ML19308C971
| ML19308C971 | |
| Person / Time | |
|---|---|
| Issue date: | 01/10/1980 |
| From: | Hanrahan E NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| To: | Ahearne J, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19308C972 | List: |
| References | |
| NUDOCS 8002130023 | |
| Download: ML19308C971 (34) | |
Text
-
~
gpaat p
,;(
UNITED STATES y
g NUCLEAR REGULATORY COMMISSION O'
- y WASHINGTON, D. C. 20555 k..... f January 10, 1980 MEMORANDUM FOR:
Chairman Ahearne Commissioner Gilinsky Commissioner Kennedy Commissioner Hendrie Comissioner Bradford FROM:
Edward J. Hanrahan
SUBJECT:
POLICY, PLANNING AND PROGRAM GUIDANCE (PPPG):
KEY POLICY QUESTIONS At the conclusion of your consideration of a draft PPPG (Commission meeting of December 21,1979) Commissioner Gilinsky suggested that a short list of questions on basic policy issues be prepared.
The responses elicited by the questions were to express Commission policy in key areas and thus provide the necessary guidance to the staff.
l Policy Questions We have assisted Commissioner Gilinsky in preparing the list of 8 key policy questions in Enclosure 1.
I believe that the December 20 draft PPPG would state Commission policy in most of the areas covered by the 8 key policy questions.
In a few instances, response tc certain of the key policy questions would either supplement the statements of tne December 20 draft PPPG or provide guidance in new areas. is a orief summary of the correlation between the key policy questions and the Der. ember 20 draft PPPG.
[
One of the issues raised in the key policy questions but not in the December 20 PPPG is a statement of siting policy.
- However, OPE has been requested by the Chairman to prepare a summary of the principal siting issues now before the Commission for decision in order to provide a framework for Commission action.
l You will have this summary later this month.
If you take action on these issues l
before the FY '82-86 budget cycle begins, a suitable statement on siting policy may be incorporated in the fina,1 PPPG.
The key policy question 8 and the draft PPPG statement concerning safety research are not completely congruent.
The PPPG statement is a general statement of
Contact:
Jim Beckerley, OPE 63-43295 c3 8 r02130 74 4
)
Commission policy while question 8 suggests detailed review of outstanding unresolved safety issues and the research required to resolve them as the basis for setting safety research program priorities.
Revised Draft PPPG I have received further comments from the Chairman and Commissioners Hendrie and Bradford on the December 20 draft.
These comments, as well as those made during the December 21 Commission meeting, have been incorporated in a " January 9, 1980" draft of the guidance (Enclosure 3).
To delineate the changes the new draft is presented with the text of the December 20 draft on opposing pages.
You will note that some of the statements of Subsection A.2, " Achieving Adequate Protection of the Public Health and Safety," of the 12/20/79 draft have been grouped under a new heading, "A.3 Other Basic Policies." The intent is to put all the guidance specifically relating to adequate protection in Subsection A.2.
Except for this change, the format of the new draft is the same as that of the 12/20/79 draft.
I believe we are converging on a useful document.
If possible, at our next meeting on the PPPG, I should like to secure your approval of as many of the specific draft statements as possible.
Then, as the PPPG is developed further, you can limit your consideration to new material that is added and old material that is revised.
Inclosures:
As stated cc: Leonard Bickwit
-Sam Chilk Lee V. Gossick Norman Haller KEY POLICY OUESTIONS 1.
How can the level of protection of the cublic health and safety and the. environ-ment that NRC considers adequate be defined in more specific terms than is at cresent?
How should NRC ensure that new and older operating cower reactors as well as other nuclear facilities and activities achieve that level cf oretection?
2.
To what extent should factors other than public health and safety and environmental protection (e.g., costs to licensees and their customers, need for power) be considered,in NRC regulatory decisions?
If other factors are to be considered, how and at what stage of the regulatory process shculd they be considered?
3.
How should current regulatory re.quirements and criteria be applied to existing facilities and facilities under construction?
4.
What is NRC's regulatory philosoony leading to the allocation of its resources among operating reactors and facilities and those in the design and construction stages and between headquarters reviews of licensee and applicant submissions and NRC presence at the site?
