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UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE       OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-0001

May 11, 1998
NRC GENERIC LETTER NO. 98-01: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 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 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.

Description of Circumstances

Simply stated, the Y2K computer problem pertains to the potential for       date-related problems that may be experienced by a system or an       application. These problems include not representing the year properly,       not recognizing leap years, and improper date calculations. An example of       a date-related problem is the potential misreading of "00" as the year       1900 rather than 2000. These problems can result in the inability of       computer systems to function properly by providing erroneous data or       failing to operate at all. 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.

Existing reporting requirements under 10 CFR Part 21, 10 CFR 50.72, and       10 CFR 50.73 provide for notification to the NRC staff of deficiencies and       non-conformances, and failures, such as some of those which could result       from the Y2K problem in safety-related systems. To date, the NRC staff has       not identified or received notification from licensees or vendors that a       Y2K problem exists with safety-related initiation and actuation systems.       However, problems have been identified in non-safety, but important,       computer-based systems. Such systems, primarily databases and data       collection processes necessary to satisfy license conditions, technical       specifications, and NRC regulations that are date driven, may need to be       modified for Y2K compliance.

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 

To alert nuclear power plant licensees to the Y2K problem, the NRC       issued Information Notice       (IN) 96-70, "Year 2000 Effect on Computer System Software," on       December 24, 1996. In IN 96-70, the NRC staff described the potential       problems that nuclear power plant computer systems and software may       encounter as a result of the change to the new century and how the Y2K       issue may affect NRC licensees. In IN 96-70, the NRC staff encouraged       licensees to examine their uses of computer systems and software well       before the turn of the century and suggested that licensees consider       appropriate actions for examining and evaluating their computer systems       for Y2K vulnerabilities. The NRC staff also incorporated recognition of       the Y2K concern in the updated Standard Review Plan, NUREG-0800, Chapter       7, "Instrumentation and Control," dated August 1997, which contains       guidance for the NRC staff's review of computer-based instrumentation and       control systems.

At the Nuclear Utilities Software Management Group (NUSMG) Year 2000 Workshop, an industry       workshop held in July 1997, some nuclear power plant licensees described       their Y2K programs and gave examples of areas in which they had addressed       Y2K issues in order to ensure the safety and operability of their plants       on and after January 1, 2000. Some of the issues discussed were (1) the       evaluation of the impact of the Y2K problem on plant equipment, (2) the       assessment process involved in the identification of Y2K-affected       components, vendors, and interfaces, (3) the development of Y2K testing       strategies, and (4) the identification of budget needs to address the Y2K       problem.

The Nuclear Energy Institute (NEI) met with NUSMG and nuclear plant       utility representatives in August 1997 to formulate an industry-wide plan       to address the Y2K issue. On October 7, 1997, representatives of NEI and       NUSMG NEI/NUSMG       97-07, "Nuclear Utility Year 2000 Readiness," to all licensees in       November 1997. The document recommends methods for nuclear utilities to       attain Y2K readiness and thereby ensure that their facilities remain safe       and continue to operate within the requirements of their license. The       scope of NEI/NUSMG 97-07 includes software, or software-based systems or       interfaces, whose failure (due to the Y2K problem) would (1) prevent the       performance of the safety function of a structure, system, or component or       (2) degrade, impair, or prevent compliance with the nuclear facility       license and NRC regulations.

Discussion

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. The scope of NEI/NUSMG 97-07 includes the       broad range of computers and software-based systems in a nuclear power       plant. However, NRC Y2K concerns are limited to safety-related systems and       other systems required by the nuclear power plant license or NRC       regulations.

One application that is common to all power reactor licensees is the       link between plant computers and the NRC's Emergency Response Data System       (ERDS). This application performs the communication and data transmission       functions that provide near real-time data availability to NRC and State       incident response personnel during declared emergencies. The NRC is       currently performing Y2K-related upgrades to ERDS, which will maintain the       same communication protocol as the current system, with the exception that       either 2-digit- or 4-digit-year fields will be accepted. Those licensees       that anticipate changes to their ERDS link should allow time in their       schedules for retesting their systems. NRC contractors will support       requests for testing on a "first-come, first-served" basis.

NEI/NUSMG 97-07 suggests a strategy for developing and implementing a       nuclear utility Y2K program. The strategy recognizes management,       implementation, quality assurance (QA) measures, regulatory       considerations, and documentation as the fundamental elements of a       successful Y2K project. The document contains examples currently in use by       licensees and also recommends that the Y2K program be administered using       standard project management techniques.

The recommended components for management planning are management       awareness, sponsorship, project leadership, project objectives, the       project management team, the management plan, project reports, interfaces,       resources, oversight, and QA. The suggested phases of implementation are       awareness, initial assessment (which includes inventory, categorization,       classification, prioritization, and analysis of initial assessment),       detailed assessment (including vendor evaluation, utility-owned or       utility-supported software evaluation, interface evaluation, and remedial       planning), remediation, Y2K testing and validation, and notification.

The QA measures specified in NEI/NUSMG 97-07 apply to project       management QA and implementation QA. Regulatory considerations include the       performance of appropriate reviews, reporting requirements, and       documentation. Documentation of Y2K program activities and results       includes documentation requirements, project management documentation,       vendor documentation, inventory lists, checklists for initial and detailed       assessments, and record retention. NEI/NUSMG 97-07 also contains examples       of various plans and checklists as appendices, which may be used or       modified to meet the licensee's specific needs and/or requirements.

