and direct communication with vendors. Interface evaluation includes both internal and external system interfaces for passing date and time related data. Test plans /results involves the development of test procedures and acceptance criteria to determine if a Y2K date problem exists. Using the CP&L Corporate Testing Guideline. If no testing is performed, justification should be provided as to why it was not required. Spare parts evaluation involves the review of items to ensure j

that Y2K problems are not recurrent after remediation efforts are completed. Training systems evaluations address training systems that duplicate plant systems, such as the plant simulator.

i The assessment considers the impact of Y2K problems on simulator existing equipment and upgrades. Subject matter expert rev ew addresses the use of any other relevant information obtained through walkdowns, review of embedded chips, and review of source code. Results of the assessments provide remediation recommendations and justifications.

The licensee is scheduled to complete its detailed assessment in December,1998. To date, detailed assessment has been completed on 308 of 736 totalitems. Based on the audit team's review of completed items, the audit team found that the detailed assessments performed to date follow the project implementation plan.

2.2.4. Y2K Testina and Validation l

As part of the implementation Phase of the project implementation plan, test procedures are to be developed for High and Medium priori!y items to determine if a Y2K problem exists using the testing criteria of the program implementation plan. If no test is to be performed justification is to be provided as to why it was not required.

The licensee is accepting vendor certifications for embedded components including those in high priority mission critical systems without conducting additional confirmatory testing at the plant site. This approach is based upon the licensee's reliance on and confidence in its established vendor qualification program and resulting approved vendor / supplier list.

Responsibility for ensuring proper implementation of the vendor qualification program lies with the Brunswick Quality Assurance Department. The audit team acknowledged that the decision on whether to perform additional embedded component susceptibility testing is based on the licensee's determination ofimportance of the affected system and knowledge of the item, prior j

experience with the vendor, and other relevant information obtained.

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j l The audit team identified an area of inconsistency in the implementation of Y2K susceptibility testing. In reviewing some of the testing that has been completed, the audit team found (in high priority applications) that different licensee business units use a variation of the test guidance as follows:

The 9/9/99 date test is not always performed. in some of the test cases, the test is done by starting from 9/9/99 and rolling the date over to 9/10/99, and in some of the cases, the test is started on 9/8/99 and rolled over to 9/9/99.

The 12/31/99 rollover to 1/1/2000 and continuance into the year 2000 is done in different ways.

The Leap Year test is done differently, with 2/28/2000 rolled over to 2/29/2000. In some l

cases the test verifies 2/29/2000 rollover to 3/1/2000, and in other tests this is not verified.

l In some cases the Leap Year tests an incorrect rollover from 12/30/2000 to 1/1/2001 (failure to recognized a 366-day year), and in other cases this is not tested.

The audit team concludes that the NGG Y2K testing effort would benefit from additional communication between the business units or additional training to ensure consistent application of the test procedure guidelines. The licensee agreed to promptly address this issue throughout the NGG organization.

2.2.5 Remediation Remediation is the process of retiring, replacing or modifying of software or embedded software devices that are to be retained in service, but have been determined to be affected by the Y2K l

problem. The program implementation plan provided Y2K compliance criteria for replacement or modification. After remediation is completed, validation testing is required. The licensee is i

performing these modifications and upgrades using existing plant procedures for digital systems. The final documentation of the detailed assessment and remediation is the Year 2000 Certification Package.

2.2.6. Beaulatorv Considerations l

The Brunswick Year 2000 Project implementation Plan and associated documents (items 1,2, 3,4, and 5 of documents reviewed) include references to existing plant procedures that have guidance on regulatory considerations, such as 10 CFR 50.59 for plant modification reviews, reportability evaluations per 10 CFR 50.72,10 CFR 50.73, and 10 CFR Part 21, and operability determinations as required by plant technical specifications.

2.2.7. Continaency Planning Brunswick has begun contingency planning using a framework similar to that described in NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning." The

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7-contingency plan is scheduled for completion in October,1998, when it will be integrated with the Brunswick Year 2000 Project implementation Plan, Revision 4. The audit team was briefed on the contingency planning aspects in the draft version of the forthcoming Revision 4. Based upon the briefing and a review of the draft plan, the audit team considers that the proposed contingency planning activities are consistent with the guidance of NEl/NUSMG 98-07. If at the completion of the detailed assessment phase the integrated plan is implemented with the same rigor as presently applied, the audit team believes that the July 1999 schedule for completion of the project contingency plans can be achieved, with the exception that some of the training needs may extend into the third and fourth quarters of 1999.

