ML16328A282

ACRS Suggestions for an NRC Long Range Plan

ML16328A282
Person / Time
Issue date:	10/15/1986
From:	Ward D Advisory Committee on Reactor Safeguards
To:	Zech L NRC/Chairman
References
Download: ML16328A282 (15)

Text

D861015 Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

ACRS SUGGESTIONS FOR AN NRC LONG RANGE PLAN As a follow-up to our letter of August 13, 1985, we have devoted considerable effort to the development of our thoughts and recommenda-tions on a Long Range Plan for the Nuclear Regulatory Commission.

Included in this effort have been discussions with a dozen highly respected people knowledgeable in the nuclear regulatory area. This effort has resulted in the attached material which constitutes a series of suggestions for development of such a plan, and we forward it for your consideration and use. We recognize the NRC Staff effort directed toward development of a long range strategy for the Agency, and we hope that our report will be useful in that effort.

Sincerely, David A. Ward Chairman

Attachment:

ACRS Suggestions for an NRC Long Range Plan October 15, 1986 ACRS SUGGESTIONS FOR AN NRC LONG RANGE PLAN

1. INTRODUCTION

Background:

The ACRS concluded during November 1984 that the NRC should have a Long Range Plan and that it could assist the Commission in developing such a Plan. The Committee subsequently appointed a subcommittee which held a series of nine meetings, some to deliberate and some to seek information and advice from a group of senior, respected people who are knowledgeable in the nuclear regulatory area. These people were:

o John F. Ahearne, Vice-President of Resources for the Future and former Chairman of the U. S. Nuclear Regulatory Commission, o Peter Bradford, Chairman of the Public Utility Commission of Maine and former Commissioner of the U. S. Nuclear Regulatory Commission, o Floyd Culler, President, Electric Power Research Institute, o Carl Giesler, Vice-President, Wisconsin Public Service Corporation, o James Knight, Director, Licensing and Regulatory Division, U. S.

Department of Energy, (Acting Director, Division of Engineering, Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, when interviewed),

o Roger J. Mattson, Vice-President, International Energy Associates, Ltd. and former Director of the Division of Systems Integration, Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, o William McDowell, NRC Audit Group, General Accounting Office, o Warren Owen, Executive Vice-President, Duke Power Company, o Victor Stello, Jr., Executive Director for Operations, (Deputy Executive Director for Regional Operations and Generic Require-ments, U. S. Nuclear Regulatory Commission when interviewed),

o John Taylor, Vice-President, Electric Power Research Institute, o James Tribble, President, Yankee Atomic Electric Company, o John West, Vice-President (retired), Combustion Engineering Corpo-ration.

Written transcripts were made of most of the discussions with these people, and we commend them to your planning staff.

The subcommittee's efforts have produced two primary results, the first being a letter to Chairman Palladino dated August 13, 1985 in which the ACRS formally stated its belief that the NRC should have a Long Range Plan. The second result is a group of suggestions for the development of an NRC Plan.

These suggestions were considered by the Committee during its 316th, 317th, and concluded during its 318th meeting, October 9-11, 1986. We wish to call them to the Commission's attention for use in the planning effort. We believe they will assist in providing a foundation on which the Commission can develop a useful and needed Plan.

Scope:

Although any NRC Plan would likely specify actions for only about a five year period, it would need in some parts to be based on assumptions of events or circumstances ten or twenty years into the future. In addition, some goals

and objectives may require considerably longer to accomplish than five years even though it may be impossible to define specific actions to be taken beyond that period of time. We have given recognition to these facts.

This study primarily addresses long-range concerns which may be receiving little of the Agency's attention rather than today's problems which normally receive heavy emphasis.

Since this is an initial effort, we have restricted our advice primarily to nuclear power plant and high level waste (HLW) issues and have paid little or no attention to other areas such as nonpower reactors and radioactive mate-rials licensing.

Outline:

In compiling our suggestions, we have chosen to utilize the following out-line:

1. Introduction

2. Mission Statement: The mission of the Agency as we perceive it is defined.

3. External Assessment: We have attempted to list most of the major factors which we believe will describe the likely regulatory environment in which the Agency must operate for the next few years.

