ML20198H495
| ML20198H495 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/18/1998 |
| From: | Buckley B NRC (Affiliation Not Assigned) |
| To: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| TAC-MA1851, TAC-MA1852, NUDOCS 9812290348 | |
| Download: ML20198H495 (29) | |
Text
__. _ __ . _. ._ _ _ _ _ . . .
December 18, 1998 t
Mr. Garrett D. Edwards Director Licensing, MC 62A-1 PECO Energy Company 1
Nuclear Group Headquarters Correspondence Control Desk {
P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
LIMERICK GENERATING STATIOh UNITS 1 AND 2 - YEAR 2000 (Y2K)
PROGRAM (TAC NOS. MA1851 AND MA1852)
Dear Mr. Edwards:
From November 3 through November 5,1998, members of the NRC staff conducted an audit
- of the PECO Energy Company's Year 2000 (Y2K) Program for the Limerick Generating l Station, Units 1 and 2. The results of the audit are delineated in the enclosure. We appreciate l your cooperation and the input from your staff in assisting the NRC staff in completing its i evaluation of your Y2K program readiness.
I In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room. Please contact me at (301) 415-1483 if you have any questions or comments on the enclosed audit report.
Sincerely, '
b m C Bu kley, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regu!ation Docket Nos. 50-352 and 50-353
Enclosure:
Audit Results cc w/ encl: See next page l
DISTRIBUTION:
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% . . . . . ,o December 18, 1998 Mr. Garrett D. Edwards Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - YEAR 2000 (Y2K)
PROGRAM (TAC NOS. MA1851 AND MA1852)
Dear Mr. Edwards:
From November 3 through November 5,1998, members of the NRC staff conducted an audit of the PECO Energy Company's Year 2000 (Y2K) Program for the Limerick Generating Station, Units 1 and 2. The results of the audit are delineated in the enclosure. We appreciate your cooperation and the input from your staff in assisting the NRC staff in completing its evaluation of yourY2K program readiness.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room. Please contact me at (301) 415-1483 if you have any questions or comments on the enclosed audit report.
Sincerely, T3fM C. Lk Bartholomew C. Buckley, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects -1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50 353
Enclosure:
Audit Results cc w/ encl: See next page
t .
t Mr. Garrett D. Edwards Umerick Generating Station, Units 1 & 2 PECO Energy Company cc:
J. W. Durham, Sr., Esquire Chief-Division of Nuclear Safety Sr. V.P. & General Counsel PA Dept. of Environmental Resources PECO Energy Company P.O. Box 8489 2301 Market Street Harrisburg, PA 17105846g Philadelphia, PA 19101 Manager-Umerick Ucensing,62A-1 Director-Site Engineering PECO Energy Company Umerick Generating Station I
965 Chestertwook Boulevard P.O. Box A Wayne, PA 19087-56g1 Sanatoga, PA 19464 Mr. James D. von Suskil, Vice President Limerick Generating Station Manager Experience Assessment Post Office Box A Umerick Generating Station Sanatoga, PA 19464 P.O. Box A Sanatoga, PA 19464 Plant Manager Umerick Generating Station Ubrary P.O. Box A U.S. Nuclear Regulatory Commission Sanatoga, PA 19464 Region I 475 Allendale Road Regional Administrater, Region l King of Prussia, PA 19406-U.S. Nuclear Regulatory Commission
. 475 Allendale Road Senior Manager-Operations l King of Prussia, PA 19406 Umerick Generating Station P.O. Box A Senior Resident inspector Sanatoga, PA 19464 U.S. Nuclear Regulatory Commission Limerick Generating Station Dr. Judith Johnsrud P.O. Box 596 ' National Energy Committee Pottstown, PA 19464 Sierra Club 433 Orlando Avenue Director-Site Support Services State College, PA 16803 Umerick Generating Station P.O. Box A Sanatoga, PA 19464 Chairman Board of Supervisors l of Umorick Township l- 646 West Ridge Pike Unfield, PA 19468 l
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EXECUTIVE
SUMMARY
From November 3 through November 5,1998, the NRC staff conducted an audit of the Year 2000 (Y2K) program at the PECO Nuclear Company (PECON), Limerick Generating Station (LGS), Units 1 and 2, in accordance with the audit plan for this activity. PECON is the nuclear portion of PECO Energy Company (PECO), which owns the Peach Bottom Generating Station, Units 2 & 3, and LGS Units 1 & 2. PECON's Y2K program applies to both stations. The audit was performed on PECON's Y2K program, and where appropriate, the audit team identified those Y2K observations specific to LGS.
The purposes of the audit were to (1) assess the effectiveness of PECON's programs 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 impir; atation to ensure 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 team reviewed selected licensee documentation regarding its Year 2000 Project Plan and 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 U.S. Nuclear Regulatory Commission (NRC) audit team's assessment and evaluation of the LGS Y2K readiness program, the following observations were made:
- 1. The PECON Y2K readiness program is comprehensive and is based on the nuclear power industry's Y2K problem guidance contained in Nuclear Energy Institute (NEI)/
Nuclear Utilities Software Management Group (NUSMG) 97-07, " Nuclear Utility Year 2000 Readiness." Internal and external audits and interactions with other utilities and organizations should further enhance the PECON Y2K program.
- 2. The PECON Y2K readiness program is receiving appropriate management support and oversight and project schedules are being pursued aggressively.
