NRC Generic Letter 93-01, Emergency Response Data System Test Program

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March 3, 1993

TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR POWER REACTORS, EXCEPT FOR BIG ROCK POINT AND FACILITIES PERMANENTLY OR INDEFINITELY SHUT DOWN

SUBJECT: EMERGENCY RESPONSE DATA SYSTEM TEST PROGRAM (GENERIC LETTER 93-01)

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to recommend a schedule to addressees for efficiently accomplishing the presently required quarterly testing of the Emergency Response Data System (ERDS), using available telephone lines. The NRC is also issuing this generic letter to recommend an acceptable testing program to addressees, based on experience of both the industry and the NRC in setting up ERDS.

BACKGROUND

On August 21, 1989, the NRC issued Generic Letter 89-15, "Emergency Response Data System," to inform licensees and applicants about the voluntary efforts that certain licensees were taking to implement the ERDS and to solicit the participation of all applicable licensees and applicants in the ERDS program. ERDS is a direct near real-time electronic data link between computer data systems used by licensees of operating reactors and the NRC Operations Center upon declaring an emergency classified as an alert or higher. Subsequently, on October 9, 1990, the NRC published a proposed rule in the Federal Register (55 FR 41095) that would require licensees and applicants to participate in the ERDS program and to establish a schedule for its implementation.

On August 13, 1991, after considering public comments on the proposed rule, the NRC published the final rule in the Federal Register (56 FR 40178). This final rule amended Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) to require licensees to provide hardware and software with specific characteristics to interface with the NRC receiving system (10 CFR Part 50, Appendix E, Section VI, Paragraph 2). The amended Part 50 also requires licensees to test, maintain, and implement the ERDS (10 CFR Part 50, Appendix E, Section VI, Paragraphs 1, 3, and 4, respectively). Finally, the amended Part 50 requires licensees to activate the ERDS in the event of an emergency, classified as an alert or higher (10 CFR 50.72(a)(4)).

The program that has been followed by industry for the past several years in setting up the ERDS system is documented in "Emergency Response Data System (ERDS) Implementation," NUREG-1394, Revision 1, June 1991. This document is referenced in a footnote of 10 CFR Part 50, Appendix E, Section VI. The NRC staff recommendations in this generic letter are based on this experience.Generic Letter 93-01March 3, 1993

REQUESTED ACTIONS

This generic letter is addressed to all facilities for which the final rule applies. This includes all licensed nuclear power reactor facilities, except Big Rock Point (which is exempt because its computer system does not have a sufficient number of parameters available for effective participation in the ERDS program) and those that are permanently or indefinitely shut down (10 CFR Part 50, Appendix E, Section VI, Paragraph 2).

Because the NRC can connect up to three plants simultaneously for testing ERDS, the NRC staff has developed a schedule (Enclosure 1) to test the system efficiently. The NRC recommends, but does not require, that each addressee follow this schedule. Each addressee should arrange ERDS testing with the NRC Operations Center at (301) 492-4102. An NRC test monitor person will be available between 8:00 a.m. and 4:00 p.m. eastern time on days scheduled for testing. The schedule is arranged by weeks of a calendar quarter, with the first week of a quarter taken to be the first entire work week (Monday to Friday) of the quarter. Scheduled test days that fall on Federal holidays will be rescheduled to Monday or Friday of the same week. Retesting may be scheduled and implemented on appropriate Mondays and Fridays per mutual agreement of the NRC and the licensee.

Based on experience of both the industry and the NRC, the NRC staff has developed a testing program that would demonstrate acceptable operation of ERDS. The NRC recommends, but does not require, that each addressee use this testing program. The program consists of demonstrating the ability to

(1) establish a link with ERDS,

(2) transmit all parameters in the plant ERDS database for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> while meeting the requirements of the final rule,

(3) reconnect with ERDS upon a loss of telephone connection, and

(4) terminate the ERDS link.

If an addressee chooses to test the ERDS in a different manner, the addressee should document and retain in appropriate plant records a justification that the alternative program satisfies the final rule.

The ERDS testing program will begin on April 1, 1993.

REPORTING REQUIREMENTS

The NRC will record the results of each test in the NRC Operations Center. Following each test, the NRC will review the transmitted data and inform the licensee of any testing anomalies noted. The NRC does not expect applicable licensees and applicants to submit any report after a test. In the event that the NRC cannot perform the scheduled ERDS test within the quarter, NRC will

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Generic Letter 93-01March 3, 1993

communicate and document this to the affected licensee(s). No written reply is required in response to this generic letter.

