GWU Y2K conference calls NRC's process to determine Y2K readiness of nuke plants "unreliable and insufficient"

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"Y2K, Nuclear Power Plant Safety and the Electric Power Grid"

Sponsored by the GW Y2K Group and Hosted by The Washington Post Company at The Washington Post July 28, 1999.

Comments prepared by Patrice Kaufman

August 4, 1999

Recently, I attended a 5-day Y2K conference at George Washington University in Washington, DC, organized by Dr. Paula Gordon, Director of Special Projects of the University's Research Program for Social and Organizational Learning. The conference included an evening session sponsored by the Washington Post, on the topic of Nuclear Power and Y2K.

This session on Nuclear Power was eye-opening and alarming. The presenters included a representative from the Nuclear Regulatory Commission, the Nuclear Energy Institute (which is the trade association for the nuclear industry), and representatives from nuclear "watchdog" agencies.

The industry reps painted a picture of near-100% compliance at the nation's nuclear reactor plants. Jose Calvo, Branch Chief, Nuclear Regulatory Commission Electrical & Instrumentation Controls Branch and Jim Davis, Director of Operations at the Nuclear Energy Institute discussed the July 7 NRC announcement on the Y2K status of the nuclear industry. This announcement reported that all of the emergency systems at all of the 103 operational nuclear plants in the U.S. were Y2K ready, but that some of the support systems at 35 plants were not yet Y2K ready.

Mr. Calvo and Mr. Davis assured the audience that the industry is well on track to meet the Y2K challenge. They stated that items yet to be remediated at the 35 plants were minor. Mr. Davis reported that since the original status announcement was made on July 7, six of the 35 plants had completed their additional work, leaving only 29 plants with remediation work to accomplish.

Following this, representatives from the Union of Concerned Scientists and the Nuclear Information and Resource Service delivered their more cautious reports. These reports questioned the reliability of industry assurances that nuclear power plants pose no threat to public health and safety during the Y2K rollover.

Paul Gunter, Director of the NIRS Reactor Watchdog Project, began by discussing the gravest problem Y2K poses to nuclear plants, the potential loss of electrical power. As a December 1998 report prepared by NIRS explains, "A little-known reality of nuclear power is that atomic reactors need a steady source of electricity to cool their cores and irradiated fuel pools even when they are shut down. Without this cooling ability, even closed reactors would melt down; fuel pools would boil dry and release their highly-radioactive inventories."

It is well known that one of the chief risks of Y2K is to the continuous, stable operation of the electrical power grid. As the February 24, 1999 Senate Y2K Committee Report stated, "local and regional [power] outages remain a distinct possibility." The potential for a prolonged nationwide blackout, while considered to be unlikely, also cannot be ruled out. Mr. Gunter spoke about the ramifications of electrical power loss to nuclear plants. The following comments are taken from his prepared text:

"In the event of a grid failure and loss of offsite power, nuclear power stations attached to disrupted grid systems will automatically scram with the rapid insertion of control rods. The reactors cease producing of electricity. Nuclear power stations are neither designed nor capable of 'black start' or the ability to operate independent of available offsite Alternating Current (AC) electricity.

"Once scrammed, a nuclear power station must address the tremendous amount of heat generated by the atomic reaction within the fuel core. With the loss of offsite power a substantial number of systems normally used to cool the reactor are also lost and unavailable."

Because the nuclear reactor fuel will melt with catastrophic results in the event of a power failure and subsequent loss of cooling capability, nuclear power plants are required to have backup power sources. These are normally giant diesel generators, as Mr. Gunter explained:

"Emergency power must be generated onsite to maintain reactor core stability through the removal of this 'residual heat' via a system of circulating coolant pumps and motor operated components. Additional safety-related monitoring and control systems require electrical power stored and generated on-site. Emergency Diesel Generators are designed to provide back-up electrical power and charge onsite auxiliary batteries necessary for the duration of any grid instability or failure."

The gravest danger inherent at nuclear power plants is the simultaneous failure of both the electrical power grid and the onsite Emergency Diesel Generators (EDG). According to Mr. Gunter, this condition, known as "station blackout," is regarded by the Nuclear Regulatory Commission as the largest postulated contributor to reactor accidents resulting in fuel damage. He explained,

"A station blackout of long duration (in excess of 2 hours) leads to auxiliary battery depletion for AC conversion and subsequent loss of vital instrumentation and control features. The uncovering of the reactor core and its associated hazards can occur within a range of 3 to 10 hours beyond the time of battery depletion without restoration of AC power...with the combination of grid failure, battery failure and EDG failure 'core damage begins in approximately one hour as the result of coolant boiloff' or uncovering the core for some reactors. Core damage can be expected to proceed to a core melt if effective and timely measures to restore AC power and core cooling are not taken or available..."

Mr. Gunter continued, "NRC studies consider a long duration blackout event in excess of two hours to be a dominant factor influencing the likelihood of core damage or a core-melt accident. Long-term or recurring grid failure as a result of Y2K vulnerabilities has not been sufficiently studied."