- 3. The licensee identified 54 systems needing remediation at the LGS. All of these systems will be Y2K compliant or ready by June 30,1999, with the exception of i the following four systems, which are presently scheduled to be completed after l July 1,1999: (1) the plant security computer, (2) hand geometry units, (3) personnel dosimetry system (RADOS), and (4) the radiation and meteorology monitoring system (RMMS). The audit team determined that this would not impact achieving Y2K readiness of LGS to operate on January 1,2000, as sufficient time is available for remediation of these systems.
- 4. Y2K rollover effects on LGS's safety-related instrumentation control equipment is very minimal because LGS uses almost entirely analog technology for activation
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and control of safety functions. The two computer based software based safety-related systems at LGS are Y2K ready.
- 5. The audit team noted a discrepancy in PECON's Y2K guidelines with respect to use of the Y2K initial assessment for the embedded equipment. The licensee revised its guidelines to require use of the template for all future equipment initial assessments.
- 6. The audit team confirmed that PECON uses the existing modification procedures ;
including those for software modifications in the Y2K remediation efforts. '
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REPORT DETAILS
1.0 INTRODUCTION
PECON's Y2K program applies to the Peach Bottom and Limerick stations. The audit was performed on PECON's Y2K program, and where appropriate, the audit team identified those Y2K issues specific to LGS. l l
The objectives of this audit were: 1 l
- 1. To assess the effectiveness of the licensee's (PECON) program for achieving Y2K readiness and in addressing compliance with the terms and conditions of the LGS license and NRC regulations and continued safe operation with respect to the Y2K problem.
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- 2. To evaluate program implementation activities to assure that the licensee is on schedule to achieve Y2K readiness in accordance with GL 98-01 guidelines.
- 3. To assess licensee contingency planning for addressing risks associated with potential events resulting from Y2K problems.
The audit review used the guidance and requirements contained in the following documents:
Generic Letter 98-01, " Year 2000 Readiness of Computer Systems at Nuclear Power Plants"
. Licensee Response (s) to GL 98-01 Plant technical specifications and license terms and conditions
. Applicable NRC regulations I .
NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness *
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NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning" Prior to the audit at the plant site, the audit team obtained and reviewed the PECON 2000 Program Plan, Administrative Guidelines, and other PECON Y2K readiness documents.
The audit process started with an entrance meeting attended by corporate managers, the PECON Year 2000 Readiness Project Manager, and various Y2K readiness organization group leaders and some of their staff. Attachment 2 is a list of the attendees. The corporate managers, the PECON Y2K solution manager, and the various Y2K ready
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9 organization leaders (managers) briefed the audit team on the project organizatic,n, the project plan and its implementation, and the current project status and future activities.
Subsequent to the entrance meeting, the audit team reviewed documents listed in
. Attachment 1, and the plan implementation products (documents and data bases) and interacted with the various organization leaders and their staffs to obtain clarification and amplification on various issues arising during the audit.
2.0 DISCUSSION 2.1 Project Organization Jack Gibson is the year 2000 solution manager (SM) for the PECON Y2K Project. The project has 30 full time persons, including contractors, in general, the contractors are PECON retirees with extensive knowledge in the systems for which they have responsibility. The SM leads the project and reports to J. Hogan, a program sponsor, who is vice present of nuclear support and chairman of the Y2K steering committee. The program manager reports to the SM, and has responsibility for the schedule, budget, and resources. Attachment 3 is an organization chart of the PECON 2000 Program Team, and Attachment 4 describes the responsibilities and interface of each Y2K organizational grour 2.2 ~ Y2K Participation with Other Organizations PECON has actively participated with NEl, NUSMG, Electric Power Research institute, and l the Boiling Water Reactor Owners Group in developing industry guidance for resolving l Y2K issues and in Y2K related workshops. In addition, it shared its Y2K experiences and l
knowledge with other licensees (1) to assist in developing and improving their Y2K programs, and (2) to improve PECON's Y2K program with lessons learned from those
, licensees. The licensees with which PECON shared information include Brunswick, Harris, l Robinson, San Onofre, and WNP2 plant licensees. Presently, PECON is leading an effort to share information with other licensees on contingency planning.
2.3 Project Plan PECON formally initiated the LGS Y2K project in January 1997. By November 1997, PECON had (1) issued the PECON Year 2000 Program Plan, and (2) completed forming th >
Y2K steering committee and staffing the Y2K program team. The program plan identified
- . the key milestones of the project. On October 28,1998, based on a recommendation from an external audit, PECON issued the Project Administrative Guideline specific for PECON tc, address the key objectives of NEl/NUSMG 97-07 Nuclear Utility Year 2000 Readiness. " The implementation plan of the PECON Year 2000 Project Administrative
! Guideline includes the following phases as recommended in NEl/NUSMG 97-07:
) awareness, inventory,' categorization /classificatian, prioritization, initial assessment, i detailed assessment, remediation, Y2K testing and validation, contingency planning,
- . quality assurance, regulatory considerations, and documentation. The audit team's review 2-
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confirmed that the PECON Year 2000 Project Administrative Guideline is based on the guidance contained in NEl/NUSMG 97-07.
2.4 Awareness The formal Y2K awareness phase of the Y2K program was begun in January 1998. On November 4,1998, PECON published the "Y2K Communication Plan," which identified target audiences, key messages, and Y2K awareness action items. Prior to issuing this document, the Y2K problem was brought to the attention of all PECON employees via published newsletters. PECON published newsletters include PERSPECTIVES, DUPONT TALES, and INSIDE NUCLEAR. Additionally, PECON organized brown bag meetings and workshops to inform plant personnel of Y2K issues. The PECON awareness program will continue until April 2000.
