Bonnie Camp, I miss your posts!

-- Anonymous, April 21, 1999

Answers

Hi Linda, I've been traveling out of state with my husband the last two weeks and we chose not to take the laptop. (Thought it might be good to remind ourselves there actually IS a world outside a computer screen. *grin*) Now I'm doing catch up on events in my absence. I did make a couple of posts yesterday, but my time is going to continue to be more limited in the next few weeks -- even though I'm sure I'll be putting my two cents in as I can!

To anyone who e-mailed me in the last couple of weeks, please know that I'm not ignoring you, it's just going to take a while to address the mail I found waiting when I got home.

Now, since I'll feel a little guilty if I don't get something about electric utilities in this post (laughing), there's some very interesting reading to be found at:

http://www.gao.gov/new.items/rc99071t.pdf

You will need an Adobe Acrobat reader for access. The report is dated Feb. of this year and is testimony to a Senate subcommittee about the NRC's ongoing efforts to adopt a risk-based approach to regulatory requirements. While this is not a document addressing Year 2000 efforts, I did think parts of it have relevance to that issue.

In the Background section concerning the effects of deregulation on the NRC's regulatory efforts, one of those parts was, "According to one study, as many as 26 of the nation's nuclear power plant sites are vulnerable to shutdown because production costs are higher than the projected prices of electricity." Since there are now 103 operating nuclear plants, this means that a full 25% are at risk of being closed due to economic issues, regardless of any potential Y2K problems. Yet a great deal of money and effort has still had to be invested into Y2K projects at all the nuclear plants. This suggests a financial burden on the utilities which own nuclear facilities, which they will be hard put to make up in generating profits.

Secondly, on page three of this report is a section titled, "Utilities Do Not Have Accurate and Reliable Design Information for Some Plants". Reading further, "Design information provides one of the basis for NRC's safety regulation. Yet, for more than ten years, NRC has questioned whether utilities had accurate design information for their plants. Inspections of 26 plants which NRC completed early in fiscal year 1999 confirmed that for some plants, (1) utilities did not have accurate design documentation, (2) NRC did not have assurance that safety systems would perform as intended at all times, and (3) NRC needed to clarify what constitutes design information subject to NRC's regulations."

There's a lot of info in this report, including, "NRC does not plan additional design team inspections because it concluded that the industry does not have serious safety problems." This was reassuring to me until I read the next sentence, "NRC's Chairman disagreed with this broad conclusion.."

This report also mentions, "However, NRC's regulations and other guidance do not define, for either a licensee or the public, the conditions necessary for a plant's safety; therefore, determining a plant's safety is subjective." While I realize that this GAO report deals in the main with how the NRC might reduce the regulatory burden on nuclear plants in a deregulated framework, it nevertheless is not a confidence builder regarding the NRC's ability to enforce Year 2000 issues either. One of the conclusions of this GAO report states, "NRC's oversight has been inadequate and slow." "Since 1979, various reviews have concluded that NRC's organizational structure, inadequate management control, and inability to oversee itself have impeded its effectiveness." Yet this is the same agency we are all relying upon to take quick action if they determine a plant has not reached targets for Y2K readiness?

While I still have the conviction that those working in nuclear power plants are just as concerned with safety as the rest of us, and I'm all for a prudent plan to reduce any unnecessary regulatory burdens on utilities, I have to admit that this GAO report did not raise my confidence level concerning NRC Year 2000 oversight issues and did raise concerns I had not been aware of previously. Anyone interested in utility issues should read this entire report carefully.

-- Anonymous, April 21, 1999

Bonnie,

Hope you had a great trip....We missed your posts! I was afraid you had gone and joined a "bump in the road" group.

-- Anonymous, April 21, 1999

Bonnie,

This concerns your second point on the NRC and "problems" in the nuclear industry. I am sure that both your post and the NRC statements in these areas are factual. However, you don't have the secret NRC-speak decoder ring.

You can do any single thing right 10,000 times at a nuclear utility and you receive no credit for it from the NRC. However, if you make a mistake just once in that same area, you now have a "problem". Make two mistakes in the same area and you have a programatic or systematic problem. Just thought you would like to know.

bob

-- Anonymous, April 21, 1999

Bob - absolutely true - remember, I worked in the nuclear industry most of my adult life. However, in all that time I never once forgot the awesome responsibility vested in the humans that operate this technology. The memory of Admiral Rickover wouldn't let me. It only takes a small problem to ruin your (and a whole lot of other people's) day.

