ML20203F428
| ML20203F428 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1999 |
| From: | NRC |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9902180138 | |
| Download: ML20203F428 (128) | |
Text
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ORIGINAL UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISS
Title:
BRIEFING ON Y2K
'PUBLIC MEETING Location:
Rockville, Maryland
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Date:
Thursday, February 11,1999 Pages:
h 1 - 106
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
BRIEFING ON Y2K 1
PUBLIC MEETING' l
l Location:
Rockville, Maryland i
Date:
Thursday, February 11,1999 h-Pages:
1 - 106 DY r
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l DISCLAIMER This'is an unofficial transcript of a meeting of
-the United States Nuclear Regulatory Commission held on February 11, 1999, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as e
the Commission may authorize.
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UNITED STATES OF AMERICA
.2 NUCLEAR REGULATORY COMMISSION 3
-4 BRIEFING ON Y2K 5
i 6
PUBLIC MEETING 7
l 1
8 Nuclear Regulatory Commission 9
One White Flint North 10 Rockville, Maryland 11 Thursday, February 11, 1999 j
12 The Commission met in open session, pursuant to 13 notice, at 9:06 a.m.,
Shirley A. Jackson, Chairman, l
14 presiding.
15 16 COMMISSIONERS PRESENT:
17 SHIRLEY A.
JACKSON, Chairman of the Commission 18 NILS J. DIAZ, Commissioner 19 GRETA J. DICUS, Commissioner 20 EDWARD McGAFFIGAN, JR., Commissioner 21 JEFFREY S. MERRIFIELD, Commissioner 22 STAFF PRESENT:
i 23 ANNETTE L. VIETTI-COOK, Secretary of the 24 Commission 25 KAR,.EN D CYR, General Counsel ANN RILEY & ASSOCIATES, LTD.
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- PRESENTERS:
2 JOHN KOSKINEN, Chair, President's Council on Year 3
2000-Conversion' 4
FRANK MIRAGLIA, DEDR, NRC' Staff 5
JERRY WERMEIL, NRR, NRC Staff 6
JOE GIITTER, Incident Response Operations, NRC-7 Staff 8
JIM DAVIS, NEI 9
PAUL GUNTER, NIRS 10 11 12' 13 14 15 16 17 18 19 20 21 i
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1 PROCEEDINGS 2
[9:06 a.m.]
3 CHAIRMAN JACKSON:
Today the Commission meets to 4
receive briefings on the issue of what some have called the 5
millennium bug, most often referred to as the Y-2000 or Y2K 6
problem.
7 With us today are Mr. John Koskinen, Chairman of 8
the President's Council on the Year 2000 Conversion, members 9
of the NRC staff who will be introduced, and representatives 10 from the Nuclear Energy Institute, and Mr. Paul Gunter from 11 the Nuclear Information and Resource Service.
12 As many of you know, the Y2K problem involves the 13 use of a two digit representation of the year element in 14 dates in digital applications, predominantly in computers, 15 but also in embedded microprocessor chips employed in many 16 electronic components.
17 Because the 20th century is only implied by such 18 representations, many of the microprocessor-based systems we 19 rely upon in day-to-day life could experience operational 20 difficulties at the turn of the century due to their 21 inability to recognize and accommodate the change from the 22 year 1999 to the year 2000.
For example, the computer may w
23 read 00 as the 1900.
24 This problem takes on special significance for the 25 nuclear industry as the unpredictable nature of a given Y2K l
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I failure, if uncorrected, offers the potential for l
2 deleterious impact on the performance of reactor plant j
3-safety systems; telecommunication systems that the NRC and
.I 4-our licensees depend upon to ensure the ability to respond j
5
'to. events; the electrical distribution systems that provide-l 6
offsite power to licensed' facilities; and the computers used l
7
-in day-to-day and emergency response activities.
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8 On Tuesday of this week I was privileged to 9
provide the keynote address to an international workshop in r
10 Canada on the Y2K problem in the nuclear industry sponsored 11 by the OECD Nuclear Energy Agency.
f 12 It was ironic that as I prepared to inform this i
13 international assemblage of the lack of any as yet l
l 14 identified impact of Y2K on U.S. nuclear facilities, the NRC l
15 was informed by one U.S. nuclear facility that a plant l
16 computer had failed as a result'of post-Y2K remediation i
17 testing.
One could take that as a negative, but one could 18 also take it as a positive since, of course, validation and 19 testing of Y2K remedia; ion is a critical aspect of the 20 overall process.
21 After modifications had been made to remove Y2K 22 vulnerabilities in this case, a test was performed which 23 involved a simulation of the turn of the century.
It was 24 during this test that the failure, which lasted for five 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and which rendered the facility's safety parameter ANN RILEY & ASSOCIATES, LTD.
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display system inoperable, occurred.
I should tell you that 2
there are backups in terms of the enunciators in the nuclear 3
plant, which tells us why defense in depth remains an
-4 important concept.
5-The good news is that, first, the problem was 6
identified now, in February of 1999, and second, that it did 7
not affect an active safety system such as the reactor 8
protection system, and third, the plant stayed on line.
So 9
these are three important points.
I will revisit this event 10 in my closing comment.
11 The NRC has been working aggressively at 12 addressing Y2K vulnerabilities in house, and as of February 13 5, 54 days ahead of the milestone established by the OMB, 14 the NRC has completed the renovation, validation and 15 implementation of all agency mission critical, business 16 essential, and non-critical systems requiring repairs.
17 That's CIO speak.
In other words, we have done it all.
18 But there still is work to be done.
The NRC 19 contingency planning for dealing with licensee Y2K failures l
20 is not yet complete, and analysis, testing, remediation j
21 efforts and contingency planning are still under way in the i
22 industries we regulate.
23 This morning we will be updated on the status of 24 Y2K activities at the federal level, the activities yet to 25 be completed within the NRC, both in terms of contingency i
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. planning and in terms of developing our regulatory posture 2
with respect to.this issue, the activities that have been 3
and still remain to be. conducted in the nuclear industry, 4
and public concerns over issues of safety as we confront 5
this issue.
6 The Commission welcomes this opportunity and 7_
appreciates the involvement of our guests.
8 Copies of the briefing materials are available at 9
the entrances to the room.
10 I understand that Commissioner Diaz may have to 11 leave early -- and he apologizes -- due to a previous 12 commitment.
13 I want to particularly thank Mr. John Koskinen for 14 joining us this morning and invite him to the table.
I'm 15 told that you went over hill and dale to get here, a/k/a 16 Beltway backup.
So we thank you for joining us.
17 MR. KOSKINEN:
Thank you, Madam Chairman and 18 members of the Commission.
I'm delighted. to j oin you this 19 morning and would like to begin by congratulating you for 20.
holding this hearing and meeting because, as we will 21 discuss, I think one of the critical aspects of dealing with 22 this problem is public information and keeping the public 23 informed and sharing with them all of the news we have of 24 whatever nature as we go forward.
25 As the Chairman noted, I am chair of the l
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President's Council on Year 2000 Conversion and I was asked 2
by the President to come back a year ago to deal with this 3
problem.
We have created the council as a vehicle for 4
coordinating the federal efforts in this area.
5 The council includes 35 federal agencies, 6
including not only the cabinet agencies, but most of the 7
independent regulatory agencies.
So the Federal Reserve 8
Board, the Securities Exchange Commission, and the Nuclear i
9 Regulatory Commission are all active members of the 10 President's Council.
11 We have been looking at this problem in three 12 areas.
1 13 The first area of our activity has been focusing 14 on federal systems which we have direct responsibility for 15 and also direct authority over.
As the Chair noted, the 16 President and the Office of Management and Budget have had a l
17 goal of completing all remediation of federal systems by i
18 March 31, 1999, nine months before we move into the year 19 2000.
20 As of the last OMB quarterly report, through 21 November 61 percent of all of the mission critical systems 22 in the government were totally compliant, meaning they had 23 been remediated, tested and implemented.
24 The next OMB report will be out the first week in 25 March, and we expect then that over 70 percent of the ANN RILEY & ASSOCIATES, LTD.
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systems will have been remediated, and by the March 31 goal 2
we expect that probably in the range of 85 percent or more l
3 of the systems will be totally done.
l 4
So the federal government, which faces some of the 5
most significant challenges in the world because we operate 6
some of the largest systems and most complicated systems in l
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the world, I think will basically meet its goals, and as I l
8 have stated on other occasions, if there are difficulties 9
for the economy or the public, they will not come from~the 10 failure of federal systems.
l 11 But it was clear to us when we started that even l
12 if all of the federal systems-are remediated, tested, 13 validated and implemented, that was not going to be enough, 14 because if other systems that we all depend upon 15 domestically or internationally failed we would have 16 significant difficulties.
So the major role of the council
- 17 has been to organize itself into 25 working groups focused 18 on the critical sectors of the economy and their operations.
19 We have working groups with the electric power 20 industry, the oil and gas industry, the transportation j
21 industry, the financial services industry, and you can move 22 across the board.
We also have a very active working group 23 with state and local governments, and we have an active 24 international working group.
25 Again, I would like to express my appreciation for r
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the active participation of the commission and its staff in 2
those working groups, particularly the electric power group.
3 We have been reaching out in all of these working groups to 4
form a cooperative working relationship with the major 5
industry associations or umbrella groups in those areas.
6 In many of these areas we are dealing with 7
organizations over whom we have no direct oversight or 8
regulatory authoriey but are in fact trying to work with 9
together with them to find out what we can all do to both 10 increase the level of-awareness in each of those critical 11-sectors and activities, and more recently, to provide 12 national assessments or the state of readiness, so that in 13 each of the working groups the trade associations, umbrella 14 groups or organizations like the National Governors' 15~
Association have been surveying their members under the 16 auspices of the Information Disclosure Act which the 17 Congress passed for us last year, which protects those 18 surveys in terms of the confidentiality of the information 19 provided, and we are sharing that information with the 20 public as it is provided to us.
P 21 About three weeks ago the North American Electric 22 Reliability Council, which has been, of course, the umbrella 23
. group for us for electric power, released its second survey.
24 We expect next week, on the 18th of February, to get the 25 second assessment from the oil and gas industry.
Those two ANN RILEY & ASSOCIATES, LTD.
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surveys are in their second cycle because we started with 2
them first because of the critical nature of them in terms 3
of their impact.
f 4
Thus far, as noted, there are no indications that l
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there will be massive failures or national failures in i
6 either the electric power area or in the oil and gas area, 7
but I would stress that does not mean that there is not a
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8 substantial amount of work to be done, and I would also
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stress that, as those surveys show, not every company is at 10 the same level of preparedness.
11 I was accused when I was at OMB of viewing all of i
12 life as a bell-shaped curve with some people at one end and 13 at the other and everybody else flailing away in the middle.
14 Clearly those surveys reveal that.
15 The NERC survey has now over 96 percent of the 16 industry, 3,000 companies, participating to some extent 17 because they listed everybody who participated and nobody 18 wanted to be on the list as a non-participant.
But they 19 noted in their first survey and in their second survey that 20 there are companies that are behind the curve, as it were, 21 and need to increase the level of activity.
22 To their credit, NERC pursued those who said that 23 they were not going to meet the June goal of the North 24 American Electric Reliability Council to be done to 25 determine exactly what their problems were.
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1 They have promised in their next survey they will 2
distinguish between those companies that have an 3
understandable reason for not meeting the goal, which could l
4 be that they will wait until they have a time in their 5
normal operations where they can shut down and do the final 6
testing or the final implementation, and distinguish those 7
organizations from the ones that in fact simply are not 8
making enough progress.
i 9
Our goal in all of this in terms of the surveys, 10 whether they are of counties or cities or power companies, 11 has been, first, to give us all information upon which we 1
12 can base our own contingency planning and emergency 13 response.
14 Secondly, to share information with the public 15 about the state of preparedness so that everyone will have 16 the informaticn we do.
17 And thirdly, to begin to set benchmarks for the 18 industry so that companies as that information is provided 19 and they can look at where the average company is will know 20 whether they are ahead or behind in the game.
It's a way of 21 in fact encouraging and increasing the level of activity as 22 we go.
23 Our concerns domestically by and large are not the 24 companies that are focused on this problem.
They are really 25 the organizations that are not focused on it, that have I
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decided for one reason or another that this is not their 2-problem.
Either they are not running major mainframe l
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operations and therefore have ignored the implicationa and i
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the impact on day-to-day operations with embedded chips and i
5 other challenges, or they have decided they are going to 6
wait and see what breaks and then they'll fix it.
Many of I
7 these organizations are small or medium sized organizations, 8
although some of those organizations of that size have done
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9 very well.
10 We have tried to stress, whether they are cities 11 and counties or small power companies or telephone 12 companies, that it's a high roll risk of the dice, because
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13 if they wait and things do not work, they are likely to find 14 themselves at the end of a very long line of people who P
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1 15 waited to see if things broke and then tried to get them 16 fixed.
l 17 We are continuing to push in a wide range of 18 activities to try to get people to pay attention to this 19 issue and understand that what they all need to do is make 20 an appropriate assessment.
21 Part of the difficulty is that everything will not 22 fail, and in fact many things will not be affected by the l
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23 problem.
So it's not simply a question of telling people to l
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24 replace everything or buy upgrades or patches.
In fact, for I
25 smaller organizations, they don't have the resources to do i
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that.
So it's critical for them not to be cold a bill of 3
2 goods, as it were.
I 3
On the other hand, there is no way to know until 4
you've made an assessment and compared notes with others.
5 Our other concern is internationally.
Probably 3
6 half the countries in the world have not taken any 7
significant action in this area.
We have been working with
^
8 the United Nations and other organizations.
9 In December we obtained the agreement of the 10 United Nations to invite countries to send their year 2000 11 coordinators or senior executives to meet with us, and in 12 mid-December we had the senior year 2000 people from 120 13 countries meet with us at the United Nations.
14 Last Friday, in response to requests from that i
15 meeting, we announced in New York at the Foreign Press 16 Center the formation of the International Y2K Cooperation l
17 Center, which will be the first coordinating group to in 18 fact coordinate the activities going on around the world.
19 The delegates, in December, agreed to go back into 20.
their regions and work on a regional basis on cross-border 21 issues, but we are still concerned about the lack of 22 activity in some countries, and we are also concerned about 23 the lack of activity in some sectors.
i 24 Significant amounts of international activity have i
25 gone on in the financial area, led by central bankers and
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market regulators like the Securities Exchange Commission.
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Significant work has gone on in 3
telecommunications.
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Some work has gone on, and it's at an increasing
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level, in air traffic.
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But there is relatively little work in an 7
organized way in the power area.
We are working with the l
8 International Atomic Energy Agency to try to increase the 9
level'of their activity, but as you know, it's a very small l
10 organization and this is a unique challenge for them.
j 11-As a result of our concern about the lack of i
l 12 activity in an organized way in shipping, under the l
13 leadership of the U.S. Coast Guard there will be an ad hoc 14 meeting of all the major international shipping 15 organizations in the first week of March in London to try to i
16 mount the same global effort in the shipping area that we i
17 have in finance and telecommunications.
18 Our concern there, of course, is that we depend 19 upon receiving goods by maritime shipping in a wide range of 20 areas, including in the energy area.
So our problem is not 21 that we know there are going to be failures; our problem is 22 we do not have information.
23 That brings me to my request of the Commission and 24 the staff and the industry.
That is that our other major
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25 problem and risk in the United States will be overreaction t
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1 by the public.to the perception of'what this problem could 2
look like.
3 We are concerned that if a few people decide to 4
change their economic behavior, it won't make a lot of 5
difference, if even a reasonable number of people do that, 6
but if 200 million Americans decide to do anything very 7
differently all at one time, the system is not geared up to 8
deal with that, and we could have a self-fulfilling prophesy 9
where we have a major economic problem even though the I
10 systems basically are functioning appropriately.
11-Our goal in this area is not tu lead people at the 12 other end of the spectrum into any false sense of security.
13 I feel we have an obligation to be candid wito them, to in 14 fact share all the information we have, whether it's 15 difficult or positive, and that we need to give them advice 16 as to how to prepare accurately and adequately.
