NG-99-0859, Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants,Per GL 98-01.Y2K Readiness Disclosure for Plant Encl

Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants,Per GL 98-01.Y2K Readiness Disclosure for Plant Encl

ML20209A773
Person / Time
Site:	Duane Arnold
Issue date:	06/25/1999
From:	Denise Wilson IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-98-01, GL-98-1, NG-99-0859, NG-99-859, NUDOCS 9907060143
Download: ML20209A773 (3)

Text

f' ALLI ANT UTILITIES IES Unlines Inc.

Duane Arnold Energy Center IES Utilities 32n DAEC Road Palo, I A 52324 97H5 Office: 319.M t.7611 Fax: 319 M1.7986 www.albant-energy.com NG-99-0859 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk '

Mail Station 0-PI-17 Washingtoa, D.C. 20555-0001

Subject:

Duane Arnold E:aergy Center (DAEC)

Docid Ne: 50-331 Op. License No: DPR-49

- Duane Arnold Energy Center's (DAEC's) Response to Generic Letter (GL) 98-01 Supplement 1," YEAR 2000 READINESS OF COMPUTER SYSTEMS AT NUCLEA.R POWER PLANTS" File: A'101b

Dear Sir (s):

The purpose of this letter is to respond to the Nuclear Regulatory Commission's request for information regarding Year 2000 readiness at nuclear power plants. Generic Letter 98-01 requested a response on the status of facility Y2K readiness by July 1,1999.

On January 14,1999, the Commission issued Supplement 1 to Generic Letter 98-01 to modify the request for information in the original generic letter.

The Supplement stated: \

l "In responding to this supplement to GL 98-01, the addressee should confirm Y2K readiness j

of the facility with regard to those systems within the scope of the license and NRC j regulations, and those systems required for continued operation of the facility after January 1,  ;

L 2000. For those systems which are not Y2K ready as of July 1,1999, the addressee should provide a status and completion schedule for achieving readiness by the year 2000." ,d i 9907060143 990625 l PDR ADOCK 05000331.

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Page 2 of 2 NG-99-0859 .

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In response, DAEC is voluntarily reporting facility readiness as outlined in Supplement I to Generic Letter 98-01. Enclosed is the Year 2000 Readiness Disclosure for DAEC, reporting the status of facility Y2K readiness. This disclosure is submitted under the guidelines of the -

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" Year 2000 Information and Readiness Disclosure Act"(Public Law 105-271). q There are no new commitments made in this letter.

Sincerely, David L. Wilson Assistant Vice-President, Nuclear 4

I Enclosed: Year 2000 Readiness Disclosure  !

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- 'ec: L. Sueper S. Haller J. Franz S. Mullooly (Madison)

B. Mozafari (NRC-NRR)

J. Dyer (Region III) l P. Baig (State ofIowa) .

NRC Resident Office Regional Administrator, Nuclear Energy Institute DOCU l

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.NG-99-0859 4

Year 2000 Readiness Disclosure This year 2000 readiness disclosure is made for DAEC under the " Year 2000 Information

. and Readiness Disclosure Act"(Public Law 105-271).

' Tliis disclosure addresses the Y2K readiness of the facility with regard to those systems within the scope of the license, NRC regulations, and other systems required for continued operation of the facility after January 1,2000. A facility that is "Y2K Ready" has followed a i prescribed program to identify and resolve Y2K issues so the facility can operate reliably while meeting commitments.  !

- DAEC has conducted a Year 2000 readiness program similar to that outlined in Nuclear Utility Year 2000 Readiness, NEI/NUSMG 97-07. The program applies to software, hardware and firmware whose failure due to a Y2K problem would prevent the performance of the safety function of a structure, system or component. Additionally, the program applies to any software, hardware, or firmware whose failure due to a Y2K problem would prevent continued operation of the nuclear facility well beyond December 31,1999. The facility program alm includes identifying and, where appropriate, remediating embedded sy stems.

The program provides for risk management efforts and development of contingency plans for-key rollover dates.

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- The Y2K readiness program has been completed for those systems required for operation of the DAEC facility. Based on the completion of those aspects of the Y2K Readiness Program within the scope of Generic Letter 98-01 Supplement 1, the DAEC facility is "Y2K Ready."

Further, contingency plans have been developed to mitigate the impact of Y2K-induced events at key rollover dates.

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. .r UNITED STATED i NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555-0001 January 14,1999 NRC GENERIC LETTER NO. 98-01 SUPPLEMENT 1: YEAR 2000 READINESS OF COMPUTER SYSTEMS AT NUCLEAR POWER PLANTS Addressees All holders of operating licenses for nuclear power plants, except those who have permanently I ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

Purpose The U. S. Nuclear Regulatory Commission (NRC) is issuing this generic letter supplement to provide addresses with a voluntary alternative response to that required in Generic Letter 98-01 on Year 2000 (Y2K) readiness of their respective facilities. This offer is consistent with the Nuclear Energy institute's (NEI) recommendation in their letter to the NRC dated November 9, 1998. The altemative response should provide information.on the overall Y2K readiness of the

- plant, includiiig those systems necessary for continued plant operation which are not covered by the terms and conditions of the license and NRC regulations.

Descriotion of Circumstances On May 11,1998, the NRC issued Generic Letter 98-01, reqtssting information regarding the licensee's programs, planned or implemented, to address the year 2000 (Y2K) problem in computer systems at their facilities.~ Specifically, item (2) under Required Response, requires addressees to provide a written response upon completing the Y2K program or, in any event, no later than July 1,1999, confirming that the facility is Y2K ready, or will be ready, by the year  !

