This paragraph on NRC contingency plans regarding allowing N-plants to violate safety regulations (enforcement discretion) really bothers me. If the NRC is overwhelmed with requests for permission to cast aside certain safety regulations, it ought to consider shutting down reactors rather than running them at full tilt. If the NRC is flooded with requests, something is seriously wrong and needs further assessment, not the "green light."

"If the volume of requests to the NRC Headquarters Operations Center is such that the NRC staff cannot review and approve all licensee requests in a timely fashion, the NRC staff will obtain the safety-significant information from the licensee to enable the NRC staff to make a prompt initial assessment. Unless the assessment is unfavorable, the licensee would be permitted to proceed with its planned course of action. The NRC staff will complete these assessments as time permits and the licensee will be advised of the results orally, if possible, and then in writing. If the NRC staff's prompt initial assessment or subsequent assessment determines that a licensee's actions raise safety concerns, the licensee would be so informed. The licensee would then be required to follow its license conditions, including TSs." see: http://www.nrc.gov/NRC/GENACT/GC/RI/1999/ri99005/attachment.pdf Attachment 1 RIS 99-05 December 1, 1999 Page 1 of 1 November 24, 1999 MEMORANDUM TO: Frank J. Congel, Director Incident Response Operations Original signed by Brian W. Sheron FOR FROM: Samuel J. Collins, Director Office of Nuclear Reactor Regulation SUBJECT: IMPLEMENTING PROCEDURE FOR POWER REACTOR NOEDs PROCESSED DURING THE Y2K TRANSITION


I will be on the Jeff Rense "Sightings" radio program this evening discussing Y2K nuclear plant problems and terrorism of nuclear plants. Shows are archived and available with the Real Player.

www.sightings.com

-- Anonymous, December 28, 1999

Answers

Imagine that, another nuclear engineer giving an unbiased opinion. (TMIA?) If you were to really read (understand) your enclosed paragraph, you would see that the NRC is saying that if requests get to be to high, they are not going to give the licensee thier interpretation of plant specific technical specifications (not thier normal job anyway), but rather let the licensee take the required actions (as required by tech specs,AOP's and end path procedures) and then evaluate what they've done.

-- Anonymous, December 29, 1999

Mike,

You are exactly wrong.

-- Anonymous, December 29, 1999

Please explain it to me then?

-- Anonymous, December 30, 1999

These requests for NOEDs (notice of enforcement discretion) are made to prevent shutting down; which is what the technical specifications would require.

The NRC is going to allow licensee's to proceed with their own plans to continue operating while the repair is being made only if contact and initial NRC assessment finds no obvious safety objections. Later, the NRC will go into more detail about the request for exemption, then if the request for exemption is denied, licensees will follow their safety specifications including shutting down (Y2K NOEDs are only called for if a shutdown would normally be required).

Licensees must make contact with NRC and ask permission. Unless initial assessment denies the request, licensees can continue with their plan for remediation without shutting down.

Thus, the NRC is saying if they are overwhelmed with requests, they would rather allow reactors to operate with an initial safety assessment, while ignoring that something may be seriously wrong for there to be so many requests....something that is not understood at the time.

Isn't that what all of the Y2K response centers are set up for, to try to head off problems? The NRC said they would watch the rest of the world to ascertain if they needed to take actions at US nuclear plants. It would be a case of not seeing the woods because of all of the trees.

see the link posted in the original message.

-- Anonymous, December 30, 1999

Scott, The plants technical specifications are the guiding principle. I challenge you to give me the paragraph that says "contact the NRC to determine if you can remain critical" the specs contain prescribed actions for certain safety related system deficiencies. Contrary to popular belief the NRC provides no input to the Licensee on how to operate the reactor.(they definetly will give an input if tech specs are violated). And the only exception to these specs is a 50.59x which allows the licensee to place the plant in a safe condition in the event that a condition exists which is not covered by tech specs. Your initial comment implies that the licensees have been given a directive to operate in an unsafe condition which is certainly not the case.

-- Anonymous, December 30, 1999

Scott, while I've enjoyed our little discussion I must go to bed, as I'm working tonight. I'll let you know how things turn out inthe morning. Sincerely. although I disagree with you, Best wishes for you and your family this new years.