17 As we are doing national surveys, those are, I 18 think, reassuring.
As the information continues to evolve 19 that, for instance, there is no indication yet that there 20 will be any failure of the power grids, that is reassuring 21 to people, but on the other hand, everybody wants to know 22 what is going to be the situation with their own power 0
23 company, what's going to be the situation in their community 24 with water treatment, with telecommunications facilities.
25 We are working from our end, but we would be ANN RILEY & ASSOCIATES, LTD.
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S-16 1-delighted to have: support across the board to encourage 2
individual companies to begin to engage in a dialogue with 3
their customers.and their communities about their state of
-4 preparedness.
5 At this point there is a lot of what I fondly 6
refer to as crummy. legal advice being given to these 7
companies that the best thing to do is not say anything, and 8
there could not be worse advice in terms of the operation of 9
a company that the public depends upon.
10 I think the public has a lot of common sense.
I 11 think if they are given the appropriate information, they 12 will respond appropriately.
I think '., now most of them 13 understand this is a complicated challenge, that it's not an f
14 expectation that people should be done today.
So companies j
15 who are :<aiting until they are totally dor' and there is no i
16 issue before they say anything may wait for a very long time i
17 because, of course, in the circumstance there is no way to l
18 guarantee, in light of the unique nature of the problem, l
19 that everything will work perfectly.
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20 I think what people will understand and what they l
21 need to know is that each company understands that this is a 22 problem, that the senior leadership, including the chief i
i 23 executive officer, has this en their list-of priorities, j
i 24 that they are managing against the problem, that they have a j
i 25 plan, that they will announce and provide information about i
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1 when they will be done, and they have backup plans that they 2
are prepared to deal with, and work-arounds.
3 One of the things that is important for people to f
4 understand, and it goes to the example of the Chairman, is 5-that this is not an all or nothing proposition:
It is not a j
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6 question of either the systems work or everything stops.
In i
i 7
fact, with appropriate planning and appropriate backup plans l
8 and' contingency plans or continuity of operation plans, 9
there are work-arounds that are implemented every day for 10 software or other kinds of failures, and most of the 11 problems the public never sees.
But all of that needs to be 12 explained to the public.
13 As I say, we are, through the spring, going to be 14 encouraging companies across the spectrum to deal with their 15 communities.
We need in a community every head of a banking 16 organization, of the power company, of the telephone 17 company, of the local government to be explaining to the 18 public exactly where they are.
If they are moving more 19 slowly than they would like, they need to explain that.
I 20 think the public will understand that.
21 The risk is that if we keep the information to 22 ourselves, even if it's positive information, people will j
23 inevitably assume the worst; there will be a void of 24 information; and the great risk that people will 25 unnecessarily overreact to their perception of the problem.
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Again, the Commission has been a great leader in 2
this area.
I applaud your announcement earlier this week I
3 that you are now totally completed with your own internal 4
system upgrades and testing and validation, but I also i
5 applaud your focus on the fact that, as we advise all of the 6
federal agencies and in fact all the companies we are 7
dealing with, everybody needs to take a look at their
~
8 contingency plans and their backup plans even though you've 9
done all the work on your systems as we go forward.
l 10-It's an interesting challenge in the next 323 days 11 that we all face, but it's clear to me that if we work 12 together on it, if we are in fact transparent-in the efforts 13 in which we are engaged, that we will make the transition I
i 14 successfully, and as the President said in the State of l
l 15 Union message, the year 2000 problem will be the last l
l 16 headache of the 20th century rather than the first crisis of
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i 17 the 21st.
j 18 CHAIRMAN JACKSON:
Mr. Koskinen, let me ask you a l
19 couple of questions.
Going back to the recently published j
l 20 NERC report, in a way the report seemed at once both 21 optimistic and cautious.
One area of caution had to do with 22 the reliability of telecommunications, given the impact it 23 could have on grid management.
l 24 Do you have an opinion on the degree of confidence 25 that we should have that we won't see multiple challenges to l
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generating stations, including nuclear plants, because of 3
2 losses of offsite power?
To put it another way, does the 3
telecommunication sector seem well in hand?
4 I have a point of view that they are what I call S
the fundamental infrastructures, and if you don't have any 6
electrical power, then everything goes out the window.
7 MR. KOSKINEN:
That's right.
There is a symbiotic 8
relationship.
The telephone companies will all tell you
)
9 that they can't function without power; the power companies 10 will tell you they can't function without 11 telecommunications; and they all also depend on oil and gas 12 supplies.
So it is in fact a mutual dependency society.
13 There was a meeting of the three working groups of 14 the council on telecommunications, oil and gas, and electric 15 power at the end of last month in Texas to begin to try to 16 again increase the flow of information.
Part of the problem 17 is we have an information flow problem not between just 18 companies and the public, but between companies and their 19 suppliers and those they rely upon.
20 Under the leadership of the Federal Communications 21 Commission we have reconstituted the National Reliability a
22 and Interoperability Council, or NRIC as it's called, headed s
23 by the chief executive officer of AT&T.
They are committed 24 to providing us a' full industry survey before our next 25 report to the public, which will be in mid-April.
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At this juncture it is clear, and has been since 2
we started, that the major telecommunication companies, both I
3 internationally as well as domestically, are vigorously
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i 4
engaged in dealing with this problem.
It's-also clear that 5
they have some of the greatest challenges of any industry, 6
in particular because it's very difficult for them to do 7
testing because you can't take the network down to test it.
8 So they have set up very complicated testing labs and they t
9 are sharing information as they go forward.
10 At this juncture, I think we are increasingly
.11 comfortable that the major companies and the major systems 12-will work.
On the other hand, there are 1,400-smaller 13 telephone companies.
i 14 As fou all know, from the power side we deliver, j
15 the Rural Utility Service of the Agriculture Department I
16 tells me, 20 percent of all utility services to rural areas.
17 It will be very helpful to have Sprint and GTE and AT&T j
18 prepared and ready to deal with this problem.
The question,i 19 though, is, if you are in a smaller town or in a rural area,i i
20 will your local telephone company be ready?
21 In the NERC surveys they've got virtually every I
22 power company participating.
We are working actively with i
l l
23 the telecommunications industry to try to have them have the f
24
'same reach, because I think our risk is not national.
There
{
f 25 is a substantial amount of work going on.
I think our risk ANN RILEY & ASSOCIATES, LTD.
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is' local, particularly in the small areas.
2 Corollary to that is the National Association of 3
Counties did a survey for us, which you may have seen, in 4
December, which on the one hand 50 percent of the counties 5
have a major clear plan.
The problem on the other side of 6
the coin is 50 percent do not.
7 The Conference of Mayors released their survey a 8
couple of weeks ago in which they listed everybody who j
i 9
participated and showed the usual spread of active 10 participation, but there were major cities that did not 11 participate.
New York City and Los Angeles did not 12 participate in that survey, and they are large cities.
And 13 they did not reach out and could not reach out obviously to 14 the thousands of smaller towns.
15 So we are basically again saying that there needs j
16 to be a dialogue.
People at the local level have a right to 17 expect that their city manager, their mayor, their county 18 executive will begin to, if they have not already, explain 19 to them exactly where they are and share information about 20 it, because that's where the risk is.
21 Montgomery County has been the leader in the 22 United States about not only engaging in a dialogue, but 23 sharing information about what they've done to remediate l
l 24 their systems and what their test programs are.
Our goal is 25 to have every county in the United States emulate that IdRJ RILEY & ASSOCIATES, LTD.
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process.
2 The bottom line is I think that the major f
3 infrastructures, it appears, will be in good shape, but our 4
problem and our focus is on individual companies and 5
individual locations.
6 CHAIRMAN JACKSON:
You indicated that you were 7
making a request to the Commission, and I take it that it 8
had to do with our having discussions with the CEOs of the 9
companies we regulate in terms of being open, engaging in 10 dialogue, et cetera.
Do you feel that there is a direct 11 educational role that entities like the NRC have?
12 For instance, our regional administrators do hold i
13 quarterly press briefings.
The question is, do you feel
?
14 that there is some opportunity that we should take?
Not 15 that we have total control in terms of any remediation, but 16 in the sense of educating the public, do you think that is i
17 an appropriate thing for us to do?
i 18 MR. KOSKINEN:
Yes.
That's a wonderful question.
I 19 It is clear to us as we deal with the public, even 20
' internationally, that the one word that resonates in the 21 public minds is " nuclear."
I continue to be asked about the 22 safety of nuclear weapons systems not only in the United t
23 States but around the world, and there is a great focus on i
.24 the safety and the operation of nuclear power plants.
25' Those who have a broader understanding understand ANN RILEY & ASSOCIATES, LTD.
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that we depend upon nuclear power plants not just for safe 2
operation but actually-as a major participant in the supply 3
of energy.
But it is clear that if we are going to have 4
people unnecessarily concerned, it's going to be if they 5
unnecessarily assume there are safety risks and problems, e
6 Going back to your example about the testing 7
failure in the year 2000 test you gave, it strikes me that 8
that is the kind of information that we need to have public.
9 As you say, the good news about that is that people have 10 done the work, they are testing it, and if there are 11 problems, they are going to discover them now, and if there 12 are problems, they are in fact not p.oblems that would shut i
13 a plant down forever, that they can be remediated.
14 I think there is a major role of education and a
15 information exchange to be played by the Commission i
16 nationally and regionally, and I think we need to encourage l
17 the companies individually to publicly discuss with their 18 customers exactly what they've done, where they are in the 29 process, what work remains to be done, what their challenges 20 are, and I think we need to have the testing process be as 21 visible as it can be.
The most important way to reassure 22 the public is to in fact share the testing process, and when 23 we have a problem, that's not a major difficulty for the
)
24 public to understand; it is.in fact reassuring.
l 25 The Defense Department got great publicity when 1
i ANN RILEY & ASSOCIATES, LTD.
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they opened their test at the White Sands Proving Grounds to 2
the press.
If it had not all gone well, that.would have 3
been very visible.
The fact that they were willing to do 4
that and in fact that it worked sent a very positive message 5
out to the public.
We need to do that, and I think we need 6
to do that even if we are unsure what the tests will show.
7 If the public feels that we will share the information with l
8 them, whether it's positive or negative, they will then both 9
have increasing confidence in the process and I think they 10 will feel that they know and will be able to make the right 11 choices.
12 CHAIRMAN JACKSON:
Has there been a discernible 13 impact of the Year 2000 Information and Readiness Disclosure i
14 Act in terms of entities?
15 MR. KOSKINEN:
We developed that Act in response 16 to particularly the telecommunication industry and the 1*;
securities industry saying that they could not exchange 18 information with each other because their lawyers said if 19 they were not 100 percent right they could be sued.
So the 20 Act basically protects all voluntary disclosure, including 21 statements of readiness even if they are not 100 percent 22 accurate, as long as you are not knowingly misleading people 23 or lying about it.
24 It has helped significantly in our survey results.
25 There is a special data gathering request section that says ANN RILEY & ASSOCIATES, LTD.
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1-that if a company provides the data to a trade organization l
2 or an umbrella organization like NERC, litigants can't reach 3
into NERC and in effect have one-stop shopping for the data.
4 So it is protected from litigants;'it's protected from the i
5 federal government for regulatory purposes.
So we have been i
6 able to increase the participation in those surveys.
l 7
There has been a slower increase than we would i
8-like -- again, we are working on it -- of technical 9
information.
One of the goals we had in that legislation 10 was for larger companies or companies further ahead in the i
11 process t'o share their technical information about their 12 experience with products, their experience with where the 13 problems were, and their fixes and their testing protocols.
14 There has been some of that but not nearly as much of it as 15 we would like.
16 It's important for companies to share that with l
17 each other as they are working through the process.
It's 18 most important, though, to have that information available 19 for the smaller companies and the medium size companies who 20 do not have the same technical resources.
l 21 Especially as we begin to run out of time here and j
22 abroad, whether they are telephone companies, water l
23 treatment companies, power companies, hospital companies, i
24 and hospitals, we need to, if we can do it, have accers to
-l 25 technical information from others in their industry that i
i l
4 i
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they can take advantage of, because you can cut through a i
2 lot of the time if you have a pretty good idea of what the l
3 systems are you should be focusing on and what the fixes are 4
for those systems.
l l
5 We are continuing to push.
I've been disappointed 6
to that extent in the lack of information sharing by some 7
industries, by some companies.
A major message that would 8
be helpful is that to the extent that the more advanced and l
9 sophisticated companies can make that information available l
10 through the Web sites or otherwise, it will be critical 11 information to smaller organizations as we move through this l
12 year.
13 CHAIRMAN JACKSON:
Commissioner McGaffigan.
14 COMMISSIONER McGAFFIGAN:
Just one question.
Y2K l'
15 is not a single date; it's a whole series of dates, as you 16 know.
We passed one of them, 1/99.
I know from reading The 17 Washington Post that HP had some problems with old 18 defibrillators, which got fixed; Blue Cross-Blue Shield had 19 some problems with its pharmacy services, which got fixed.
20 We had some heightened readiness here consistent with our 21 contingency plan.
As that night rolled through, I watched l
22 CNN to see if any problems had occurred in Japan or Europe, i
23 and the staff did something more systematic.
24 I think the next one is 4/9/99, the 99th day of 1
25 this year, and 9/9/99.
I forget what the others are.
Is l
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there a dialogue as those dates get passed about what i
2 problems we found, in which sectors, and how they were
'3' handled?
That might be a way to build some confidence.
f f
4 MR. KOSKINEN:
It's a very important point.
It 5
turns out the press and all of us monitored what happened.
l 5
6 We have now, thanks to this meeting, a list server so I can i
7 reach about 130 countries' senior year 2000 9xecutives by I
8 the push of a button.
There were probably ten or 12 or 15 9
incidents in the world, which means that the vast majority 10 of systems passed the 1/1/99 date without a problem.
There j
11 was some visibility to that.
l 12 Although I think you are right the first date most 13 people are really focused on is April 9, because that will j
i 14 be the 99th day, the real date that everybody has known from l
15 the start is September 9th, because that will be 9/9/99.
16 We need to provide visibility to that both in 17 terms of what the difficulties are and what works.
With the i
18 difficulties, it will be important for people to understand l
19 how did we deal with those.
20 An interesting event along those lines was last 21 week for air traffic.
The airlines historically do not book 22 farther than 330 days ahead.
Last Thursday was the first I
r 23 day that you could book an airline reservation into the year l
24 2000.
Everybody watched, and it turned out all of those i
systems worked fine except for one airline, which in fact 25 r
i F
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j 1
had not scheduled itself to be able to deal with that.
The 6
2-other major airlines and the major reservation systems j
f 3
passed that deadline.
i l
4-In fact there was some coverage about it.
The I
5 good r.ews doesn't travel as fast as the bad news.
So it was l
l
?
l 6
not as easy for us to get that out.
l
-7 I think your point is well taken, first, that we 8
should be aware of those dates; secondly, they are going to 9
occur as we go through the year; and thirdly, we need to see l
10 how people deal with them.
Everyone dealing with a fiscal 11 year that starts before the end of the year obviously will l
l l
l 12 have to have financial systems capable of dealing with 13 fiscal year 2000 as we go forward.
14 We think that the 9/9/99 or the 99 phenomenon has 15 been certainly well known and visible for the last year and I
16 a half or two, so that people who are remediating systems l
17 are using those as test dates for themselves, j
18 I think ultimately if we get through, as I think i
19 we will, 9/9/99, that should provide reassurance to the l
l 20 public.
What we are encouraging people, and it is critical, C
al if there are problems, we should have those be visible as f
t I
j 22 well, because then I think we will have greater credibility.
t 23 CHAIRMAN JACKSON:
Who is dealing with the GPS 24 system?
l 25 MR. KOSKINEN:
The GPS system, for those who have j
i -
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1 haven't followed the bouncing ball, is August 21, 1999, in i
2 which the global positioning system satellites will roll 3
over.
Aney keep track of weeks, and they'll go back to week i
4 zero.
That is run by the air force and the Defense 5
Department as well as others.
Those satellites will be l
l o
6 fine.
Satellites generally turn out to be fine because they 7
are basically just antennas floating around the world.
The l
t 8
issues are in the ground stations that provide information.
l 9
At this juncture, therefore, the basic GPS system i
10 will be sound.