2.5 initial Assessment PECON commenced the initial assessment in January 1998. By July 31,1998, PECON completed the initial assessment including an inventory, categorization, classification, prioritization, and analysis of systems potentially impacted by the Y2K problem.
2.5.1 Inventory The inventory identifies all software items (information technology systems) and embedded systems in the PECON program potentially affected by the Y2K problem. The inventory of all information technology (IT) systems identified 356 software items of which 133 items were for LGS. From the components record list (CRL), which contained more than 65,000 components, the licensee identified 1066 embedded components for review.
2.5.2 Categorization / Classification -
Categorization of the inventoried items is the process that groups devices, software, and systems by type of equipment. This allows management to efficiently assign resources to the classification and prioritization activities based on team member expertise. Typical Categories are: mainframe applications, system software (operating systems, databases, utilities, etc.), client server applications, workstations, software interfaces, i telecommunication equipment, and plant embedded devices and systems. Within the j system categories, the subject matter experts classified each system to determine !
whether the system required a detailed Y2K assessment. Each inventoried item is I classified under one of the following classes: 1 Class 1: Saf ety-related, important-to-safety Class 2: Required by regulation, license, operational needs and/or for personnel safety 3-
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Class 3: Continuity of business Class 4: Non essential l
PECON required a detailed assessment of systems classified under Class 1,2 or 3 or if the j system interfaced with another system in those classes.
L 2.5.3 Prioritization Each of the classified items was prioritized for purposes of assigning an order to the performance of the detailed assessment. PECON stated that the criteria used to set the l priorities are as follows:
l Priority 1, STRATEGIC Has safety implications to employees / customers / general public, l Required by regulatory agencies for operation, Severe impact to PECON operation, Lost productivity to most the employees.
Note: All embedded components in plant systems have this priority.
Priority 2, HIGH Mandated by regulatory agencies but can be lost for short periods of time, Operation continues but with difficulty, Lost productivity to a majority of employees, Asset is used solely as a backup to an asset of severe importance.
Priority 3, MEDIUM Mandated by regulatory agencies but have compensatory measures, Operation continues but is cumbersome, Lost productivity to some number of employees, Asset is used solely as a backup to an asset of high importance.
Priority 4, LOW Minimal or no impact to business unit operation,
, Lost productivity to a minimal number of employees, Asset is used solely as a backup to an asset of medium importance.
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2.5.4 Analysis of Initial Assessment Analysis of the initial assessment is the final step in the initial assessment phase. PECON used the results of this analysis to determine the scope, schedule, and estimated resources required for the detailed assessment. During the analysis, items are determined to be "Use-As-Is" or designated as needing further detailed assessment. Items are designated "Use-As-Is" if (1) the items are determined not to be mission critical, and (2) there is no business reason for performing the detailed assessment.
PECON performed an analysis of the initial assessment on 356 software items identified during the inveritory phase. Of those 356 software items,133 items are for LGS. Of those 133 items, the subject matter experts determined that 76 items need a detailed assessment. In addition,1066 embedded components were identified during the inventory phase consisting of 15i, different types of components (devices). PECON took a conservative approach and required a detailed assessment of all 156 different types of embedded components. The results of the initial assessment are placed in the Y2K assessment checklist.
2.0 Detailed Assessment in the detailed assessment phase, PECON obtained information on each inventory item to determine its expected performance when subjected to the rollover dates identified in NEl/NUSMG 97-07. PECON used the assessment results to make a decision regarding the action required to ensure the continued operation of the systems being assessed. During this phase, PECON evaluated software and interfaces to determine whether the item is Y2K ready. For embedded systems, PECON also evaluated hardwr firmware, and operating systems, if necessary for Y2h readiness.
PECON is scheduled to complete its detailed assessment by Novemb: 'O,1998. To date, PECON has finished the detailed assessment on 60 of 76 software items and 145 of 156 different types of embedded components identified during the initial assessment. The audit team reviewed 16 completed folders of software items as listed in Table 1 (Attachment 7) and 17 completed folders of the embedded system items as listed in Table 2 (Attachment 8).
Based on the review of the completed software and embedded system items identified in detailed assessment folders, the audit team found that the detailed assessments performed to date have followed the project implementation plan. However, in reviewing the packages of embedded system components whose initial assessments have been compieted, the audit team found that PECON did not use the initial assessment template provided in the Guideline for Classification and Characterization of System Inventory. For IT items, the audit team found that PECON did use the initial assessment template provided in the project guideline. The audit team discussed this discrepancy with the PECON staff and determined that PECON had obtained the data required by the Guideline for Classification and Characterization of Systems for the embedded systems in a different I
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l format. In addition, the audit team found that the template was included in the PECON '
l 2000 project document after PECON completed the initial assessment of embedded system components. In response this to this finding, PECON revised its guidelines so that any new embedded item identified will use the initial assessment template.
, 2.7 Y2K Testing and Validation l
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Y2K susceptibility testing is performed during the detailed assessments and requires the j development of test procedures. Y2K validation testing will also be performed subsequent to remediation to confirm that the modifications have eliminated the Y2K problem and no unintended functions are introduced. The PECON Y2K susceptibility tests consist of unit testing, integration testing, and system testing. Unit testing focuses on a single application, software module or component. Integration testing tests the integration of l related software modules and applications, and system testing tests the hardware and software components of the systems as a whole. These tests are performod using procedures developed in eccordance with PECON guidelines for Y2K testing, and determine whether the item is Y2K ready or requires remediation.