5.
What is the NRC siting policy? How shall it apply to existing facilities, those under construction, and new license applications?
6.
What is the NRC role in the response to radiological emergencies vis-a-vis the responsibilities of the licensee and other Federal, State, and local authorities?
7.
What timescale should be used in assessing the adequate protection from the radiological hazards resulting from present nuclear activities, particularly as applicable to the development of regulatory criteria for disposition of high level wastes and uranium mill tailings?
8.
What safety research is needed to enable the determination of adequate protection?
e e
4 i
knclosure 2 CORRELATION.BETWEEN 12/20/79 DRAFT PPPG AND THE KEY POLICY QUESTIONS 1.
How can the level of protection of the oublic health and safety and the. environ-ment that NRC considers adecuate be defined in more specific ter s than71s at
- resent? how should NRC ensure inat new and older cDerating Dower reactors as well as other nuclear facilities ano activities achieve that level of orotection?
The 12/20/79 draft includes a statement on adequate protection and in Q states that no explicit detemination of an adequate level of protection has been made.
Alb states that risks should be described in the context of the risks available ai terna tives.
Neither really answers the ouestion how to define adequate protec-tion. The second part of the question is addressed in A_2a through d and Bl.
2.
Tc what extent should factors other than public health and safety and envirormental protection (e.g., costs to licensees and their custcmers, need for power) be considered in MC regulat ry decisiens? If other fac: rs are to be censidered, how and at what stage cf the regulatory process should they be censidered?
This' question is addressed in A2c_ but only with respect to operating reactors.
It should be noted, however, that NRC practice (since the Calvert Cliffs decision) has been to consider need for power and power costs (vis-a-vis available alternatives) in the NEPA review, i.e., during consideration of CP applications.
In'A2b the policy for considering economic factors is also addressed with the implication that CP and OL reviews are involved.
3.
How should current regulatcry recuirements and criteria be acolied to existing facilities and facilities under construction?
This question is addressed in Bla with respect to operating reacters and in BJ with. respect to reactors under construction.
However, B,1 is not a comprehensive backfit policy statement.
4 What is NRC's regulatory philesc5hy leading to the allocation of its rescurces among coerating reacters and facilities and those in the design and construction stages and between headouarters reviews of licensee and acclicant submissions
{
and NRC presence at the site?
The first part of the question is addressed in A2e.
One aspect of the second part of the question is discussed in B3; however, the ouestion of the relative l
priorities of licensing (CP or OL) application review work and onsite inspection is not addressed.
2-5.
What is the NRC siting policy? How shall it apply to existing f acilities, these under construction, and new license applications?
This cuestion is not addressed in the 12/20/79 draf t.
6.
What is tne NRC mle in the res onse tc raciological emergencies vis-a-vis the responsibilities of the licensee anc ether Federal, state, anc local autnerities?
B3 stated that the staff should give priority to answering this question.
(Other parts of B5, i.e., 85a and 85f, imply'how the question should be answered.)
7'.
What timescale should be used-in assessing the adequate protection from the radiological hazards resulting from present nuclear activities, particularly as applicable to the development of regulatery criteria for dtspesition of high level westes and uranium mill tailings?
Ag[ addresses this question in a qualitative manner.
The "timescal e" is not specified.
L 8.
What safety research is needed to enable the determination of adequate protection?
This question is not really addressed in the 12/20/79 draft, although B9 has a a general policy statement.
4 1
l
\\
Enclosuro 3 i
COMPARISON OF TEXTS OF 1/9/80 AtID 12/20/79 DRAFTS OF THE POLICY, PLANNIt!G, AND PROGRAM GUIDANCE (FY82-85) DOCUMENT l
t NOTE:
Pages'are numbered only on 1/9/80 draft.
Pages 6 through 14 of the 1/9/80 draft are unchanged from I
the 12/20/79 draft except as noted.
I i
6 e
l l
- ~,
n
- n e
DRAFT 12/20/79 FISCAL YEARS 1982-86 POLICY, PLANNING, AND PROGRAM GUIDANCE (PPPG)
I.
INTRODUCTION
/
This occument provides guidance from the Commission to the staff on policies that are the basis of NRC planning and multi-year budget preparation.*
The PPPG document has two parts.
