ML20210L125
| ML20210L125 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1999 |
| From: | Merrifield J NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20210L093 | List: |
| References | |
| SECY-99-162-C, NUDOCS 9908090043 | |
| Download: ML20210L125 (2) | |
Text
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NOTATION VOTE L
RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary i
FROM:
COMMISSIONER MERRIFIELD 1
SUBJECT:
SECY-99-162 - POLICY FOR REGULATORY ACTIONS FOR LICENSEES OF NUCLEAR POWER PLANTS THAT HAVE i
NOT COMPLETED YEAR 2000 READINESS ACTIVITIES I
Approved Disapproved Abstain Not Participating l
l COMMENTS:
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DATE Entered on "AS" Yes t/
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CORRESPONDENCE PDR 9 0hObOOl[3 t
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.g Commissioner Merrifield's Vote on SECY 99-162 Staff's proposed policy for regulatory actions to be taken for nuclear power plants that have not completed their Y2K readiness activities by July 1,1999 is a reasonable plan. However, I believe that additional clarity needs to be provided to ensure that stakeholder concern is not raised unnecessarily.
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. A key issue is ensuring that the plants will be in a stable, safe condition during the Y2K transition, and that orders will be prepared and implemented sufficiently in advance of the rollover date. This important message is not clear from the SECY paper or the attached policy.
The last sentence in the nt:xt to the last paragraph on page 3 of the policy states that "The staff will then conduct a thorough assessment of the likelihood that the licensee will be able to remediate the Y2K deficiencies so that the plant will be Y2K-ready before the end of December j
1999, and detemline the potential impact of unremediated deficiencies". In my mind, this does not provide the appropriate level of assurance that the plants will be in a stable, safe undition during the Y2K transition. No information is provided that specifies the length of time that remedial activities will take, or the actual date of completion of such activities. I believe that firm dates should be provided for December activities so that we do not provide the inappropriate impression to stakeholders that we are making last minute decisions which could raise unnecessary concern.
l In addition, it is my understanding that the reason that many of plants that have not completed i
Y2K-related remedial activities until after September 30,1999 is not due to Y2K complexities.
Rather, many licensees have scheduled refueling outages after September 30* and have determined that for efficacy, Y2K deficiencies will be handled concomitantly, fhis seems quite logical, however it is not clearly articulated in the SECY paper or the policy. Again, without providing such clarity, it is likely that stakeholder concerns could be elevated unnecessarily. I believe it is important to state this and any other reasonable explanations regarding why 100% of the licensees will not have fully remediated Y2K related deficiencies by the deadlines provided.
Finally, as I stated in my vote on SECY 99-135, and as former Chairman Jackson stated in her memorandum dated June 30,1999 to the Commissioners, the subject paper should be clear that overall plant safety will be assured before a decision is made to allow continued operation in support of the grid.
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77 99 l
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UNITED STATES J
NUCLEAR REGULATORY COMMISSION g
g WA SHINGTON, D.C. 20555 0001
/
August 5, 1999
$ECRETARY MEMORANDUM TO:
William D. Travers Executive Director for Operations William M. Beecher Director, Office of Public Affairs i
W FROM:
Annette Vietti-Cook, Secretary J
SUBJECT:
STAFF REQUIREMENTS - SECY h9-162 - POLICY FOR REGULATORY ACTIONS FOR LICENSEES OF NUCLEAR POWER PLANTS THAT HAVE NOT COMPLETED YEAR 2000 READINESS ACTMTIES The Commission has approved the policy for staff action for nuclear power plants that have not completed Y2K readiness activities by July 1,1999, subject to the comments provided below.
1.
The policy needs further clarification so that stakeholders understand that nuclear power plants will be in a stable, safe condition during the Y2K transition, and that regulatory action, where appropriate, will be taken sufficiently in advance of the 2K rollover date (i.e, as soon as September 30, but no later than December 1,1999). The staff should clarify that if, by September 30, it appears that Y2K readiness activities will not be completed in advance of the December 31,1999 transition, the NRC will take appropriate regulatory action, including issuance of orders, if warranted. These regulatory actions should be consistent with the NRC's Y2K Contingency Plan and the Interim Enforcement Policy for the Y2K transition. The staff should update the policy to reflect the receipt and analysis of the responses to Generic Letter 98-01 and its Supplement. This update should include the current and projected completion dates for Y2K readiness.
2.
In addition to providing this policy to the public, further efforts to increase public confidence in Y2K readiness of the nation's nuclear power plants should be taken. For i
all plants, with priority for those plants that have yet to achieve Y2K readiness, the licensee responses to Generic Letter 98-01 and its supplement or a synopsis that provides the Y2K readiness status -including the licensee's stated rational for postponing remediation actions and schedule information for remediation actions -
should be placed on our Y2K website. The Y2K website should also include the staff's preliminary assessment of each of the sites that are not fully Y2K ready, using plain language to describe plants (rather than Categories A, B, or C, as described in the attachment to SECY-99-162). Press releases should be issued at appropriate intervals to describe the readiness of plants and the rationale for their remediation schedule.
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4 3.
As part of the monthly reports to the' Commission on the status of facility readiness for Y2K, the staff should include a summary status of the numbers of plants in Dategories A, B, and C as described in Section 4.3 of the policy, as well as the licensee's and the staff's intended actions fcr each facility that will not be Y2K ready by September 30 (EDO)
(SECY Suspense:
8/31/99) cc:
Chairman Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield OGC CIO CFO OCA OlG' Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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