2.2.8, Y2K Proaram Manaaement The Brunswick Y2K readiness program schedule is aggressively tracked on a continuous basis by corporate and site management. The Y2K program progress is summarized in a lightboard format that defines the progress of each Y2K system being evaluated. Additionally, the licensee graphically summarizes the status of each phase for corporate management review.

From discussions with licensee personnel, schedule slippages have resulted in counseling and immediate corporate management attention. At present, there are no schedule slippages in the

- Y2K program at Brunswick.

j 2.2.9. Electric Grid issues The audit team discussed electric grid issues with the licensee. The licensee stated that the Southeastern US region has initiated activities to address grid reliability with respect to the Y2K problem. Within this region, there are four subregions, one of which is VaCar, consisting of power suppliers Virginia Power, Duke Energy, CP&L, and Southern Carolina Gas & Electric.

CP&L as part of VaCar, has initiated Y2K problem assessments of the various business urits affecting the grid including Generation, Transmission & Distribution, and Power Management Systems.

The CP&L corporate Y2K program includes contingency planning which interfaces with the Brunswick Y2K program contingency plan. The licensee is addressing intemal and external risks that can affect the grid availability. The contingency plans are intended to be consistent between utilities in the region to ensure one utility will not adversely impact others. The contingency plans will consider probable and credible worst-case scenarios for external as well as internal events. To ensure sufficient electrical energy resources are available, the region utilities are using last New Years Eve electrical demand to estimate the energy demand required for New Years eve,1999. The licensee estimates that the grid load will be at 60%

capacity and is committed to have reserves on line to handle additional supplier demands.

Black-start capabilities and capacities are also being addressed.

The licensee plans to test the software at the Power Management Systems' energy control center on the energy control center simulator. The simulator will be run to simulate potential Y2K events. Extemal risks will also be considered via impact studies. Such risks include critical item suppliers, sabotage potential, telecommunications, satellite 4

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. synchronization, and global positioning system failures. The audit team determined that licensee Y2K program efforts 1o address grid reliability are appropriate.

3.0 AUDIT TEAM OBSERVATIONS The following observations were made by the team auditing the Brunswick Y2K readiness program:

1.

CP&L has a common Y2K project implementation plan which establishes the scope and controls of the NGG Year 2000 Readiness Program at CP&L's three nuclear power stations (Brunswick, Robinson, and Shearon Harris) and two engineering divisions. The plant-specific NGG Year 2000 Readiness Program Project implementation Plan for the Brunswick Nuclear Plant is comprehensive and incorporates the major elements of the nuclear power industry Y2K problem guidance contained in Nuclear Energy Institute (NEI)/ Nuclear Utilities Software Management Group (NUSMG) 97-07, " Nuclear Utility Year 2000 Readiness."

2.

The Brunswick Y2K readiness program is receiving appropriate management support and oversight.

3.

The licensee began the formal Brunswick Y2K readiness program in September 1997, developed the plant inventory by December 1997, and completed the initial assessment phase in March 1998, and is scheduled to complete the detailed assessment phase in December 1998. The licensee has established a tightly-controlled schedule in order to meet the June 1999 Y2K readiness date established by the program. (The one exception in meeting the readiness schedule is the installation and integrated system testing of the modified, Y2K compliant digital feedwater control system application in Brunswick Unit 1. The licensee plans to take a forced outage on Unit 1 sometime in the Fall of 1999 to accomplish this activity.) The Y2K readiness schedule appears to be achievable because of the dedicated effort at this site, the fact that the licensee has already begun modification of major critical computer systems, and the licensee has received support via information sharing with the Boiling Water Reactor Owners Group EPRI and CDSV, the utility alliance with Duke Energy, South Carolina Electric & Gas, and Virginia Power.

4.

The licensee has started the Brunswick Y2K contingency planning. The licensee is using the nuclear industry guidance in NEl/NUSMG 98 07, " Nuclear Utility Year 2000 Readiness Contingency Planning," for this effort and is in the process of integrating contingency planning in the next revision of the Brunswick Year 2000 Readiness Project Implementation Plan. With proper integration of this effort in the project implementation plan and schedule, the licensee should be able to complete this effort by July 1999, with the exception of some required training.

5.

