ML20206K338
| ML20206K338 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Brodsky R NEW YORK, STATE OF |
| References | |
| GL-98-01, GL-98-1, NUDOCS 9905130138 | |
| Download: ML20206K338 (11) | |
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[ S I NUCLEAR REGULATORY COMMISSION U
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WASHINGTON, D.C. 20555 4 001
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April 9, 1999 The Honorable Richard L. Brodsky, Chairman Assembly Committee on Environmental Conservation -
New York Assembly -
Albany, New York 12248
Dear Mr. Brodsky:
Thankyou foryourletter of Februa , 1p jip asked Chairman Jackson to help you understand the potential effects 5y ar 30 ) issue on nuclear power plants in and near the State of New York, in your letter,yo,u asgegeven questions and requested any other information that might further yo99 unEs61nding o' f eiis issue.
By way of background information, I am pleased to tell you that over the past several years the U.S. Nuclear Regulatory Commission (NRC) staff has been working with our licensees and continues to maintain an appropriate regulatory framework for overseeing Y2K readiness efforts at all nuclear power plants.
Since 1996, the NRC has been working with nuclear industry organizations and licensees to address the Y2K problem. To ensure that senior-level management at operating U.S. nuclear facilities was aware of the Y2K issue, the NRC issued Information Notice (lN) 96-70, " Year 2000 Effect on Computer System Software," on December 24,1996. IN 96-70 describes the potential problems that nuclear facility computer systems and software might encounter during the transition to the new century. All U.S. nuclear power plants, fuel cycle facilities, and other materiallicensees were provided with copies of this document.
In 1997, the Nuclear Energy institute (NEI) agreed to take the lead in developing industry-wide !
guidance for addressing the Y2K issue at nuclear power reactors. In November 1997, NEl !
issued a guidance documen! to all U.S. nuclear power plant licensees, titled " Nuclear Utility Year 2000 Readiness" (NEl/NUSMG 97-07). !
In May,1998, the NRC issued Generic Letter (GL) 98-01," Year 2000 Readiness of Computer Systems at Nuclear Power Plants." In this GL, the NRC accepted the NEl/NUSMG 97-07 !
guidance as an appropriate program for nuclear power plant readiness. The NRC also required I that all operating U.S. nuclear power plant licensees submit written responses regarding their .
facility-specific Y2K readiness programs in order to obtain confirmation that licensees are i addressing the Y2K issue effectively. Alllicensees have responded to GL 98-01 stating that /
they have adopted plant-specific programs that are intended to make the plants Y2K ready by /
July 1,1999. GL 98-01 also requires a written response, no later than July 1,1999, confirming I that these facilities are Y2K ready. Licensees who are not Y2K ready by J'aly 1,1999, mW provide a status report and schedule for remaining work to ensure timely Y2K readiness.
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- Mr. Brodsky . !
L One of a number of initiatives undertaken by the NRC staff to address the Y2K problem was the conduct of 12 sample audits of licensee Y2K readiness programs. A sample audit approach was determined by the NRC staff to be an appropriate means of oversight of licensee Y2K l- readiness efforts based on the fact that all licensees had committed to the nuclear power industry Y2K readiness guidance (NEl/NUSMG 97-07) in their first response to GL 98-01 and the NRC staff had not identified any Y2K problems in safety-related actuation systems. The 12-licensee sample included large utilities such as Commonwealth Edison and Tennessee Valley Authority (TVA) as well as small single unit licensees such as North Atlantic Energy (Seabrook)
- and Wolf Creek Nuclear Operating Corporation. Because licensee Y2K programs are corporate-wide, many of the NRC staff audits applied to more than a single nuclear power plant j' site since many utilities own more than one nuclear power plant. In all, a total of 42 of 103 operating nuclear power plant units were associated with the Y2K readiness program audits of 12 utilities. The NRC staff selected a variety of types of plants of different ages and locations in
! this sample in order to obtain the necessary assurance that nuclear power industry Y2K
!- readiness programs are being effectively implemented and that licensees are on schedule to meet the readiness target date of July 1,1999, established in GL 98-01, l
in late January 1999, we completed the 12 audits. Based on the results of these audits, we concluded that the audited licensees were effectively addressing Y2K issues and were undertaking the actions necessary to achieve Y2K readiness per the GL 98-01 target date. We did not identify any issues that would preclude these licensees from achieving readiness.
These findings are consistent with those recently reported by the Department of Energy in the report prepared by the North American Electric Reliability Council on the status of Y2K readiness of the electric power grid.