Bonnie - welcome back! Getting away from the computer, even if only occasionally, is a sanity saving necessity. ;-)

-- Anonymous, April 22, 1999

Rick,

You said "However, in all that time I never once forgot the awesome responsibility vested in the humans that operate this technology." Very admirable (slight pun).

You did this in the absence of the expanded federal government oversight program that you and NERC advocate. Granted, the NRC swings a mighty heavy hammer, but would your efforts (or your peers) been any less without the NRC? When my company instituted a structured development program for protection and control techs, it bragged that the standards and practices in place in T&D met or exceeded the practices required in nuke stations. T&D practice = nuke practice ( - minus red tape).

I don't necessarily disagree with the need for oversight of the utility industry. I ask you to go back and re-read your recent posts, through the lens of the typical euy2k forum member. It could be inferred from your comments (taken in total) that you believe that the electric utility workers are all "Homer Simpsons", hoping to avoid oversight so as to continue to goof off and procrastinate - reliability be damned.

I have seen reliability be risked through maintenance budget cuts, excessive layoff that cut quality folks and bleed vital knowledge. All at the hands of bean counters with no love of engineering. During the 70's budget cuts caused critical wounds that didn't get healed until the middle 80's when reliability began to reflect the neglected maintenance policies. We are in the 70's mode now, analyze how much can be cut without impacting operations, then cut more until you see exactly when operations begin to show the effects. Sorta like not changing your oil until you hear the valves start to knock. Eventually, the bottom line and the potential for huge expense correcting neglect induced equipment problems will bring staffing and maintenance back to proper levels. If not, a competitor with sound maintenance practices rooted in realistic engineering economics with a long term vision will take over the slackers in a triumph of the free market system. (patriotic music plays soflty in the background).

This is what I fear with big gov't heavy in the utility biz. Bean counters at the helm and politicians overseeing it all. I'm afraid that the government tendency to gravitate to the least common demoninator will lead to the excellent utilities doing exactly what the gov't requires - and downgrading their performance. Won't the market and the love of sound engineering do a better job than the gov't?

Also, you don't explicity state it, but I'm certain it will be inferred here - the engineers, technicians, and craft people at power plants and substations DO care about their system. They moan in disgust at budget cuts that prevent them from keeping their piece of "the world" in top notch shape. Design engineers really do take pride in the conservative levels of design, dependability, security, speed, and redundancy achieved using sound engineering economic principles. Please take an active role in preventing your comments from being used by others to paint the entire industry as a bunch of "Homer Simpsons", all for the sake of polemics in the Y2K discussion.

-- Anonymous, April 23, 1999

CL - My apologies to you (and anyone else in the forum) if I've given the impression that I feel nuclear plants are being run by a mad pack of Homer Simpson's. I agree with you that most of the people at the engineering, technican, and craft level DO care about their facilities, and understand the importance of their positions.

I'm concerned about the bean-counting executives. The "Montgomery Burns" of nuclear power, rather than "Homer Simpson", if you will, and the overall impact that cutting costs at any cost has had. Your background is in T&D. You know as well as I that the system is not maintained in the manner that it was ten years ago, when cost per kilowatt hour was not a consideration. Someday that's going to catch up with us. But more importantly in the short term, the budget cutting and "working smarter" (tm) has perceptibly impacted the culture of the industry.

Somewhere on this site, in one of my past columns, I talked about a nuclear plant that I visited in February 1998. This 2 unit facility had not started a serious Y2k effort. They had one (count 'em, one) person assigned part time to Y2k.

The safe operation of a nuclear plant and being a management slave to budget cutting are mutually exclusive priorities. Fortunately, we (the collective "we") haven't yet been bitten by this exclusivity, but I feel that it's only a matter of time. My continuing hope is that Y2k is not the trigger mechanism for the bite.

-- Anonymous, April 23, 1999

I apologize in advance for the length of this post, but I'm putting three replies into one answer to save time.

**Bob, thanks for the chuckle I got over "secret NRC-speak decoder ring". You must be somewhere in my age bracket to remember secret decoder rings! Is there an NRC box top I can save up to send in and get me one? (smile)

I can understand what you wrote about one or two problems catching the attention, rather than thousands of successes. That's pretty much the same thing that happens in all areas of life. You can drive a car for twenty years without even a parking ticket, have one accident and your insurance skyrockets. You can spell almost every word in an essay correctly and that won't get you any credit -- but the one or two you don't spell right will have points taken off by the professor. Darn frustrating, huh?