The licensee is accepting vendor certifications for embedded components including those in high priority mission critical systems without conducting additional confirmatory testing at the plant site. This approach is based upon the licensee's reliance on and coniidence in its established vendor qualification program and I

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.g.

resulting approved vendor / supplier list. The audit team acknowledged that the decision on whether to perform' additional embedded component Y2K susceptability testing is based on the licensee's determination of the importance of the affected system and knowledge of the item, prior experience with the vendor, and other relevant information obtained.

6.

The audit team identified an area of inconsistency in the implementation of Y2K l

susceptability testing. In reviewing some of the testing that has been completed, the audit team found (in high priority applications) that different licensee business units use a variation of the test guidance. The audit team concludes that the NGG Y2K testing effort would benefit from additional communication between business units or additional training to ensure consistent application of the test procedure guidelines. The licensee stated that aggressive actions to address this issue at the NGG level has been initiated.

Table 1 Brunswick Y2K Project Implementation Schedule Table 2 Software Inventory Table 3 Inventory of High Priority Software at Brunswick Table 4 inventory of Embedded Systems Table S Embedded Components Reviewed by the Audit Team Brunswick Y2K Audit Plan Outline Documents Reviewed Entrance Meeting - Attendees i

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Table 1 - Brunswick Y2K Project implementation Schedule Activitv Startina Date Finishina Date Awareness 1994*, August 1997 September 1998 (continuing)**

Initial Assessment December 1997 March 1998 Detailed assessment June 1998 December 1998 TestingNalidation June 1998 June 1999 Remediation June 1998 June 1999 Contingency September 1998 July 1999 A limited awareness effort began with the receipt and review of NRC Information Notice 96-70 in December 1996.

The Brunswick personnel are kept informed of the Y2K readiness project status through the Site News Letters.

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Table 2 - Software Inventory Priority BSEP Business Unit High Medium Low R/O Total Chemistry 4

26 2

32 Document Services 1

12 6

19 Engineering 3

11 12 5

31 Emergency Planning 2

2 4

Health Physics 29 20 1

50 Maintenance 2

8 6

1 17 Nuclear Assessment 5

5 Nuclear information 1

1 18 8

28 Technology Outage and 3

9 12 2

26 Scheduling Process Computing 11 6

10 1

28 Regulatory Affairs 1

1 Security 4

4 Training 4

3 7

Total 26 71 125 30 252 T.2 - 1

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e Table 3 -Inventory of High Priority Software at Brunswick.

, Software Applications File Number Name Complete A0578 Pod Y*

A0579 Pod _apps Y*

A0764 SPDS Y*

A0887 Work Control Y*

A0057 Battery Capacitance Test Set A0067 BNP Simulator A0068 BNP Simulator CMS (new)

A0130 Core Flow Calculations A0135 CPL DOSE -Initial Dose Projection A0172 DIALOGIC (BEN)

A0231 EQDB A0234 ERDS A0236 ERFIS

_A0309 HEATBALA_ Heat Balance Calculations, PT 1.8D A0310 HEATBALF. Heat Balance Calculations, PT-1.8D A0358 IRIX Operating System for Simulator Computer A0473 NE - Nuclear Engineering core monitoring program A0509 Off Gas 6.2.1 (OG61)

A0570 Plant Monitoring System (AFORA PMS)

A0572 Plant Process Computer (PPC)

A0701 RODTIM A0771 SPTMS A0810 TIP Traces, ETIP A0818 TRA A0857 VOTES (BNP)

A0903 DFW-Simulator

  • Reviewed by NRCaudit team during audit.

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Table 4 - Inventory of Embedded Systems Priority Business Unit Hig'h Medium Low R/O Total Engineering 146 105 164 3

418 Process Computing 44 2

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66 Total 190 107 177 10 484 Table 5 - Embedded Components Reviewed by the Audit Team Embedded Systems File Number Name Completed BNP0084 X-Ray Search Y*

BNP0085 X-Ray Search Y*

BNP0086 X-Ray Search Y*

BNP0104 C95-P603D. Shift Foreman Display Mon / processor Y*

BNP0110 C95-P601C. TSC RM143 Color Display Mon / processor Y*

BNP0111 C95-P602C. TSC RM123 Color Disolay Mon / processor Y*

BNP0111 C95-P602C. TSC RM123 Color Display Mon / processor Y*

BNP0112 C95-P603B. STA Desk Color Display Mon / processor Y*

BNP0113 C95-P603D. Shift Foreman Display Mon / processor Y*

BNP0121 C95-V3CR11. SPDS RTGB Workstation.

Y*

BNP0121 SPDS Workstations Y*

BNP0121 C95 V3TS02. TSC RM143A SPDS Workstation.

