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August 5, 1999

The Commission has approved the policy for staff action for nuclear power plants that have not completed Y2K readiness activities by July 1, 1999, subject to the comments provided below.

1. The policy needs further clarification so that stakeholders understand that nuclear power plants will be in a stable, safe condition during the Y2K transition, and that regulatory action, where appropriate, will be taken sufficiently in advance of the Y2K rollover date (i.e, as soon as September 30, but no later than December 1, 1999). The staff should clarify that if, by September 30, it appears that Y2K readiness activities will not be completed in advance of the December 31, 1999 transition, the NRC will take appropriate regulatory action, including issuance of orders, if warranted. These regulatory actions should be consistent with the NRC's Y2K Contingency Plan and the Interim Enforcement Policy for the Y2K transition. The staff should update the policy to reflect the receipt and analysis of the responses to Generic Letter 98-01 and its Supplement. This update should include the current and projected completion dates for Y2K readiness.
   
   
2. In addition to providing this policy to the public, further efforts to increase public confidence in Y2K readiness of the nation's nuclear power plants should be taken. For all plants, with priority for those plants that have yet to achieve Y2K readiness, the licensee responses to Generic Letter 98-01 and its supplement or a synopsis that provides the Y2K readiness status - including the licensee's stated rational for postponing remediation actions and schedule information for remediation actions - should be placed on our Y2K website. The Y2K website should also include the staff's preliminary assessment of each of the sites that are not fully Y2K ready, using plain language to describe plants (rather than Categories A, B, or C, as described in the attachment to SECY-99-162). Press releases should be issued at appropriate intervals to describe the readiness of plants and the rationale for their remediation schedule.
   
   
3. As part of the monthly reports to the Commission on the status of facility readiness for Y2K, the staff should include a summary status of the numbers of plants in Categories A, B, and C as described in Section 4.3 of the policy, as well as the licensee's and the staff's intended actions for each facility that will not be Y2K ready by September 30.