NRC Generic Letter 1989-15
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C.20555 August 21, 1989 TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR
NUCLEAR POWER PLANTS*
SUBJECT: EMERGENCY RESPONSE DATA SYSTEM - GENERIC LETTER 89-15 The Commission is in the process of implementing an Emergency Response Data System (ERDS). The ERDS will provide direct electronic transmission of a limited set of parameters from a licensee computer to the NRC during an emergency at a licensed nuclear power facility. Implementation is proceeding on a voluntary basis and efforts are being taken to minimize the burden on the participating facilities. We believe that the implementation of this system will be beneficial to both the NRC and licensees for the reasons explained below.
The Commission has defined the NRC's primary role in an emergency at a licensed nuclear facility as-one of monitoring the licensee to assure that appropriate recommendations-are made with respect to offsite protective actions. Other aspects of our role include supporting the licensee with technical analysis and logistic support, supporting offsite authorities, including confirming the licensee's recommendations to offsite authorities, keeping other Federal agencies and entities informed of the status of the incident, and keeping the media informed of the NRC's knowledge of the status of the incident.
To fulfill the NRC's role, the NRC requires accurate, timely data on four types of parameters: (1) core and coolant system conditions must be known well enough to assess the extent or likelihood of core damage; (2) conditions inside the containment building must be known well enough to assess its status;
(3) radioactivity release rates must be available promptly to assess the from immediacy and degree of public danger by these pathways; and (4) the data the plant's meteorological tower is necessary to provide insight into the potential distribution of a release.
Experience with the voice-only emergency communications link, currently of utilized for data transmission, has demonstrated that excessive amounts or time are needed for the routine transmission of data and for verification correction of data that appear questionable. Error rates have been excessive and the frequency of updates has been unreliable.
The ERDS concept is a direct electronic transmission of selected parameters (Enclosures 1 and 2) from existing facility electronic data for systems which have been established by the licensees. The ERDS would be use only during and would be activated by the licensees upon emergencies at the facilities declaration of an ALERT or higher emergency classification to begin transmission to the NRC Operations Center. The ERDS would be supplemented with voice transmission over the existing Emergency Notification System (ENS) of essential data not available on licensees' systems, rather than requiring modifications to existing systems.
- e p e 3 Tor special instructions for certain plants.
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Generic Letter 89-15 - 2 -
August 21, 1989 The utility is expected to provide an output port system and the necessary software to assemble on the appropriate data the personnel action should be required for the acquisitiondata to be transmitted. No data after activation of the system. or transmission of Accuracy and reliability are expected to be excellent human interfaces and many data systems, such as because there are no System (SPDS), will incorporate automatic data the Safety Parameter Display validation.
be excellent because the system would be immediately Timeliness should rapid transmission with frequent updating. Parametric available and capable of be excellent because the primary objective of coverage is expected to the provide the licensee with a tool for quickly assessing SPDS requirement is to of the plant, i.e., the same need that the NRC the overall status communications would be directed toward plant faces. Therefore, voice rather than individual instrument readings. conditions and plant response Tests of the ERDS concept have been conducted and with Commonwealth Edison (LaSalle and Zion).with Duke Power Company (McGuire)
that there is great value in using electronic These tests have demonstrated limited set of reliable, time tagged data. The data transmission for obtaining a more efficiently and their assessments were more NRC response teams functioned the ability to focus on significant factors and timely. Major improvements in were noted. The questions that were asked of to predict the course of events the overall status and corrective actions being considered licensee were focused on the requests, thereby reducing the volume of voice rather than simple data communications.
