The bureaucrats at the Nuclear Regulatory Commission are caught. Their job is to guarantee the safety of nuclear power plants. Their job is not to guarantee that the plants will stay in business. But if the plants go out of business, everyone at the NRC will get fired; nothing will remain to regulate. Well, they won't actually get fired. Nobody ever gets fired in Washington. But they will not be allowed to expand, hire more secretaries, or advance their careers. The NRC will be put into caretaker mode.

The #1 job of the NRC, as with any bureaucracy, is to stay in business. This means they must keep the nuclear power industry alive. Somehow. But if they wimp out and refuse to enforce their own July 1 deadline, then their authority will be called into question.

What do do? Oh, my.

Ah, ha! A potential loophole! Define plant safety as non-digital. Then give a clean bill of health to these non-digital safety segments of the plants. This, basically, is what the NRC has been doing.

At the same time, mention that the ability of the plants to operate is problematical if the digital segments (non-safety) are not y2k-compliant (i.e., y2k-ready, i.e., "we're hoping for the best"). That puts the industry and Congress on notice: "The industry is in big trouble, but not because of the NRC. It isn't our fault. We've done our job by the book."

Issue Information Notice 99-12. Establish language that will allow the NRC to go either way -- "shut down those plants" or "leave those plants open" -- depending on political pressure, but without compromising the authority of the Commission.

They have until July 1 to test the waters, put their finger in the air, etc. This, according to the NRC's Generic Letter No. 98 (May 11, 1998). There, we read:

"However, problems have been identified in non-safety, but important, computer-based systems. Such systems, primarily databases and data collection processes necessary to satisfy license conditions, technical specifications, and NRC regulations that are date driven, may need to be modified for Y2K compliance.

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

Security computers

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

Radiation monitoring systems

Dosimeters and readers

Plant simulators

Engineering programs

Communication systems

Inventory control systems

Surveillance and maintenance tracking systems

Control systems. . . .

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

I am not sure which way the NRC will go. I am sure of this: all of the plants will not be compliant and tested on July 1. I am also sure of this: those that aren't compliant, let alone tested, will all submit an official statement saying that they will be compliant, i.e., ready, before December 31, 1999 -- cross their hearts or hope to fry.

This is a posting by the tireless NRC-watcher, Bonnie Camp (May 19).

* * * * * * * * * *

The most interesting part of this Information Notice for me was the specifics given about the differences in mission critical safety systems versus mission critical non-safety systems. The entire I.N. is worth reading but here are the two paragraphs which specifically caught my attention:

"Most commercial nuclear power plants have protection systems based on analog technology rather than digital technology. Since Y2K concerns are associated with digital systems, analog reactor protection system functions are not affected directly by the Y2K problem. Although there is limited use of computer systems in nuclear power plant mission critical and safety-related functions, licensee Y2K programs have identified some software and digital devices that affect a small number of safety functions. None of these safety functions are actuation based."

"Digital systems and components requiring remediation of Y2K-related problems perform functions such as post-accident sampling, fuel handling, core power distribution monitoring, and reactor vessel level measurement. Licensees have identified incorrect dates in safety-related printouts, logs, and displays in systems such as radiation monitoring. These errors, however, have not affected the functions performed by the devices or systems. There are mission critical non-safety-related functions such as digital feedwater controls, moisture separator reheater controls, reactor recirculating coolant controls, and motor generator set controls that are affected by the Y2K concern and have required remediation. These balance-of-plant functions are critical for power generation."

Well, now we know that there ARE mission critical non-safety-related functions, considered critical for power generation, that are affected and do need remediation. The general idea of this Information Notice seems to be that since the NRC is concerned only with the oversight of safety-related systems, they are attempting to let licensees know that they found other non-safety critical systems with Y2K problems, even though those are outside the NRC jurisdiction.