PECON is performing validation testing to confirm that the system is capable of performing its intended function. Validation is performed either subsequent to remediation or when the detailed assessment determines that the system or component is Y2K ready with need for modification.
2.8 Remediation or Replacement The purpose of remediation is to retire, replace, or modify items identified as not Y2K ready during the detailed assessment. Any changes during remediation will follow the existing PECON change process and quality assurance control guidelines. The PECON change process includes the requirement to specify new spare parts that will be required for the installation, testing, start-up and maintenance of the new equipment and to identify and remove obsolete spare parts.
PECON identified 54 systems needing remediation at both LGS and Peach Bottom.
PECON stated that the schedules for remediation are being pursued aggressively.
Remediation of all 54 systems is scheduled for completion by June 30,1999, with exception of four systems scheduled for completion after July 1,1999, as follows: (1) the plant security computer, (2) hand geometry units, (3) personnel dosimetry system (RADOS), and (4) the radiation and meteorology monitoring system (RMMS). The audit team determined that remediation of these systems appears reasonable in accomplishing LGS readiness to cperate on January 1, 2000.
2.9 Regulatory Considerations PECON stated that the Y2K readiness program guidelines for LGS indicated that any system changes or modifications developed as a result of the Y2K program will be
. 1 implemented using existing approved PECON procedures, which include the necessary reviews against the requirement of 10 CFR 50.59. PECON also stated Y2K problem remediation will employ existing PECON software quality assurance controls and guidelines for software modification configuration management.
The audit team reviewed the PECON Y2K program guidulines and found that they did not clearly identify the applicable plant documents for the Y2K team members to follow during the remediation. However, from the interviews with the Y2K team members, the audit team found that the Y2K team members and plant staff coutinely use the existing LGS procedures and employ the existing required software A ce ntrols for Y2K remediation efforts. The audit team reviewed the appropriate plant prt,ndres, and confirmed that the documents address the necessary regulatory requirements of 10 CFR 50.59, 10 CFR 50.72,10 CFR 50.73,10 CFR Part 21, and 10 CFR Appendix B for modification reviews, reporting of failures and defects, and quality assurance.
2.10 Contingency Planning The purpose of contingency planning is to provide a process for reducing the risks associated with unanticipated Y2K-induced events. Contingency planning includes contingency plan management, development, and integration. Based on the source of risk, contingency planning is civided into three categories: remediation risk, internal facility risk, and external risk.
PECON has begun contingency planning following the guidance in NEl/NUSMG 98-07,
" Nuclear Utility Year 2000 Readiness Contingency Planning." On October 28,1998, PECON issued Guidelines for Year 2000 Contingency Planning, Revision 1. The issued guidelines defined the program and laid out the implementation and documentation requirements. Attachment 5 shows how the contingency planning team will be organized.
PECON will also establish a contingency risk evaluation panel to guide the contingency planning team and to make the final decision regarding which contingency plans will be developed. Presently, the LGS contingency planning process is scheduled to be completed by July 1999. In addition, training of LGS staff on contingency plans will continue through the second half of 1999.
2.11 Y2K Program Managemerit All LGS systems are scheduled to be Y2K ready or compliant by July 1999, except for the four systems previously discussed. These systems are on the " watch list" and their Y2K readiness status is actively fo!! owed by management. As of November 6,1998, the Y2K readiness project team completed the inventory and initial assessment. The audit team found that Y2K activities and the overall progress of the Y2K program are actively followed by corporate managers through quarterly, monthly, biweekly, weekly, and daily meetings. During these meetings, the project schedule is updated and any issues requiring management attention are identified.
2.12 Electric Grid issues:
PECO Energy Distribution (PED) briefed the audit team on its Embedded Technology (ET)
Project, which is the Y2K readiness project for PECO's transmission and distribution '
systems. PED stated that the ET project began on June 1,1998, with support from PECON's Y2K team members. PECON's support includes training, planning, and assisting in performing some of the Y2K readiness activities.
PED's ET team consists of one coordinator, one engineer, an ar'alyst, two senior field l technicians, and one vendor field technician. The team surveyed 570 substations and identified 3000 embedded components. These components consist of 150 different types of equipment. An initial assessment of these 150 types of embedded components identified 75 different types needing further Y2K susceptibility testing.
Testing and remediation of PED embedded systems is scheduled to be completed by the end of the second quarter 1999. In addition, contingency plans for power distribution are scheduled to be completed by April 9,1999. Attachment 6 shows the detailed schedule and progress of the various PED Y2K activities.
The audit team was briefed by the PED power staff on the operating plan for Y2K grid availability. The PED staff stated that its operating p:an will address power load, generation, transmission, and interchange. Load covers how much power needs to be generated during the Y2K rollover period. Generation covers what power generation mix would provide the required power at the lowest risk during the rollover period.
Transmission covers actions necessary to provide sufficient grid voltage. Interchange covers actions for' grid stability whether PECO is tied to the Pennsylvania, New Jersey and Maryland grid or not. Each of these areas interacts with each other so that when one area is affected by Y2K-releted problems, other areas will support the affected area.