4. Internal Assessment: We have tried to enumerate the major strengths and weaknesses of the Agency as we and many other people view them.

5. Possible Changes by the NRC: We have given many examples of possible, important changes which could be considered in an effort to enhance the Agency's performance and to prepare it to meet future problems and challenges.

6. Goals and Objectives: We stop short of designating goals and objectives, believing that this step is the responsibility of the Commissioners themselves. We view the material presented as a foundation upon which the Goals may be based.

2. MISSION STATEMENT This section deals with questions such as: What does the NRC do? What are its responsibilities? What did the Congress intend for it to do? In our judgment, what should it do?

Section 1 of the Atomic Energy Act states: "It is -- declared to be the policy of the U. S. that (a) the development, use, and control of atomic energy shall be directed so as to make the maximum contribution to the general welfare, subject at all times to the paramount objective of making the maximum contribution to the common defense and security; and (b) the development, use, and control of atomic energy shall be directed so as to promote world peace, improve the general welfare, increase the standard of living, and strengthen free competition in private enterprise."

We believe that the major responsibilities of the NRC with regard to nuclear

power plant regulations and waste management are:

2.1. First and foremost, to provide a regulatory environment which will limit to an acceptable level the probability and consequences of any nuclear power plant accident which would have a major impact on the public health and safety (including in-plant personnel).

2.2. To assure that routine operation of nuclear power plants does not result in an undue impact on the public health and safety (including in-plant personnel).

2.3. To meet the above responsibilities while imposing the minimum regulatory and economic obstacles on the development of the uses of nuclear energy for the benefit of the nation.

2.4. To determine the levels of safety which are appropriate to the public interest.

2.5. To assess the degree to which its objectives are being met.

2.6. To enunciate clearly to the public the objectives and results of its efforts. (To regulate in a fashion which will give the public confidence in the regulatory process.)

2.7. To accomplish its mission efficiently.

Major activities of the NRC are or should be:

2.8 To issue safety approvals and licenses, write and set standards and criteria, lead in the development of national nuclear safety goals, and guide the development of nuclear technology in a safe manner.

2.9 To advise other federal and state agencies and groups on these and related matters.

2.10 To integrate its nuclear safety efforts with those of other govern-mental, private, and international groups.

NRC actions and/or approvals have considerable influence on:

2.11 The regulated industry.

2.12 Competition among vendors, sub-tier vendors, countries, and so on.

2.13 Actions by intervenor groups.

2.14 State legislatures and regulatory agencies.

2.15 Actions by government agencies, safety organizations, and vendors in other nations.

2.16 The public view of nuclear power plant hazards and public health and safety.

The NRC is distinguished by characteristics such as the following:

2.17 The NRC was granted federal preemption in radiation safety matters by the Congress, and the courts have upheld this preemption.

2.18 The NRC has lengthy nuclear regulatory experience and a strong institutional memory, and it has contributed to an excellent record in terms of protecting the public health and safety.

2.19 The NRC has the ability to cause major perturbations, for better or worse, in the industry it regulates and in the cost of electric power to the consumer.

3. EXTERNAL ASSESSMENT The Long Range Plan must relate to and be consistent with the societal, economic, and technical environment of the time period for which the Plan is developed. This environment must be defined as well as possible before the Plan is developed, and the Plan should be changed, as needed, if the environment changes. We believe that the factors listed below are some that should be considered in attempting to describe the environment:

Current Situation 3.1. Construction of approximately 120 nuclear power plants will have been completed in the next five years or so, and the utilities will endeavor to operate many of these plants for lifetimes of 50 to 100 years.

3.2 It is extremely unlikely that any new energy sources for the large-scale production of electricity will be demonstrated to be economically competitive during the next decade.

3.3 Efforts to conserve energy will become less effective in diminish-ing the demand for more growth in electricity production capability as the easier steps are finished and the more difficult ones are undertaken.