-- Bonnie Camp (bonie camp@!.!), May 20, 1999

Answers

On the SEC y2k companies disclosures I have been seeing "Y2K ready" alot. Now I may be wrong but this means that "we will make it work regardless if it is truely compliant" From Bonnie's post >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> At the same time, mention that the ability of the plants to operate is problematical if the digital segments (non-safety) are not y2k-compliant (i.e., y2k-ready, i.e., "we're hoping for the best"). >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> And BankAmerica Corporation >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>  
 Form 10-K
           & nbsp;      ANNUAL REPORT PURSUANT TO SECTION 13 OF THE
           & nbsp;            SECURITIES EXCHANGE ACT OF 1934
  For the Fiscal Year Ended December 31, 1998 - Commission File Number 1-6523
 

           & nbsp;          & nbsp;         ---------------
           & nbsp;          & nbsp;    
 

The Corporation tracks Systems/Projects and Infrastructure for Year
2000-required changes based on a risk evaluation. Of the identified
Systems/Projects and Infrastructure, approximately 1,900 Systems/ Projects and
1,100 Infrastructure items have been designated "mission critical" (i.e., if
not made Year 2000 ready, these Systems/Projects or Infrastructure items
would substantially impact the normal conduct of business) >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Do I have this wrong? If it has anything to do with nukes, I hope I do.

-- Brian (imager@home.com), May 20, 1999.

Sorry about the mess, sometimes it works and sometimes I screw up big * BG*

Still what is Y2K ready? To a Nuke?

-- Brian (imager@home.com), May 20, 1999.

Bonnie, Thank you for vetting and posting this information. You can't beat free expert analysis!

One of the large pictures developing here is that bureaucracies are poorly suited for crisis management. It has been so long since this country required real immediate leadership that to say we need courageous leadership sounds trite, hackneyed and childish . . . but I believe that to be the case.

Please continue posting so that laymen such as I can have some understanding of what's developing with the utilities.

-- Puddintame (achillesg@hotmail.com), May 20, 1999.

This is Bonnie's article but she uses her real email address when she posts here.

-- Wiseguy (got@it.gov), May 20, 1999.

To whoever started this thread -

It's only polite to give proper attribution when you post someone's writing. Bonnie Camp has posted here before, so posting "as her" is a bit off, y'know? Best to be as transparent (to use Tom Bartlett's term) as possible, especially with sources. This allows everyone to review the source data for accuracy and validity.

Just so everyone can check source, the item containing Bonnie Camp's commentary on the NRC was from a recent posting at Gary North's site.

-- Mac (sneak@lurk.hid), May 20, 1999.

And which in fact points back to a posting by the actual Bonnie Camp here on the Yourdon forum: NRC Y2K Information Notice 99-12

So, we have here a Yourdon thread, which jumps to Gary North's site, which links back to another Yourdon thread. LOL!

-- Mac (sneak@lurk.hid), May 20, 1999.

Thanks Mac and Wiseguy, for catching that I did not post this thread here. It's always something of a shock when I see my name on a topic I know I didn't post. The truth of the matter is that my initial post on the I.N. was to the euy2k forum. Gary North picked it up, and part of the above are Gary's comments, not mine! The earlier thread here, posted by Lane Core, also links back to the euy2k thread.

Round and round we go....but please, whoever is faking my name, I'd appreciate it if you would cease and desist. It's hard enough for me to keep track of what I'm doing as it is!

-- Bonnie Camp (bonniec@mail.odyssey.net), May 20, 1999.

Bonnie -- I mean the real Bonnie -- are there parts of the initial post here that you do not support? Could you cover the topic in your own words? (Perhaps in a separate thread...)

Some of us are a bit reluctant to accept Gary North's interpretations, as you may know.

CC of this also to bonniec@mail.odyssey.net.

-- Tom Carey (tomcarey@mindspring.com), May 20, 1999.

In response to Brian's question, the following is from NEI/NUSMG 97- 07, "Nuclear Utility Year 2000 Readiness", Section 3, "Definitions":

3.2 Y2K Compliant - Computer systems or applications that accurately process date/time data (including but not limited to, calculating, comparing, and sequencing) from, into and between the twentieth and twenty-first centuries, the years 1999 and 2000, and leap-year calculations.

3.3 Y2K Ready - A computer system or application that has been determined to be suitable for continued use into the year 2000 even though the computer system or aplication is not fully Y2K Compliant.

-- T Myers (twmyers@wnp2.com), May 21, 1999.