The challenge and the concern is everybody 1
11 who reads off that system, because they have to make sure 12 that their systems also roll over to week zero so they read 1
13 it appropriately.
Otherwise they will be in trouble.
There 14 has been a major push through various commercial and l
15 non-commercial networks to get people up to speed.
16 Our real concern are people who have bought
{
17 recently, but not recently enough, personal GPS readers.
We 18 are concerned about people who are out sailing or out hiking 19 in the mountains who may have in fact an older system that 20 doesn't roll over and they will no longer be able to get an 21 accurate reading.
We are doing whatever we can, but I think 22 basically it will be another date.
It's not a year 2000 23 problem per se,-but it's a similar problem because you are 24 changing the way the system calculates.
25 CHAIRMAN JACKSON:
That's right.
It's a delta i
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eystem.
2 MR. KOSKINEN:
Right.
3 CHAIRMAN JACKSON:
Commissioner.
.4 COMMISSIONER MERRIFIELD:
I have a couple of t
{
5 comments and a couple of questions.
First, I want to t
6 express my thanke for your coming out and sharing your time f
7 with us.
It's very helpful for our deliberations to get.
[
8 that kind of interaction and comment.
9 We are very pleased here about what we have done 10 at the NRC for our compliance issues.
I personally want to 11 express my thanks to Tony Galante and his folks for doing a 12 crack job.
The fact that we are among the first is j
i 13 something that we have to be very proud of.
I'm glad we 14 could share that today as well.
15 We will be hearing later on from NIRS.
We've i
16 heard from others who do have concerns about these nuclear 17
~ power plants being ready, being compliant for the Y2K issue.
18 I understand your concern, and I share it, that we 19 need to have an interaction with the plants that we regulate 20 to make sure that not only are they doing the right thing, 21 but they are also communicating that they are doing the 22 right thing.
23 I've only been a Commissioner for about 13 weeks I
24 now, and I've had an opportunity to meet dozens of CEOs over i
25 the course of the last few months.
One of the main topics
]
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that we have talked about has been the Y2K issue.
Uniformly 2
there has been a commitment of those CEOs that they are 3
taking the actions necessary to be ready for those date
'4
. turnovers as we look at them.
Similarly, the Nuclear Energy 5
Institute has also been doing a lot of work.
They've 6
explained a lot of-the work that they have been doing to be 7
ready as well.
8 I think there is an issue of communication there.
9 I don't think they are doing enough and perhaps we aren't 10 doing enough to assure the public that we are indeed taking 11 this very seriously.
12 You see the commercials on the cable television I
13 shows:
buy your six months of food supply; make sure you l
14 have emergency generating facilities.
There are a lot of 15 charlatans out there who are going to try to make a fast 16 buck out of this whole concern.
I think we need to do what 17 we can to assure the public that we are serious about this.
18 In addition to our own internal procedures, we 19 have touched a little bit on making sure that we have 20 contingency plans.
We had a vote on a contingency plan for l*
21 the NRC within the course of the last two months.
I think i
22 all of the Commissioners took that very seriously to make 23 sure that we are indeed ready for that as a Commission as 24 well when that turnover takes place.
25 I think it is very good that we have had this l
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.1 dialogue today and hopefully we can continue it.
2 My two questions are this.
The first one is, in l
l 3
order to gauge how the plants are doing we conducted an l
l 4
audit of 12 facili'cies and the results of those were j
5 positive that they were doing the activities necessary to be l
5 6
ready for the yea.r 2000.
Of the 103 plants we have out
'7 there now, we sarnpled 12 licensees, but that covered --
f 8
CHAIRMAN JACKSON:
Over 20 reactors.
l 9
COMMISSIGNER MERRIFIELD:
I was going to say that.
10 It covered over 20 reactors.
l 11 I guess my question for you is, is that type of an I
12 audit process that doesn't sample the entirety of the plants t
13 that we regulate a procedure that you believe would be i
14 appropriate, or should we be doing more in that regard?
[
15 MR. KOSKINEN:
It's a difficult question.
To the i
16 extent that the 20 reactors cover the basic systems so that j
l 17 you now in effect have audits that the fixes are known for i
18 the 103 plants out there, I think that is very helpful.
19 We have urged and encouraged the federal agencies l
20 to have independent verification and validation of their j
i 21 work.
So whether it's done by the Commission or whether l
22 companies have their own contractors or others doing it, I 23 think it is important to recognize that companies when they 24 assert and provide information that they are compliant need 25 to advise the public and us not only what they did, but how ANN RILEY & ASSOCIATES, LTD.
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they tested it and what their verification and validation of 2
that was.
t 3
What we all need to recognize -- and the 4
companies, I think most of them do -- is this is a unique 5
challenge.
We'have never confronted anything as e -
6 all-encompassing as this before.
You never know and we'll-7 never know until we actually cross those dates that it all 8
has worked perfectly.
So you can't' test too much, and it's 9
very'important to make sure that there is an independent
+
10 validation, particularly in an area like nuclear plants.
11 My sense would be that one way or the other in the 12 area of communication companies need to establish either the
~
13 Commission has provided an independent verification or they 14 otherwise-have some independent verification that the work 15-that they have done is appropriate, that the tests they've 16 run in fact have been run and are appropriate.
17 As we have said with the federal government, it's l
18 not a question of finding people who are cheating or cutting l
19 corners; it's really a question of just making sure that we 20 have gone through and looked at all the processes jointly, 21 in a cooperative way to make sure that the work has been 22 do.le and been done accurately.
23 Correlated to that is the information sharing.
It 24 would be very helpful to the extent that companies share 25 testing protocols and information with each other.
As the l
1 I
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oil and gas industry, we have 25 trade organizations, major 2
umbrella organizations.
Their position is this is not a 3
competitive issue, that nobody is very interested in having 4
somebody create a major problem in these systems.
So they 5
are increasingly beginning to share information.
6 The nuclear power industry, it seems to me, is a 7
wonderful area for potential cooperation, for people to 8
compare notes about what their testing protocols were and 9
where they found difficulties or what their fixes were, 10 because if you are a company and you've done a certain set 11 of tests, it's very helpful to know somebody else has tested 12 the same systems in a different way and come out with the 13 same answer.
If they come out with different answers, that 14 is also critical information, and the only way you will know 15 that is in fact if you can get that information shared.
16 I'm dealing 90 percent of my time with people who 17 don't have to listen to what we tell them, but we've been 18 able to generate a cooperative response, and I think there 19 is a large area of very important potential cooperation 20 among the plants themselves.
Not only cooperating with you 21 all, but cooperating among themselves in terms of sharing 22 information.
23 CHAIRMAN JACKSON:
Let me interject something.
I 24 think it's important that you not be put in a position of 25 answering a question out of context.
It is true that the ANN RILEY & ASSOCIATES, LTD.
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NRC has audited 12' licensees, and they represent different 2-regions, which means they are part of different grids,- they p
3 represent different types of reactors, different size'of I'
4 licensees; some are larger, some are smaller; therefore some 5
have more resources, et cetera.
i
+
6 Coming out of that there will be a review of six 7
additional licensees specifically focusing on contingency 8
planning.
But all of this is occurring within a' larger 9-context having to do with now a three-year-old effort that 10 the NRC has been carrying out in conjunction with the 11 Nuclear Energy Institute.
We have Mr. Jim Davis here today 12 who is going to be talking with the Commission about that.
13 Therefore, in a certain sense it's unfair to ask you the 14 question without your having the context of an overall 15 effort.
16 I think Mr. Davis will talk with us -- I know you 17 are a very busy man, but we will be happy to send you the 18 relevant parts of the transcripts -- about the degree of 19 cooperation within the industry and what kinds of.
20 information is'being shared.
It's an important issue, but 21 it's an important issue that, in the sense of your statement i
22 about not panicking the public, people understand the 23 context.
24 MR. KOSKINEN:
I think that's right.
25 COMMISSIONER MERRIFIELD:
The Chairman has more l
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1 artfully and articulately been able to put that in context.
i 2
I appreciate her having done that.
{
3.
The other question I had for you.
Different 4
countries have dealt with this issue relative to their power 5
plants in different ways.
6 In Sweden, we had a report they decided to turn 7
all the dates forward to the year 2000 date and see what l
8 happened.
There were some results that happened from that.
9 There was also a test in Nova Scotia where they l
10 artificially decid-d to turn it to beyond 2000.
This is not f
11 for their nuclear power plants but for some of their i
12 conventional generating facilities.
They are now somewhere f
13 in May of 2000 and they have not had any problems.
[
14 Do you have any thoughts about different I
~
15 activities by other countries in the context of how they are f
i 16 addressing this with power generating facilities?
l 17 MR. KOSKINEN:
Again, to the credit of the f
18 Commission and the industry, I think we are farther ahead 19 and in a more systematic way dealing with this problem than l
4 20 certainly some of the countries which do not-have the same 21 events.
22 I've seen the article about the Canadian plant, l
?
23 which is, as you say, running months into the year 2000, t
24 which'again is something that would be useful if more people
[
t i
25 understood that in fact there are people out there who have l
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met the challenge, rolled it forward and done well with it.
2 It goes back to my point about industry cooperation and 3
sharing.
There are a lot of different ways to test and deal 4
with systems.
5 It would be helpful if we could in fact get more e
6 information shared among the companies about different ways 7
they are dealing with it and what the results are.
If you 8
come at it in three or four different ways and you get the 9
same result, you increase significantly, obviously, your 10 level of confidence that the basic underlying fixes are 11 working.
12 Our bigger concern internationally is not the 13 pecple who are at a stage where they can roll the clocks 14 forward and test successfully; our bigger concerns are 15 places in areas such as those countries running Russian 16 designed nuclear plants where it's not clear that there are 17 appropriate resources and attention being paid.
That is why 18 we have spent a lot of time working with the International 19 Atomic Energy Agency, because I think there we have more 20 significant challenges.
21 CRAIRMAN JACKSON:
You know that the U.S.
22 Government is supplying a cost-free expert that we helped to 23 identify to help with that effort.
24 MR. KOSKINEN:
Yes.
25 CRAIPMAN JACKSON:
It's not enough, but it is a ANN RILEY & ASSOCIATES, LTD.
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beginning.
2 MR. KOSKINEN:
Morgan Libby has been provided on a 3
cost-free basis from the United States to the IAEA.
They 4
are using a lot of the materials that you all and the 5
industry have generated here as basically course materials, 6
trying to educate and share that information through those.
7 I think it is 66 plants that run across nine different 8
countries, the newly independent states and in Russia.
9 It's a classic example of the sharing of 10 information and the value of it, because if that information l
11 had to be developed from scratch, they'd never be able to do I-12 it.
So we are transporting our experience and expertise to 13 the extent we can.
As the Chairman notes, we need to do 14 more of that.
15 COMMISSIONER MERRIFIELD:
Thank you.
16 CHAIRMAN JACKSON:
Thank you very much, 17 Mr. Koskinen.
We appreciate your coming out.
I know cn1 18 spend a lot of your time doing this.
It is very helpful to 19 us.
20 MR. KOSKINEN:
It's my pleasure.
Again, I would 21 commend all of you and the Commission and the industry for 22-the work you are doing and the leadership you are providing 23 in an area the public is greatly focused on and interested 24 in.
Good luck.
25 CHAIRMAN JACKSON:
We don't mind if you take away ANN RILEY & ASSOCIATES, LTD.
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the mtssage that we do have the best CIO in the government.
l 2
[ Laughter.)
3 CHAIRMAN JACKSON:
Thanks very much.
i 4
I would like to invite the NRC staff and Mr. Davis i
t 5
from NEI to come forward to give us an update on the status I
6 of nuclear utility readiness in this area.
I'm going to ask i
7 Mr. Miraglia to begin, j
8 MR. MIRAGLIA:
Thank you, Madam Chairman.
Good 9
morning, Commissioners.
l 10 The staff has bean aggressively addressing the i
11 year 2000 problem with our licensees and preparing the 12 agency to deal with unanticipated issues that may result I
i 13 from the Y2K problem.
14 Over the past couple of years the staff has worked i
15 to ensure that our licensees are aware of the 2000 problem, 16 and as you are aware, we provided an appropriate level of 17 regulatory oversight.
18 As has been mentioned, there are 323 days to the 19 turn of the millennium.
We believe that the efforts that we 20 have under way and are yet to complete will provide 21 continued reasonable assurance of the protection of the 22 public health and safety during the transition to the year 23 2000.
24 We have broken in some respects the panel at the 25 table today, because we also have sitting with the staff l
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industry.
We recognize our regulatory role in terms of 2
arm's length relationship with the industry, but this has 3
been a very cooperative effort, as the Chairman has 4
articulated in some of her remarks, and even as you heard 5
f rom 14r. Koskinen on the involvement of the industry with 6
us.
i 7
We've also worked over the past ten months within 8
the President's Council.
I as a member of that council 9
would also like to express my appreciation to Mr. Koskinen l
10 for taking the time to be with us today to support this 11 Commission meeting.
12 CHAIRMAN JACKSON:
He's asked for a transcript, so 13 he'll know that you said that.
14 MR. MIRAGLIA:
I'll see him this afternoon at a 15 council meeting.
16 With me today is Jim Davis from the Nuclear Energy 17 Institute.
Staff with me is Jerry Wermeil from the Office 18 of Nuclear Reactor Regulation and Joe Giitter from the 19 incident response organization.
20 CRAIRMAN JACKSON:
By the way, if I may just take 21 a moment to interject.
I'd like to take note of the fact
~
22 that Mr. Wermeil is going to be moving and taking over the 23 reactor systems branch.
As some have said, from the frying 24 pan into the fire.
Nonetheless, I want to take this 25 opportunity to thank you publicly for all the work you've ANN RILEY & ASSOCIATES, LTD.
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been doing.
I know we've had a number of sessions, and it's
)
2 a difficult issue to get your hands around.
'3 MR. WERMEIL:
.Thank you very much, Chairman i
4 Jackson.
l 5
MR. MIRAGLIA:
I appreciate those remarks, Madam 6
Chairman.
The matter of transition is under review by me.
7
[ Laughter.]
i'l 8
CHAIRMAN JACKSON:
I see.
So this may be 9
premature.
10 MR. MIRAGLIA:
No.
It has to be done, but it 11 needs to be done in an orderly and appropriate way.
12
[ Slides shown.)
13 MR. MIRAGLIA:
I will go through this very L
14 quickly.
It has been indicated by Mr. Koskinen that there l
15 are 25 working groups, and the NRC has been participating-1 j
16 within the energy group, as mentioned; the health care l
i 17 section in terms of our NMSS office working within that 18 group relative to medical devices and the like; and in the 19 emergency services sector, which is response planning and 20 coordination with the emergency response and coordinated 21 federal response.
The Office of Response Organization has 22 been actively involved in that sector.
23 Our approach to the Y2K concerns is an integrated 24 and inclusive approach.
As has been mentioned, from an l
25 international perspective, the agency sponsored a resolution 1
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at the September meeting of the-IAEA regarding the Y2K issue l
2 and the attention that should be paid to nuclear power 3
plants worldwide.
That resolution was passed this past 4
September.
l 5
The NRC did identify, as indicated by the f
l 6
Chairman, a cost-free expert that the U.S. Government is 7
paying for to support the IAEA activities in this respect.
l
~
8 In terms of public awareness, I think Mr. Koskinen l
9 made it very clear that awareness of the issue, sensitivity 10 to the issue, and addressing of the issue and status is very 11 important communication.
f 12 Our Office of Public Affairs has been working with i
13 us in terms of putting our information out on our Web pages 14 with respect to not only general letters, the responses, the 15 results of the audits.
l 16 You will hear a little bit later we have done 12 i
r 17 audits.
Eight of those audit reports are out and issued and 18 on the Web.
The others are in various stages of preparation i
19 and when completed will also be on the Web.
l 20 So we have been sharing that information in a l
21 public way along with the industry as well.
l 22 In terms of our approach overall, we are using a 23 risk-informed and graded approach.