3.4 The cost of electricity from coal will continue to increase as the impact of fossil plant effluents on the environment and climate, the impact of SO2 et al on public health, coal mine safety, and the disposal of fossil wastes receive more public recognition. For these same reasons, the cost of electricity from oil and gas will also increase, although not as markedly.

3.5 The use of oil to generate electricity will continue and perhaps increase modestly over the next five to ten years due to recently lowered petroleum prices. However, there is also considerable possibility that prices will rise significantly during this period and even the possibility that a Mideast crisis will occur which will deny oil to the West. The need for nuclear power would increase in either case, quite drastically in the latter.

Factors Delaying New Nuclear Power Plant Orders 3.6 There may be a modest shift back to the use of natural gas to

generate base-load electricity, and such usage may continue over the next decade.

3.7 The cogeneration of electricity will increase nationally and retard the need to order new, large coal or uranium plants by as much as five years in some parts of the country.

3.8 The date for ordering new power plants will be delayed somewhat as relatively modest amounts of power are purchased from Canada or Mexico. This date will also be delayed if Congress passes legis-lation to permit utilities to use existing transmission lines more easily to sell power to other utilities in other regions of the country or if it passes legislation to establish a national grid.

3.9 In the present political and economic climate, most utility com-panies will delay the construction of large-scale plants as long as possible. This will result in the use of short-term-economic but long-term-uneconomic solutions to meeting power needs (such as through the use of low-capital-cost, high-fuel-cost, high-cost-per-kw-hr gas turbines) which will frequently not be in the nation's best long-term interests.

3.10 The unlikely prospect for new nuclear power plant orders during the next few years stems largely from matters such as:

a. uncertainty over probable State regulatory actions in ensuring adequate rates of return; e.g., inability to charge construction-work-in-progress costs,

b. uncertainty over the impact of a new nuclear commitment on the financial rating of an electric utility,

c. uncertainty over the economic effects of possible NRC backfit requirements,

d. uncertainty over the lack of a national consensus on the need for nuclear power,

e. uncertainty over the time required to license, construct, and place a nuclear power plant in operation,

f. uncertainty over the status of the Price Anderson pro-vision, and

g. uncertainty in estimating the growth in electricity usage.

Factors Significant to New Construction Activities 3.11 It is unlikely that any utility will place an order for a new nuclear power plant within the next few years. It is quite possible, however, that a utility or a consortium may apply to reinitiate construction on a partially-constructed-but-deferred plant within the next five years.

3.12 Regional nuclear-power-generation companies which will generate electricity and sell it to utilities for distribution may come into

being. State public utility commissions may encourage such com-panies in the same context as cogenerators are encouraged.

3.13 It is believed that utilities will lean very heavily toward pur-chasing advanced LWRs which have evolved from present-generation LWRs when they purchase new plants. Emphasis may be placed on small (i.e., 500-600 MWe) as well as on large plants. They will give serious consideration to duplication, replication, and stan-dardization of plants.

3.14 The cost of electricity from uranium in ^/kwhr would be signifi-cantly less from a modern nuclear plant constructed "today" than from a modern coal plant if the nuclear plant construction time could be reduced to a five-or-six-year period. Such a construction time can be achieved by competent utility management if the nation-al and state regulatory processes can be improved. In fact, a representative from one utility company stated it can build nuclear plants today from which electricity costs would be 20% lower than from coal plants.

3.15 It is believed that new nuclear power plants will be ordered in as short a period as three years or as long as 15 years from now. The actual date will depend largely upon economic matters such as:

o the cost of electricity from coal o the cost of oil o the cost of money However, it will also depend on social factors such as political pressure on utility organizations to shift from ensuring conserva-tion to ensuring the availability of low cost electricity when needed. Earlier dates will become more likely as plant con-struction times decrease, interest rates decrease, regulatory uncertainties decrease, the need for electricity increases, and so on.