Actual work on the ERDS project began in 1985 with an initial feasibility survey conducted at approximately 80 percent facilities in the United States. of the licensed nuclear An ERDS implementation contractor began work in activities of the contractor have focused on an January 1988. The initial results, the production of final NRC hardware indepth review of the survey and procurement of the necessary hardware and software.software designs and the with an initial set of utilities that have agreed We are currently working to establish initial plant connections in 1989. to participate and we expect implementation with this initial group will be The lessons learned in participants. Extensive interactions were held fed back to the subsequent ERDS program was discussed at the NRC Regulatory with NUMARC. Additionally, the April, 1989. We hope to complete all plant connections Conference with industry in Enclosed is a list of frequently asked questions by early 1992.
you in a better understanding of the ERDS program.and our answers to assist This request is covered by Office of Management
3150-0011 which expires December 31, 1989. The and Budget Clearance Number is 150 person hours per licensee response, including estimated average burden hours formulation of licensees' position, and preparation staff and management review, These estimated average burden hours pertain only of the requested response.
related matters and do not include the time for to these identified response- any follow on implementation.
t- Generic Letter 89-15 - 3 - August 21, 1989 Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Records and Reports Management Branch, Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Commission Washington, D.C. 20555; and to the Paperwork Reduction Project
(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
We believe the benefits to the overall incident response capability are substantial and the costs to each utility are small. We would like to continue implementation on a voluntary basis. The purpose of this generic letter is to solicit the participation of those utilities which have not yet volunteered* in the ERDS program. Since we also plan to contact each utility individually, please provide an appropriate contact in your organization for followup discussion. Should you have any questions, please feel free to call Gary Zech, Chief, Incident Response Branch at (301) 492-4193 or have your staff call John Jolicoeur, ERDS Project Manager at (301) 492-4155.
Sincerely, Ja esG. Partlow As ociate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. PWR Parameter List
2. BWR Parameter List
3. Questions and Answers List
4. List of Most Recently Issued Generic Letters
- This generic letter is for information only for Zion, Dresden, Quad Cities, Byron, LaSalle, Braidwood, Palisades, Three Mile Island, Oyster Creek, Fitzpatrick, Ft. St. Vrain, LaCrosse, Big Rock Point, Rancho Seco, Davis Besse, Oconee, McGuire and Catawaba because these facilities are exempt from providing a response since they fall into one of the following categories:
1. Licensee has already volunteered
2. Reactor facility is inactive
3. Reactor facility has been deemed inappropriate for connection to ERDS.
Enclosure 1 PWR Parameter List Primary Coolant System Pressure Temperatures - Hot Leg Temperatures - Cold Leg Temperatures - Core Exit Thermocouples Subcooling Margin Pressurizer Level RCS Charging/Makeup Flow Reactor Vessel Level (When Available)
Reactor Coolant Flow Reactor Power Secondary Coolant System Steam Generator Levels Steam Generator Pressures Main Feedwater Flows Auxiliary/Emergency Feedwater Flows Safety Injection High Pressure Safety Injection Flows Low Pressure Safety Injection Flows Safety Injection Flows (Westinghouse)
Borated Water Storage Tank Level Containment Containment Pressure Containment Temperatures Hydrogen Concentration Containment Sump Levels Radiation Monitoring System Reactor Coolant Radioactivity Containment Radiation Level Condenser Air Removal Radiation Level Effluent Radiation Monitors Process Radiation Monitor Levels Meteorological Wind Speed Wind Director Atmospheric Stability
Enclosure 2 BWR Parameter List Primary Coolant System Reactor Pressure Reactor Vessel Level Feedwater Flow Reactor Power Safety Injection RCIC Flow HPCI/HPCS Flow Core Spray Flow LCPI Flow Condensate Storage Tank Level Containment Drywell Pressure Drywell Temperatures Hydrogen and Oxygen Concentration Drywell Sump Levels Suppression Pool Temperature Suppression Pool Level Radiation Monitoring System Reactor Coolant Radioactivity Level Primary Containment Radiation Level Condenser Off-Gas Radiation Level Effluent Radiation Monitor Process Radiation Levels Meteorological Wind Speed Wind Director Atmospheric Stability
Enclosure 3 ERDS QUESTIONS AND ANSWERS
1. Will the implementation of the EROS affect the NRC response role or the way that role is fulfilled?
No. The NRC response role was defined and approved by the Commission and would not change due to the ERDS. Current response activities, including discussions with the licensee, will be done more quickly and efficiently due to ERDS implementation but would not materially change.
2. What communication protocol will be set up to accomplish the EROS
implementation?
