ML20203A957
| ML20203A957 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Merrifield J, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20203A963 | List: |
| References | |
| NUDOCS 9902100158 | |
| Download: ML20203A957 (4) | |
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UNITED STATES ag l
j NUCLEAR REGULATORY COMMISSION WASH!NOTON, D.C. 20666-0001
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January 19, 1999 c,
MEMORANDUM TO:
Chairman Jackson l-Commissioner Dicus l
Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield FROM:
William D. Travers b
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Executive Director for Operations
SUBJECT:
STATUS OF Y2K PROGRAMS AT NUCLEAR POWER PLANTS The following is provided in order to update the Commission on the status of nuclear power plant licensee Y2K readiness programs and future staff efforts on this subject based on information obtained by the staff since the previous memorandum dated October 26,1998.
The staff notes that one critical transition date (12/31/98 to 1/1/99) included in Y2K readiness programs occurred without a reportable Y2K problem at a nuclear power plant.
Since late September 1998, the staff has been conducting the 12 planned sample audits of licensee Y2K programs. To date,9 have been completed with the remaining 3 scheduled for completion by the end of January 1999. After compietion of the audits, the staff plans to issue an information notice to inform licensees of the observations and lessons learned from the audits. Overall, the audits indicate that the industry is undertaking effective Y2X readiness _
efforts, and schedules are consistent with NRC expectations. The following observations and lessons learned from the audits to date were shared with licensees at the NEl sponsored workshop in Atlanta, GA on December 9 and 10,1998. Most nuclear power plant licensees were in attendance at the workshop.
Observations:
- 1. Nuclear power plants are generally on schedule to be Y2K ready by July 1,1999. Ucensees are completing detailed assessments of Y2K susceptibility and are remediating/ replacing mission critical systems as necessary.- Some licensees have scheduled testing of some mission critical remediated systems for refueling outages in the Fall 1999, but all audited licensees have confirmed that their plants will be ready to operate on January 1,2000. No Y2K l
problem in a safety-related actuation system has been identified.
- 2. Licensees have just bagun their Y2K contingency planning. While this is an irnportant part of the Y2K program, it is not overly time consuming, and sufficient time is available to complete the effort including the training of plant staff and exercising of the plans. However, because the staff has been unable to review detailed plans as part of the 12 plant sample audits, some additional follow up review of contingency planning will be conducted at several plants other than those in the 12 plant audit program in the Spring 1999.
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- 3. Licensee management oversight of the Y2K readiness programs has generally been aggressive and is contributing to the success of Y2K readiness efforts. Management buy-in at allleve!s is essential to program effectiveness. Licensees are devoting the necessary resources to their programs to achieve their readiness schedules.
- 4. Independent assessments and/or peer reviews of licenseo programs are very useful to the effectiveness of the program. The continued significant sharing of work and information through owners groups and utility alliances is aiding in proper program implementation.
- 5. As part of their contingency planning, licensees are working with regional grid councils in order to provide for additional grid capacity in the event of loss of normally available power sources due to unanticipated Y2K problems.
Lessons Learned:
- 1. Central control of Y2K susceptibility testing reduces the chance for testing errors.
- 2. Tracking of remediation efforts should be consistent with the overall plant configuration management procedure thereby avoiding the introduction of possible future non-Y2K compliant software changes. Licensees should maintain configuration control for those systems and components identified for Y2K review under the program.
- 3. Independent verification and validation of Y2K readiness status of remediated mission critical systems is important to ensuring their proper function.
- 4. Reliance on vendor certification of Y2K readiness of nonsafety systems varies. While the staff believes that it is prudent for mission critical systems to receive Y2K susceptibility testing regardless of vendor confirmation of readiness, it is recognized that no regulatory basis exists to require such testing.
- 5. Coordination of plant specific Y2K readiness contingency plans with other licensee facilities and regional grid councils is essential to the Y2K readiness program.
By letter dated January 4,1999, the Chairman informed NEl that the staff will issue a supplement to Generic Letter (GL) 98-01 consistent with the recommendation from NEl in their letter to the Chairman dated November 9,1998. The supplement to GL 98-01 provides licensees with a voluntary alternative response on overall Y2K readiness of their plants in lieu of the more narrow response to GL 98-01 which refers only to readiness within the scope of the plant license and NRC regulations. This alternative response is due by July 1,1999, as is the response to GL 98-01 and is consistent with the Year 2000 Information and Readiness Disclosure Act (Public Law No:105-271) which was enacted in October 1998, and which encourages information sharing on Y2K readiness in order to support the availability of the t
nation's infrastructure. The Commission Paper with the proposed GL 98-01 supplement was sent to the Commission on January 6,1999.