-- Anonymous, December 31, 1999

I come back to see if anybody's tune has changed, and find Scott fighting against Y2K and nuclear power at T minus a couple of hours. What will be the crux of your anti-nuclear argument tomorrow? Regarding this NRC statement; in reality, nothing is done here that isn't already allowed under 10 CFR 50.59(x). This one says allowances will be made in the very specific circumstance of grid reliability depending on nuclear based power generation. I read the memo and I asked the on-site NRC representative for the intention. Do you think it is unreasonable to maintain grid stability if (for example) the risk factor is changed from one accident every 25 million reactor years to one every 20 million? You intentionally leave the impression of much riskier odds, don't you Scott? If the SAFEST thing to do is violate tech specs, I have every right to do so, that is what 50.59(x) is for and has been for years. How many invocations of 50.59(x) do you know of, Scott? No operator is throwing caution to the wind because of this memo. No plant is going to ramp up to 110% power to make a little extra cash. The world of nuclear power is a much different - safer- better- place than it was during the TMI era. Regarding the name-calling charges; Scott you ARE a fear-monger with an emotional attachment to your chosen cause that clouds your objectivity. Is this name calling? Do you deny that you are here to stir up sentiment that agrees with your own? The facts do not bear out your position.

Don't bother waiting around for me to hear your retort, because I and the nuclear powered lights around here will both be well-lit at midnight.

To all on this forum, if you agree with me or with Scott, safety is the over-riding concern for both of us. DO NOT party and drive home drunk tonight. Enjoy a bright new year. nucpwr

-- Anonymous, December 31, 1999

The point of my post has been lost by you both. If all of a sudden nuclear plants request so many NOEDs that the NRC can't keep up, there might be something seriously wrong that is not understood.

By the way, Ralph Beedle of NEI used the phrase "violate their licenses" at a meeting I attended.

Maintaining the grid is not the statuatory mandate of the NRC, protecting us from radiation is.

The TMI accident caused more fear, and caused the majority of this nation to be anti-nuclear, not me or TMIA. If the NRC had paid attention to our fears before the accident, they would have shut the plant down for repairs.

My y2k "fight" has been the need for more reliable Emergency Diesel Generators; other nuclear engineers agree is a valid concern. I set up a data base for that. It was researched through the NRC's own data. It is a valid concern before and after Y2K. (The NRC brought up the topic first - not me)

The rest of my time is devoted to better security and the problems with lost and stolen nuclear materials. I can't imagine you are opposed to those ideas.

You have never seen me calling for the shutdown of nuclear plants except for safety or financial reasons. That will surprise most of you but it is true. I'm not your typical activist or even an environmentalist. I joined TMIA at the suggestion of PA legislators after I gave overwhelming, accurate, and well-researched data at a hearing in 1993. I have been thanked by many nuclear engineers within and outside of the NRC for my testimonies and presentations. I have even set the NRC Chairman straight on a mistaken idea he held which he went on to admit at a nationaly aired press conference. I have met with former NRC commissioners who recognize the validity of my concerns. None of those people have called me a fear monger.

Mike, the "real" media call upon us all of the time. In fact many reporters tell us that TMIA is more reliable than GPU (former TMI owners) and other some anti-nuclear groups. You have no idea how many stories we get into the news without our name on it. We are watching the industry carefully so do your jobs the best you can.

I am opposed to nuclear power because of the risks and because "humans" will cheat, lie, sleep on the job, cut costs and fall victim to all of the various other human defects which will assure another accident. Engineers tend to forget that. Admiral Rickover was anti-nuclear, so I'm not in bad company.

As for the future's concerns, I'll stick with the ones I've always had; although there are still dozens of unresolved issues (since the time of the TMI accident) the NRC said it needs to address and has yet to do so. But, I'm dancing as fast as I can. Maybe you could read the GAO's reports on NRC regulatory practices. They are not fear mongers.

I guess telling the truth bristles people's hair. TMIA hasn't been called fearmongers for 20 years.

-- Anonymous, December 31, 1999

made it through the rollover with no problems. I don't recall my meeting with Adm. Rickover being anti-nuclear but I was under quite a bit of stress. Also I see your point now, the 2 headed cow really did it for me and I can see why TMIA is such a media mogul. I'm guessing the enquirer took the week off?

-- Anonymous, January 01, 2000

P.S. you've definetly proven the abilities of the human race to lie (such a strong word, Let's just say misrepresent the truth.), cheat (as in cheating people out of independent thought.) and sleep on the job (as in not doing your self proclaimed job). Please take a moment to check out "hostages of each other" this is written by a gentleman who was also frightened by nuclear energy and did some actual research into what the industry has done since TMI. His results were an outstanding essay on the industry, not barnyard freak shows and misinterpreted articles. This man is still not to keen on nuclear energy, but he has come to a well researched and carefully thought out opinion. oh well that's enough I don't have anymore time to spoon feed you, and your welcome for my part in keeping you safe for one more day.

-- Anonymous, January 01, 2000

When you admit you were dead wrong about the initial post, then we can more on to other points where you will again prove you lack of awareness.

-- Anonymous, January 01, 2000