A generic letter providing information about the EROS and plans for its implementation will be promulgated to all licensees requesting their participation in the program.
Once a utility has committed to participate in the EROS project, it will be contacted by telephone by the AEOD EROS project manager and the NRC contractor to make arrangements for a site specific implementation schedule.
The NRC will send a questionnaire to the licensee to obtain necessary preliminary information about the licensee's computer system and the EROS
parameters. For many licensees this questionnaire will also serve to
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confirm data obtained during the ERDS feasibility study conducted in Response to this questionnaire should be forwarded to the NRC and its contractor. Any questions or problems concerning the questionnaire sht be referred to John R. Jolicoeur, AEOD EROS Project Manager at (301)
492-4155 or Tony LaRosa, ERDS Project Manager, EI International at (208
529-1000.
After this information has been reviewed, we will proceed with the systf implementation process as described in the response to the following question.
3. How will the plant specific design and implementation aspects of EROS b finalized with a facility?
Once a utility has committed to participate in the EROS project, an ir meeting will be held at the licensee's facilities with the NRC and ou implementation contractor. The topics to be discussed include:
The data points available on the licensee's computer to be transmitted that best satisfy the NRC parameter list.
The computer or computers that will be sending the data str'
their operating characteristics.
The data stream characteristics and communications metho(
EBCDIC) to be used to transmit the data.
- 3- Any hardware and software required for the ERDS implementation. The plant specific implementation schedule based on plant capabilities, the need for hardware additions or modifications, and software development requirements.
Subsequent ERDS development and initial testing will be done based on the agreed upon schedule.
4. What is the current program schedule?
Software is being developed by the NRC's contractor and should be completed by late summer 1989. The first utility on line to the NRC
Operations Center in Bethesda'is scheduled for early 1990 with subsequent connections scheduled over a 2 to 3 year period.
5. Will the implementation of the ERDS require significant equipment modification or addition by licensees?
The only equipment requirements are for the hardware that is needed to provide the data stream from the current licensee equipment that processes the requested data. Should the computer system not be capable of producing
.the data stream for transmittal, then the ERDS will be implemented as site equipment modifications permit. Approximately 5 to 10 percent of the licensee's systems are running at close to 100 percent processing capacity in the post trip or incident environment, and approximately 10 to
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15 percent of the licensee systems are hardware limited (e.g. no available output port for an ERDS connection). The EROS will follow, not drive, licensee equipment modifications. For those licensees where no new hardware is required, the costs per reactor unit are estimated in the range of $20K to $50K. This estimate includes labor costs associated with software development, design change notice documentation, testing, and procedure development. At the upper end of the cost spectrum, the survey revealed that two plant sites would require additional computer equipment to provide the necessary ERDS feed. The hardware costs were estimated at $150K plus licensee staff time required to set up a custom system development effort with the appropriate contractor.
6. Will the EROS be considered safety grade or require redundant equipment?
No. The ERDS feed will be as reliable as the current licensee equipment providing data to the licensee's own TSC and EOF. The addition of new plant instrumentation or computer data points to provide EROS data will not be required.
7. Will the current data list be expanded?
No. The issue has been well studied since the Nuclear Data Link was originally proposed after TMI. The development of the data list followed our determination of our role in an emergency and provides the information we need to perform that role. Needed data not transmitted over ERDS will still be passed over the ENS.
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8. Must the ERDS be used to transmit drill data?
That is not a design requirement. For those system configurations which only allow the transmission of real data, no modification will be expected. However, if the licensee system is used for drills and can provide the transmission of the drill data, we would like to use the capability for our drill participation.
9. Will the EROS be an LCO or Tech Spec item?
No.
10. How soon does the NRC expect the system to be initiated after an Alert declaration?
The EROS should be initiated when the licensee notifies the NRC of the declaration of an Alert or higher emergency classification.
11. Will the transmission of data point values for times prior to the time of the EROS activation be required?
No. Only the data values from the time of the transmission initiation will be required over the EROS. Information on initiating conditions and plant status will be provided over the verbal communication line as necessary. Specifically, earlier parameter values will not be required.