. The NRC staff is not aware of any Y2K problems in nuclear power plant systems that directly impact actuation of safety functions. The majority of commercial nuclear power plants have protection systems that are analog rather than digital. Because Y2K concerns are associated with digital systems, analog reactor protection system functions are not impacted by Y2K issues. Errors such as incorrect dates in print-outs, logs or displays have been identified by licensees in safety-related devices, but the errors do not affect the functions performed by the devices or systems. Most Y2K issues are in balance-of plant and other systems such as security systoms and plant monitoring systems which support day-to-day plant operation but have no direct functions necessary for safe operation of the reactor. These systems are being addressed in the licensee Y2K readiness programs consistent with the industry guidance and G),98-01 schedule.
We have noted from the completed audits that licensee Y2K contingency planning efforts have not progressed br enough for a complete NRC staff review, and, therefore, additional oversight of this area is planned for the Spring of 1999. The NRC staff currently plans to review the contingency planning eff 3rts of six different licensees from those included in the initial 12 sample Y2K readiness aedits, beginning in April 1999 and ending in July 1999. These reviews will focus on the licensee's approach to addressing both internal and external Y2K risks to safe plant operations based on the guidance la NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning."
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H In addition to the NRC staff activities addressed above, NRC inspectors will review plant-p specific.Y2K program implementation activities at all nuclear power plant facilities. The inspectors will be using guidance prepared by the NRC headquarters staff who conducted the 12 sample audits.
- The NRC staff will continue its vigorous oversight of the Y2K issue in nuclear power plants through the remainder of 1999. In July 1999, we will review all licensee responses to GL 98-01 and address any responses that raise concems. By September 1999, we will
- determine the need for issuing orders to address Y2K readiness issuec, including,' if
- warranted, shutdown of a plant. At this time, we believe that all licensees will be able to operate their plants safely during the transition from 1999 to 2000 and do not believe that significant plant-specific action directed by the NRC is likely to be needed.
Neverthelessi the nuclear utility industry and the NRC are developing comprehensive contingency plans to cope with any unanticipated problems should they arise on December 31,1999. This approach is consistent with the defense-in-depth philosophy applied to assuring nuclear safety.
l The NRC staff has examined your questions and has answered them individually in the enclosure.
In response to your request for any other information that might further your understanding of the Y2K problem, I refer you to the NRC Web site at
<http://www.nrc. gov /NRC/ NEWS / year 2000.html>. The Web site identifies Y2K resources, notices, conferences, and other related information that you should find helpful.
' The NRC is committed to ensuring that nuclear power plant licensee Y2K readiness efforts are completed so that these facilities operate safely throughout 1999,2000, and beyond.
Your proactive approach to'this issue as demonstrated by your offer to support and enhance efforts to address Y2K problems is appreciated. Please let me know if you have any additional questions on this matter.
Sincerely, g l William D. Travers Executive Director for Operations l
Enclosure:
As stated DISTRIBUTION: SEE NEXT PAGE
'lDENTICAL LETTER SENT TO THE HONORABLE PAUL D. TONKO.
This correspondence formulates policy or expands, revises, or interprets policy, involves matters pending Commission decision, contains items relating tu the performance of Commission dutie.s and responsibilities, or involves items of high Commission interest.
ument Neme: A:\N NC ENCES ETQP AND A /NYGTONKogP *SEE PREVlouS OFFICE 'EICB:DE ' TECH ED 'AC/EICB:DE *C/EELB:BC 'D/DE NAME KMortensen:nkw RSanders JMauck JACalvo JStrosnider DATE 03/25/99 03/18/99 03/6/99 03/8/99 03/23/99 mm. -
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OFFICE 'ADT/NRR 'D/NRR h C NAME BWSheron SCollins ( YT SAJac on l 'DATE- 03/25/99 03/25/99 31/99 oh T /99 OFFICIAL RECORD COPY.
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Responses to Questions About the Effects of the Year 2000 Problem
- The NRC staff has addressed the following seven questions from your letter.
Question 1:-
is NRC aware of any scenario related to the year 2000 computer problem which:
- a. could result in the release of radiation or radioactive material from a nuclear power plant,
- b. could result in the release from a nuclear power plant of any other material, e.g. an unusually large release of cooling water, which could have adverse environmental effects, or
- c. - could otherwise compromise the safety of its operation?
Please explain any scenario which meets any of the above criteria. If the answer to any of the categories above is in the negative, please explain the basis for your confidence that these problems could not arise.