The above four areas will be developed in three phases. During the first phase, PED will define the basic elements of the plan, develop a range of scenarios, and determine the risk and impacts. During the second phase, PED will develop the operating pian by performing system studies to test the Phase 1 scenarios, revising scenarios as necessary based on up-to-date information, training personnel, and conducting Y2K related drills where appropriate. Finally, during the third phase, PED will test equipment where practicci, develop a commitment strategy, and implement the overall Y2K readiness operating strategy.
The audit team finds that the PED Y2K effort to address grid availability is appropriate.
3.0 OBSERVATIONS l The following observations were made by the audit team of the PECON Y2K project:
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( 1. The licensee's Administrative Guideline is a comprehensive document and is based on the guidance contained in NEl/NUSMG 97-07 and NRC GL 98 01. The PECON documents listed in Attachment 1 provide appropriate procedures for performing j the various Y2K readiness activities. In addition, the PECON Guideline for Year l
2000 Contingency Planning is a comprehensive document and is based on the guidance contained in NEl/NUSMG 98-07. The audit team finds that the licensee is using effective planning practices to develop the LGS Y2K contingency plans. The feedback from internal and external audits and interactions with other utilities and industry organizations should continue to enhance the PECON Y2K Program.
- 2. The Y2K readiness program is receiving an appropriate level of senior management's support and oversight. The Y2K activity schedules and status are ,
actively followed by corporate managers through quarterly, monthly, biweekly, I weekly, and daily meetings. During these meetings, the project schedule is updated and any issues that need management attention are identified.
- 3. Currently, 54 systems require Y2K remediation. Of these 54 systems, all are scheduled to be Y2K compliant or ready by July 1,1999, except the (a) plant se::urity computer, (b) hand geometry units, (c) RADOS, and (d) RMMS. The audit team determitied that this would not impact Y2K readiness of LGS to operate on January 1, 2000.
- 4. The two safety-related computer-based systems at LGS, the General Electric NUMAC steam leak detection system and the GA Technology /Surrento radiation monitoring systems are Y2K ready. The Y2K problem impact on the remainder of LGS safety-related instrumentation and control is minimal because LGS uses almost entirely analog technology for actuation and control of saf** - functions.
- 5. The audit team found that the PECON Y2K project team was not using the initial assessment template as stated in the PECON Guideline for Classification and Characterization of System Inventory. The audit team discussed this discrepancy with the PECON staff and found that the project team had obtained the data required by the PECON Y2K guidance for initial assessment documentation but had used a different format. In addition, the audit team found that the template was subsequently included in the PECON Y2K project documents after completion of the initial assessments, in response to this finding, PECON revised its guidelines to require use of the template for all future equipment initial assessment. In addition, the Y2K plan and guidelines contain the statement that remediation and implementation efforts are to be performed using appropriate software modification
.and administrative controls and procedures. The audit team found that the Y2K team members and plant staff routinely use the existing software modification procedures and administrative controls for Y2K remediation effort.
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Attachment 1, Documenta Reviewed Attachment 2, Attendees List Attachment 3, Organization chart of the PECON 2000 Program Team ,
Attachment 4, Y2K Organizational Group's Responsibilities and Interf aces Attachment 5, PECON 2000 Y2K Contingency Planning Staffing / Organization Attachment 6, PED Y2K activities' Progress and Schedule Attachment 7, Table 1, Goftware items Reviewed Attachment 8, Table 2, Embedded System items Reviewed 4
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l DOCUMENTS REVIEWED
- 1. PECON 2000 Program Plan, Revision 0-0, issued 11/12/97
- 2. Administrative Guideline, Y2K-AG 210, Revision 0-0, issued 10/27/98
! 3. Guideline for identification, Assessment, Remediation and Validation, Y2K-CG-310, Revision 2-1, issued 10/28/98
!- 4. Gi.:ideline for Classification and Characterization of Systems inventory, Y2K-CG-311, Revision 2-0, issued 10/27/98
- 5. Testing Guideline for Embedded Systems, Y2K-TG-410, Revision 0-1, Issued 10/28/98 1
- 6. Guidelins for Validation of Plant Systems, Y2K-GL-430, Revision 0-0, issued 10/28/98 !
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- 7. Information Technology (IT) Testing Guideline for Computer Systems, Y2K-CG-510, Revision 2-0, Issued 10/27/98
- 8. Guideline for Year 2000 Contingency Planning, Y2K-CG-610, Revisica 1-0, issued l
10/28198 I
- 9. Guideline for Remediation Risk Contingency Planning, Y2K-CG-611, Revision 1-0, issued 10/27/98
- 10. Guideline for internal Facility Risk Planning, Y2K-CG 612, Revision 1 -0, issued 10/27/98 l
- 11. Guideline for External Risk Planning, Y2K-CG-613, Revision 1-0, issued 10/27/98 l
l ATTACHMENT 1 l
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t Attendees j
i Name Representing Phone Initials 1
1 NRC . ' '
- Chiramal, Matthew NRR - Lead
- Lee, Eric NRR-J Cahill, Chris Region 1 I
i i PECO l Arvay, Patrice IT Solution Coordinator, PECON 2000 5491 a
Canziani, Rich Y2K Project Manager, Limerick GS
{
802:2807 g Farrington, Bob Manager, EMS Support 801:6301 i
j Funsten, Steve Y2K Implementation Mgr., PECON 2000 6125
- Galatola, Mickey Y2K Program Director, PECO Energy 801
- 5865 i Gibson, Jack Y2K Project Manager, PECON 2000 6234 i {
Goebel, William NQA 802:3918 Hoefner, Dave Y2K Program Manager, PECO Energy 801:4165 Kaucher, Jim Contingency Planning Coord, PECON 2000 6092
{ Koehler, Mike Y2K Project Manager, Corporate Laboratories 803:7235 i
j LeQuia, Darryl Director, LGS Site Support 802:3030 j Loomis Thomas Licensing 6793
- Lower, Kelly Y2K Test Lab Manager, PECON 2000 6957 1
- Matthews, Cassandra CIO, PECO Energy 801
- 6619 i .