3.16 It is expected that several foreign nuclear power plant vendors (e.g., from the Federal Republic of Germany, France and Japan) will be ready to make serious, full-fledged sales efforts to U.S.

utilities within five years. It is expected that advanced LWRs will have been built and be operating in foreign countries within a decade. These plants will have been licensed under regulatory programs based generally on the U.S. model, will have been constructed in five-year-or-so periods, and some will be producing electricity quite economically. U.S. utilities will be strongly attracted to purchase these plants. In addition, there is considerable likelihood that U. S. manufacturers will have lost much of their nuclear power plant design and construction capability within the next five years; they should have retained capability to service existing plants, but they may well have lost the capability to produce and supply major components for new plants (e.g., pressure vessels) without strong support from foreign affiliates.

Factors Influencing Nuclear Power Plant Safety 3.17 Some nuclear power plant utilities may go bankrupt during the next

decade for many reasons including the possible advent of deregulation of the utility industry and the associated development of competition among utilities. The potential impact of such developments on the implementation and utilization of safety procedures will have to be considered.

3.18 State public utility commissions will, in some cases, adversely affect nuclear power plant safety as they impose economic incentive programs, limit utility research, and so on.

General Matters 3.19 With 120 nuclear power plants soon to be in operation, one can anticipate a continued occurrence of abnormal events. Some of these may cause potential adverse health effects or even deaths among the plant labor force or even among neighboring populations.

Any such event will undoubtedly cause considerable alarm among members of the public (although perhaps not as much as occurred at TMI), and the NRC credibility will suffer badly unless positive steps have been taken to inform the public that such events can occur. This loss of credibility could frustrate the objectives of the Atomic Energy Act.

3.20 The NRC must provide assurance that aging nuclear power plants can continue to operate safely.

3.21 Little decommissioning of nuclear power plants will occur in the next decade or two except for early, small plants. There may be demands for more assurance that plants can be decommissioned economically, but the responsibility for showing this will fall largely on the utilities or DOE and not on NRC.

3.22 The U.S., under DOE leadership, will continue development work on advanced liquid-metal and gas-cooled reactors. It is possible that the U.S. will initiate design of an advanced plant within five years and that the NRC will be called upon to license it.

3.23 Legislators and the public will continue for another decade to view HLW disposal as a serious problem. The national repository disposal program will fall behind and target dates will not be met, increased emphasis will be placed on temporary, above-ground storage, and the NRC will need to continue to give high priority to HLW activities as at present. A similar problem exists relative to the disposal of low level waste.

3.24 Serious efforts to initiate fuel reprocessing will not be made in the next decade because of marginal economics as well as safeguards concerns.

4. INTERNAL ASSESSMENT This section is directed toward defining the strengths and weaknesses of the NRC. Among the strengths of the Agency are:

4.1 It has a fine track record in protecting the national public health and safety. Further, it has had a strong influence on the

regulatory programs in most of the Western countries, and the records for protecting public health and safety have been outstanding there, also. It deserves its fair share of the credit for this additional accomplishment.

4.2 It has extensive knowledge of the design of safety-related systems.

The NRC, as a group, has a strong knowledge of how designs have changed with time and the accompanying reasons. This knowledge centers on the safety aspects of the designs rather than on the economic aspects.

4.3 It has a good understanding of risk assessment and its related applications in the nuclear power area. There probably isn't any better group in the world than the NRC Staff and its contractors in the field of risk assessment.

4.4 It has a significant institutional memory and a knowledge of good engineering practice. The Agency has key people and groups which have been involved in regulatory-related activities for two decades or more. Individual members have obtained a strong knowledge of engineering practice both before and after joining NRC. Participa-tion by members in the codification of national standards (e.g.,

ASME piping code) has been a significant factor here.

4.5 The NRC has recently completed and published a policy statement on safety goals for the operation of nuclear power plants. The Agency has also formulated a Severe Accident Policy Statement. The development and formal issuance of these two documents represents a signal accomplishment on the part of the NRC and makes it the only Federal agency that has directly addressed and publicly enunciated policies on such controversial issues.

4.6 It has a competent technical and administrative staff.

Among the weaknesses of the Agency are:

4.7 It is lacking in the area of long range planning. This was demon-strated by the fact that the Agency was totally unprepared for the Three Mile Island accident, although considerable progress has been made since then.