Most attention is being 24 paid, naturally, to the power reactors, but we are also 25 looking at fuel cycle facilities, material licensees, and i
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1 power reactors,_and we?ve been working with the Agreement L
'2
-States and state programs to communicate the issue.
l l
3 The common elements of all of those activities is j
4 awareness of the issue, notice of what the problems are, I
t i
i 5
information exchange as to what are they doing and how are l
l 6-they planning and the activities that they are engaged in, 7
and some validation of that either by inspection, audit and 8
follow-up in various meetings and the like.
t 9
CHAIRMAN JACKSON:
Within a risk-informed context, 10 Mr. Miraglia, how is the NRC dealing with issues outside its 11
-traditional. area of authority that could impact risk to the i
12 public vis-a-vis nuclear operations, such as 13 telecommunications?
14 MR. MIRAGLIA:
I think in a number of ways.
With I
15 respect to some of the issues, in terms of the power plant 16 itself, our concern would be the potential loss of offsite 17 power.
We need to pay more sensitivity to those processes 18 and procedures in terms of contingency planning.
Those are 19 elements of risk.
At some plants, as you aware, that is a 20 higher contributor to risk, 21 CHAIRMAN JACKSON:
Is Mr. Wermeil going to speak 22 to that?
23 MR. MIRAGLIA:
He can.
24 In the telecommunications sense, Mr. Giitter has 25 been working with the response sector and how we are looking i
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1 at that and backup communications and the like.
4 l
2 Joe.
3 MR. GIITTER:
NRC is a member of the National 4
Communications System.
We've been working very closely.
In 5
fact we've had a very good relationship with the National 6
Communications System and the President's National Security 7
Telecommunications Advisory Committee.
One of the things
~
8 that they are doing for us at this time is going to those 9
small telephone companies that are near our nuclear power 10 plants.
11 Many of our nuclear power plants are serviced by 12 the major telephone companies, but they are going to the 13 smaller ones and helping us get some information as to i
l 14 whether their switches are going to be Y2K compliant.
l 15 We are also working with those agencies to
[
l 16 establish a backup communication system that will be l
17 independent of the public switch network for the transition.
18 We also are a member of the Government Emergency
[
19 Telecommunications System, which will provide a high level 20 of assurance that we would be able to reach our sites and l
l l
21 that they would be able to reach us in the event of network
[
l congestion possibly caused directly or indirectly by a Y2K 22 t
23 problem.
i 24 I might also add that in the industry's i
25 contingency planning document, and maybe Mr. Davis can talk ANN RILEY & ASSOCIATES, LTD.
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about this later, NEI/NUSMG 98-07, they have a template or
[
l l
2 recommendation for utilities to use in developing their own 3
contingency planning.
{
t 4
One of the key aspects of that is to have the 5
utilities contact their local telecommunications providers, t
[
o 6.
including the public service answering point, such as the 7
911 centers, to make sure that.in the unlikely event that 8
there is a problem at the plant they would be able to call 9
in the necessary resources, such as the fire department, or 10 reach the state and local officials.
11 MR. MIRAGLIA:
Jerry.
12 MR. WERMEIL:
You raised a very interesting point.
13 The Y2K problem was recognized sometime ago by the staff as 14 putting this agency in a somewhat unique position of not
-15 only exercising its primary responsibility for nuclear 16 safety, but also being aware of the impact of the year 2000 17 problem on the nuclear power plants' contribution to the 18 continued availability of the electric grid.
19-That was also obvious to the industry itself, and 20 in the original guidance document, NEI/NUSMG 97-07, that the 21 staff accepted in its Generic Letter 98-01 on this topic, 22 not only are those systems that we would traditionally be 23 responsible for for ensuring the safety of the plant 24 included within the scope of the program, but systems 25 necessary for continued safety operation of the plant are ANN RILEY & ASSOCIATES, LTD.
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1 part of the focus.
j 1
2 Because we believe that program was appropriate in i
3 its scope in our oversight of industry efforts to address
]
i 4
Y2K, we have looked at not only those systems with a safety
)
1 5
function,'but those that are necessary for the continued 6
operation and those that support the plant's ability to l
7 maintain its grid function.
We point out in our audit l
8-report some of what.we see licensees doing in that regard.
9 We believe for their own reasons that, because i
10 they are not in the business.of anything but generating i
I 11-power while at the same time doing it safely, that they also i
12 recognized how important that was, and they are addressing 13 areas like that in accordance with the guidance that the i
14 staff believed was appropriate.
15 CHAIRMAN JACKSON:
Let me ask you two other l
16 questions, one other on power reactors and then in another 17 area.
s i
18 Ifsa power reactor couldn't demonstrate Y2K i
19 readiness in a safety system but at the same time had not 20 identified a specific vulnerability, how would NRC react?
{
21 MR. WERMEIL:
We would react to ensure that that 22 plant was meeting its license requirements and our f
i 23 regulations.
If the information to us indicated that at l
24 some point, either January 1, 2000, or some other point, 25 that licensee was not in compliance with its license based i
i f
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on a Y2K problem in a system that was necessary to maintain j
the safety of the plant, we would raise that issue to the 2
i 3
licensee and ensure that the licensee pursued it 4
appropriately.
5 CHAIRMAN JACKSON:
You wouldn't do it until 6
1/1/2000?
7 MR. WERMEIL:
No.
The information on the status
~
8 of these systems, Chairman Jackson, will be provided by all l
9 licensees by July 1.
(
10 CHAIRMAN JACKSON:
Is he going to walk us through 11 that?
l 12 MR. MIRAGLIA:
Yes.
13 CHAIRMAN JACKSON:
And talk about the decision-14 making?
l l
15 MR. MIRAGLIA:
Yes.
16 CHAIRMAN JACKSON:
Okay.
I'll wait.
l l
17 MR. WERMEIL:
We have a plan that allows us l
18 sufficient time to address these issues and make the 19 necessary decisions in order to assure safety at these 20 plants.
21 CHAIRMAN JACKSON:
All right.
Let me ask you one 22 last question.
What sort of Y2K vulnerabilities may impact 23 the public outside of the power reactor field?
For l
24 instance, could failures in brachytherapy devices cause 25 patient overexposures, and what are we doing in that area?
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MR.'MIRAGLIA:
I think one of the areas in the materials area is the medical licenses.
As I indicated,
)
3 NMSS has been interacting with the sector.
As well, we have 4
been interacting with FDA in terms of awareness of problems 5.
how they are being addressed, and are the systems going to 6
be Y2K ready or compliant in those areas.
i 7
Dr. Cool is'here, if you would like to hear more
~
8 on some of the interactions.
9 CHAIRMAN JACKSON:
Dr. Cool, could you give us a
)
l 10 cool, succinct statement?
l 11 DR. COOL:
Good morning, Madam Chairman and l
12 Commissioners.
We have been doing a number of things i
13 particularly with the medical community because there are 14 some of those potentials.
For a larger part of the 15 community, where you are dealing with unsealed materials, j
16 diagnostic doses, or even therapeutic nuclear medicine, l
17 safety is by procedure and by handling, not by the t
18 electronics.
So they would have to look and make sure that 19 the the dose calibrators were in fact reading out properly.
20 That allows us then to focus more precisely on 21 things like brachytherapy, teletherapy, some of the units i
22 which have in one sense safety built in because the sources j
23
-are shielded.
Those systems are generally designed such i
24 that power failures result in them either not being able to f
25 move out at all -- they fail safe -- or to retract the l
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-source if there is an issue associated with those, via some l-2 spring mechanisms or otherwise.
3 We have been working closely with FDA, who has the 4
actual lead responsibility within the federal government for A) things like treatment planning systems.
Interacting with 5
1 6
the various manufacturers, we have in fact identified both 7
through interactions with the manufacturers and on some of 8
the inspections we have been looking at this issue on every 9
inspection since about November of 1997.
So we have gone 10' essentially all the way through the priority ones already.
11 We have identified some cases where treatment 12 planning systems were not Y2K compliant.
We have been 13 identifying those.
Those were also already known to those 14 manufacturers.
My understanding in fact is that upgrades
.15 are already available for those systems that we have been 16 able to identify.
A lot of those have already been put into l
17 place or may take place.
18 Our understanding of the failures is more a matter l
19 of non-functioning rather than an incorrect functioning if
)
20 they were to roll over on that date.
21 CHAIRMAN JACKSON:
Thank you very much.
22 You were going to mention contingency planning, d
23 MR. MIRAGLIA:
Yes.
What I propose to do is go to 24 the next slide, Madam Chairman.
What we have is a timeline.
i 25 COMMISSIONER MERRIFIELD:
Madam Chairman.
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1 CHAIRMAN JACKSON:
Yes, please.
2 COMMISSIONER MERRIFIELD:
I'm sorry to interrupt.
3 I have a follow-up question to one of yours.
4 CHAIRMAN JACKSON:
Sure.
i 5
COMMISSIONER _MERRIFIELD:
I have a question about l
6 the U.S. Enrichment facilities at Portsmouth and Paducah, 7
I believe I'm right on this.
If those facilities-8
'were to be shut down, there is a question about them turning 9
back on once they are down.
I'm wondering what we have been l
10 doing with them to make sure that they are ready as well.
11 MR. MIRAGLIA:
They have reported that they will l
12 be Y2K ready by April of this year.
The facilities will 13 remain on line.
They will have extra fuel on site to I
14 maintain onsite power and emergency power.
The residual i
15 heat in the plant will allow them to stay hot for a period i
16 of-three to four days.
l 17 The plants would be shut down to a safe condition 18 in terms of no criticality or release issues.
The concern i
19 is not to have the plant go cold.
So they would have those 20 procedures in place and have taken those steps.
21 CHAIRMAN JACKSON:
Has any inspection or audit
~
22 function been assigned to resident or regional inspectors in i
23 these areas?
24 MR. MIRAGLIA:
In terms of the materials area and 25 in these areas, the Y2K issues are being followed up in the i
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i 1
-course of the inspections.
As Don indicated, the priority l
2 ones.
l 3
CHAIRMAN JACKSON:
What about for power reactors?
t 4
MR. WERMEIL:
Not specifically, Chairman Jackson,
)
l 5
but we have contacts with all the regional offices and there l
6 have been designees to keep us informed of information that j
7 they obtain that may be of use to us at headquarters in
)
8 dealing with the problem.
9 CHAIRMAN JACKSON:
Wouldn't it be prudent to have 1
i 10 the resident inspectors, if only in an accompaniment role, 11 involved perhaps as you go through these six plants with the i
i 12 contingency planning since they are the ones who are right 13 there?
i 14 MR. WERMEIL:
Absolutely.
One point that perhaps 15 I shoul1 have made is during the 12 audits the resident 16 incpector on site was available and was aware that we were 17 there.
18 CHAIRMAN JACKSON:
I'm talking about beyond being 19 aware that you are there, even if they are a silent team l
20 member, to have them there so that they can be much more 21 informed and apprised of situations and attuned to them.
22 MR. T/ERMEIL:
With regard to contingency planning, 4
23 that is an excellent idea.
The resident inspector will be 24 asked to be on site on January 1, 2000, and will be involved 25 in that effort very strongly.
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S-52 1-CHAIRMAN JACKSON:
So we agree that 's it 's prudent i
i 2
to have at least have some coverage by having some 3
inspectors involved at this stage of the game.
4 MR. WERMEIL:
Yes, we do.
5 CHAIRMAN JACKSON:
Very good.
6 COMMISSIONER DICUS:
Madam Chairman.
7 CHAIRMAN JACKSON:
Yes, please.
8 COMMISSIONER DICUS:
You may have said and I 9
missed it.
Were medical licensees the only materials j
10 licensees that have been identified as potential problems?
j i
11 MR. MIRAGLIA:
No.
Don, since he's at the table, 12 can perhaps address it in more detail.
All the materials 13 licenses were looked at in different ways in terms of 14 notification, what activities that they had undertaken.
l 15 Don.
I 16 DR. COOL:
We have in fact done a number of 17 things.
The information notices that we have put out have i
10 gone to all licensees.
Early on in the process, well over a t
19 year ago, we did a survey which involved talking to a f
20 representative or to a licensee or to each of the classes'
[
21 broad scopes in a variety of situations, looking to see if t
22 there were potential weaknesses that we needed to follow up I
~
23 in a particular segment.
We have not identified any of i
24
- those, l
i 25 My inspectors are asking a series of Y2K issues in ANN RILEY & ASSOCIATES, LTD.
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terms of awareness, identification of issues, and any 2
actions that are taken on every single inspection that they
]
3 are going on irrespective of the kind of facility.
4 COMMISSIONER DICUS:
How about non-power reactors?
5 MR. MIRAGLIA:
In terms of non-power reactors, 6
there are a number of issues there in terms of notices.
We 7
have been working with the organization TRTR, the Test 8
Research Test Reactor group, in terms of understanding the 9
problems and how they are addressing those kinds of issues.
10 In a similar manner, during the course of inspections those 11 matters are looked at.
That covers the range of the 12 activities.
13 As I said, there are common elements of making our 14 licensees aware of our understanding of what they are doing
)
l 15 to address the problem and then in some sort of follow-up 16 either by inspection, audit or follow-up surveys and 17 telephone calls and things of that nature.
18 Another example, Commissioner Dicus, is that 19 during the MRBs with Agreement States for the last 18 months 20 that has been a question that has been put to the state 21 representatives during the course of the MRB meetings.
22 CHAIRMAN JACKSON:
Thank you.
23 MR. MIRAGLIA:
The next few slides are represented j
24 in a timeline of the activities of the NRC's oversight with I
25 respect to the Y2K issue.
It's sort of a road map of where i
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we have been, where we are.today, and what is left to be 2
done.
3 The main focus within the timeline is power 4
-reactors, but you will note that we also address some of the 5
activities that we have engaged with in terms of the fuel 6
cycle facilities as well.
7 As indicated, this is an issue that the agency has C
identified and has been dealing with back to 1996.
9 At the request of the NRC, the Nuclear Energy 10 Institute and the Nuclear Utility Software Management Group, 11 the NUSMG acronym that you've heard, initiated an effort to 12 provide a guidarce document to assist nuclear power plants 13 to develop a program that would effectively address these 14 issues.
15 The scope of that document is broad in terms of 16 determining the scope of issues and systems to be examined, 17 the test protocols, the documentation, the QA oversight, and 18 the sharing of information.
So it's a fairly complete 19 document.
As Mr. Wermeil has indicated, it is one that we 20 endorsed in the context of our initial Generic Letter 98-01, 21 which was issued in May of 1998.
22 Responses to that letter were received in August 23 of that year.
What the letter asked for is what program 24 were they going to follow, and that 98-08 and the NUSMG 25 document was an appropriate protocol; if they were going to ANN RILEY & ASSOCIATES, LTD.
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1 deviate from that, they needed to explain what they were t
i 2
doing'and how they were doing it.
All of those responses l
3 indicated that that was the document that the industry was i
4 going to follow, without exception.
5 In September of 1998, we started audits of 12 l
6 licensees.
As has been discussed to some degree, these 12 7
audits represented approximately 20 plants, representing i
8
~ units of different vendors, different size, different 9
locations, large utility, small utility, to try and get a l
\\
l 10 range of utilities with large resources, small resources, 11 and it addressed the problem.
12 If you look at the total number of facilities that 13 we have licensed for these utilities, although we went to 14 those 20 plants, de expands out to 42 units.
For example, 15 Commonwealth.
We looked at one dual unit station, but that i
16 program and implementation would be applicable to all of l
17 their stations.
18 Those audits were started in September.
We 19 completed the last of the audits at the end of the month 20 As I indicated, eight of those audit findings are on the 21 Web; four of the audits which ha'e been completed in the 22 last few months are in various stage of preparation, and 23 those will be placed on the Web as well.
24 Also, in January we issued 98-01 Supplement 1.
25 That supplement was a request in response to the industry l
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request to provide information beyond the information 2
requested in our initial generic letter.
This was a result l
3-of the Disclosure Act that Mr. Koskinen discussed with the l
4 Commission a short while ago, to provide the information on l
5 systems even beyond those covered.
That was acceptable, and 6
the supplement indicates that.
l 7
The results are all due to be reported to the l
8 staff in July of 1999.
1 9
That is sort of where we are today.
l l
10 Our plan is, in March, to issue an information notice that summarizes the findings from all of the audits 11 l
12 and share that with the industry and provide those 13' observations and lessons learned 14 I think you will hear from Mr. Davis that there is 15 a fair amount of industry exchange among the industry with 16 respect to their findings.