The policy and clanning guidance section states broad policies, the implications of these policies, and other factors that influence the planning of NRC programs.
The program guidance section reflects the Commission's instructions in the major program areas; program guidance may change substantially each year as the staff achieves earlier objectives and as the policy and planning guidance evolves.
This PPPG covers the fiscal years ~1982-1986.
Since this is the first PPPG to be issued by the Commission, the policies also apply to fiscal years 1980 and 1981.
The primary NRC mission is to protect the public and the environment in the uses of nuclear facilities and materials.
In protecting the public, NRC must (1) determine what level of protection is adequate, and (2) assure that 'this level of protection is achieved and maintained.
A number of policy statements in the PPPG address these two fundamental issues.
"This oocument focuses on NRC's health, safety and environmental policies and programs.
It is not intended to be all-inclusive.
DRAFT 1/9/80 FISCAL YEARS 1982-86 POLICY, PLANNING, AND PROGRAM GUIDANCE (PPPG)
I.
INTRODUCTION This document ("PPPG") provides guidance from the Commission to the staff on policies, plans and programs for the fiscal years 1982-1985.
Since this is the first PPPG to be issued by the Commission, the policy guidance also applies to fiscal year 1980 and 1981.*
The guidance provided here covers a pivotal time for nuclear regulation.
The Three Mile Island accident has called many regulatory assumptions and practices into serious question, cut, even before that accident, many of the assumptions that underlay the first quarter century of nuclear develop-ment for peaceful purposes were under skeptical review.
The demand pro-jections of the early 70's for nuclear plants in the year 2000 have been lowered by a factor of five.
Interagency review groups have been convened on nuclear waste and low-level radiation.
An international review group is reviewing nonproliferation concerns.
The NRC itself has had to refine some of the statements on reactor safety that have been issued in the context of.'
WASH-1400.
,If there is a common flaw revealed in the events that have led to these reassessments, it is complacency.
The current reappraisals must be seen as an opportunity to orient nuclear regulation away from any sense of complacency and toward an outlook befitting a technology that combines remote possibilitieg of fatal accidents or catastrophes with substantial day-to-day benefits.
It is the Commission's intention that nuclear regulation reflect a con-tinuing commitment to come to grips with the realities of nuclear tech-nology and of its relationship to those who control it, to those who live
- The focus of this document is on NRC's health, safety, and environmental policies, plans and programs.
It is not intended to be all-inclusive.
Vertical lines in the left-hand margin indicate where changes in the 12/20/79 draft have been made.
l
DRAFT 12/20/79 II. POLICY AND PLANNING GUIDANCE A.
Policy Guidance The follcwing are statements of NRC policies and practices which are to serve as guidelines for the agency activities.
1.
Risk Assessment [LevelofProtection]
Through its licensing actions, the NRC has implicitly deter-a.
mined the level of protection of the public health and safety that it deems adequate and is to be maintained by the nuclear industry.
Thus, no explicit determination of an adequate level of protection has been made.
b.
NRC'will describe to the public the risks of nuclear activities and the uncertainties in the judgments of risk. The risks of nuclear activities should be described in the context of the risks of alternative means of providing the electrical energy or required services. Public input will be solicited in developing regulations and, through interactions with Congress and through rulemakings and hearings, NRC will seek public judgments on the acceptability of various levels of nuclear risk.
[the risks of nuclear activities.]
The NRC will attempt to make an explicit determination of c.
the level of protection of the public health and safety that it believes is adequate based on statutes, public input, and NRC's subjective and quantitative evaluations.
To this end, NRC will accelerate the development and use of means for assessing the levels of protection associated with licensed nuclear activities.
near it, and to the general public. This commitment requires not only an open and questioning approach within the agency, but an approach to the public (including the regulated public) that encourages dialogue and informed participation in nuclear decisicq-making.
As part of this process, the Commission must state its basic assumotions and criteria clearly, amend them when the~ facts sc require, and live by them consistently
,and forthrightly in all of its activities.
II'. POLICY AND PLANNING GUIDANCE A.
Policy Guidance The following are statements of NRC policies and practices which are to serve as guidelines for the agency activities.