BACKFIT DISCUSSION

The final rule requires each licensee and applicant to test the ERDS each quarter. In this generic letter, the staff recommends but does not require (or seek to impose) an ERDS testing schedule and procedure to implement the testing required by the rule. Because the staff recommendations are voluntary in nature, this action is not considered to be a backfit under NRC procedures. The recommended test schedule is designed to efficiently use limited facilities at the NRC Operations Center. The recommended elements of the testing program are based on the experience of both industry and the NRC in setting up the ERDS system during the past several years, as documented in NUREG-1394, Revision 1. The recommended program should enable the licensee or applicant to successfully test the ERDS with a minimum of inconvenience and yet with sufficient detail to ensure satisfactory performance of ERDS.

A notice of opportunity for public comment was published in the Federal Register on August 20, 1992. Comments were received from seven licensed utilities, one industry organization, and one State agency. Copies of two documents containing the staff evaluation of these comments have been made available in the public Document Room (Accession Numbers 9210210136 and 9211040117).

The information collection contained in this request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1994. The estimated average number of burden hours is 4 person hours for each licensee's response (for each unit) each calendar quarter. This estimate of the average number of burden hours pertains to the requested action. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to Ronald Minsk, Office of Information and Regulatory Affairs (3150-0011), NEOB-3019, Office of Management and Budget, Washington, D.C. 20503, and to the U.S. Nuclear Regulatory Commission, Information and Records Management Branch (MNBB 7714), Division of Information Support Services, Office of Information and Resources Management, Washington, D.C. 20555.

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Generic Letter 93-01March 3, 1993

If you have any questions about this matter, please contact John Jolicoeur, Office for Analysis and Evaluation of Operational Data, NRC, or your project manager in this office.

Sincerely,

ORIGINAL SIGNED BY

James G. Partlow Associate Director for Projects

Office of Nuclear Reactor Regulation

Enclosures:

1. ERDS Quarterly Test Schedule

2. List of Recently Issued Generic Letters

TECHNICAL

CONTACT

John Jolicoeur, AEOD (301) 492-4155

LEAD PROJECT MANAGER: John Hickman, NRR (301) 504-3017

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Enclosure 1 GL 93-01 March 3, 1993 Page 1 of 1

ERDS QUARTERLY TEST SCHEDULE

1. This recommended schedule is made necessary because only three telephone lines are available in the NRC Operations Center to ERDS for testing. On some days, for example, the second and eighth Wednesdays of each quarter, a single utility is scheduled to test four units. To accommodate the testing, the licensee should establish a sequence with the test monitor person in the NRC Operations Center, (301) 492-4102.

2. The formal test on the ERDS computer at the NRC Operations Center (step 10 of the ERDS implementation process described on page A-3 of NUREG-1394, Revision 1, "Emergency Response Data System (ERDS) Implementation," which is referenced in 10 CFR Part 50, Appendix E) will serve as the test for the quarter in which it is completed. Quarterly testing as described in the generic letter begins in the next calendar quarter.

3. Applicants receiving operating licenses after the date of this generic letter will be added to this recommended quarterly schedule.

WEEK TUESDAY WEDNESDAY THURSDAY 1 BEAVER VALLEY 1, 2 CALVERT CLIFFS 1, 2 HOPE CREEK FITZPATRICK GINNA INDIAN POINT 2, 3

2 LIMERICK 1, 2 MILLSTONE 1, 2, 3 NINE MILE PT 1, 2 MAINE YANKEE HADDAM NECK OYSTER CREEK

3 PILGRIM SEABROOK SUSQUEHANNA 1, 2 PEACH BOTTOM 2, 3 SALEM 1, 2 THREE MILE ISLAND 1

4 VERMONT YANKEE BROWNS FERRY 2, 3 BRUNSWICK 1, 2 CRYSTAL RIVER 3 SEQUOYAH 1, 2 GRAND GULF

5 CATAWBA 1, 2 FARLEY 1, 2 HATCH 1, 2 McGUIRE 1, 2 ROBINSON HARRIS

6 NORTH ANNA 1, 2 OCONEE 1, 2, 3 SUMMER SURRY 1, 2

7 ST LUCIE 1, 2 VOGTLE 1, 2 BRAIDWOOD 1, 2 TURKEY POINT 3, 4 CALLAWAY BYRON 1, 2

8 CLINTON DRESDEN 2, 3 DAVIS BESSE COOK 1, 2 LASALLE 1, 2 DUANE ARNOLD FERMI 2

9 KEWAUNEE MONTICELLO QUAD CITIES 1, 2 POINT BEACH 1, 2 PRAIRIE ISLAND 1, 2 ZION 1, 2

10 PALISADES ARKANSAS NUCLEAR 1, 2 FT CALHOUN PERRY COMANCHE PEAK 1, 2 SOUTH TEXAS 1, 2 COOPER

11 RIVER BEND DIABLO CANYON 1, 2 PALO VERDE 1, 2, 3 WATERFORD TROJAN WOLF CREEK

12 SAN ONOFRE 2, 3 WASHINGTON NUCLEAR 2