Resoonse to Question 1:
'The NRC is not aware of any scenario related to the year 2000 (Y2K) computer problem that could result in the release of radiation or radioactive material from a nuclear power plant. -To date, the NRC staff has not identified or been apprised of any Y2K problems in nuclear power plant systems that directly affect actuation of safety functions. The majority of commercial nuclear power plants have protection systems that are analog-based rather than digital- or software-based, and thus are not affected by the Y2K issue.
Errors such as incorrect dates in printouts, logs, or displays have been identified by licensees in some safety-related devices, but the errors do not affect the safety functions performed by the devices or systems.
The NRC is not aware of any scenario related to the Y2K computer problem that could result in the release from a nuclear power plant of any material that could have harmful environmental effects. Any credible scenarios involving failure of balance-of-plant and other systems have been previously analyzed and found to be within environmentally acceptable limits. Additionally, these systems are being addressed in the licensee Y2K readiness programs consistent with the industry guidance and Generic Letter (GL) 98-01 schedule.
The NRC is not aware of any scenario related to the Y2K computer problem that could otherwise' compromise the safety of the operation of a nuclear power plant. In GL 98-01 it was also noted that despite the best of efforts to achieve Y2K readiness, unanticipated problems (particularly events external to a plant) could occur and could disrupt continued Enclosure t
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plant operation. Therefore, contingency plans are needed to address potential unanticipated Y2K problems. To respond to this need, in August 1998, the Nuclear Energy institute (NEI) issued another guidance document, " Nuclear Utility Year 2000 Readiness Contingency Planning" (NEl/NUSMG 98-07), which is being incorporated into ,
- Y2K readiness programs by all U.S. nuclear power plant licensees. These detailed plant-specific Y2K contingency plans also are scheduled to be completed by July 1,1999.
. Question 2:
What are the major factors external to the nuclear power plant itself that could contribute to or exacerbate a problem related to the year 2000 computer problem at the nuclear power plant? How is NRC planning to assist its licensees in planning to cope with these -
problems?
Resoonse to Question 2:
'The NRC's approach to coping with the potential problems posed by external problems is two fold. First, the NRC is working with its licensees to ensure that potential Y2K problems are identified and appropriately addressed before the year 2000. Second, recognizing that the potential for Y2K problems initiated external to the nuclear plant cannot be totally precluded, the NRC is working with its licensees to ensure that they are developing contingency plans to cope with such events should they occur. ,
Some of the ma' jor factors external to the nuclear power plant that could contribute to or exacerbate a problem related to the Y2K problems include (1) loss of the electrical grid, (2) -
loss of the normal supply chains for critical consumables, and (3) loss of communications ;
links. A' discussion of these external factors follows:
(1)- _ With regard to the loss of the electrical grid, external electrical grid system problems that could arise as a result of a Y2K problem are loss of offsite power, grid instability, voltage and frequency fluctuations, circuit breaker malfunctions, load fluctuations, and loss of grid control systems. All operating nuclear power plants in the United States are designed to cope with external electrical grid system problems. The scope 'of licensees' .Y2K programs cover the emergency onsite power systems. NRC audit results to date have verified the licensees' consideration of these systems and have not identified any associated Y2K problems. Emergency onsite power is usually provided by diesel generators, which
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supply' electric power to the plant safety systems upon a loss of all offsite power from the external power grid. NRC regulations require that the onsite electric power supplies and onsite_ electric distribution system shall have sufficient
! independence, redundancy, and testability to perform their safety functions assuming a single failure. Thus by design, normally a single emergency diesel generator with its dedicated set of safety system equipment is capable of safely shutting down the reactor and maintaining it in a safe condition. The operation and maintenance of the emergency diesel generators and the other safety-related
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4 equipment necessary for the safe shutdown of the reactor are controlled by the plant technical specifications (TSs). One of the plant TSs requires the emergency diesel generators to be tested routinely in order to demonstrate their operability and capability of supplying power as needed. This test ensures a high level of
. readiness and reliability.
The electric power industry has an aggressive program for monitoring industry-wide Y2K progress that is being coordinated by the North American Electric Reliability Council (NERC). More than 95 percent of the Nation's 3,000 electric power .
companies participated in NERC's most recent survey of industry progress.
- According to NERC, the industry has completed work on more than 50 porcent of its critical systems and is committed to achieving 100-percent compliance by June j
30,1999. Massive national disruptions in electric power are unlikely. The possibility of minor local outages can never be completely ruled out. However, the electric power industry is ready to meet that challenge each day because of the many naturally occurring events, such as storms and floods, that it must be prepared to handle as part of current standard operating procedures.
