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1998-05-12 11:05:49


Deadline for Nuclear Power Plants' Compliance: July 1, 1999



The NRC issued a follow-up on y2k on May 11. It has set a deadline for the completion of each power plant's y2k project: July 1, 1999. This includes testing, making new repairs in the code, re-testing, and implementation.

The NRC is requiring all plants to submit a letter within 90 days stating that they are on schedule. It's now legal liability time. Whoever signs his name to such a document has placed his career on the line.

The other shoe has now fallen.

Code repair and testing are supposed to take anywhere from 85% to 90% of a y2k repair project's resources, including time. The question is: Are most of the 108 nuclear power plants in the U.S. well into code repair stage? If not, there is not enough time to meet the NRC's deadline. The government had better find out if this is the case, fast. It had better hold hearings and be ready to cross-examine witnesses under oath. The witnesses had better be CIO's and y2k project managers, not managers from the financial side.

Fat chance. The government does not want to create a panic. The day the public finds out the the power grid really is at risk is the day the panic begins. The politicians would rather be kept in the dark.

Beginning in the first week of January, 2000, they will get their wish.

* * * * * * *

The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to require that all addressees provide the following information regarding their programs, planned or implemented, to address the year 2000 (Y2K) problem in computer systems at their facilities: (1) written confirmation of implementation of the programs and (2) written certification that the facilities are Y2K ready with regard to compliance with the terms and conditions of their licenses and NRC regulations. . . .

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. Consequently, the Y2K problem could result in a plant trip and subsequent complications on tracking post-shutdown plant status and recovery due to a loss of emergency data collection.

The Y2K problem is urgent because it has a fixed deadline. It requires priority attention because of the limited time remaining, the uncertain risk that the problem presents, the technical challenges presented, and the scarcity of resources available to correct the problem. . . .

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

Security computers

Plant process (data scan, log, and alarm and safety parameter display system) computers

Radiation monitoring systems

Dosimeters and readers

Plant simulators

Engineering programs

Communication systems

Inventory control systems

Surveillance and maintenance tracking systems

Control systems. . . .

Diverse concerns are associated with the potential impact of the Y2K problem on nuclear power plants because of the variety and types of computer systems in use. The concerns result from licensees' 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. . . .

It is recognized that in spite of every reasonable effort by licensees to identify and correct Y2K computer system problems at their facilities, some software, applications, equipment, and systems may remain susceptible to the problem. Additionally, software, data, and systems external to the facility could potentially affect the facility adversely. Therefore, to ensure continued safe operation of the facility into the Year 2000 and beyond, contingency plans should be formulated for affected systems and equipment. The concept of Y2K readiness includes the planning, development, and implementation of appropriate contingency plans or compensatory actions for items that are not expected to be Y2K compliant or ready and to address the possible impact of unidentified items and their effect on safe plant operation.

Because of the limited time remaining in which to address the Y2K problem, at some facilities it may be necessary that some remediation and implementation activities be performed during normally scheduled plant outages in order to avoid additional outages to effect these activities. Hence, licensees should plan for this work accordingly. The NRC staff notes that unless the majority of the Y2K program remediation, validation, and implementation activities are completed at a facility by mid-1999, leaving only a few such activities scheduled for the third and fourth quarters of 1999, the facility may not be Y2K ready by the year 2000. . . .

In order to gain the necessary assurance that addressees are effectively addressing the Y2K problem with regard to compliance with the terms and conditions of their licenses and NRC regulations, the NRC staff requires that all addressees submit a written response to this generic letter as follows:

1.Within 90 days of the date of this generic letter, submit a written response indicating whether or not you have pursued and are continuing to pursue a Y2K program such as, or similar to, that outlined in NEI/NUSMG 97-07, augmented appropriately in the areas of risk management, contingency planning, and remediation of embedded systems. . . .

2.Upon completing your Y2K program or, in any event, no later than July 1, 1999, submit a written response confirming that your facility is Y2K ready, or will be Y2K ready, by the year 2000 with regard to compliance with the terms and conditions of your license(s) and NRC regulations. If your program is incomplete as of that date, your response must contain a status report, including completion schedules, of work remaining to be done to confirm your facility is/will be Y2K ready by the year 2000. . . .

The public reporting burden for this collection of information is estimated to average 100 hours 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 the existence of a Y2K program, similar to that outlined in NEI/NUSMG 97-07, and that the program will be completed by July 1, 1999. Licensees whose Y2K program significantly differs from the NEI/NUSMG guidance or whose Y2K program will not be completed by July 1, 1999, must submit additional information to the NRC. . . . Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation


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