j Muntz, Debbie Group IS Manager, NISD Limerick 802:3757 Netzer, Terry Program Maru.;;- . PECON 2000 6052 j Whelan, Mark Director, Nuclear Infcenation Systems 6905
- Wiegle, Reed Non-IT Solution Coordinator, PECON 2000 6050 4
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- Attachment
PECON 2000 g Program Team O
2000 V
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PEGON 20 1 Program '
T ROLES '
i . ,
Steering Committee Program Year 2000 Solution IT Solution i
8 Non-IT Solution e Manager Manager Coordinator Coordinator
. Provides High Level . Provides Program . Lead Responsible . Coordinates IT system . Coordinates Non-lT Business Focused Management for Manager (LRE) readiness System Readiness o Guidance for Team Schedule Budget, and . Conducts Senior methodologies and Methodologies and e Activities Resources Management Program s
documentation across Documentation Across
. Conducts System Update Presentations all PECON sites c a!! PECON Sites Review of Mission . Provides PECON . Conducts evaluation
' . Maintains System i Coticality" and Representation on and selection of testing Status in PECON 2000 p Prioritization PECO Year 2000 Team tools Database ;
i . Cntical Review of . Manages PECON 2000 . Maintains system status
' . Manages Technical Program Actions, awareness campaign in PECON 2000 Screening Team l
Processes and . Manages PECON 2000 database Resources Checkpoints system database . Coordinates and . Coordinates and
. Conducts Management . Maintains PECO Y2K recommends system R Recommends System
. System Risk Review' database readiness strategy E Readiness Strategy S
. Approve selection of a Maintains integrated P Technical Screening schedule for IT system Team implementation N O . Program Plan
. Year 2000 Readiness . Sample System Test . Sample System Test S . Program Schedule Administrative Guideline Plans Plans I , . Overall Budget ,
. Y2K Test Lab Budget . System Readiness . System Readiness B v = System implementation !
Schedule Schedule 'I I e Schedule L '
. Due Diligence I
b Documentation T , .
i Readiness Status PI's e . Y2K Database Reports ~
E S I PECON Senior
. . Steenng Committee . PECO Y2K Program . PECON 2000 Solution
" . PECON 2000 Solution Management . Year 2000 Solution Manager Manager Manager
, . PECON 2000 Managers Manager . PECON 2000 Program . Y2K Test Lab Manager . Technical Screening
, . PECO Y2K Program Manager .
Site Solution Resources Team f Manager a
Solution Coordinators . Site Solution Resources
. Steenng Committee e -
5 Attachment 4
PECON 20 1 Program - ~~
T ROLES 4
i Year 2000 Test Lab Technical Screening IT Solution Non-lT Solution Documentation Manager Team Resource Resource Manager
. Recommand Lab . Accepts initial Y2K = Accects initial Y2K . Accepts initial Y2K D . Maintains System Hardware and Software Action Request for Plant Action Request for IT Action Request for Non- Documentation l . Cenfigure Test LAN Non-lT Systems Systems IT Systems information in PECON c . Recommend Testing . Review System Evaluates Systam per r Tools Database for ). " Year 2000 Readiness
. Evaluates System per 2000 Database i Year 2000 Readiness
. Manage Daily lab Completeness Guidehne* Guideline
[; Operations . Contact Vendor for Y2K Status of Components ,
o . Evaluates System per R n Year 2000 Readine"
/^
E Guideline' S
p . Test Lab Configuration . System Y2K Strategy . System Y2K Strategy . System Y2K Strategy . System Readiness O Documentation . System Readiness Cost . System Readiness Cost . System Readiness Cost
, Documentation N I
. Test Lab Capabthfies Estimate EstimMe Estimate Packages 3 : Documentation . System implementation . System !mplementation . System implementation i v . System Test Schedule Plan Plan Pian
B
- Year 2000 Test . System Test Plan . System Test Plan . System Test Plan l ,' Scenario Doc's . System Readiness . System Readiness . System Readiness
- 1. b . Test Lab Equipment Schedule Schedule Schedule l 8 Y2K Rea@ ness Doc's . System Dependencies . System Dependencies . System Dependencies T . System lnterfaces . System interfaces . System lnterfaces i
E S . PECON 2000 Solution . Site Solution Resources . IT Solution Coordinator . Non-IT Solution
' . PECON 2000 Solution g l Manager . Non-IT Solution .- Vendor Contact Coordinator Manager ._
," . IT Solutior Coordinator Coordinator Coordinator . Vendor Contact . Technical Screening
. . Site IT Solution . PECON 2000 Solution . Year 2000 Test Lab Coordinator Team r Resource Manager Manager . Technical Screening . Site Solution Resources f
. Vendor Contact Team Coordinator e
s Page 2 of Attachment 4
PECON 20 1 Program .
nr ROLES I
' Database Architect Communications Clerical Year 2000 Site Support Coordinator Support Testers (NISD,I&C Engr., etc.)
c D
- Modifies Database . Develops PECON N00 .