1.
Level of Protection
~
a.' Through its licensing actions, the NRC has determined on a
~
case basis the level of protection of the public health and safety that it deems adequate and is to be maintained by the nuclear industry. The NRC will seek to define the level of protection of the public. health and safety that it believes.
is adequate based on statutes, public input, and NRC's sub.
jective and quantitative evaluations.
b.# In the ccurse of its work, NRC will describe to the public the risks of nuclear activities and the uncertainties in the judgment of risk.
Through interactions with Congress and through rulemakiI and hearings, NRC will seek public judgments on the acceptability of the risks of licensed nuclear activities.
l l
i
(
Substantial change from 12/20/79 draft.
I
DRAFT 12/20/79 2.
Achievino Adequate Protection of Public Health and Safety Licensed nuclear activities will be regulated by NRC so as a.
to achieve and maintain adequate protection of the'public health and safety.
Licensees who cannot achieve and maintain this level of protection will not be permitted to operate.
b.
Even though in making regulatory decisions to assure adequate
' protection,_some consideration of the costs involved may be implicit in the evaluations of the practicality of the means of providing adequate protection, cost-benefit balancing is not appropriate for determining whether to require ~ achievement of a specific level of protection.
However, explicit con-sideration of the costs which the licensee or its customers might incur in achieving the necessary level of protection is appropritate in evaluating alternative methods for achieving that level and for determining, after achievement of the necessary level of protection, whether measures providing an even greater degree of protection should be taken.
In NRC regulatory decisions every effort should be made to identify explicitly any economic considerations that.may be involved and to indicate their effect on the decision.
In deciding whether an operating nuclear facility provides c.
adequate protection of the public health and safety, NRC will consider the public health and safety implications of not operating the facility as well as the potential radio-logical risks associated with its operation.
e e
l l
e 3-i 2.
Achievino Adeouate Protection _ of Public Health and Safety a.' Licensed nuclear activities will be regulated by NRC so as to achieve and maintain adequate protection of the public health and safety.
Licensees who cannot achieve and maintain this level of protection will not be permitted to operate.
b." Explicit consideration of costs which the licensee or its customers might incur in achieving and maintaining an adequate level of protection of the public health and safety is appro-priate in evaluating alternative methods for achieving and maintaining that level and in determining whether measures pro-viding a degree of protection greater than that level should be taken.
Every effort should be made to identify explicitly any economic considerations that may be involved in NRC regulatory decisions and to indicate their effects on each decision.
OR bf* Some consideration of costs which the licensee or its customers might incur w,ld beappropriate in deciding whether an adequate woa level of protection is met and maintained.
Where these factors are considered they shall be set forth explicitly and applied, recognizing that protection of the public health and safety is a paramount consideration.
Consideration of costs is always appropriate in deciding alternative methods for achieving a given level of risk.
However, in some circumstances -- for
^
example, in considering requests for exemptions from regulations affecting the level of risk -- little or no consideration can be given to costs.
i c5 In deciding whether an operating nuclear facility provides i
adequate protection of the public health and safety, NRC will t
consider the public health and safety implications of not operating the facility as well as the potential radiological l
or other hazards associated with its operation.
- No change from 12/20/79-draft.
- Substantial change from 12/20/79 draft.
l t Minor change at beginning of last line.
DRAFT 12/20/79 d.
Recognizing that accidents and theft, sabotage and other illegal acts can occur, NRC will place increased emphasis on measures that can minimize their harmful consequences.
e.
priority, in terms of resources and schedules, will be proportioned to those NRC activities to the degree that they are expected to have the greatest effect on reduction of risks to the public health and i
sa fety.
First priority will be assigned to assuring that operating facilities achieve and maintain adequate levels of protection of the public health and safety.
However, assuring that facilities are de-signed and constructed to achieve adequate protection must also have f
high priority, since these facilities will soon operate.
Only faci-lities that are designed 'and constructed properly can be continuously operated in a manner that achieves and maintains adequate protection.
f OR e.
The overriding NRC priority, in terms of resources and schedules, will be assigned to assuring that operating facilities achieve and maintain adequate levels of protection of the public health and safety.