This situation you wrote about did stir a memory, so I went back and reread the GAO risk-based regulatory requirements report. In the section titled, "NRC's Enforcement Process Continues to Be in a State of Flux" it states, "NRC has revised its enforcement policy more than 30 times since its implemention in 1980......The industry has long standing problems with it....Among the more contentious issues are NRC's practice of aggregating lesser violations into an enforcement action.." So it does appear the GAO, at least, has a decoder ring.

I also got a clue in the report to the NRC rationale behind the sensitivity about just a couple of mistakes out of thousands of things done right. There is mention of "reducing safety margins" with the context being that yes, a couple of mistakes does not indicate any major safety issue, but it's desirable to notice and act on those rather than take the risk that more develop which will erode the larger buffer zone margin set up so that inevitable human mistakes and equipment failure do not degrade into true safety issues. While I myself would hate to deal with what seems to be a nitpicking at little issues, I can see why it might be part and parcel of working in a nuclear facility. Who doesn't want glow-in-the-dark jokes to remain only black humor and nothing more?

This GAO report also does note that a valid industry complaint exists, in that the lines between what actually is a safety issue and what isn't are blurred and infractions are often noted by the NRC that have nothing to do with safety issues and therefore any nitpicking in those areas is unjustified. This appears to be the main reason why there's a move toward a "risk-based" regulatory reform, and the GAO approves of the effort, even if they have serious problems with the implementation of such reform.

**LindaO, thanks for the kind wishes. The trip had ups (I've got adorable little grandchildren!) and downs (the airline sent our luggage one place, while we went another!). Even though I'm going to have times when I can't post here, I'll let you know right now that it won't be because I've joined the "bump in the road" scenario. While I've seen, and continue to watch for improved activity and changes in various Y2K arenas, the concept that there will be only few and minor problems is one I became unable to subscribe to as of last year. Both my husband and I became convinced last summer that there was not enough time remaining to do an adequate job of remediation for those many businesses and federal and state agencies which were so late in beginning their efforts, or which had not started at all. There remain many gaps in awareness and effort; to date there are plenty of businesses, towns, cities, and entire countries which have made no repair efforts at all, and many more who don't have a hope (in our opinion) of completing enough remediation and testing to *ensure* their viability. Standing outside of a focus on only the utility industry for a moment, and considering the broad picture, I cannot find any logical reason to believe the risks have been reduced to a bump in the road level, nor do I believe they can be in the time remaining regardless of some "accelerated efforts" in a few places. For this reason I will continue to promote risk-management plans for individuals and families, as well as for industry. I think that when future historians write about the Year 2000 computer date problem, readers will be able to find the words, "too little, too late" in every treatise. I don't know for sure exactly what failures or corruption of data will happen, or where, but a little "bump in the road"? No.

**CL, I can identify with your fear of " big gov't heavy in the utility biz", but your picture of the state of the industry now certainly doesn't cause warm and fuzzy feelings, either. It confirms what has been postulated before in other threads, that industry workers are hard put to manage their normal jobs without the extra added burden of a rush to remediate and test Year 2000 problems. There is a thread debating possible reasons for the seemingly excessive number of explosions occurring recently in utilities and refineries. What you stated gives added import to that discussion:

"I have seen reliability be risked through maintenance budget cuts, excessive layoff that cut quality folks and bleed vital knowledge. All at the hands of bean counters with no love of engineering. During the 70's budget cuts caused critical wounds that didn't get healed until the middle 80's when reliability began to reflect the neglected maintenance policies. We are in the 70's mode now, analyze how much can be cut without impacting operations, then cut more until you see exactly when operations begin to show the effects. Sorta like not changing your oil until you hear the valves start to knock. Eventually, the bottom line and the potential for huge expense correcting neglect induced equipment problems will bring staffing and maintenance back to proper levels."

How you can describe the industry, as it stands now, in terms of degraded maintenance policies, barebone work forces and loss of quality folks with their attendant vital knowledge, and still be ultra confident that all Y2K work is getting done, or done competently, without introducing even further reliability risks because of Y2K demands superimposed on already strained maintenance tasks, is beyond my understanding. I know you're going to hate this, but to tell you the truth, your assessment that the industry is "in the 70's mode now" has raised my concern level substantially.

-- Anonymous, April 23, 1999