Wntes and Issues PIMS . Creates Application . Provide Solution e Structure as Needed to Communication Plan Action Requests Test Scripts in s Support Program Resources When
. Wntes and Distnbutes . Updates PECON 2000 Cooperation With End-c Reouirements Available for Pub!!shing, Articles Database AR Status Users and Developers r . Develops Reports and Pertaining to Year 2000
. Coordinates Utilization i
. Modifies Application of Program Staff Performance indicators information and p Test Scripts as Needed Augmentation as Program Status t Required
. Promotes Year 2000 i
. Accepts / Rejects Awareness in PECON ^
o Using Various Media Recommended n Readiness Solution R D . Database = " Daily Locar Arbcles . PIMS Action Requests .
E e Application Test Senpts . Design Package for Documentation .
Banners. Posters. and S
. Test Script Solution implementation I . Sample Reports Flyers etc P i Documentation
. Sample PI's . Video Billboard Displays O v . Communication Plan N e Schedule S r 3 I a O b I I L e I ;
T l
E 7g S v I . PECON 2000 Sotution . PECON 2000 Solution .
PECON 2000 Solution .
n Year 2000 Test Lab . PECON 2000 Solution Manager Manager Manager Manager Manager t .
IT Solution Coordinator .
Site IT Solution e
IT Solution Coordinator
. Non-IT Solution Resource r . Non-lT Solution Coordinator .
End-Users g Coordinator Technical Screening . Developers a
. Technical Screening Team c Team Site Solution Resources . Site Solution Resource; e
s Page 3 of Attachmeni 4
PECON 20 1 Program -
_$ ROLES *[
linplementation Contingency .
i
' Management Sponsor Program Sponsor Manager Planning Manager
- Facihtates the .
Facthtates program .
Provides overall .
development of integration within Develops contingency .
program sponsorship on planning guidance for o remediation schedules PECON
. behalf of the Chief PECON
, Coordinates the . Assists in s Nuclear Officer .
Recommends reporting of remediation interdepartmental C
schedule information coordination methodology, staffing
[ . Maintains a hst of and schedule for p Current remediation contingency planning t work implementation i .
. Develops contingency ^
n planning awareness -
through presentations, meetings, articles and R papers E
S P
O N D = List of Systerns .' .
S * .
currently in remediation Contingency Planning .
~ ~ ~
I , . Sample remediation Guidehnes B y schedule templates .
Contingency Planning I e implementation L '
schedute I .
T ,
i e r%
E -
S- t . Solution Manager Solution Manager .
Chief Nuclear Officer .
. Site Project Managers Program Sponsor Solution Manager .
Solution Manager .
, . Corporate Y2K Management Sponsor
- Steering Committee . Program Sponsor r scheduhng team .
Site Management .
i Corporate Contingency Planner C
e S
I i
Page 4 of Attachment 4 o
PECON 2000 Y2K Contingency Planning Staffing / Organization J. Kaucher Team Leader -
B. Carlson F. Lake Intemal Risk Coordinator Remediation Risk Coordinator External Risk Coordinator LGS SRO LGS SRO EP Coord Security Coord ~~
PB SRO PB SRO License Coord Goods / Services Coord LGS Systems LGS Systems PB Systems PB Systems A AA. . t. - - a r=
a E.2.S.9 YR2000 - EMBEDDED TECHNOLOGY !
1998 1999 2000 2001 20 10 Test 3 Task Name Durat Finish % Complet Q2lQ3l04 Q1lQ2l03l04 Q1l02l03lQ4 Q1lQ2lQ3l04 Q1lQ2 1 Y2K Mip Embedded Systems 283d Mon 7/12/99 54 %
2 Identification of Team Members 15d Wed 7/22/98 100 %
3 Resources identified 23d Wed 7/1/98 100 %
k DCf N % e W 4 Identify Database! tools needed 180d Wed 7/1!98 100 %
h LDCkmbedded-DB-Analysta[0.2]
5 Staffing in place 45d Fri 7/31/98 100%
6 Database for embedds 3 systems 330d Fri 9/11/98 100%
L mbedded-DB-Analysts [0.2]
7 Commence PECO inventory 98d Sun 11/15/98 100 %
LbC-Embedded-investigators [0.8] O' 8 Inventory assessment / criticality 78d Wed 9/30/98 100%
DC-Embedded-B usiness-Review s[0.4]
9 inventory Co-Gens and Pole-tops 25d Fri 9/25/98 100% gj 10 Inventory Major Customers (top 44) 62d Wed 12/30/98 25 %
gj
- 11 Vendor Letter Campaign 154d Thu 1/7/99 100 %
12 Retirement documentation 165d Frt 1/15/99 100%
13 Vendor intervention fbliow-up 196d Tue 3S99 60%
- -l LDC-Embedded-Administration [0.2]
14 Interface w/ EPRI website/ database 22d Wed 9/30/98
- 100% g 15 Testing Methodology (ECS/DMACS/ GAS) 110d Frt 10/30/98 100 %
g is Testing (ECS/DMACS/ GAS) 105d Tue 2/9/99 66 %
-) LDC-Embedded. Test Team [0.2],LDC-Embedded-Process-Systems [
17 Testing Schedule 142d Thu 12/17/98 80 %
__s is Testing Embedded systems 100d Tue 6/1/99 2% - - -
19 Cont @ncy Plans 219d Frl 4/9/99 45 %
.- -- ---l LDC-Embedded-Process-Systems [0f]
20 Y2K Remediation 195d Mon 7/12/99 10%
] ;
Propct: Err xdded MPP Task (( , ,, , ,] Summary Rolled Up Prograss N Data: We( t 1/4/98 Progress - Rolled Up Task [' * .l Mi)estone $ Rolled Up Milestone < >
Page1 Attachment 6
l' Table 1 - Software items i
System Name Classification Priority / Plant Detailed Assessment Y2K Compliant / Reedy i Operation ,
impact (OPS)
LTAFLA Class 1 Priority 3 Performed Yes ,
LGS Penetration Seal Class 1 OPS = NA Performed No Tr:cking Data base program Obtained Y2K information i from vendor is sufficient ;
Screm Timing Class 1 OPS = 4 Performed Yes .