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If a licensee system has the capability to transmit earlier data point values the NRC would like to utilize that feature but it clearly is not a
design requirement.
12. Once the ERDS is implemented, will continuous manning of the ENS (Red Phone)
still be required?
Yes. The EROS will not eliminate the need for verbal transmission of information such as licensee actions, recommended protective actions, and supplemental event-specific data not provided by ERDS. Emphasis will be given to producing no new impact on Control Room personnel due to the transmission of data over the ERDS.
13. What procedures and system controls will be required for the ERDS?
A procedure will be required for activation of the system during emergencies, probably an emergency plan implementing procedure, and for conducting system tests with the NRC. Any procedures or controls for system verification and validation or configuration control should be done in conformance with existing plant procedures as modified to require prompt notification of the NRC for any change which affects ERDS
parameters or the ERDS data stream.
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14. Will the ERDS data be provided to State authorities?
in Although the NRC is not soliciting or recommending State participation the ERDS program, one provision of the systems design is user ports for States within the 10 mile plume exposure EPZ. This provision was made to a
reduce the likelihood of different data being provided to the NRC and State because of differing data sets where the State has decided to collect a
data. This provision is not expected to affect States that already have in data collection system. If a State expresses a desire to participate a
the ERDS program, the NRC will provide ERDS data to that State under of specific Memorandum of Understanding. The purpose of this Memorandum Understanding would be to specify communication protocols for clarifica- tion of ERDS data and data security requirements. The NRC would provide those States with contractor developed software and make one output port available to the State from the NRC Operations Center. The States would have to obtain compatible PC hardware and licensed software used in the ERDS system to receive the data. This will ensure that all parties involved are using the same data base for their analysis. Any request made by a State to set up the capability to receive the data will be discussed with the utility.
15. Will the NRC require a periodic test of the ERDS, and if so how frequently?
The NRC does expect that periodic testing will be required to ensure system operability. Currently we expect that testing will be done quarterly. Should system reliability permit, the frequency of testing may
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-8- be reduced. Testing of a State link portion of the system will be done with the NRC. Therefore, no licensee participation will be required for this test.
16. Will participation in the ERDS program remain voluntary?
The NRC is reviewing the need for rulemaking to require the implementation of ERDS at all nuclear power plants in the event the voluntary program is not achievable. It is anticipated that the provisions of a proposed rule would be the same as those of the voluntary implementation program currently in effect.
17. What will be the boundary of system maintenance responsibility?
The NRC will be responsible for maintenance of all parts of the ERDS
system installed starting at the input port of the first ERDS-specific piece of hardware (e.g. modem for single feeder plants and multiplexer for multi-feeder plants).
Enclosure 4 LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. Subject Issuance Issued To
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89-15 EMERGENCY RESPONSE DATA 08/21/89 ALL HOLDERS OF
SYSTEM GENERIC LETTER NO. OPERATING LICENSES
89-15 OR CONSTRUCTION
PERMITS FOR NUCLEAR
POWER PLANTS
89-07 SUPPLEMENT 1 TO GENERIC 08/21/89 ALL LICENSEES OF
LETTER 89-07, "POWER REACTOR OPERATING PLANTS,
SAFEGUARDS CONTINGENCY APPLICANTS FOR
PLANNING FOR SURFACE OPERATING LICENSES,
VEHICLE BOMBS" AND HOLDERS OF
CONSTRUCTION PERMITS
89-14 LINE-ITEMS TECHNICAL SPECIFI- 08/21/89 ALL LICENSEES OF
CATION IMPROVEMENT - REMOVAL OPERATING PLANTS,
OF 3.25 LIMIT ON EXTENDING APPLICANTS FOR
SURVEILLANCE INTERVALS OPERATING LICENSES,
(GENERIC LETTER 89-14) AND HOLDERS OF
CONSTRUCTION PERMITS
89-13 GENERIC LETTER 89-13 7/18/89 LICENSEES TO ALL
SERVICE WATER SYSTEMS POWER REACTORS
PROBLEMS AFFECTING BWRS, PWRS, AND
SAFETY-RELATED EQUIPMENT VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
89-12 GENERIC LETTER 89-12: 7/6/89 LICENSEES TO ALL
OPERATOR LICENSING POWER REACTORS
EXAMINATIONS BWRS, PWRS, AND
VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
89-11 GENERIC LETTER 89-11: 6/30/89 ALL BWR PLANTS &
RESOLUTION OF GENERIC ISSUE ALL LISTINGS
101 "BOILING WATER REACTOR APPLICABLE TO
WATER LEVEL REDUNDANCY" GENERIC LETTERS &
VENDORS, ETC.