It should be recognized that NEI/NUSMG 97-07 is programmatic and does       not fully address all the elements of a comprehensive Y2K program. In       particular, augmented guidance in the area of risk management, business       continuity and contingency planning, and remediation of embedded systems       is needed to fully address some Y2K issues that may arise in licensee       program implementation. The NRC staff believes that the guidance in       NEI/NUSMG 97-07, when properly augmented and implemented, presents an       example of one possible approach for licensees when addressing the Y2K       problem at nuclear power plant facilities.

Another document that provides a useful overview of the elements of an       effective Y2K program is a guide issued by the Accounting and Information       Management Division (AIMD), U.S. General Accounting Office (GAO), GAO/AIMD-10.1.14, "Year       2000 Computing Crisis: An Assessment Guide," September 1997. This guide is       a distillation of the best practices of the Government and the private       sector for dealing with the Y2K problem.

It should be noted that the guidance in NEI/NUSMG 97-07 and       GAO/AMID-10.1.14 provides a framework only. Any Y2K program employed at a       nuclear facility must be tailored to meet the specific needs and       requirements of that facility and should, in general, be composed of the       following phases: awareness, assessment, remediation, validation, and       implementation. Completion of the Y2K program means the attainment of the       program objectives, which could range from all computer systems and       applications, including embedded systems, being Y2K compliant, to some       being Y2K compliant and the remaining retired or with permanent and/or       temporary compensatory measures or work-arounds in place. Also to be       considered are the future maintenance requirements for keeping the systems       and applications Y2K ready, for example, when the "fixed date window"       approach is used.

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 the course of implementing the Y2K program, problems could be       identified that potentially affect the licensing basis of the plants. In       certain cases, license amendments may be needed to address the problem       resolution. Licensees should plan to submit such license amendments to the       NRC on a timely basis. The utility Y2K programs and schedules should have       the flexibility to accommodate such an eventuality. In addition, licensees       are reminded that any changes to their facilities that affect their       current licensing basis must be reviewed in accordance with existing NRC       requirements and the change properly documented. Finally, we strongly       encourage licensees to share information regarding identified remediation       and implementation activities in order to maintain the likelihood that all       Y2K problems are identified. We understand that Owners' Groups are       implementing this and we encourage this effort.

Required Response

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. If your program significantly differs from the             NEI/NUSMG guidance, present a brief description of the programs that             have already been completed, are being conducted, or are planned to             ensure Y2K readiness of the computer systems at your facility(ies).             This response must address the program's scope, assessment process,             plans for corrective actions (including testing and schedules), QA             measures, contingency plans, and regulatory compliance.(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.
Address the written reports to the U.S. Nuclear Regulatory Commission,       Attention: Document Control Desk, Washington, D.C. 20555-0001, under oath       or affirmation under the provisions of Section 182a, Atomic Energy Act       1954, as amended, and 10 CFR 50.54(f). In addition, submit a copy to the       appropriate regional administrator.

Backfit Discussion

This generic letter requires information from addressees under the       provisions of Section 182a of the Atomic Energy Act of 1954, as amended,       and 10 CFR 50.54(f). The required information will enable the staff to       verify that each nuclear power plant licensee is implementing an effective       plan to address the Y2K problem and provide for safe operation of the       facility before January 1, 2000, and is in compliance with the terms and       conditions of their license(s) and NRC regulations. The following NRC       regulations form a basis for this requirement:
- 10 CFR 50.36, "Technical Specifications," paragraph (c)(3),         "Surveillance Requirements," and paragraph (c) (5), "Administrative         controls." These sections relate, respectively, to requirements         pertaining to testing, calibration, or inspection to ensure that the         necessary quality of systems and components is maintained and to         provisions relating to management, procedures, recordkeeping, and review         and audit necessary to ensure operation of the facility in a safe         manner.         
- 10 CFR 50.47, "Emergency Plans," paragraph (b)(8), which relates to         the provision and maintenance of adequate emergency facilities and         equipment to support the emergency responses.         
- Appendix B to 10 CFR Part 50, Criterion III, "Design Control,"         requires that design control measures shall provide for verifying or         checking the adequacy of design, such as by the performance of design         reviews, by the use of alternate or simplified calculational methods, or         by the performance of a suitable testing program.        
- Appendix B to 10 CFR Part 50, Criterion XVII, "Quality Assurance         Records," requires that sufficient records shall be maintained to         furnish evidence of activities affecting quality. The records are to         include operating logs and the results of reviews.        
- Appendix E to 10 CFR Part 50, Section VI, "Emergency         Response Data System," which relates to the provision and maintenance of         licensee links to the ERDS [this citation was         inadvertently omitted from the final copy of NRC Generic Letter         98-01].        
- Appendix A to 10 CFR Part 50, General Design Criterion (GDC) 13,         "Instrumentation and Control," which addresses the provision of         appropriate instrumentation and controls to monitor and control systems         and variables during normal operation, anticipated operational         occurrences, and accident conditions, as appropriate, to ensure adequate         safety.        
- Appendix A to 10 CFR Part 50, GDC 19, "Control Room," which requires         the provision of a control room from which actions can be taken to         operate the nuclear plant safely.         
- Appendix A to 10 CFR Part 50, GDC 23, "Protection System Failure         Modes," which requires that the protection system shall be designed to         fail into a safe state or into a state demonstrated to be acceptable on         some other defined basis. 

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), approval number 3150-0011, which expires on September 30,       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.

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?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.
Original signed byD. B. MatthewsFORJack W. Roe, Acting DirectorDivision of Reactor             Program ManagementOffice of Nuclear Reactor         RegulationTechnical Contact:M. Chiramal, NRR301-415-2845E-mail:           mxc@nrc.govLead Project Manager:Allen G. Hansen, NRR301-415-1390             E-Mail:  agh@nrc.gov
Attachments: List of Recently       Issued NRC Generic Letters       
      (NUDOCS Accession Number 9805050192)       
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