4.8 There are fundamental questions in terms of the way the Commission is set up and operates:

o There is a lack of direction within the Agency. The planning process, no matter how well done, will not be executed well because the Commission has trouble, first, in articulating its priorities and second, in getting them implemented.

o Information does not flow well within the agency. Many components of the Agency really do not communicate well with one another, largely because communication channels have become unduly formalized. People in one part of the Agency tend not to talk to people in another part. There is some-times a tendency for people not to work together to solve common problems. The Commissioners seem frustrated about their lack of ability to share ideas among themselves, to

ventilate issues, and to talk on a professional level with the Staff because of the applicable statutes.

4.9 It has a tendency to regulate in an economically wasteful fashion.

NRC must accept its share of the blame that backfitting has been necessary and very expensive, that QA/QC requirements lead to very high costs, that "nuclear power has priced itself out of the market" in the words of one utility representative, and so on. In some cases it has established unduly conservative, expensive, sometimes unnecessary regulations (e.g., 10 CFR Part 21-Reporting of Defects and Noncompliance). The Staff builds in conservatism discipline by discipline and parameter by parameter, rather than being as realistic as the technology will support and then adding an appropriate factor of safety at the end. It seemingly does not act on the results of safety research (if in the direction of relaxation), and requirements once established are seldom relaxed.

The Staff seems frequently not to arrive at practical, cost-effective ways to solve problems.

4.10 There is an adversarial relationship between the Agency and the regulated that sometimes detracts significantly from the ability of the Agency to operate in an effective and efficient manner.

4.11 It lacks the ability to regulate in a fashion which builds confi-dence and trust in the regulator. It has not exercised adequate discretion in avoiding relatively needless modification and back-fits, although the performance of the Committee to Review Generic Requirements (CRGR) has been very encouraging. (There is a need to bring more operating experience to the Staff and to improve the Agency's understanding of the operational nuances of the plants that it regulates.) We are told by industrial representatives that industry will not build new plants until it has confidence that a stable, predictable regulatory situation exists.

4.12 It has developed a regulatory system that is so comprehensive, and frequently so prescriptive, that both the NRC and many of the operating utilities have come to believe, or act as though they believe, that compliance with the regulations is itself sufficient to assure safety. The assumption that regulations and safety are synonymous may be dangerous and should be reexamined.

4.13 With the new Safety Goals, the Commission has addressed the ques-tion, "How safe is safe enough?" However, it has not decided what it intends to do with the Goals -- how it intends to implement them. It has not resolved the fundamental questions: "Do we want to make operating plants safer than they are now? If so, how much?

How do we decide?" For example, how ought the unresolved safety issues and the elements of the Severe Accident Policy Statement be handled?

4.14 It has not established a convincing argument for how much and how long it should continue doing safety research.

4.15 The Agency has an inadequate public information program. The

public is informed of public health and safety hazards related to nuclear power and of the NRC's regulatory activities only as information comes out through the media, which are themselves poorly educated and frequently biased. The NRC has no program of going out and truly informing the media especially and the public in general. The quality of reporting of the next major nuclear accident will depend upon the quality of the relations between the NRC and the media, which will in turn depend upon the credibility that is established during the preaccident period. This can have a profound effect on the degree of panic engendered by the media, with inevitable consequences for the public health and safety.

4.16 The Agency has no assured supply of new blood. It has no plan to assure that technologists will be available as needed in the future and that relevant academic programs will survive the quiescent period of the next few years.

4.17 The Agency has no Congressional or public constituency. No one gives it encouragement, and that probably affects what it does.

Outsiders may view the Commission and Staff as vacillating as the Agency is criticized from all sides and as it attempts to satisfy all sides.

4.18 Much of the public criticism of the NRC is ill founded and lacks credibility, but some is constructive. The Agency tends to respond to both kinds by becoming defensive in its reponse.

5. POSSIBLE CHANGES BY THE NRC This section deals with development and decisions on alternatives. What could the NRC do differently? What could it change? What is it possible for the NRC to do in each of the areas above where weaknesses, strengths, oppor-tunities, threats, current capabilities, and so on have been pinpointed?