17 In addition, in January we issued a draft 18 contingency plan.
That contingency plan is out for comment.
19 The comment period is due to end the 19th of February.
Our 20 plan is to review those comments and provide a final NRC 21 agency contingency plan to the Commission in the March time 22 frame.
23 COMMISSIONER MERRIFIELD:
Madam Chairman.
l 24 CHAIRMAN JACKSON:
Yes, please.
25 COMMISSIONER MERRIFIL'LD:
I have a question i
I a
i
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1 regarding that.
To what extent are we going to be putting j
2
.those contingency plans through exercises to test emergency 3
communications?
4 CHAIRMAN JACKSON:
They are going to talk about l
5 table top exercises.
6 MR. MIRAGLIA:
We are going to cover that, 7
Commissioner.
We will talk in terms of some table tops and 8
some additional work to be done.
9 COMMISSIONER MERRIFIELD:
That's fine.
10 MR. MIRAGLIA:
In addition, as was discussed in 1
1 11 the previous panel, we have identified the need to review at 12 least six licensees' implementation of the contingency plan.
13 The industry's guidance relative to contingency planning was 14 developed a little later than the initial NUSMG guidance, 15 and as a result of our audits, they weren;t developed enough 16 for us to make judgments.
We do plan to conduct at least 17 six reviews of the contingency planning efforts by the 18 industry.
19 Also, you are probably aware that we have been j
l 20 petitioned by the Nuclear Information Resource Services for
)
21 three rulemakings.
Those petitions were received in 22 December and a Federal Register Notice was published asking 23 for comments on those petitions for rulemaking.
24 It deals with three issues in terms of rulemaking:
{
25 to have the plant shut down prior to the transition to i
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F h
S-58 1-assure safety; concerns about providing adequate emergency l
2 and additional emergency power supplies on site; and the l
3 contingency planning for the licensees be exercised.
l 4
The staff has that petition under review.
We are 5
receiving comments on that, and we hope to provide that 6
review and-that decision in the month of April.
j 7
In June we would hope to complete the six reviews, f
8 We haven't picked the facilities yet, but our plan would be 9
to complete those reviews.
Our overall plan is to have l
10 information relative to their readiness in July and our 11 audits completed, to have that information to decide where 12
-do we go from here based on the information or our 13 understanding of the state of readiness.
i 14 CHAIRMAN JACKSON:
I was correct in saying that j
)
15 these six licensees are different than the 12?
i 16 MR. MIRAGLIA:
That's our plan, yes,. Madam 17 Chairman.
4 18 In that same time period we are also going to 19 further develop our internal procedures for our own 20 contingency plan and test those initiatives.
21 There is a national table top exercise that is 22 being considered in the month of June.
Perhaps Mr. Giitter 23 can talk a little bit to that to give the Commission an idea 24 of the scope of that.
25 MR. GIITTER:
There are two dates.
I don't know I
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that they have been firmly established yet, but they seem to 2
be the dates ~that people are' focusing in on, particularly 3
FEMA.
4 The first date would be an exercise where the l
5 major players in the federal response plan would respond to 1
6 a Y2K scenario of_some kind.
They would respond in their 7
roles under the federal response plan.
That would be like 8
an exercise on a Saturday, eight hours long.
9 The following Saturday-there would be a cabinet l
10 level exercise where the heads of the agencies, the cabinet 11 secretaries, and the vice president-would participate for 12 about four hours.
It would be more of a walk-through of the 13 process that occurred on the previous Saturday.
14 I believe the dates scheduled for those right now 15 are the 19th and 26th of June.
16 MR. MIRAGLIA:
Two consecutive Saturdays in June j
17 is the initial plan at this point in time.
18 Next slide, please.
19 CHAIRMAN JACKSON:
Let me just ask a question.
i 20 Did this address your question?
Did that answer i
21 your question you asked about' testing of contingency plans?
22 COMMISSIONER MERRIFIELD:
I'll hold off until we 23 get to the end.
24 MR. MIRAGLIA:
We have another exercise planned 25 later.
Our present plan in October, Commissioner 4
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Merrifield, would be for us to conduct an NRC Y2K exercise.
i 2
Joe.
l 3
MR. GIITTER:
Right now, what we are looking at is 4
a fairly significant exercise that would essentially dry run 5
all aspects of the contingency planning, including the j
l 6
international cooperation and communication.
We would hope l
7 to have some licensee involvement.
We know that many 8
-licensees will be exercising their contingency plans at 9
about that same time frame, and we would-like to have some l
i 10 licensee participation as well.
It's possible we will be 11 testing our own internal procedures that we developed.
I 12 Right now we are looking at the October time frame for that l
13 exercise.
14 COMMISSIONER MERRIFIELD:
Is it the thought to 15 also test the emergency communications procedures?
16 MR. GIITTER:
Yes.
That would be a major part of 17 that.
18 COMMISSIONER MERRIFIELD:
We would have some of I
19 the equipment at that point?
20 MR. GIITTER:
That is one of the reasons we are 21 looking at October and not sooner.
We think it's going to 22
'take a while to implement that.
23 In fact, what we are looking at is mobile 24 satellite equipment that would be easy for people to use at 25 every nuclear power plant site tying into a national ANN RILEY & ASSOCIATES, LTD.
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telecommunications coordination network, the network that I 2
talked about that the National Communications System is 3
setting up.
The idea would be that during that exercise we 4
would test those communication links.
5 COMMISSIONER MERRIFIELD:
One of the things that 6
the contingency plan goes into is if there is a loss of 7
grids.
Region IV, for example is on a different grid.
Will 8
we be testing that element of it as well?
9 MR. GIITTER:
As part of that exercise we will 10 have Region IV play in the role as a backup operation 11 center.
We haven't determined yet whether it would involve 12 a simulated failure of the headquarters operations center or j
13 having Region IV take overflow of some Y2K problem that may 14 be simulated during the exercise.
That is what we are 15 looking at right now This is very preliminary.
We still 16 have a lot of details to work out.
l 17 MR. MIRAGLIA:
Commissioner Merrifield, there is 18 still a lot to do and work to be done.
The first one is to 19 finalize the contingency plan, and that is going to happen 20 in March.
June is to start developing those internal 21 procedures relative to how we are going to implement that 22 plan, including the aspects of the backup response center 23 that we have envisioned in the plan, and then how to 24 exercise that plan.
25 COMMISSIONER MERRIFIELD:
Do we have any specific ANN RILEY & ASSOCIATES, LTD.
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contingency plans as it relates to the Portsmouth facility I 2
asked about earlier?
3 MR. GIITTER:
They are included in the contingency 4
plan that we developed along with our nuclear power plant 5
licensees, non-power reactors, and materials licenseos.
So 6
they are included, and that is something we are looking at 7
in the contingency plan.
8 CHAIRMAN JACKSON:
Don, do you have any additional 9
comments you want to make in that regard?
10 DR. COOL:
Just to note that at this point the l
l 11 planning is to include within the staffing of the center 12 folks who can handle a fuels facility in parallel with a 13 power reactor facility.
So there would be some personnel 14 immediately available on that night.
15 CHAIRMAN JACKSON:
Do we know how many reactor 16 events requiring an NRC response the agency could handle at 17 one time?
I la MR. GIITTER:
The design basis is two events at 19 once, and that has been tested in the past.
20 MR. MIRAGLIA:
It has been tested.
I can recall 21 one instance where we had an ongoing reactor event and an l
22 ongoing materials event in the center as well.
That has 23 been a while back.
So we have had simultaneous issues to 24 various degrees.
25 MR. GIITTER:
It was on the 4th of July.
I can't ANN RILEY & ASSOCIATES, LTD.
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remember the year.
We had two events at once, and one was f
2 loss of offsite power and a diesel generator problem, and l
l 3
the other one was a stuck-open safety valve.
We responded 4
to both events at the same time.
But that is our design l
5 basis, two events at once.
- e 6
COMMISSIONER DICUS:
Does our contingency plan 1
7 have the flexibility, however, to handle three?
8 MR. GIITTER:
That is one of the reasons we are 9
looking at Region IV to provide some backup.
l 10 MR. MIRAGLIA:
In addition to that, what we need L
11 to work out and an issue that we' haven't fully developed, 12 and this is work to be done, is that we are planning for 13 Region IV to be the backup, but there are the other regions 14 there, and what role might they play.
We need to coordinate i
15 that.
Those are additional activities that we need to 16 consider and try to address.
17 Each region will have a different role, depending
[
18 on circumstance and situation.
Region IV has been i
19 designated as the backup in terms of it's a separate grid.
20 It's also a two-hour time difference that is working for us
)
i 21 in terms of the rollover of the clock, and that's why Region l
22 IV was chosen.
We do have some other elements that are l
23 planned and that we need to flush out and consider.
24 CHAIRMAN JACKSON:
It's a different grid, but it 25 also is fairly interconnected, is it not, with Mexico?
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1 MR. MIRAGLIA:
I believe.that is the case.
If you 2
go to Region III, we would probably have interconnections L
3 into Canada as well.
~
4 CHAIRMAN JACKSON:
Maybe Mr. Davis can speak about 5
some of what the industry may be doing in that regard in 6
terms of grid reliability, because the trans-boundary 7
interconnection creates vulnerabilities for the U.S. grid in j
8 '_
certain spots.
I know we have had very strong, at least I'm 9
told, planning and coupling with Canada.
I have less 10 information about Mexico.
But that may be because I just I
11 came back from Canada.
12 MR. MIRAGLIA:
Slide six, please, j
t 13 As I said, in July we received the responses, and 14 we'll have an idea on the state of readiness in terms of 15 dates and compliance and readiness issues within the 16 industry.
We also have the results of our audits to 17 evaluate.
i 18-The point in time in August is to assess what 19 regulatory actions might be necessary to follow up based on 20 our understanding for the state of readiness.
Those could 21 be focused reviews, additional site visits, requests for 22 additional information, management meetings, telephone 23 conferences, and plant-specific orders to assess the 24 information and require appropriate response.
25 In September of 1999, we would make a decision on l
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any need to issue a plant-specific order for Y2K problems.
2 We hope to be ahead of the power curve, so to speak.
3 As we have discussed already, in October of 1999 4
we would have the exercise of the agency's contingency plan.
5 Joe indicated there has been some interest in the 6
international community of various countries to come and 7
witness and observe.
We hope to have some participation of 8
licensees within that context.
9 In December we will stand ready to implement the 10 plan, and within the context of the contingency plan, the 11 response center will be manned 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before, and we will 12 have sustained manning until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the transition 13 date.
14 Commissioner McGaffigan mentioned some additional I
15 dates.
Those dates are being considered within the 16 industry.
In fact, I believe there are dates that go beyond 17 the year 2000 that are being looked at as other transition 18 type and rollover kinds of issues.
19 CHAIRMAN JACKSON:
Let me ask you two questions.
20 Should plant-specific Y2K actions be required, will they be 21 coordinated in such a way as to allow time to arrange for 22 replacement power?
23 MR. MIRAGLIA:
Our plan in terms of having it done 24 in September would give us that time.
Those orders could be 25 as severe as shutdown or they may address specific issues as
/
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well.
The idea would be if we have concerns to have those 2
identified by September such that we can plan accordingly.
3 CHAIRMAN JACKSON:
If a shutdown order were 4
required, have you developed factors that would affect when 5
the actual shutdown would best be accomplished?
6 Mr. Gunter, of course, is going to speak with us, 7.
and he has suggested that they be ordered six months in 8
advance of the new year.
Obviously, if we are coming up on 9
a September time date, we don't feel that is necessary, or 10 at least the timeline doesn't suggest that.
Or is there a i
11 risk-informed basis for a variability in shutdown?
3 12 MR. MIRAGLIA:
I think there is a little bit of 13 both, Madam Chairman.
It's in the area of work to be done.
14 We have some preliminary views that maybe Mr. Wermeil can l
15 share in a broad kind of context of some of the
[
l 16 considerations that we are looking at.
I 17 CHAIRMAN JACKSON:
It's still under review.
[
j l
l 18 MR. MIRAGLIA:
It's not even half-baked.
It's raw j
19 dough in a cold oven.
f l
20
[ Laughter.]
l f
21 MR. MIRAGLIA:
I don't want to raise expectations.
~
22 CHAIRMAN JACKSON:
Is your oven on?
23
[ Laughter.]
f 24 MR. WERMEIL:
Mr. Miraglia is correct.
We are
- 25 considering a set of guidance or an approach to how we would j
i I
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address issues where we felt we needed to act on a 2
plant-specific basis to address a Y2K concern.
That is 3
being coordinated now within the staff.
4 I think whatever action we would take, Chairman 5
Jackson, would depend on what the situation was, 6
CHAIRMAN JACKSON:
It's not that you need to tell a
7 me specifically, but I think the Commission needs to know 8
that you have some set of criteria developed certainly by 9
the time of the September date for making that decision.
)
10 MR. MIRAGLIA:
We will be sharing that with the 11 Commission.
12 CHAIRMAN JACKSON:
Thank you very much.
13 MR. MIRAGLIA:
That completes our prepared 14 presentation.
15 CHAIRMAN JACKSON:
Don't go away.
Now we will 16 hear from Mr. Jim Davis from the Nuclear Energy Institute.
17 I want to thank you for sharing your phone number with us.
1 18 We'll give you a call.
i 19 MR. DAVIS:
I want to thank you for an opportunity 20 to share some of my insights on what is going on in the 21 industry programs.
I have been responsible over the last 22 two years for the coordination of that program.
23 I think I would like to start with what I'll call 24 a compliment and a challenge to the Commission.
25 As I look around at all the people that have been i
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critiquing that program and making comments, the only people 2
that have the technical competence to really evaluate and 3
have been involved in the industry's program in an oversight 4
role has been the NRC.
There is no other government agency 5
or private agency that has attended our meetings or taken l
6 advantage of the opportunity to see what we are doing.
7 We've operated in the public arena, workshops, meetings.
l 8
We started long enough ago that Y2K was not a big 9
issue in the public arena, and we got most of our planning l
10 done before the rest of the world was interested or your l
11 staff was there.
As we get to'the end and start talking i
12 about what I call the madness bug, I think we both have the 13 challenge to put the right story into the public arena, and 14 you're the only one who has the independent capability to l
l 15 make that judgment on how we are doing.
People think I'm l
l 16 biased.
17 Second slide.
18 Three topics I'd like to cover very briefly.
I l
l l
19 want to look forward to what we are doing and not look l
i 20 backward.
i 21 To do that, with all the discussion that has gone
~
1 r
22 on, the objectives of our program have sort of gotten fuzzy
)
23 as the rest of the world has defined their objectives.for 1
1 24 what a program ought to be.
The name of the manual is 25
" Facility Y2K Readiness."
That is what we are moving toward i
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reporting'in July.
2 The objective of the program from the beginning l
l~
3 was to'be able to keep steam to the turbine and electricity
'4 coming out the other end.
To do that, as always the intent l
5 was to comply with regulations, rules, and licensing.
That's not just the NRC's, but anybody else that has put 6
7 requirements on'the operations of a facility.
It went well
\\
8 beyond just regulated components that other people have 9
implied, to include all systems that have some potential for 10 impacting the ability to keep that turbine going around and 11 putting electric power out.
12 CHAIRMAN JACKSON:
Let me just say the following.
13 I would like to think since you are talking to the NRC that i
14 there is really a twofold goal, one part of it-is the 15 safety of the plant, that is, minimize the risk problems 16 with plant safety systems.
The second goal is within that 17 context to keep the plants running relative to these larger 18 issues of stability of the grid and infrastructure.
19 MR. DAVIS:
I guess it's a fully integrated l
20 approach.
The philosophy is you operate safely.
So if I
~'
21 say I want to keep the turbine running, of course we want to 22 keep it running in a safe manner.
23 CHAIRMAN JACKSON:
I just think it's important, at j
24 least from our perspective, to --
25 MR. DAVIS:
I think you will sort of see some of i
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that thought process in the naxt slide when I get to it.