What is the probability that a nuclear power plant's Emergency Diesel Generators would fail to operate if needed in the event of a Y2K-induced electrical power loss? The most sobering information released during the July 28 panel regarded the unreliability of these backup power systems.

Mr. Gunter reported that ongoing evaluations of Emergency Diesel Generator reliability at our nation's nuclear power plants reveal cause for great concern; at best, the NCR says that they are 95% reliable. Mr. Gunter stated that "multiple events [of EDG unreliability] occur each month," and cited six recent events of EDG failure at various plants. He concluded his report by saying, "NIRS expects to see continued problems with EDG design, hardware failures, operation and maintenance errors and failures related to support systems to occur up to and beyond the Y2K susceptible dates."

In light of this situation, last December NIRS petitioned the NRC to require nuclear power plants to install additional backup power onsite. To date, Mr. Gunter reported, the NRC has not responded to the NIRS petition.

David Lochbaum of the Union of Concerned Scientists also spoke at the July 28 panel. Prior to joining UCS in 1996, Mr. Lochbaum worked as a nuclear engineer in the U.S. commercial nuclear power industry for over 17 years. His presentation addressed the process used by the NRC to determine "Y2K-readiness" of the nation's nuclear power plants. In a July 7 article entitled "Y2K and Nuclear Safety," Mr. Lochbaum stated that this process, consisting of NRC-conducted audit tours and surveys completed by nuclear plant operators, was unreliable and insufficient:

"NRC inspectors conducted audits of Y2K preparations at nuclear power plants...The inspectors have been told what to examine, but they have not been provided acceptance criteria. Therefore, these audits--which are more precisely termed sightseeing tours--cannot determine if the nuclear plants meet minimum safety standards."

In his July 7 article, Mr. Lochbaum explained that some nuclear plant owners are reporting to the NRC that their systems are Y2K compliant when they may not be:

"NRC inspectors went to the Brunswick nuclear plant in North Carolina and learned that the plant's owner relied exclusively on certifications by companies supplying its hardware and software. Brunswick did no testing when it had a piece of paper saying that a computer system was Y2K compliant. The NRC inspectors then traveled to the Salem nuclear plant in New Jersey. At Salem, the plant owner tested some of the hardware and software that had been certified to be Y2K compliant. Some of the certified systems flunked the tests."

In this same article, he also questioned the NRC's lack of compliance standards:

"The NRC knows that some nuclear plant owners are relying heavily on paperwork instead of testing. The NRC has documentation that this paperwork cannot always be trusted. The NRC is not unhappy about this situation. Why? Because in the NRC's eyes, no nuclear plant can be below Y2K minimum standards because there are no standards defined. Everyone passes an NRC test because there is no answer key."

The General Accounting Office has also chastised the NRC for lack of compliance standards. In a January 1999 report entitled "Major Management Challenges and Program Risks: Nuclear Regulatory Commission," the GAO said, "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."

Another issue of concern addressed by Mr. Lochbaum was NRC press release No. 99-153, issued July 22, 1999, entitled "NRC Issues Interim Enforcement Policy on Y2K." In this press release, the NRC announced their approval of an interim enforcement policy allowing the use of "enforcement discretion" under certain circumstances for nuclear power plants during Y2K transition periods. In his prepared statement for the July 28 panel, Mr. Lochbaum explained the meaning of this interim policy:

"The NRC is preparing to allow nuclear plants with broken emergency equipment to continue operating. Remember that just last month the NRC announced that the emergency equipment at every nuclear power plant in the United States is Y2K ready. That's what they say. Actions speak louder than words. The NRC has taken steps to allow plant owners to continue operating plants with emergency equipment disabled by Y2K by simply picking up the phone and calling a friendly NRC agent for special dispensation."

As Mr. Lochbaum told the audience, Technical Specifications, or Tech Specs, define minimum standards that must be met for plants to operate. For example, when a piece of emergency equipment is found to be broken, the Tech Specs might require it to be fixed within 72 hours. If it is not fixed in time, the plant must be immediately shut down.

He said, "For Y2K, the NRC wants to set aside the Tech Specs and allow plants with broken emergency equipment to continue operating...the NRC will be gambling with the lives of millions of Americans. The catastrophic accident at Chernobyl was caused when plant workers deliberately disabled emergency equipment before a test. The test went badly and the plant literally exploded--twice--because its emergency equipment was disabled. The core meltdown at Three Mile Island was caused when plant workers intentionally turned off emergency equipment. The NRC now appears willing to allow plants to operate with emergency equipment disabled by Y2K. The NRS apparently assumes that the emergency equipment will not be needed. If it is..."

Mr. Lochbaum's final analysis is that the NRC is acting "irresponsibly." It's hard to come to any other conclusion but this, given the above information.

