I would like to suggest that someone who knows something about NRC rule submission, submit a rule proposal to the NRC. This rule would require that each nuclear power plant pass a third party audit of their procedures to verify that they will operate safely as the computers and systems move into the year 2000 and beond. I would suggest that three independent software/hardware audit organizations be chosen to do the audits, and that each plant be assigned one of these organizations by lottery. The plant would then be required to be certified by this organization. My arguments in favor of this is that it would stop much of the speculation going on concerning Y2K safety, while also verifying public safety. It is *important* that more than one audit organization be used, and that they be selected by lottery. It would also be important that these audit organizations be disallowed to perform any remediation. It would also be important that these audit organizations have experience and a good reputation.

What do you think? Could this be done?

-- Anonymous, February 22, 1999

Answers

This is very possible Reporter. Have you read through the NRC rulemaking information? If not, go to: http://www.nrc.gov/NRC/rule.html If you haven't been there, you will find that right now there is an open proposal concerning Y2K Emergency Planning Excercise (don't quote me on the title). I believe that the last day to comment is 2/24/1999 though. I even think your suggestion is a good one, although I would modify it to be a vertical slice audit instead of just an audit of procedures (Y2K plans might look good, but until you look at portions of the efforts from top to bottom, you never know). Our plant has had several audits, a third party walkdown. The second audit was a peer audit that was fairly thourough, the third party walkdown was an excellent move that had good results.

Regards, FactFinder

-- Anonymous, February 23, 1999