2 CHAIRMAN JACKSON:
I very seldom sit in this 3
position and give advice to people across the table, but 4
from the point of view of what Mr. Koskinen talked about i
earlier in terms of sharing of information, and you've given 5
1 i
6 us a challenge, which I think is an appropriate one, I want 7
to give you a challenge.
I think that the language with i
8 which you discuss what your intent is is very important, 1
l 9
because people do realize that there are licensees or people l
l 10 who are so focused on operating sometimes.
i l
11 MR. DAVIS:
I understand.
12 CHAIRMAN JACKSON:
I think it's a question more of 13 semantics, but I think it is very important in terms of what 14 message is conveyed to the public that people understand 15 that that balance is there.
That's all I'm saying.
16 MR. DAVIS:
The final point is, of course, we are 17 not just looking at the rollover date; we are looking at the 18 ability to operate well beyond December 31, 1999, for a i
19 number of years after that.
~
20 Next slide.
i 21 I think this sort of addresses your point.
When 22 we started, we realized, one, you're going to have to fix
(
23 everything that has a year 2000 problem some day, and yet we l
24 were a little bit concerned about the ability to.fix 25 everything before the rollover date.
So we did what we call i
d i
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initial assessment, a prioritized approach.
I have sort of i
2 used some color coding.
3 At the top of the list was " critical."
I've sort 4
of split it.
You'll see a red band, which in fact t
5 represents the safety systems and the systems required for 6
the safe operation of the plant.
Within that same area 7
would be something like the turbine control unit.
If it 8
trips, it shuts down the plant immediately.
1 9
Important items are other things like plant 10 process computer, the security system, and other components 11 that have an impact on your ability to operate the plant 12 even though they don't instantaneously trip that.
13 Within the context of the program, we see that 14 whole matrix as being what we are talking about in the l
l 15 facility readiness arena.
There was a prioritized approach.
1 16 We addressed the most important, the critical ones to safety 17 and those issues first, and worked our way down through the l
18 list.
So it was prioritized.
'19 There was an "other" category, which represented l
20 some things that were important to the business continuity 21 of the system.
An example might be a training management l
22 program that keeps track of requalification dates.
You can 23 do it manually, but it's manpower intensive.
That system l
24 would be cost effective to get it taken care of.
25 Finally, we found that there were a number of 1
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things that were in fact not essential in any manner, such 2
as a fax machine in a secretary's office.
It was not worth 3
the time and energy.to track and remediate that.
So if it 4
fails, we'll fix it when we get there.
5 So it's sort of important to go back and remember 6
where we started in this particular arena.
7 Next slide.
8 With that as background, I thought I would give 9
you the status of the industry as of January 31st.
Of 10 course we are talking about the 66 facilities and 103 11 nuclear plants, and we have total cooperation of every one 12 of those.
That initial assessment has been completed.
13 The detailed assessment, which is a phase where 14 you test to see whether there is a year 2000 problem and l
15 establish the remediation program that you are going to put 16 in place, on average we are 92 percent through that 17 particular program.
18 Most of the items remaining are in a structured 19 I program to come to completion or a lower priority on the 20 industry's list as far as impact on the plants.
I 21 Remediation on average is 54 percent complete.
t 22 CHAIRMAN JACKSON:
When do you think that 23 remediation average will be 95 to 100 percent?
24 MR. DAVIS:
Sometime in May would be my 25 projection.
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CHAIRMAN JACKSON:
Has the industry established a i
2 target date that in any way ties in with our target dates 3
for your response?
4.
MR. DAVIS:
Yes.
Our goal is.to finish the f
5 program and to be ready by 1 July, the final bullet.
Since 6
November my reporting has been aimed at that report.
We are 7
using the same terms and verbiage as we used in the manual 8
and'as we expect people to use in the report that they make 9
on 1 July.
In the final bullet we have 17 sites that have i
10 identified specific remediation items that will go beyond 11 that 1 July date.
The average is two items at any one site.
12 So we are talking about 34 items.
L 13 CHAIRMAN JACKSON:
But nothing in that red and j
14 dark red band?
l 15 MR. DAVIS:
There is something in that red and 16 dark red band.
For example, we consider the feedwater 17 control unit to be a critical item because if it trips, it 18-will shut down the plant.
There are two cases where we will i
19 have upgrades done in a fall outage to a feedwater 20 controller.
~
21 It,has been done on one unit, the same exact piece 22 of equipment, so we know it's going to work.
They are going 23 to put it in the second unit in the fall outage.
24 It doesn't seem appropriate to recommend a 25
.five-day unplanned outage to do that upgrade when you have i
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1 very high confidence that you are going to be able to make r
2 that repair.
That's the only thing I can think of that is 3
up in that top quadrant of my band.
l 4
CHAIRMAN JACKSON:
We've decided what we are going l
l 5
to do given our September date, something within this red 6
and dark red?
7 MR. MIRAGLIA:
That will have to be examined.
As 8
I said, site visits and follow-up Mr. Koskinen mentioned
]
9 the consideration of the NERC information.
We are going to 10 try to differentiate status in terms of delayed status with j
11 good justifiable cause relative to outages as opposed to 12 those things that are not indicating progress in the 13 program.
So I think it is that same kind of logic that we 14 hear.
We'd have to have an understanding of what is done 15 and the basis for the deferral.
16 CHAIRMAN JACKSON:
What is the status of 17 activities at the slowest plant?
18 MR. DAVIS:
Status of activities at the slowest 19 plant?
20 CHAIRMAN JACKSON:
Right, in terms of their degree 21 of detailed assessment, remediation, et cetera.
~
22 MR. DAVIS:
.I don't remember the specific numbers 23 for'which plant was at the slowest end, but my analysis 24 shows that every plant can meet the objective of completing 25 their program by 1 July and making the report.
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1 CHAIRMAN JACKSON:
I guess I'm interested in the 2
actual work being done, the testing, and so forth.
3 MR. DAVIS:
The problem with the numbers is that 1
4 we are working our way down and we are talking about a short 5
list of items.
If I really want to know what's going on on 6
a plant, I talk to them about the list of items they are j
7 working on and when those will actually be completed.
8 Whether they are at 40 percent on remediation or 80 percent l
9 on remediation, the actual items that they are working and 10 their significance is more important.
11 CHAIRMAN JACKSON:
I agree, but I'm speaking to 12 the data you presented to us, which is presented in terms of 13 percentages.
What I expect these folks to look at is in 14 fact the actual items, particularly those that would be in 15-the red and the dark red bands.
16 MR. DAVIS:
And the report that comes in in July l
17 will list the actual items that are outstanding; line number 18 by line number, it will list every item that is outstanding.
19 Any other questions on the status?
20 CHAIRMAN JACKSON:
No.
I'll have more for you, 21 though.
22 MR. DAVIS:
Audits has been a topic of discussion 23 in the past.
I guess I'd point out that the title of our 24 manual has the word "NUSMG."
People don't realize that this 25 industry may be a little bit strange.
NUSMG is a software l
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quality assurance organization that has been in place for a 2
significant period of time.
They are in there because we 3
drew on their talents.
So we've had quality assurance 4
inputs and involvement from the beginning of the program.
5 Within the industry there have been three types of 6
audits conducted.
7 The first is the internal QA program audits 8
conducted by the independent auditors within the facility, a 9
program developed and required by regulation.
Fifty-four of 10 those audits have been conducted.
11 CHAIRMAN JACKSON:
Is that at 54 sites?
12 MR. DAVIS:
At 54 sites, that's correct; 54 of 66 13 sites have had the internal QA program audit.
14 Cross utility audits have been one of our most 15 productive audits where we bring the expert from one 16 facility to another facility or from several facilities to a 17 facility to do an audit, in part because the program 18 managers take back almost as much as they give when they are 19 doing the audits.
We've had 33 of those.
20 Third party audits from a variety of independent 21 contractors or whatever, 43 of those have been conducted
~
22 throughout the industry.
This does not include any of the 23 NRC oversight.
24 At this point, 62 of the 66 facilities have 25 completed an audit of some type, as listed above.
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other sites have audits in progress or scheduled.
So we j
2 will have an audit conducted at every site.
3 CHAIRMAN JACKSON:
How are the lessons learned 4
disseminated within the industry?
Is INPO involved in terms 5
of best practices, et cetera?
- =
6 MR. DAVIS:
INPO is not involved in this aspect of 7
the program.
I have what is called a moderated list server, 8
which means you've got to be a member of it to use it.
It 9
involves the proj?ct managers at every facility and in many 10 cases the people working for them.
Insights and lessons 11 learned have been freely shared and exchanged on that 12 particular Web site.
That includes insights that we have 13 gotten from the NRC audits.
We summarize those; we publish 14 that to the industry.
15 In December we had a two-day workshop which was 16 basically an opportunity to review where we were and sort of 17 do the course correctionc that might be needed for the final
)
i l
18 year of the effort.
Y.
reviewed the NRC audits in detail
~
19 and we reviewed all the industry audits that had been 20 conducted, and we shared lessons learned during that 21 particular workshop.
22 COMMISSIONER MERRIFIELD:
Madam Chairman, I have a f*
23.
question.
24 Regarding your analysis of various aspects, to 25 what extent have you been working on the issue that was l.
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raised in the earlier panel about telecommunications?
Some 2
of these plants are served by telephone companies of very 3
small size that may not be as fully up to speed.
To what 4
extent have the utilities been going out beyond the plant 5
gate, so to speak, to deal with those issues from a 6
communications standpoint?
7 MR. DAVIS:
When we looked at contingency 8
planning, and that is a primary area that you look at, we 9
thought that grid stability and telecommunications support l
10 were the two issues that were most important to the facility 11 in that arena.
12 In the grid stability arena, we've been heavily 13 involved in NERC and following the NERC process.
They ure 14 obviously the experts in managing the grid and what is going 15 on.
In fact, in the most recent meeting a concern was 16 raised that the total load is going to be so low and we are 17 talking about so much spinning reserve on line that we may 18 generate instabilities by the number of plants that we put i
19 on line.
So there actually is going to have to be some 20 thought in that arena to ensure that the load and the 21 generation on line is in fact appropriate.
22 My evaluation is I think that is an area that NERC 23 is very good at.
They've been doing that since the '80s, 24 and they seem to be approaching that part of their 25 assignment fairly well.
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We recommended that the facilities delay their 2
~ contingency planning until January of this year.
We issued 3
the manual in August, but we found that there just wasn't 4
information available from the suppliers to make rational 5
judgments and evaluate whether they.would or would not be
.~
6 able to provide the services.
That information is now 7
available and people can judge which of their suppliers will 8
be reliable and which ones won't.
People are looking at 9
multiple sources of communications to provide the backup 10 that they need.
11 I'm sure you are aware that EPRI has had a program 12 working on embedded systems.
That has also provided another 13 forum for sharing.
This isn't just a nuclear problem; this 14 is for all the electric utility businesses.
15 They've had several interactions with the 16 telecommunications industry during those forums all the way 17 back to the one last August, and they also had some other 18 discussions in one just recently held.
In that forum there 19 is a lot of information being shared on what is going on in 20 the telecommunications area.
21 At this point I think the facilities have the 22 information they need to make rational decisions on what the e
23 risks are and what the mitigation strategies would be for 24 issues in the telecommunications area.
25 That sort of backs me into the discussion of ANN RILEY & l.9SOCIATES, LTD.
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contingency planning.
The reason I want to spend a few 2
minutes on th.is is because from the planning standpoint, 3
this is where we put most of our work and that's where a lot 4
of our discussions and the exchanges back and forth are 5
going.
The remediation program, the guidance has been laid 6
out, and we're coming to the close of the execution phase of 7
that.
8 In the first slide, the thing I really want to 9
emphasize is that contingency planning is in fact an element 10 of the overall facility readiness program and not a 11 stand-alone program that goes off and does something totally' i
12 independent.
It's an integrated effort to keep the facility 13 so it can operate and operate safely.
14 I didn't put it in the slide, but one of the other j
15 points that we have continually made is that contingency 16 planning is not an alternative to remediation.
Our program 17 requires that you find and fix the Y2K issues related to the 18 scope of the program that we discussed earlier and you don't 19 say, gee, I may have a problem here; I'll put a contingency 20 plan in place and hope that that will catch it.
21 Next slide, please.
22 We are looking at two distinct areas because of 23 the difference in how you have to analyze it and manage the 24 program in that area.
25 One is internal risks, which are things that are ANN RILEY & ASSOCIATES, LTD.
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l 1
under the facility's control, things that are within the l-l 2
fence, so to speak..
f 3
External risks is primarily the suppliers that we l
4 are talking about.
In fact, the external may be a different l
5 element of the same company, and we consider that an 3
6 external risk or an external factor.
7 Then sometimes you have to make judgments without 8
having full information.
9 CHAIRMAN JACKSON:
Let me ask you a variant on the 10 question that I asked Chairman Koskinen when he was here.
11 To what extent has.the Y2K Information and Readiness 12 Disclosure Act enhanced information sharing?
You mentioned I
13 there is sometimes a lack of detailed information.
14 MR. DAVIS:
I can answer that one.
In 1997 the 15 engineers were freely exchanging information.
I would call l
16 a facility and they would give me anything.
I would call a l
l 17 vendor, and they would tell me exactly what was going on and j
18 what the issues were.
19 CHAIRMAN JACKSON:
Stop.
You're telling me the 20 history of the industry, and so there is as much information 4
21 sharing as there needs to be.
22 MR. DAVIS:
No.
In 1998 the story changed.
The o
23 Washington Post said there is more money to be made in i
24 litigating than there is to be made remediating.
Suddenly l
25 it became very difficult for us to get information from l
i i
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anybody because now there was this legal concern that was l
2 coming to the fore as we started to move forward in the 3
program.
I have seen that pressure relieved and people are 4
now back to exchanging information because of the Disclosure I
5 Ac't.
It has had a very definite impact on the ability to 6
get reasonable information from suppliers and from other l
7 parts of the program.
l 8
CHAIRMAN JACKSON:
That's good.
i 9
COMMISSIONER MERRIFIELD:
Madam Chairman, there l
10
-was another element of Mr. Koskinen's comments, and that was 11 the degree to which the utilities are sharing with the 12 general public information about what they are doing.
He t
13 asserted that some entities, some companies were being very i
14 closed mouth about what was going on.
i i
15 I guess my question is, to what extent is NEI and i
l 16 its members going to be doing, for lack of a better word, a 17 public informational effort to try to give some confidence
{
10 to the public that you are indeed doing the things that need 19 to be done to have the confidence that when they turn on the 20 lights when that date rolls around that they will be still I
i 21 on it.
22 MR. DAVIS:
There are two issues.
One, the
=
23 priority has to be on getting the work done and getting the 24 remediation done.
I've been trying very hard to protect the 25 project managers, because this is a challenging program and ANN RILEY & ASSOCIATES, LTD.
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they've taken on an ambitious task and made some commitments 2
to get things done.
I've been trying to protect the project 3
managers so that they can get their part of it done.
The 4
nuclear element is one part of a program.
Every utility has 5
some sort of information sharing approach.
J5 6
In fact, Steve Unglesbee, one of our PAO types is 7'
here today, and we'll make sort of a media release.
We're t
8 trying to get the information out at the NEI level.
9 What I see is important is this report that we are 10 talking about at 1 July, because I see that as an 11 opportunity for us to come to a point where I think we can
[
r 12 put the whole thing in the public arena and have it 13 understandable.
14 When you have lots of little elements that you are 15 talking about and you say, well, this one is going to be 16 done there and this one is going to be done there, it gets 17 very confusing, and in fact you have to spend a lot of time 18 and attention to truly understand where the industry really l
19 stands, as we discussed earlier.
The numbers by themselves 20 tell me very little.
It's only a vehicle for me to get at 21 what is really going on.
22 I'm looking for this 1 July time frame to be an 23 opportunity for us to lean forward in that area.
i 24 COMMISSIONER DICUS:
If I could follow up on that.
25 I certainly would encourage you to encourage the industry to l
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be as open as possible, though, and to be dealing with the 2
public, particularly the public around the plants, as early 3
on as possible.
I think that will help give much greater 4
confidence.
I'm not sure I would wait until July.
I
{
5 understand the report, et cetera.
1 6
MR. DAVIS:
That is a generic issue.