89-10 GENERIC LETTER 89-10: 6/28/89 LICENSEES TO ALL
SAFETY-RELATED MOTOR-OPERATED POWER REACTORS,
VALVE TESTING AND SURVEILLANCE BWRS, PWRS, AND
VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
Generic Letter 89-15 - 3 - August 21, 1989 Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Records and Reports Management Branch, Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Commission Washington, D.C. 20555; and to the Paperwork Reduction Project
(3150-00111, Office of Management and Budget, Washington, D.C. 20503.
We believe the benefits to the overall incident response capability are substantial and the costs to each utility are small. We would like to continue implementation on a voluntary basis. The purpose of this generic letter is to solicit the participation of those utilities which have not yet volunteered* in the ERDS program. Since we also plan to contact each utility individually, please provide an appropriate contact in your organization for followup discussion. Should you have any questions, please feel free to call Gary Zech, Chief, Incident Response Branch at (301) 492-4193 or have your staff call John Jolicoeur, ERDS Project Manager at (301) 492-4155.
Sincerely, Originai signed by James G.Partlow James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. PWR Parameter List
2. BWR Parameter List
3. Questions and Answers List
4. List of Most Recently Issued Generic Letters
- This generic letter is for information only for Zion, Dresden, Quad Cities, Byron, LaSalle, Braidwood, Palisades, Three Mile Island, Oyster Creek, Fitzpatrick, Ft. St. Vrain, LaCrosse, Big Rock Point, Rancho Seco, Davis Besse, Oconee, McGuire and Catawaba because these facilities are exempt from providing a response since they fall into one of the following categories:
1. Licensee has already volunteered
2. Reactor facility is inactive
3. Reactor facility has been deemed inappropriate for connection to ERDS.
DISTRIBUTION
Central File Memo to Murley from Jordan dated July 27, 1989, JHickman has concurrences and also CRGR approval.
NRC PDR
Miraglia
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8/;;/89 8/ /89
August 21, 1989 ,
MEMORANDUM FOR: All NRR Project Managers FROM: James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation SUBJECT: EMERGENCY RESPONSE DATA SYSTEM GENERIC LETTER NO. 89-15 Enclosed is a copy of Generic Letter 89-15 on the Emergency Response Data System (ERDS). The ERDS, as described in the Generic Letter, is a direct electronic link between an emergency response oriented data system currently used by the licensee to a data system at the NRC's Operations Center. The ERDS would transmit a limited data set (approximately 65-100 points), only during emergencies (Alert or above), and would be activated by the licensee.
Participation in the development of the ERDS is currently voluntary, although rulemaking is under way, therefore, a commitment to participate is not required by this letter.
When the licensee for the plant to which you are assigned responds with a point of contact, please provide a copy of that response to the lead PM, John Hickman (mail stop 13-D-1), so that he can forward it to the appropriate AEOD staff.
Questions on this Generic Letter can be addressed to John Hickman at X23017.
Original signed by James G.PaWtoW
James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
Generic Letter 89-15 cc w/enclosure:
J. Taylor, EDO
H. Thompson, DEDS
Division Directors, NRR
Associate Directors, NRR
Project Directors, NRR
Regional Administrators J. Conran, CRGR
H. Silver, NRR
C. Berlinger, DOEA
S. Treby, OGC
Distribution:
Central Files HSmith JHickman JPartlow NRCPDR
[ERD PM MEMO]
OFC :PD3-S :ADP:::::
NAME :J Ickman:ps :JPartl : : :
DATE :8/:2/89 :8/21/89 : : *
OFFICIAL RECORD COPY