Y*

BNP0121 C95-V3CR12. SPDS Control Operators Workstation Y*

BNP0122 C95-V7EF04. TSC RM123 SPDS Workstation.

Y*

BNP0122 C95-V7TS03. TSC RM150 SPDS Workstation.

Y*

BNP0211 Flow Controller Y*

BNP0211 Flow Controller Y*

BNP0211 Flow Controller Y*

BNP0211 Flow Controller Y*

BNP0217 VA-FR-3359. Main Stack Flow Recorder Y'

1 BNP0220 D12-RR-R601. Off Gas System Radiation Recorder Y*

BNP0220 D12-RR-R601. Off Gas System Radiation Recorder Y*

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BNP0221 CAC-AR-1260. CONT ATM RAD, H2 & O2 Recorder Y*

BNP0221 CAC-AR-1260. CONT ATM RAD, H2 & O2 Recorder Y*

BNP0221 CAC-AR-1262. CONT ATM RAD, H2 & O2 Recorder Y*

BNP0221 CAC-AR-1264. RX BLDG Roof Vent Radiation Recos der Y*

BNP0221 CAC-AR-1262. CONT ATM RAD, H2 & O2 Recorder Y*

BNP0225 SRV Leak Detectors Y*

BNP0225 SRV Leak Detectors Y*

T.5 - 1

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Table 5-continued l

Embedded Systems File Number Name Completed BNP0255 Suppression Pool Temperature Monitoring System Y*

BNP0257 SPDS RTGB Workstation Y*

i BNP0257 SPDS Control Operators Workstation Y*

BNP0258 C95-V7CN11. SPDS Master Station Y*

BNP0258 C95-V7CN21. SPDS Master Station Y*

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Brunswick Y2K Audit Plan Outline A. Project organization B Project Manager -

C. Project Sponsor -

1. Participation in BWR Owners Group, CDSV group activities related to the Y2K effort, (EPRI, NEI). Peer review efforts thru CDSV group. EPRI participation for embedded systems.
2. Corporate activities
3. Schedule of activities for Y2K readiness Activity Starting Date Finishing Date Communication /

Awareness Project Plan Inventory Detailed analysis / testing Remediation Validation / testing Contingency Planning

4. Inventory (Review the Information Database.)

Classification:

5. Analysis -

Number of items identified as Y2K compliant. Review how this was determined -

Vendor data;any additional testing.

Number of items not Y2K compliant -

I ATTACHMENT 1 i

_ - - -. - ~..

. Accept As is: (Review how this was determined. __ require validation testing. Check vendor data, Owners Group data, any testing by vendor?)

Eliminate Fix Replace a) Vendor evaluation - validation testing based on criticality of item, prior experience with vendor, extent of documentation, or plant knowledge of the item b) Plant owned or supported software (including tools) evaluation - knowledge based decisions, scanning, testing. When testing proposed, need test specifications and procedures.

l c) Interface evaluation - Part of corporate plan (?) Grid, substation, communication, d) Embedded components evaluation - knowledge based decisions and testing. When sufficient vendor and plant information is available to support a knowledge-based decision, no additional testing is required. (Review the documents when this is the case.)

6. Remediation - Use of existing software procedures (?). Verify long term commitments for maintaining Y2K readiness.
7. Y2K Testing and Validation Assessment testing - Per Computer problem / change reports (PCRs) and associated V&V plans and test procedures.

Testing subsequent to remediation - unit testing; integration testing; system testing.

8. Regulatory Considerations - 10 CFR 50.59 reviews; reportability evaluations per 10 CFR 50.72,50.73 and part 21; operability determinations.
9. Contingency Planning - NEl/NUSMG 98a7, GAO/AIMD -10.1.19 Internal Risks External Risks Remediation Risks (Vendor support, resource limitations, etc.)
10. Y2K Management Plan-Tracking against milestones of the project. Management awareness. Status reporting External resources Use of existing procedures for software QA, configuration management, V&V.,

Documentation Audits (any audits done/ reports issued).

. - _ - -... - _ -. -. =. - _ _. =..

Documents Reviewed 1.

NGG Year 2000 Readiriess Project Team (Roster of participants) 2.

Carolina Power & Light Company Year 2000 Compliance Program Organization Chart, dated August 18,1998 3.

" Project implementation Plan, NGG Year 2000 Readiness Pr*6 gram," Rev. 3, dated September 4,1998 4.