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- s TY.,iwill review all licensee responses to either GL 98-01 or its supplement in July 1999.
3 independent audits of the responses are planned. However, based on the licensee's l
response and any other information available on Y2K readiness, the staff will determine the need for further plant specific follow up such as an onsite review, phone call or meeting with the licensee. For example, if a licensee indicates that significant mission critical system testing is required during a Fall 1999 outage or if it is unclear from the response what the status of facility I
readiness is, the staff may verify via an onsite review that sufficient time has been allotted for successful completion of testing prior to January 1,2000, or that readiness has been achieved.
In this way, the staff believes sufficient time is available to make any necessary decisions for further action on a plant specific basis by September 30,1999 including a decision to shutdown a plant. Should the staff identify a situation where the Y2K problem results in a licensee being in noncompliance with the plant license or NRC regulations, appropriate action, including a shutdown order, can be taken as necessary.
In order to provide a more clearly defined decision rationale for addressing unresolved Y2K issues with individual licensees, the staff is working with OGC to develop criteria on which to base shutdown of a plant. The staff's initial thinking is to divide the plant systems into three categories depending on their function and establish criteria for actions to be taken including plant shutdown based on the impact of the unresolved Y2K concerns on the plant license and its compliance with NRC regulations. This criteria will be provided to the Commission, as appropriate, in the Spring 1999.
With the approval of the Commission, the staff released the Draft NRC Y2K contingency plan (COMSECY-98-036) to the public. The staff is obtaining comments on the document from stakeholders including NEl and FEMA in order to finalize the plan in the first quarter of 1999. A key issue on which the staff expects input is the question of evoking the provisions of 10 CFR 50.54 (x) versus the need to develop a policy on enforcement discretion for those unanticipated situations where a Y2K problem creates a condition outside the plant license yet shutdown of the plant, in order to maintain license compliance, may not be the desirable action in view of the recognized need for continued plant operation to ensure grid stability on January 1,2000. The staff will address these options in the final NRC contingency plan.
The staff is also continuing its interactions with the President's Council on Y2K Conversion, other govemment agencies, international nuclear regulatory organizations and foreign govemments on the Y2K problen. Attached for your information is a copy of "The President's Council on Year 2000 Conversion, First Quarterly Summary of Assessment Information" and extracted information from the January 11,1999, North American Reliability Council's Y2K Status Report as it relates te Electric nuclear power plants.
The staff attended a meeting of the Catastrophic Disaster Response Group at FEMA on December 16,1998, at which a number of issues were discussed regarding Y2K contingency planning for the ration as a whole by the Federal government. Issues discussed included staffing of the FEMA headquarters operations center during the year 2000 rollover period, collection and dissemination of information on Y2K failures and events in other countries, and brokering of scarce resources if significant Y2K problems occur in certain areas of the country.
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FEMA is coordinating Fe&sm wovernment activities including conducting regional workshops and a national tabir*@2K exercise in June 1999 in which all affected government agencies will participate ' mddition to the above meeting, the staff met with the Canadian Atomic Energy Control Be-
.a December 1998 to share information on Y2K contingency planning actions.
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sul also participate in the NEA international conference on the Y2K problem in nuclear l
powe plants in Ottawa in February 1999 to exchange information and experiences on the Y2K problem and contingency planning efforts. Further, the staff continues to respond to public and i
media inquiries on its Y2K problem efforts with the assistance of OPA.
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Of further note, on December 10,1998, the staff received three petitions for rulemaking on the Y2K problem from the Nuclear Information and Resource Service. These petitions are being published in the Federal Register for public comment in accordance with the NRC procedures for handling rulemaking petitions. Because of the time constraints imposed by the nature of the Y2K problem, the staff is seeking prompt public input in order to make a timely decision on the need for a rule on the issue.
The staff will continue to provide periodic status reports to update the Commission on its Y2K efforts and the progress of nuclear power plant licensees on addressing the issue.
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