(Note: We are interested primarily in what the possibilities are with regard to correcting potential or actual weaknesses, and the following is prepared in that context.)

The NRC:

5.1 Could initiate a long-range-planning activity which would incorpo-rate not only forecasting and trying to look ahead but also policy setting and positioning and preparing things for the future -- not just forecasting things beyond its control and attempting to accommodate them but actually trying to shape the future and developing a strategy for the future. This might be termed strategic planning rather than long-range planning. It would look farther and more broadly into the future than the Policy and Planning Guides (PPG), and the latter could likely be a subset of a Long Range Plan.

5.2 To study its internal operation, could engage an outside firm of management consultants to review the way the NRC conducts its business and to recommend changes as appropriate.

5.3 To regulate in a more cost-effective fashion, could do such things as:

a. Set up an impartial, learned group to study whether regulation in the U.S. has been unduly costly. Such a group could examine allegations such as those in a recent Booz, Allen, and Hamilton, Inc. study which states that regulation caused over 70% of the nuclear plant cost escalation in the U.S. between 1973 and 1983, that nuclear building costs grew 22% per year vs. 12% per year for coal plants during the period, and that cost growth in both France and Japan was at a rate much closer to the rate of U.S. coal construction growth than the rate of U. S. nuclear growth. Such a group could compare regulatory cost effectiveness in the three countries taking into account the strong similarity between safety standards and practices.

b. Undertake a study to determine if the NRC follows up the results of research work to tighten or relax standards and requirements as appropriate. If not, it could institute and enforce a policy to correct this situation.

c. Make a specific attempt to establish a consensus among the NRC, the Congress, state public service commissions, industry and other special interest groups, and the general public as to when the expenditure of public resources (money) to achieve higher levels of public health and safety is no longer appro-priate. Such a consensus could be based on the Safety Goal Policy Statement.

5.4 To minimize the adversarial aspects of regulation, could develop methods to place greater reliance on industry self-policing initia-tives or to try harder to instill in utilities the desire to do a better job and to seek excellence. The activities of the Institute of Nuclear Power Operations are supportive in this area.

5.5 To endeavor to remove the large uncertainties (actual or perceived) from the licensing process, to bring greater stability to the regulatory process, and to establish a positive climate for the renewal of growth in the nuclear power industry, could do such things as:

a. Establish a clear distinction between the safety requirements for new plants vs. existing plants. (Although automobiles are recalled to repair defective brakes, they are not recalled to replace operable brakes with improved ones.)

b. Consider an alternative approach to present regulatory trends wherein the NRC is moving in the direction of giving greater attention to the balance of plant. One alternative to that approach could be to focus regulatory activities on a defined "safety envelope" of systems and equipment which would address only the essential core-safety and public-safety requirements.

For example, for LWRs, it might be possible to limit the safety envelope to a highly reliable:

- Core subcriticality mechanism,

- ECCS and decay heat removal system,

- Reactor vessel and primary piping with inspectability throughout service life, and

- Containment,

coupled with a performance-based limitation on the frequency of safety challenges from the balance of plant.

The intent would be to specify only the systems and components absolutely required for safety, and only these would be rigorously regulated. Other systems and components throughout the plant would be under the utility self-policing initiative and Institute of Nuclear Power Operations good practice standards.

An integral part of this approach might be the willingness of the NRC to answer the question, "If we don't think it is safe, what will it take to make it safe enough?" If an envelope as proposed does not meet the requirements in NRC's judgment, the Agency should be willing to state what would meet them. The NRC would not design components of the plant; rather it would say, "There are probably many approaches that would satisfy requirement X. One such approach is such-and-such providing all the detailed considerations are handled adequately."

c. Influence plant design to minimize the impact of off-site hazards and to reduce the size of emergency planning zones.

d. Continue pursuit of the source term work with the objective to more properly define emergency planning zones.

e. Continue the recently initiated efforts to interact with the designer on licensibility matters in the early design stages of advanced plants.

f. Develop improved General Design Criteria based on experience of the past twenty years, including insights gained from improved methods for risk and consequence analysis.