- (2)- With regard to lots of the normal supply chains for critical consumables, the licensees are assessing the potential problems in these areas and are including ,
them in their contingency plans, which will be based on the guidance in ,
~ NEl/NUSMG 98 07, " Nuclear Utility Year 2000 Readiness Contingency Planning." l Because of the nature of the Y2K problem, it is not possible to be 100-percent ,
certain that all potential problems that could affect NRC licensees (e.g., Y2K l problems outside the direct control of licensees) will be addressed. For this reason, the NRC staff has daveloped a draft NRC Year 2000 Contingency Plan for helping -
to ensure that the NRC resources are in place should unforeseen Y2K problems occur. The NRC_ Year 2000 Contingency Plan is a rapidly evolving product, subject
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to coordination efforts with other Federal agencies and with NRC licensees. To - '
initiate this coordination effort, the plan han been made available to the public in s order to promote valuable communication and dialogue regarding the proposals discussed therein (Federal Reaister: January 20,1999, Volume 64, Number 12, pages 3139-3140). In its current form, the plan proposes actions and approaches involving policy issues that have not had the benefit of formal Commission review and guidance; however, the Commission is giving this subject high priority and these issues will be resolved well before the time necessary to support the Y2K l
- transition. A copy of the draft contingency plan can be obtained via the World Wide Web at <http://www.nrc. gov /NRC/Y2K/Y2KCP.html> or from the NRC's Public Document Room, 2120 L Street, NW (lower level), Washington, DC 20003 . <
1527; telephone 202-634-3273; fax 202-634-3343.
-(3) With regard.to the potential loss of communications, the licensees' readiness
. programs include actions to assure that reliable Y2K-ready communications will be available. The NRC is planning to provide additional communications support to its licensees as is discussed in our response to your Question 3, below.
g 9 e 4-Question 3:
- We understand that NRC's' Emergency Response Data System is directly linked to
.~ operating nuclear power' plants. What measures, if any, has NRC adopted to deal with a loss of communications between NRC and any of its licensees? Can a nuclear power plant continue to operate safely and reliably if the communications links fail? Will a plant have the option to continue in operation without a direct link to NRC?
Response to Question 3:
' The Emergency Response Data ' System (ERDS) performs the communication and data transmission functions that provide near real-time data to NRC incident response personnel- )
during declared emergencies. We have verified that this system has been made Y2K l compliant and that the interface of the system with licensed facilities is functional. !
l The NRC provides an Emergency Telecommunications System (ETS) at all commercial nuclear power plants. This system provides seven essential communication functions in the Control Rooms, Technical Support Centers, and Emergency Operations Facilities. The ETS is carried on dedicated lines to the Federal Telecommunications System (FTS) 2000
- network. This network is separate from the public switched telephone network. The General Services Administration (GSA) has advised the NRC that the FTS 2000 network will be Y2K ready by July 1999, in addition to the ETS, the NRC may be contacted via l the public switched network.' The NRC has worked extensively with the Office of the Manager, National Communications Systems (NCS) to keep abreast of Y2K developments I in the public switched network. We have been advised that interoperability testing for all of the major telephone vendors and networks is in progress and that the major portions of the public switched network will be Y2K ready by mid-1999. We are also working closely with NCS to ensure that the switches in the small local telephone companies near our
- licensed facilities are being upgraded as necessary. The NRC also participates in the Emergency Response Link program, which provides a secure Internet communication path for information exchange, and in the NCS' National Telecommunication Coordination Network (NTCN), which is a dedicated network, independent of the public switched network, for coordination of emergency telecommunication issues. As part of the NRC Y2K Contingency Plan, the NRC is initiating an effort to provide at least one portable
- satellite telecommunications unit at each nuclear power plant in the United States. This channel of communication will be sufficient to provide adequate notification of any l events. If normal telephone access to the NRC Operations Center is lost, the site could still communicate with the NRC via either direct satellite communication or via satellite link relayed through the NTCN.
A nuclear power plant can continue to operate safely and reliably if the communication links fail.- These communication functions are not safety systems and are not directly l related to operation at the plant. ' Th'ey are used to provide information to the NRC in the case of an event at a licensed facility. Loss of ERDS or any of the other emergency
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5 telecommunications functions would not be sufficient justification to shut down a power plant.' Nuclear power plants may continue to operate without a direct link to the NRC.
9 Question 4: -
Does NRC plan to audit nuclear power plants to assure the safety of the plants at critical times in the transition to the year 20007 If so, please explain NRC's specific audit
- procedure in this regard.