Evaluation OPTlX Class 1 OPS = 4 Performed Yes PERMON Class 1 OPS = 4 Performed No !
Being remediated 3D Monicore Class 1 OPS = 2 Performed No I Will be upgraded j MOV Trending Class 2 Performed test Performed Yes Plant information . Class 2 Priority 1 NA No ;
Monitoring System Initiated Y2K Remediation Completed (PIMs) program for PIMS i
Attachment 7 !
r
i i
2 SCRITS System OPS = 2 Class 2 Performed Yes L
1 Deep Bed Demin. Class 2 Priority 1 Performed Yes Centrol System !
P3 Primavera/PIMS Class 3 OPS = 3 Performed Yes Interface ,
Vcitage Drop Program Class 3 NA Not Performed NA Not Mission No further action is required Critical Rrbrcca Program Class 4 NA Not Performed NA Not Mission No further action is required '
Critical LABCALCS Class 4 OPS = 4 Performed Yes lonics Desktop Class 4 OPS = 4 NA Obtain Y2K verification from Computer vendor Qur,st Noise Monitor Class 4 NA Performed Yes Not Mission l Critical I
Table 1 continued
~
l, .
,c..,
Table 2-Embedded Components Component Vendor Comments Bramshaw Master Reliance Electric Y2K Comply / Does not !
l Programmable Logic Component. have a clock function I Control '
L i Seismic monitoring System Kinemetric Inc Has clock function. The
! Computer vendor is in the process of performing Y2K compliance i testing. Based on the vendor's evaluation of I similar equipment, PECON is planning to update the equipment.
I Steam Leak Detection General Electric Y2K Compliant / GE 1
1 Temp Monitor evaluated the equipment l and found the system does not perform date factions. l
- j. Input Measurement Card Zeefax inc. (Solartron) Y2K Compliant /Does not
! have a clock function l Rod Sequence Control General Electric Not Applicable / This l System Panel equipment has been deleted from Unit 1 and never existed on Unit 2.-
c Redundant Reactivity General Electric Y2K Compliant / GE Control System Logic evaluated Y2K assessment Cabinet for BWR Owner's Group and determined that Limerick's RRCS firmware does not contain Year 2K defects.
Suppression Pool Temp Simmonds Precision The SPTMOS is scheduled instrumentation System to be replaced prior to the Division (SPTMOS) Y2K.
Drywell Sump Tank Level Foxboro ,
Y2K Compliant /Does not Monitoring System have a clock that utilizes or provides date function 3
, Attachment 8 l
l
- - -- --- - -. . . - . -. - - - - - - - ~ . - - . . . .. ._ ._
4 I#
I 2
Feed Water and Best Power Technology Ready with correction /UPS Recirculation Board and will continue to function UPS but will require that the data parameters be reset l following the rollover to the Y2K Digital Controller Nutherm International Y2K Compliant /Does not use a date function l Rod Worth Minimizer General Electric Y2K Compliant /both units
- l. (NUMAC) at LGS do not make use of j
1 the timing option. i Recorders for various Westronics Y2K Ready /Three versions j systems. (Too many to of Recorder Compliant l list) version - use as is Ready l
versien - use with administrative control i Upgrade version - Recorder referred to as Westroics l (Yokogawa Replacement) j on the attached list of the j detailed assessment will be i
- replaced with Yokogawa Recorders prior to January j
l 1,2000. )
l Flow Control / Loop Control Bailey-Fisher & Porter Y2K Ready / PECON tested the equipment (not up to PECON 2000 guidelines)
! and recommended "use as l is" l
Control Enclosure Chlorine Anacon (KWJ Engineering) Compliant / clock ,which detector provides date information, is not used i RHR SW LOG count rate General Electric Y2K Compliant /Does not l Radiation Monitor / Steam process any date Leak Detection Temp.
Monitor /Off Gas Sample Chamber / Main Steam Line Radiation / Air Ejector &
( Holdup Pipe Discharge (NUMAC)
Table 2 continued l
l
e s '*
.a 3 l l
Condensate Feedwater Tracor Westronics Y2K Ready /Two Models Temp ITF/ Remote Selector Bank /CRDHS Control Rod MX 60 - does not process Drive /FW Heater Temp calendar date.
Indicator DDS 7800 - does process calendar date for display only. It makes no use of the date for any calculation. Requires administrative control.
Suppression Pool Simmonds Precision Replace /No detailed Temperature / Panel Supp. Instrument System assessment /the equipment Pool Temp. & Cont. Division, is scheduled to be replaced Atmos. Monitoring prior to the Y2K l
l l
r 7
l Table 2 continued