CP&L Phased Project Authorization Distribution, "BNP Year 2000 Readiness," dated June 15,1998.

j 5.

Implementation Phase Project Authorization, "BNP Year 2000 Readiness Project,"

dated May 15,1998.

6.

NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," dated October 1997.

7.

NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning,"

dated August 1998.

8.

NRC Generic Letter No. 98-01, " Year 2000 Readiness of Computer Systems at Nuclear Power Plants," dated May 11,1998.

9.

Letter from CP&L to US NRC, " Response to Generic Letter 98-01, ' Year 2000 Readiness of Computer Systems at Nuclear Power Plants,'" dated August 7,1998.

10. " Year 2000 Business Unit Action Plan Summary - BNP SW," dated September 23, 1998
11. " Year 2000 Business Unit Action Plan Summary - BNP Plant Systerns," dated September 24,1998
12. Brunswick Nuclear Plant NGG Year 2000 Program implementation Status,"

(lightboards for Applications and Plant Components), dated October 2,1998

13. Brunswick Nuclear Plant NGG Year 2000 Program Milestone Schedule," (for Applications and Plant Components), dated October 2,1998
14. "Y2K Project Schedule Exception Report," memorandum from J. Colbum, CP&L, to T.

D. Walt, CP&L, dated October 1,1998,

15. " Project Review and Authorization Standard Procedure," Vol. 99, Book /Part 99, Rev.

1, ADM NGGC-0102, dated August 22,1997.

16. " Project Management Standard Procedure," Vol. 99, Book /Part 99, Rev. 3, ADM-NGGC-0103, dated May 7,1998.

ATTACHMENT 2

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17. " Corrective Action Management Standard Procedure," Vol. 99, Book /Part 99, Rev.1, CAP-NGGC-0001, dated July 8,1998.
18. " Computer Configuration Control Standard Procedure," Vol. 99, Book /Part 99, Rev.

O, CSP-NGGC-2505, dated August 21,1998.

19. " Computer Software Change / Activity Request Standard Procedure," Vol. 99, Book /Part 99, Rev. OiCSP-NGGC-2506, dated August 21, &998.
20. " Computer Software Documentation and Testing Standard Procedure," Vol. 99, Book /Part 99, Rev. O, CSP-NGGC-2507, dated August 21,1998.
21. " Quality Assurance Program Manual," Rev.1, NGGM-PM-OOO7, dated July 10,1998 l

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22. " Engineering Service Requests Standard Procedure," Vol. 99, Book /Part 99, Rev. 9, CSP-NGGC-2505, dated July 13,1998
23. " Project implementation Plan, NGG Year 2000 Readiness Program," Rev. 4 (Draft).

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24. Trip Report from M. Pugh to NGG Corporate Management, " Region ll Y2K i

Contingency Planning Workshop on September 910,1998," no date.

25. Summary of Y2K Vendor Management Program accomplishments. detad September 30,1998.
26. Phase i pie graph of responses from vendors regarding product Y2K compliance.
27. Phase 11 Supplier list of vendors with Y2K compliancy dates for letters mailed to vendors and responses received fron vendors.
28. Sample letters to vendors and from vendor regarding Y2K compliancy of products 1
29. Samples of Awareness presentations and newsletter l
30. Year 2000 Compliance Packsges (see File No.s corresponding to asterisks in i

" Complete" column in Tables 3 and 5).

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Entrance Meetina - Attendees October 6.1998 J. S. Keenan VP, Brunswick NP E.Hux Director of Site Operations K. R. Jury Manager, Regulatory Affairs G.Long Operations Project Analyst J. P. Gawron Nuclear Assessment Section Manager G. D. Miller BNP Engineering Support Services Manager R. Delong Elec/l&C ESS Supervisor K. Nicely Senior Engineer, Regulatory Affairs P. Leich NIT Supervisor K. Karp BESS Project Engineer E. Northeim NGG Y2K Project Manager G. Manacsa NIT Y2K Site Coordinator N. Segars NIT Y2K Admin Asst B. Lindgren Site Support Section Manager G. Johnson PES Principal Engineer H. Willetts BESS Elec/l&C Supervisor J. Corcetti Security Sr Business Analyst C. Schnell Operations Project Analyst E. Campbell Comed Y2K Project Manager E. Brown NRC Bb.ip Resident inspector G. Guthrie NRC BNP Resident inspector M. Chiramal NRR M. Waterman NRR C. Smith DRS, Region ll ATTACHMENT 3