Response to Question 4:
As previously discussed, the NRC Headquarters staff has conducted audits of the Y2K effort at 12 sample plants. The auditors have found that the licensees are devoting
.the necessary resources to their programs to meet their readiness schedules. The NRC will review Y2K computer program activities at all nuclear plant facilities beginning in April
-1999 to ensure they will be able to function safely on January 1,2000, and beyond. In addition, the NRC will conduct special audits of Y2K contingency plans at six plants, including Indian Point 2 in New York. The audits at these facilities will examine in more detail backup measures the utilities have in place to deal with possible Y2K problems, either onsite or offsite, that might affect plant operations, it is currently our intent to have these reviews completed by July 1999.
The reviews will allow NRC to check on the progress of all power reactor licensees and determine whether any regulatory action is needed. Information from the reviews also will be used in conjunction with status reports NRC has directed its licensees to provide by July 1,1999. The reviews will be conducted between April 1 and June 30 by NRC inspectors. The reviews will (1) verify that all NRC power reactor licensees have implemented Y2K program activities; (2) evaluate the progress they have made to assure they are on schedule to achieve Y2K readiness; and (3) assess their contingency plans for addressing Y2K-related problems.
Inspectors conducting the Y2K reviews will receive special training. Their inspection manual and Y2K audit checklist have been posted on the NRC Internet web page at
<http://www.nrc/ gov /NRC/ NEWS / year 2000.html>. The NRC also plans to post results of the reviews after they are complete. This web site has additional information relating
- to steps NRC !s taking to deal with the Y2K problem.
Question 5:
Has NRC determined how nuclear power plants in or close to New York state compare to similar plants in the northeast and the rest of the nation in terms of the potential for year
__2000 problems? Does NRC have plans to provide additional auditing or monitoring for nuclear power plants that seem more vulnerable to such problems?
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I I Resoonse to Question 5: I The NRC has found no indication that nuclear power plants in or close to the State of e New York are more vulnerable than similar plants in the Northeast or the rest of the Nation .
In terms of the potential for Y2K problems. The NRC staff will continue its vigorous oversight 'of the Y2K issue in nuclear power plants through the remainder of 1999. In July 1999, we will immediately review all licensee responses to GL 98-01 and address any that may raise concerns, in addition to the 12 audits already completed, inspector
. raviews will be performed at all reactor sites. If any of these activities identify plants with particular vulnerabilities, the NRC will take appropriate regulatory action. By September 1999 we will determine the need to issue orders to address Y2K readiness, including, if warranted, shutting down a plant.
Question 6:
Will NRC review and approve contingency plans cf nuclear power plants? If so, what criteria will NRC apply to assure that the plans are adequate? What action plans will the NRC implement in the event that unforeseen consequences occur despite best efforts under contingency plans?
Response to Question 6:
The nuclear utility industry and the NRC are developing contingency plans to cope with i any unanticipated problems if they arise in connection with the transition'from 1999 to l 2000. The NRC staff currently intends to review the contingency planning efforts of six i facilities (including Indian Point 2 in New York) that were not reviewed in the initial 12
, audits. These reviews will take place between April and June 1999. In addition, NRC i
inspectors will carry out site-specific evaluations of the licensees' Y2K contingency plans.
These re. views will focus on the licensees' approach to addressing both internal and !
external Y2K risks to safe plant operations on the basis of the guidance for contingency planning in NEl/NUSMG 98 07. By September 1999, we will determine the need for the issuing of orders to address Y2K readiness issues, including those mentioned above.
The NRC plans to conduct a " dry run" in early October 1999 of the activities expected to occur during the actual year 2000 transition in this dry.run we will attempt to ensure that all aspects of the contingency plan are in place. Plans are being made to include some nuclear power plant licensees in the exercise.
l Additionally, as year 2000 approaches, the NRC will be monitoring plant conditions and l- ' licensee activities, both remotely from NRC Headquarters and locally at each reactor site.
l This monitoring will begin well before midnight, December 31,1999, in order to include
' evaluation of international experience as reactors located in time zones to the east of the United States go through the transition. Extra staff will be on duty as needed to provide this monitoring.
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Question 7:
What specific actions can the New York State Assembly take to support and enhance the
- efforts of the NRC and local nuclear power plants to avoid adverse effects resulting from the year 2000 problem?
Resoonse to Question 7:
With regard to specific actions that the New York State Assembly can take to support and enhance the efforts of the NRC and local nuclear power plants to avoid adverse effects resulting from the Y2K problem,'there are many concerns regarding the infrastructure that are beyond the authority of the NRC. Your committee could contact the individual nuclear utilities in the State of New York to determine what assistance might be helpful. The
- utilities may be able to identify portions of their contingency plans in which the State could assist.
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