It has been e'
7 discussed.
It has not only been discussed within our forum, 8
but it has been discussed within the NERC forum, the
'9 workshops I've gone to there, and various others.
I think i
10 we all realize the need to get the right information into i
11 the public arena, and I think we are trying to do that, i
12 while at the same time keep the program going forward.
13 We've actually got some demonstrations that we are 14 recommending people run for the press to try to understand 15 what causes a failure and what it looks like and that kind i
16 of stuff.
17 Don't get the impression that we are not involved I
18 and not trying to get the information out.
I think at every l
l 19 utility the program manager is working with their public i
20 relations people.
I look at a number of Web sites and there 21 is a lot of information available in the public arena from
)
22 the utilities.
The question is whether people can digest
(
- 23 that and accept that as a truthful answer.
I think that is 24 where our problem is.
People sometimes don't want to accept 25 the utilities' statements as to where they are.
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COMMISSIONER MERRIFIELD:
I share Commissioner 2
Dicus' comments.
There was a CEO at a utility I recently 3
visited who shared the same concerns.
There are a lot of 4
people out there trying to sell generators to the American 5
public that they don't need because of a concern that the h
6 lights are going to go out.
To the extent that there is not 7-sufficient information, I think part of that activity is 8
because some of the public haven't gotten that information.
9 I think there does need to be a commitment of NEI i
10 and its members with other non-nuclear power producers to be 11 out there not only getting the job done, but making sure the 12 public is aware of it.
I can't stress that strongly enough.
13 CEAIRMAN JACKSON:
I'd put it even more strongly.
14 I would say a part of getting the job done is sharing the 15 information with the public.
You mentioned something that I
16 struck my fancy, which had to do with even having 17 demonstrations.
Otherwise, it becomes a " don't worry, be 18 happy" message.
19 There is always this balance of protecting.
We 20 have it around here with people so that they can get done l
21 what they've been asked to do vice having to interface, but i
22 it doesn't necessarily have to be the project manager who 1
e 23 goes out there and does it.
24 You all know as much as we do that you exist
[
25 within a particular context in terms of these communities l
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where the plants are, with your own public advocates in 2
states that have them, and things like that.
Investment up 3
front could pay dividends in the end not.only in terms of 4
not having public panic, but actually developing a level of
'5 trust with the communities around you.
6 MR. DAVIS:
Thanks for the input.
r' 7
Slide number,9 just emphasizes that it's a
~8-balanced program and that in fact most of the contingency 9
planning will focus.on the external risks because 10 remediation has been the predominant effort in the internal l
11 risk area.
l 12 To do an individual contingency plan relative 13 component, you need three elements.
There has got to be 14' some risk of failure; there has got to be some consequence l
l 15 of that failure; and you need to have some sort of 16 mitigating strategy.
l 17 The example I use'in that area is the turbine 18 control unit.
If the turbine control unit trips, of course l
l i
l 19 there is a very short period of time, nanoseconds between i
l 20 the time it trips and the time the reactor trips.
So having
~
21 a contingency plan for what you do in that case is not very 22 productive.
You ought to put your effort somewhere else in 23 there.
{
l 24 CHAIRMAN JACKSON:
Is the industry aware of NRC's 25 contingency planning and are there any significant concerns 3
i i
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l 1
one way.or the other?
2 MR. DAVIS:
The industry is aware of the NRC i
l 3
contingency plan, and it was issued, I think, the day before l
4 our workshop and we'actually discussed it at the workshop.
l 5
You will get some comments from us tomorrow morning.
The l
^
6 NSAIC is meeting today and they have an opportunity to l
7 review it.
We basically think it will be very supportive.
8 The one comment that we have is we think that the 9
discussion of ' 50.54 (x) is unnecessary because we don't see a 10 scenario that will put us in a position that we will go that 11 far.
So our recommendation is that you not waste your time 12 thinking about 50.54(x), that the other elements are going l
13 to be perfectly adequate to support the scenarios that we 14 see.
15 MR. MIRAGLIA:
We asked for comments on those 16 approaches.
17 MR. DAVIS:
You asked for comments, and you're 18 going to get them.
l 19 MR. MIRAGLIA:
Thank you.
20 MR. DAVIS:
I'm obviously winding down here.
21 The next slide, number 11, just says you've got to 22 do some analysis.
You get a list of hundreds of items.
You 23 don't do contingency planning for every one.
If it's low L
24 risk, low consequence, you don't plan for it; the high risk, i
i 25 high consequence, you do plan for it.
I leave in the yellow 1
4 d
s
]
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area because I'm having trouble convincing people that 2
engineering judgment is involved as part of this process; 3
it's not a PRA analysis; you've got to use some judgment.
i 4
CHAIRMAN JACKSON:
Specific areas are put into i
5 these boxes?
6 MR. DAVIS:
There are a variety of schemes, but 1
7 you look at rish versus consequence.
8 CHAIRMAN JACKSON:
What I am saying is these 9
things are populated with actual areas or systems.
t 10 MR. DAVIS:
Or you have a table with a number.
11 You try to prioritize on the two scales.
12 CHAIRMAN JACKSON:
What about the exercise of the 13 contingency plan?
Is that built into what you are doing, 14 actually walking through or exercising the contingency plan?
15 MR. DAVIS:
Yes.
The final slide leads to that.
16 You've got to take all these individual elements that you've 17 developed for the components, wrap them up in an integrated 18 contingency plan, and that is what we are targeting to have 19 done as part of our overall program by July.
20 Then you have the execution phase.
It involves 21 training, exercises and various other elements.
If you look
~
22 at the manual, you will see that we actually have a section 23 in that form that says what action has to be taken, level of 24 training, exercise, and that kind of stuff, to exercise the 25 capability and train the people and if necessary order the ANN RILEY & ASSOCIATES, LTD.
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spares, buy the extra radios, or whatever you want to do.
2 I just wanted to close with one final slide.
It's 3
my opinion that we are going to be able to come to closure 4
on this year 2000 program and that in fact we will be able 5
to control the Y2K bug fairly handily.
But as we have sort a.
6 of discussed, I think the " madness bug," and I picked that 7
up from a recent Time article, is becoming more of a problem 8
to us as we move through the rest of this year and how to 9
handle that.
That is sort of beyond some of my technical 10 expertise and abilities.
11 CHAIRMAN JACKSON:
Thank you very much.
I'd like 12 to thank the staff and Mr. Davis.
13 I'd now like to call forward Mr. Paul Gunter from 14 the Nuclear Information and Resource Service, for a 15 presentation.
16 MR. GUNTER:
I'd like to thank the Commission for 17 the opportunity and your flexibility to provide us with this 18 time, albeit late in the hour here.
19 CHAIRMAN JACKSON:
That's all right.
Our meetings l
20 are always long.
21 MR. GUNTER:
I know.
22 I think what we would like to do is just briefly 9
23 revisit the three petitions that are now before NRC with 24 regard to the rulemaking.
l 25 The first is to require compliance by December 1, l
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1999.
I'think one of our concerns here is the issue of 2
readiness versus compliance that was raised by GAO in.its 3
critique of General Letter 98-01.
4 It's apparent to us that there is an economic 5
driver here and that readiness does not necessarily equate 6
to compliance.
I think it woul'd be helpful if there was 7
some way to make the process more transparent in terms of 8
how economics is playing into this issue.
Certainly there 9
are a number of other areas that we are aware of where 10 economics plays to the detriment.
This is another example 11 we'd like to see some clarification on.
I think that is 12 part of the purpose behind addressing this in a rulemaking.
13 CHAIRMAN JACKSON:
Let me ask you this question.
14 Why is compliance vice readiness such a focus?
What is it 15 that you see that readiness doesn't gain you from a public i
16 health and safety point of view that compliance will?
17 MR. GUNTER:
I'm coming at this from a lay f
18 understanding.
You'll have to bear with me here.
My 19 understanding is that on December 31, 1999, with the 20 rollover compliance, it would provide that you roll over to 21 January 1, 2000.
'~
f i
22 In fact, it's my understanding that that is not 23 going to be the case in a number of systems, that you will f
24 have patches or actually rollbacks, where you will roll back 25 to a date that has some suitability determination and j
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analysis that determines that while it is not compliant, l
2 there will be noted in the operator log that it's not 1982 3
or whatever the date is, but that the equipment will still i
j 4
be reliable and operable.
5 I think what GAO addressed was that there needs to e.
6 be a more transparent and visible process for how the 7
utility made those determinations of suitability.
8 Certainly, I think the more that is out in the public arena, 9
the more independent review you have of those kinds of 10 suitability judgments.
11 The second petition would require annual emergency 12 drills only for the year 1999 at all reactors with a Y2K 13 component to exercise.
14 I think basically what our focus here is that we 15 were looking to a rule that would provide the broadest 16 experience for contingency planning, and that those drills 17 and the information gleaned from those drills could be put 18 into an NRC guidance document that would be put into each 19 and every one of the reactors' emergency operation centers 20 so that when we roll over to the year 2000 that there is a 21 log that would provide for an operator to go to an event 22 that is occurring, that was run through in a drill, and he 23 would have the experience of that drill; he would have the 24 expertise of another operator who went through that drill; 25 but this would be not on an unseen or unprepared for event.
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1 We have an opportunity to run through this drill 2
at 103 reactors and provide a very broad range of 3
contingency planning through the preparation of such a 4
guidance document.
5 CHAIRMAN JACKSON:
You don't think that the Y2K l
6 exercise that the staff described, the li -le curve that is i
7 being planned, will accompliFh that?
{
8 MR. GUNTER:
I don't know that.
I haven't seen 9
the extent to which staff is planning to run through the 10 number of events that would be covered and made available.
11 CHAIRMAN JACKSON:
Maybe that information can be 12 shared.
r 13 MR. GUNTER:
That would be helpful.
14 The third petition would require that all t
15 emergency diesel generators be operable at the rollover date 16 and subsequent sensitive dates.
i 17 CHAIRMAN JACKSON:
Is it not true that the 28 licensees are planning to in fact have their diesel 19 generators on?
Is that true?
20 MR. GUNTER:
This would raise a concern.
Again, I i
21 think that " operable" is the word here.
If we look just i
22 recently to the Fie.zpatrick event, during that fire the 23 licensee turned the emergency diesel generators on in 24 advance of actual loss of offsite power, and subsequently in j
25 a DER we learned that in fact that activity could or I
(
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probably would -- I'm not exactly sure what the language was 2
in the DER -- but that it would have prevented, I think, the 3
loading of those safety buses, cecause you would have those 4
EDGs opcrating in advance of an actual loss of offsite 5
power.
6 CHAIRMAN JACKSON:
I don't know that the 7
connectivity was ther". in the Fitzpatrick event.
There was e
8 an issue of loading the safety buses, but I don't know that 9
it had to do specifically with the EDGs being turned on 10 beforehand.
I think the issue of the safety buses not 11 loading in this specific case of the Fitzpatrick event 12 MR. GUNTER:
Okay.
I'd like to see clarification 13 on that.
14 CHAIRMAN JACKSON:
You guys are my technical guys, 15 but that is my understanding, that it wasn't the fact that 16 the diesel generators, EDGs were on, that prevented the 17 loading.
The issue about the safety buses not loading had 18 to do with a separate set of issues; is that correct?
19 MR. WERMEIL:
That's my understanding.
20 CHAIRMAN JACKSON:
Okay.
~
21 MR. GUNTER:
I'll have to work that over with Dave 22 Lochbaum.
He's my technical adviser.
23 CHAIRMAN JACKSON:
All right.
24 MR. GUNTER:
Again, I think the app ndix that we 25 put together gave us some pause.
In looking over the past ANN RILEY & ASSOCIATES, LTD.
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two years'of EDG events, we didn't share that 95 percent 2-level of confidence that NRC and the industry tout for the 3
emergency diesel generator turning on.
Still, even with 95 4
percent reliability, that still leaves 5 percent out there 5
in question.
That's why we have included an additional 6
request that there be some additional backup power because 7
of the uniqueness of this event and the possibility of 8
widespread disruptions, and that that be considered, and it 9
was placed in the rulemaking.
10 Additionally, that rulemaking request also would 11 provide that the irradiated fuel pools be reclassified to 12 class 1E systems so that they would be safety-related 13 systems with emergency power available at the time of loss 14 of offsite power.
15 I think the two questions that we have to NRC and 16 staff basically go back first to the staff memorandum dated 17 January 19th, which basically states that independent 18 verification and validation of Y2K readiness of remediated 19 nission-critical systems is important.
20 Additionally, the memo states that industry 21 reliance on vendor certification of Y2K susceptible systems
~
22 varies.
However, NRC has determined that no regulatory 23 basis exists to require testing.
24 Given that a number of Y2K vulnerable systems, 25 while not classified as safety related or mission critical, ANN RILEY & ASSOCIATES, LTD.
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.can have impact on safety and operation, our question is, t
2 how can the public safety be assured without the 3-verification and validation process available only through 4
' independent testing of remediated susceptible systems?
5 Certainly we gain confidence by hearing that there l+1 6
is some testing going on out there, but without knowledge of l
[
7-the degree of testing, there still is this area of concern.
8 If ycu can shed some light on this, it would be helpful, but 9
certainly in the light that NRC doesn't claim to have a 10 regulatory basis for requiring such testing.
11 CHAIRMAN JACKSON:
You are saying there needs to 12 be some knowledge of the degree of testing that is going on, 13 a verification and validation.
14 MR. GUNTER:
Not only knowledge, but it would be 15-comforting to know that there was an enforcement level out 16 there.
17 COMMISSIONER McGAFFIGAN:
Madam Chairman, should 18 we consider this a fourth petition for rulemaking?
19 I don't read it in your first three.
There are no 20 words in your first three petitions about independent 21 verification.
j 22 MR. GUNTER:
We can submit it.
23 COMMISSIONER McGAFFIGAN:
I'm not looking for a l
l 24 fourth.
25
[ Laughter.)
i 9
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1-MR. GUNTER:
Obviously there a lot of thought has i
2 gone into this process between when our petitions were put 3
forward and certainly more questions will continue to come l
4 to the fore as we move closer to the date.
Hopefully, there 5
will be much more resolution than questions coming to the 6
fore.
This is one area that came to light to us in terms of j
s 7
the NRC's own response through it's January 19th memorandum.
~
8 Finally, in the interest of public safety, we I
9 would like to know if the NRC can provide the public with i
10 the knowledge of just how many irradiated fuel pools out 11 there are not currently hooked up to emergency power for 12 cooling capability.
This is not only a concern of NIRS',
13 but UCS does share this concern with us in light of the fuel l
14 pool issue.
I 15 So we would like to get some sense of just how i
16 much uncertainty is out there in terms of providing l
l 17 emergency power to the large inventories of radioactive j
18 waste that are at each of these sites that currently would l
l 19 begin to' heat up in the event of a loss of offsite power.
l 20 COMMISSIONER McGAFFIGAN:
Madam Chairman.
I 21 CHAIRMAN JACKSON:
Please.
i 22 COMMISSIONER McGAFFIGAN:
I'd like to ask a couple f
23 of qu2stions that follow up on a point that was made 24 earlier.
t 25 It's a little frustrating to get petitions for t
L i
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rulemaking on December 10, one of which cites 1/1/99 as a L
2-critical date, that the rulemaking petition should be 3
granted by that date.
It was stated earlier that NEI for l
4 several years has had these meetings; NRC has dutifully l
l 5
attended and worked with them; and others haven't attended.
l
-e, 6
When did you all start following this issue closely, and why l
7 didn't we receive these petitions in 1997 or some date that 8
might be in the art of the possible to respond to them by i
9 1/1/99, if indeed you wanted one of them in effect by 10 1/1/99?
11 MR. GUNTER:
I think you have to understand that
)
l l
12 we only have six people on statf and that there are a number 13 of issues out there.
We deal with resource issues'as well.
1 14 So part of it is dealing with and managing issues according j
i 15 to available resources.
16 Again, we don't view these as controversial 17 petitions.
18 COMMISSIONER McGAFFIGAN:
It strikes me, as one i
19 Commissioner, that some of these things that you are asking 20 for here couldn't possibly have passed any sort of 21 cost-benefit analysis.