Many Y2K analysts and observers are deeply concerned about the possibility of potentially catastrophic Y2K-induced nuclear events. Dr. Paula Gordon, the organizer of the above mentioned Y2K conference, has written a widely read White Paper covering these concerns [A Call to Action: National and Global Implications of the Year 2000 and Embedded Systems Crisis, http://www.gwu.edu/~y2k/keypeople/gordon.htm].

I believe we have to be very cautious about self-generated reports of compliance coming from within the various industry sectors. The July 28 discussion panel reconfirmed my conviction that behind these assurances of Y2K readiness lie stacks of conflicting data, arguing against a smooth transition to the Year 2000.

Unfortunately, the vast majority of the American public are receiving only the soothing industry assessments. Given the information obtained at panels such as this, the current widespread levels of complacency and unconcern about the Year 2000 problem would be difficult to maintain.

-- a (a@a.a), August 25, 1999

Answers

Here's the link, and additional commentary from another participant:

http://www.gwu.edu/~y2k/keypeople/gordon/1999conference.html

Comments by Professor Stuart Umpleby on the July Conference on Y2K at GW

The y2k conference at GW in late July, which was organized by Paula Gordon, was a very educational event for those who attended. My conclusion is that key officials still do not understand the problem and hence are not preparing adequately. For example, Federal Reserve System Governor Roger Ferguson is aware of the liquidity problem (bank runs) but not the loan portfolio problem -- if a lot of companies cannot function and hence cannot repay loans, banks are in jeopardy. He is the Fed governor in charge of increasing awareness of y2k among bankers! At the close, he said that the discussion had been useful....

In the session on nuclear power, I was not reassured by the replies from the Nuclear Regulatory Commission (NRC) and the nuclear industry. The nuclear industry apparently views the questions raised by nuclear activists as the same issues they have raised for years. It is not clear that the industry and the NRC see y2k as a special time with increased risks.

In the panel on education the speakers from MIT and Penn State described how their universities are fixing internal equipment. I was the only one who connected y2k to the education, research, and public service missions of universities. With very, very few exceptions this pattern holds across the country.

The majority of officials seem to be expecting disruptions at the level of 1,2,or 3. This is the future they are planning for. If disruptions turn out to be at the level of 5 or greater, their organizations will be unprepared. There is a saying, "Hope for the best, prepare for the worst." Regarding y2k we are hoping for the best and preparing for the best.

I did not expect that at this late date the level of public and official concern with y2k would be at such a low level. Yagmur Denizhan in Turkey recently told me about a Navajo proverb, "It is not possible to awaken someone who is pretending to be asleep."

I heard the following quotation by Albert Camus at a conference in Germany last week. "They were able to do so much, but they dared to do so little." It reminded me of what Paula Gordon has been saying about government officials.

August 10, 1999

-- a (a@a.a), August 25, 1999.


These statements are from Paula Gordon's white paper BTW. Thanks Paula, these voices would otherwise have gone unheard.

-- a (a@a.a), August 25, 1999.

Great posts a.

Much to ponder.

-- Dog Gone (layinglow@rollover.now), August 25, 1999.


Thanks a.

" Brunswick did no testing when it had a piece of paper saying that a computer system was Y2K compliant. The NRC inspectors then traveled to the Salem nuclear plant in New Jersey. At Salem, the plant owner tested some of the hardware and software that had been certified to be Y2K compliant. Some of the certified systems flunked the tests."

[snip]

""The NRC knows that some nuclear plant owners are relying heavily on paperwork instead of testing. The NRC has documentation that this paperwork cannot always be trusted."

I really need to stop reading this stuff before I go to bed at night....

:-)

-- Deborah (infowars@yahoo.com), August 26, 1999.


Just a note to clarify that the items quoted on this thread from Patrice Kaufman and Stuart Umpleby are from website pages on the Y2K Conference which was held at George Washington University July 26 -30. While both played roles in the conference, the quotes were not statements made at the Conference. To read additional commentary written after the Conference, some prepared statements that were given at the conference, and some statements that were read at the Conference (one from Ed Yourdon and another from Robin Guenier), see http://www.gwu.edu/~y2k/keypeople/gordon/1999conference.

The four and a half day conference was videotaped owing to support provided by the Nathan Cummings Foundation. The videotapes will be posted soon at a RealVideo website at http://www.y2kapproaches.com/real/pgordon.htm.

There are five other programs at the RealVideo website that might be of interest, including a press briefing by Ed Yourdon and myself that took place in Washington in March.

Part 4 of my White Paper was posted on August 18. It includes a transcript of an exchange with Congressman Dennis Kucinich that took place on July 28 at the Y2K Conference. The exchange includes a discussion of the approach that the President and the Administration have taken to addressing Y2K. Parts 1 - 4 of the White Paper can be found at http://www.gwu.edu/~y2k/keypeople/gordon. I am hoping to have Part 5 reading for posting soon.

Additional Y2K events in the Washington, DC area will be scheduled beginning in September. Please watch the announcements page at my GW website for details.

Regards,

Paula Gordon

-- Paula Gordon (pgordon@erols.com), August 27, 1999.



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