2000 with regard to compliance with the terms and conditions of the license and NRC l

regulations. For incomplete programs as of that date, the licensee is to provide a status report, l

' including completion schedules, of work remaining to be done to confirm the facility is/will be d ready by the year 2000.

~ Since issuance of GL 98-01, increased public awareness and govemment attention to the Y2K problem have resulted in concem over not only public health and safety of nuclear power plants but also concem over the ability of nuclear power plants to continue to provide power to the l national electric power grid. A key aspect of this concem is the recognition of the need for

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GL 98-01,Supp.1 January 14,1999 Page 2 of 4 significant disclosure and sharing of information on the Y2K problem and its impact on the nation's infrastructure as described in the Year 2000 Information and Readiness Disclosure Act (Public Law No: 105-271) which was enacted on October 19,1998. The information requested in this supplement to GL 98-01 is consistent with this Act.

Discussion As discussed in Generic Letter 98-01, the Y2K computer problem pertains to the potential for

. date-related problems that may be experienced by a computer system or an application. The Y2K problem has the potential of interfering with the proper operation of computer systems, hardware that is microprocessor-based (embedded software), and software or databases relied upon at nuclear power plants. Diverse concerns are associated with the potentialimpact of the Y2K problem on nuclear power plants because of the variety and types of computer systems in use. The concerns result from a reliance upon (1) software to schedule maintenance and technical specification surveillance, (2) programmable logic controllers and other commercial  !

off-the-shelf software and hardware, (3) digital process control systems, (4) software to support facility operation, (5) digital systems for collection of operating data, and (6) digital systems to monitor post-accident plant conditions.

Some examples of systems and computer equipment that may be affected by Y2K problems follow:

• Security computers e Plant process (data scan, log, and alarm) and safety parameter display system computers e Radiation monitoring systems e Dosimeters and readers e Plant simulators

. Engineering programs e Communication systems e inventory control systems e Surveillance and maintenance tracking systems

-* Control systems The NRC and the nuclear industry recognized the importance of the Y2K concern to the above systems, even though some of the systems may not be covered by specific requirements of the facility license, because of their impact on the ability of the plant to support the grid and the ,

nation's electric power infrastructure. For this reason, the NRC will permit addressees to provide an alternative response to that identified in item (2) of GL 98-01 which addresses overall plant Y2K readiness. Addressees may still provide the more narrowly focused response required by GL 98-01 on the readiness of only those systems within the scope of the facility license and NRC regulations under the provisions of 10 CFR 50.54 (f). However, addressees are reminded that existing reporting requirements under the provisions of 10 CFR Part 21,10 CFR 50.72,10 CFR 50.73 and 10 CFR 50.9 are still applicable as appropriate when Y2K problems in safety-related systems are identified.

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r GL 98-01,Supp.1 January 14,1999 Page 3 of 4 Voluntary Response Addressees may respond to this supplement to GL 98-01 on or before July 1,1999, in lieu of

' item (2) of GL 98-01 but must respond to one or the other. In responding to this supplement to GL 98-01,'the addressee should confirm Y2K readiness of the facility with regard to those systems within the scope of the 1icense and NRC regulations, and those systems required for continued operation of the facility after January 1,2000. For those systems which are not Y2K ready as of July 1,1999, the addressee should provide a status and completion schedule for achieving readiness by the year 2000.

Address the written response to the U.S. Nuclear Regulatory Commission, Attention:

Document Control Desk, Washington, D.C. 20555-0001.

' Backfit Discussion

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The NRC staff has determined that the backfit rule, Section 50.109 of the Code of Federal Regulations (10 CFR 50.109), does not apply to this generic letter because it only requests i information from addressees (in particular, those addressees who choose to respond to the NRC in the manner described herein, rather than in accordance with item (2) of GL 98-01) that will enable the NRC staff to confirm that a facility is Y2K ready, or will be ready, by the year 2000 with regard to complying with the terms and conditions of the facility license and NRC regulations. Therefore, no backfit analysis was prepared.  ;

Paperwork Reduction Act Statement '

This generic letter contains information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget (OMB), spproval number 3150-0011, which expires on September 30,2000.

The public reporting burden for this collection of information is estimated to average 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per response, including the time for reviewing the instructions, searching data sources, gathering and maintaining the needed data, and completing and reviewing the information collected. This estimate assumes a licensee's response simply confirms that the Y2K program will be completed by July 1,1999. Licensees whose Y2K program will not be completed by July  ;

.1,1999, must submit additional information to the NRC.

l The NRC is seeking public comment on the potential impact of the collection of information contained in this generic letter and on the following issues:

1. Is the proposed collection of information necessary for the proper performance of the functions of the NRC, including whether the information will have practical utility?

2. Is the estimate of burden accurate?

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3. 'is there a way to enhance the quality, utility, and clarity of the information to be collected?

4. How can the burden of the collection of information be minimized, including the use of automated collection techniques?

Send comments on the burden estimate and any aspect of this collection of information, including suggestions for reducing this burden, to the information and Records Management Branch, T-6 F33, U.S. Nuclear {

Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202 (3150-0011), Office of Management and Budget, Washington, D.C. 20503.

The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number, if you have any questions about this matter, please contact one of the technical contacts listed below or the appropriate office of Nuclear Reactor Regulation (NRR) project manager.

/s/'d by David B. Matthews, Director Division of Reactor Program Management  !

Office of Nuc' ear Reactor Regulation Tcchnical

Contact:

Matt Chiramal, NRR 301-415-2845 E-Mail: mxc@nrc. gov Lead Project Manager: Allen G. Hansen, NRR 301-415-1390 E-Mail: agh@nrc. gov l

Attachment:

List of Recently Issued NRC Generic Letters u _