g. Orient some of the NRC LWR research programs toward "creative research" or "exploratory research" -- looking for new ways to bring about better safety. Perhaps the Department of Energy should be the group to do this, but there is little evidence that it does.

h. Position itself, the industry, and the nation so that, when another major accident such as TMI occurs, the nation will not lose the benefits of nuclear energy. This could include activities such as:

o Development of an effective program to educate the media on nuclear power plant safety and on the concepts of risk and probability, o Steps to explain to the public the kinds of efforts that are made to ensure public health and safety, to compare for the public the safety aspects of electricity from uranium to those for electricity from other realistic energy sources, and to explain to the public the benefits and costs of nuclear power,

o Efforts to make the public realize that there could be another accident involving severe core damage and that it should not mean the end of nuclear power.

5.6 To be prepared to carry out changing missions in the future, could do such things as:

a. Analyze whether it has the right mix of technical people to accomplish its probable future missions, and how it can keep those people active in any period of minimum activity. Can technical people expert in one area today be shifted to other work tomorrow and still be able to shift back five or ten years later? Can design analysts be effectively shifted to inspection-oriented activities? Should the NRC reduce to a minimum staff level soon, with the expectation of expanding later? Will the appropriate people be available on the market later? Does the NRC need a more extensive and more formal internal or external continuing-education program?

How will the NRC retain its share of the more experienced people and not be left with a stable of less competent people for the time when there is a resurgence in the licensing of new designs? Can it be done? How can the NRC add more "workplace experience" to its Staff?

b. Consider how it will regulate on a (likely) declining budget and how it will conduct the necessary research on a (likely) declining budget.

5.7 Could give consideration to a wide variety of important matters which do not fit in the categories above, such as:

a. The ramifications of the Agency changing from an organization heavily involved in licensing to one which is primarily an inspection group. Several hundred people may be switched from the design/construction area to the operational area, and careful control may be required to prevent the establishment of large numbers of unneeded positions and a significant loss in agency efficiency.

b. Whether the NRC should license the utility as it does now or whether it should license the plant (as an airplane is ap-proved in the aircraft industry) and license the utility only to operate the plant in a safe manner.

The topics which have been selected in the paragraphs above are considered to be only representative, but they are also considered to be among the more basic or fundamental issues the Commission might address.

6. GOALS AND OBJECTIVES The Goals and Objectives are the essence of a Long Range Plan. However, we cannot write a comprehensive and specific set of recommendations related to Goals and Objectives. We know little of the political pressures the Commissioners face. We have not studied the personnel problems within the Agency nor have we attempted to look at the Agency budget except that portion

for research. We have restricted our discussion primarily to issues related to nuclear power plants. We have had little interaction with the Licensing Boards, the Appeals Board, and the legal staff. A Long Range Plan must be comprehensive and cover all aspects of the organization or it will be a failure.

We believe, however, that we should make our views known, including the following:

6.1 We believe the Commissioners should develop a Long Range Plan as we discussed in our letter of August 13, 1985.

6.2 We believe that a Plan is a comprehensive analysis and review of the activities of the Agency, the enunciation of the Commissioners' judgment of the highest priority goals and objectives for an appropriate period of the future, and a plan of action for achiev-ing those goals and objectives. We believe the Plan should repre-sent a comprehensive, integrated course of action for the entire Agency. The Long Range Plan should be realistic, but it should also be visionary.

6.3 We wish to reemphasize the points made in our letter to Chairman Palladino on August 13, 1985 concerning the importance of a Long Range Plan for the Agency. At that time, we listed the following benefits which could follow from the strategic element of long range planning;

a. The exercise of establishing a Plan should help the Commis-sioners develop consistent Agency goals.

b. The existence of a Plan could lead to more deliberate regu-lation and could lend stability to the entire regulatory process.

c. A Plan could allow a more efficient allocation of resources.

d. A Plan will help the Commissioners in explaining and justify-ing their programs to the Congress and the Executive Branch.

e. The existence of a Plan will help to ensure that future problems are anticipated and resolved in a timely fashion.

While the lack of a Long Range Plan does not preclude the achieve-ment of these goals, such a Plan would help ensure them.