We do have a backfit rule and all of 22 that.
I'm not sure whether we will even get to that point.
l 23 A 60-day supply of fuel for emergency diesel generators.
i j
24 There is nothing in your petition, for example, that 25 provides any justification for a 60-day supply.
That is the
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.one that was supposed to ba in effect by 1/1/99.
So they l
2 would have had to have all run out in December and bought 60 l
l 3
days worth of fuel.
l l
4 Is there a better way to have a dialogue with you l
5 all than have three petitions for rulemaking come in on L
6 December 10th and get you involved in these ongoing public t-I t
7 interactions that we have and ask questions?
i 8
A petition for rulemaking is a resource-intensive 9
process.
We put it out for Federal Register Notice, as you 10 requested, more promptly than we normally do.
We are 11 getting responses back.
We'll analyze the responses.
To 12 some degree that may not even serve your purpose if it
)
13 diverts resources from people who are trying to get the job 14 done and processing a bunch of paper.
15 Is there a way other than the rulemaking process i
16 to constructively engage with us?
)
17 MR. GUNTER:
I think that we would be interested 18 in opening that dialogue.
We only have the resources that l
19 are available.
Me become aware of the process through i
20 participation.
There is the 2.206 process as well, but I 21 think that we made an evaluation that this was a way of
~
22 engaging the public and opening the issues to dialogue, 33 albeit at a late date, but certainly we have opened up the 24 process and we have engaged the agency and the industry 25 through these petitions, and that was our intent.
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CHAIRMAN-JACKSON:
Let me kind of piggyback on 2
what Commissioner'McGaffigan has raised.
Have you had the 3
opportunity to review the NEI guidance for dealing with Y2K
.4 and do you havelany thoughts about whether there is anything 5
missing, et cetera?
6 MR. GUNTER:
We have looked at the guidance 7
document.
It's not our study, but we did review the GAO's e
8 report..There were areas in.the GAO letter of March '98 9
that did study the industry guidance and found it wanting, 10 particularly in areas of not necessarily providing enough 11 information to licensees on embedded chip systems, as well 12
.as the GAO's recommendation that the regulator not have too 13 much reliance on this industry guidance document as well.
14 COMMISSIONER McGAFFIGAN:
The-only point I was 15
.trying to make is I think there is a constructive way to 16 engage with us short of these formal processes, the 2.206 or 17 the rulemaking process.
Those are two avenues, but you 18 mentioned UCS earlier.
19 Mr. Lochbaum, I think over the last couple of 20 years, has done wonderfully well in engaging us outside of 21 those processes.
Millstone restart was not a formal 1
22 proceeding.
He was invited to talk to the Commission.
He 23 participated up there in our enforcement review.
He has 24 been involved in the public dialogue, our new inspection and 25 assessment systems.
He has been involved in the public i
f-ANN RILEY & ASSOCIATES, LTD.
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S-100 1
dialogue not through petitions or rulemakings, but showing i
2 up at these meetings and workshops and writing very powerful j
3 and on the point letters evaluating, say, our escalated 4
enforcement actions over the last couple of years, or S
evaluating the effectiveness of our level 4 enforcement 6
program, et cetera, et cetera.
^
7 He doesn't always agree with us.
Occasionally he 8
does on level 4 enforcement; occasionally he doesn't on 9
Millstone restart.
10 But I think without using these formal processes, 11 which you are welcome to use, but these informal processes.
12 Appearing before ACRS.
I think Mr. Lochbaum has engaged 13 them on PRA and how much faith we should have on PRA.
14 That was my only point.
It is frustrating.
15 CHAIRMAN JACKSON:
I think there is a way to 16 provide a context for this.
We don't know all there is of 17 what your history has been in terms of NRC and having issues 18 that you feel affect public health and safety addressed in a 19 straightforward and fair way, but this Commission has taken l
20 major steps to engage all of our stakeholders, not just the l
21 nuclear industry, but in fact that is part of how 22 Mr. Lochbaum has come to be more directly involved in a 23 number of things but in a way that doesn't compromise what 24 his role is.
25 I think there is an opportunity for you or a ANN RILEY & ASSOCIATES, LTD Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.
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i S-101 1
representative of your group to be equally engaged.
2 Of course, if you don't feel that we are being 3
responsive or at least answering the questions, and 4
responsiveness may not always mean that we do exactly what 5
you may ask, that's true of the nuclear industry too.
You
[
lm 6
may have a different perspective, but that is certainly the i
7 point of view that I have advanced, that we engage, and 8
being responsive doesn't mean we do exactly everything that 9
they want us to do.
l l
10 I think that we would like to have more 11 participation and have you involved in the stakeholder 12 process so that you have on a more continuing basis an 13 opportunity to have us understand where your concerns are.
14 Even in the midst of that,'you are still very welcome to 15 have petitions for rulemaking or any other kind, but I would 16 also urge and invite you to do that, j
17 MR. GUNTER:
I appreciate that.
I believe it is a l
18 two-way street that we are talking about here.
Our 19 participation is facilitated by notification and by 20 invitation and a number of avenues.
l 21 CHAIRMAN JACKSON:
That's a fair statement.
22 COMMISSIONER MERRIFIELD:
I would just piggyback 23 on the comments of the Chairman and my fellow Commissioner.
l 24 I take it from your comments a lot of your concern is i
25 generated out of the GAO document and that snapshot in time ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 2
84 - b34
S-102 i
-1 where the industry or perhaps we were.
That document at 2
this point is almost: a year old, and I think there has been j
3 a lot of work, as we have heard today, both by our staff as.
l 4
well as by the industry.
5 Are we where we should be?
That's a decent 6
question and one which you and your limited staff can go w
7 back and take a look at that.
As the Commissioners have 8
encouraged you to become engaged on that, you've got 9
constructive work to help all of us move together to make 10 sure that when we do get to that time change it's done 11 right.
12 The other thing I would mention is we have our own j
13 contingency plan that the agency has prepared so that we are 14 ready as well.
I don't.know whether you've had a chance to I
15 look at that document, whether you have any comments.
I 16 Certainly I would encourage you, if you haven't, to have the 17 same kind of engagement with that document and our plans as 18 you do with the direction the utilities are going in.
19 CHAIRMAN JACKSON:
I will ask the staff to make I
20 sure that it reaches out in terms of a notification and 21 invitation to workshops and meetings, and we invite your
[
22 participation in the Commission meetings.
i 23 I heard what you said.
It facilitates, it helps 24
.you when you are really notified.
Many of the things are on 25 the Web and/or in the Federal Register, but we can make a i
i ANN RILEY & ASSOCIATES, LTD.
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1-particular effort to ensure that you know when-the various meetings and workshops occur and that there is appropriate 2
3 sharing 4
COMMISSIONER McGAFFIGAN:
Madam Chairman, I think 5
that goes outside of this area.
m 6
. CHAIRMAN JACKSON:
That's right.
i 7
COMMISSIONER McGAFFIGAN:
Lochbaum may have been
?.*
8 particularly effective at it the last couple of years.
We 9
know what his list of interests are, and I think he gets 10 special invitations.
11 Indeed, we had a fiasco back in December where he 12-got the special invitation.
We didn't get it on the Web 13 page and he didn't participate in the meeting, as was his 14 right, because he didn't feel he had been properly noticed, 15 although he personally had been properly noticed.
=16
.If we can get a list of items on which you want to 17 engage, I think we can do what we do for Mr. Lochbaum, make 18 sure you get outside of the Web page and these other formal L
19 mechanism direct invitations.
20 CHAIRMAN JACKSON:
And information as appropriate.
21 Certainly we can provide you an answer to a question of what 22 our regulatory basis or authority really allows us to do in 23 some of these areas as well as. knowledge of the degree of l
24 testing of these systems that occurs.
i 25 MR. GUNTER:
I appreciate it.
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I S-104 1
CHAIRMAN JACKSON:
Anything else?
2 COMMISSIONER MERRIFIELD:
I have a final comment.
3 I want to thank the Chairman for convening this meeting 4
today.
This is obviously a very important issue and one I 5
think all the Commissioners, including me, are treating 6
very, very seriously.
I think we as a Commission have gone 7
ahead with'a contingency plan, which I think is a good one.
8 I think the staff is to be commended for that as well.
9 I personally would like to be very involved in the 10 exercises.
Obviously the Chairman has the control over 11 those, but I would like to be an interested participant at a f
12 minimum, because I think it's important.
13 CHAIRMAN JACKSON:
Thank you.
l l
14 On behalf of the Commission, I would like to thank 15 all of our speakers today.
While the information presented 16 by the industry and the NRC staff is encouraging, the vexing 17 nature of it demands that we remain focused and vigilant.
18 Indeed, as Chairman Koskinen pointed out in his 19 testimony before the House Committee on Government Reform 20 last month, "You are never really done" preparing for Y2K.
21 Mr. Gunter's sobering observations also provide a 22 useful counter to any inclination to become complacent.
23 As I mentioned in my opening remarks, I would like 24 to go back to this issue of the failure of a plant computer 25 this week at one of our nuclear plants.
I mentioned the ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
S-105 1
good news, and I repeat it.
2
.One, the problem was identified.
'3 Two, it was identified as a consequence of' 4
testing.
5 Three, it did not affect an active safety system
- q 6
such as the reactor protection system.
7
'And four, _the plant stayed on line.
8 This occurrence highlights, though, the need to 9
analyze, remediate and validate early so that multiple 10 failures do not occur simultaneously.
It always points'out 11 that, as always, and you hear me say this all the time, 12 results are what matter.
Results are what matter.
13 I had someone tell me that, oh, well, this is like 14 any software glitch.
We know that software has mistakes.
15 But no amount of analytical elegance will obviate the need 16 for thorough testing.
17 I would encourage the staff and the nuclear 18 industry to remain mindful of this as confidence in the 19 ability of our licensees to pass through the turn of the 20 century unaffected increases over time.
~
21 There is one other point that became evident 22 through the course of the international workshop that I O
23 attended, and'that was the degree to which some countries 24 are unprepared for Y2K.
Someone said that contingency 25
. planning is no substitute for actual remediation, but I have I
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ANN RILEY & ASSOCIATES, LTD.
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e S-106 1
said this, and I'll say it here.
It would appear that in 2
fact contingency planning may, for those countries, and 3
maybe should, require the greatest emphasis, as insufficient 4
time may remains to approach the problem in a measured way, 5
in the way that the U.S.
industry and the NRC has.
6 It therefore underscores the imperative to 7
maintain our focus and to complete our own preparations as 8
expeditiously as we can, because it will help to protect us 9
from having to become reactive and allow us to be a model 10 and supply help to the international community.
11 Once again -- he's not here -- I would like to 12 thank Chairman Koskinen; I would like to thank our own 13 staff, Mr. Giitter, Mr. Wermeil, Mr. Miraglia; thank 14 Mr. Davis from the Nuclear Energy Institute; and Mr. Gunter 15 from the Nuclear Information and Resource Service for 16 participating in today's meeting.
17 Unless there are any final comments, we are 18 adjourned.
19
[Whereupon, at 11:36 a.m.,
the briefing was 20 concluded.]
21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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h l
CERTIFICATE-i 1
l
. This is to certify that the attached description of a meeting of the U.S. Nuclear Regulatory Commission entitled:
v, I
TITLE OF MEETING:
BRIEFING ON Y2K PUBLIC MEETING l
PLACE OF MEETING:
Rockville,' Maryland DATE'OF MEETING:
Thursday, February 11, 1999 was held as herein appears, is a true and' accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company Transcriber:
Michael Paulus
)
Reporter:_ Michael Paulus i
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NRC BRIEFING ON YEAR 2000 i
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February 11,1999 i
i FRANK J. MIRAGLIA, JR.
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i NRC & PRESIDENT'S COUNCIL i
President's Council on Year 2000 Conversion l
i Energy /
Health Care Emergency Services Electric Power Sector Sector Sector r
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REGULATORY APPROACH FOR l
ADDRESSING Y2K CONCERNS
- Integrated, inclusive Approach
- Stakeholders involvemerit i
- Public awareness
- International
- " Risk-informed", Graded Approach
- Power Reactors
- Fuel Cycle Facilities
- Material Licensees
- Non-power reactors
- State Programs i
- Contingency Planning 3
i g
2 i
TIMELINE OF NRC Y2K OVERSIGHT EFFORTS 1996-May 98 --
- Information Notices (2)
Work with Industry / Stakeholders May 1998 - -*
Issued GL 98-01, " Year 2000 Readiness of Computer Systems at Nuclear Power Plants" r
i June 1998 - -*
GL 98-03 to fuel cycle facilities Received first licensee responses to GL 98-01 August 1998 - -*
confirming implementation of NEl/NUSMG l
97-07, " Nuclear Utility Year 2000 Readiness" t
Information Notice 98-30 to material licensees and fuel cycle facilities Began NRC staff sample audits of September 1998 - -*
12 licensee Y2K readiness programs
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TIMELINE OF NRC Y2K OVERSIGHT EFFORTS
[
January 1999 -
Completed sample audits of Y2K readiness l
programs; issued GL 98-01 Supplement 1 l
Issue Information Notice summarizing Y2K l
March 1999 - -*
readiness audit observations and lessons learned Final Y2K Contingency Plan to Commission I
Begin review of 6 licensee contingency April 1999 - -*
planning efforts 1
Decision on NIRS petition l
i June 1999 - -*
Complete licensee contingency planning reviews Complete internal Y2K response procedures and provide industry guidance i
National Table Top Exercise j
e l
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4
+
TIMELINE OF NRC Y2K OVERSIGHT EFFORTS July 1999 -
Review second licensee responses to GL 98-01 or GL 98-01 Supplement 1 confirming Y2K readiness and determine need for plant-specific followup action August 1999 - -*
Appropriate regulatory follow-up may include:
- Focused reviews / site visits
- Requests for additional information
- Management meeting / teleconference
- Plant-specific orders NRC decision on need to order plant specific September 1999 -
Y2K action October 1999 - -*
NRC Y2K Exercise Implement Contingency Plan December 1999 - -*
6
4 Nuclear Ltility Readiness
)
Status Report l
February 11,1999 l
Jim Davis
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,U iLJ t) <> : 13 Nuclear Energy Institute 202-739-8105 NEI I
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Topics i
l i
I Program Objectives i
1 i
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Current Program Status i
l Contingency P. lanning l
NEI 1
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i
" Facility Y2K Readiness" I
= Objective is continued safe production of electric power
. Within regula: ions, license and commitmen1:s
. Includes systems that could preven:
continued plant operation
. Oaerate well beyond December 31, j
1999
= Al 66 facilities with 103 plants NEI k
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i Initial Assessment i
t A prioritized approach l
=
i Facility Readiness ITUpOrtant s
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No action l
Inventory 4
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Status--January 31,1999 Initial Assessment -- 100%
=
l Detai; ed Assessment -- 92% (average)
=
l
. Most items in progress or
. Items oflow priority j
i
= Remediation -- 54% (average)
. Wor 1ing a finite list
.17 sites have a few items t:aat will finish after July 1 -- most appropriately delayed until a scheduled outage NEI 5
i 3-
l i
Industry Audits i
f
= Three types of audits conducted j
. In:ernal QA program audi:s -- 54
. Cross u':ility audits -- 33
. Third party audits -- 43 j
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+ Does not include NRC oversight
= All 66 sites will have an audit i
. 62 completed
~
. 4 in progress or scheduled NEI 6
l i
Contingency Planning
= An integral part of" Facility Y2K Readiness"
= Contingency P:anning, in conjunction with the facility remec iation program, is an effort to prevent the occurrence of and mitigate the consequences of l
equipment, software or process failures caused by Y2K problems NEI 7
e.
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Two Distinct Areas
= Internal Risks
. L nder facility control
. Testing and remediation conduc:ed
= External Risks
. Evaluation of supplier programs
. May be other elements within company
. Sometimes lack detailed information NEI 8
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Balanced Program I
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Risks o
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Internal Low Risks l
Prevention Mitigation l
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Three Elements Required
= Is there risk of failure?
. complexity of sys:em
. remediation insights
= Are there consequences from failure?
. Severity
. Immediacy
= Are there mitigating actions?
NEI 10 1
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" individual" Contingency Plan "I
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