Prio r-ities of NRC activities that involve those NRC resources not engaged in assuring adequate levels of protection for operating facilities l
will be assigned according to risk-reduction potential, i.e. activities !
expected to achieve the greatest reduction in risk to the public health f and safety will be assigned the highest priority.
f.
NRC supports and will implement the Presidential mandate for improving i government regulation by requiring careful consideration of the benefita, and costs of alternative ways to achieve regulatory objectives.
NRC l
will systematically review all safety regulations for content and l
structure.
Resources pennitting, this initial review will be com-pleted by 1984 and subsequent reviews will be made on a five to seven year cycle. [on a continuous basis.]
g.* In dealing with licensees who are unable or unwilling to comply with NRC requirements, NRC will emphasize prompt and visorous enforcement.
The goal of the enforcement program will be to increase each licensee's incentives for compliance and to insure that a licensee will nct benefi9 by violating NRC regulations.
h.
NRC will actively encourage and support licensee initiatives that will provide greater public protection.
- Transposed without change to "Other Basic Policies" section in 1/9/80 dra(
DRA W l/?/80 4_
d." Recognizing that accidents, theft or diversion of nuclear material and sabotage or other illegal acts can occur, NRC will place increased emphasis on measures that can minimize their harmful I
effects on the public health and safety.
ef Priority, in terms of resources and schedules, will be given to NRC activities that are expected'to have the greatest effect on reduction of risks to the public health and safety.
First oriority will be assigned to assuring that operating facilities achieve and maintain adequate levels of protection of the public health and safety.
However, assuring that facilities are designed and constructed to achieve and maintain an adequate level of protection must also have high priority, since these facilities will soon operate.
Only facilities that are designed and constructed properly can be continuously operated in a manner that achieves and maintains adequate protection, f.' NRC supports and will implement the Presidential mandate for improving government regulation by requiring careful consideration of the benef ts and costs of alternative ways to achieve regulatcry objectives.
NRC wil,1 systematically review all safety regulations for content and structure.
Resources
. permitting, this initial review will be completed by 1984 and I
subsequent reviews will be made on a five to seven year cycle.
~
g.* NRC will actively encourage and support licensee initiatives that will provide a higher level cf protection of the public health and safety.
Minor changes from 12/20/79 draft.
i
- First option of 12/20/79 has been chosen with minor change in first sentence.
DRAFT 12/20/79
- i. The objectives of NRC regulation will not only be to provide protection in the near term, but also to provide adequate protection of future generations.
NRC will not permit the licensing of facilities if the NRC does not have confidence that the waste they generate can be safely disposed of.
i I
- j. Maintenance of radiation exposures as low as reasonably achievable (ALARA) is a fundamental objective of NRC's radiation protection activities.
k.
With respect to its international responsibilities, the NRC recognizes that the proliferation of nuclear explosive devices poses a direct threat to the security interests of the United States and continued international progress toward world peace. Hence, in discharging its statutory mandate relating to the import and export of nuclear materiais, equipmelt, and facilities, the NRC will seek to confirm the reliability of the U.S. in meeting its supply conunitments to nations
~
which adhere to effective non-proliferation policies by l
establishing procedures to facilitate the timely processing of export licenses.
Concerning its statutory role in otner U.S. nuclear activities, the NRC will provide independent assessments and validations of Executive Branch decisions.
DRAFT 1/9/80
. hI The objective of NRC regulation will not only be to provide adequate protection of the public health and safety during the term of each license but also to provide adequate protection after license termination.
Accordingly, NRC will not license a i
facility unless the NRC is confident that, after termination of the license, the level of protection of the public healtn and safety from the potential ha: arcs of the oecommissionec facility itself as well as the wastes it generates, will be at least equal to the level of protection provided during the term of I
the facility license.
3.
Other Policies a." In dealing with licensees who are unable or unwilling to comply with NRC requirements, NRC will emphasize prompt and vigorous enforcement.
The goal of the enforcement program will be to increase each licensee.'s incentives for compliance and to insure.
that a licensee will not benefit by violating NRC regulations.
b.# Maintenance of radiation exposures as low as reasonably I
achievable (ALARA) under normal (routine) conditions is a fundament objective of NRC's radiation protection activities.
c.# With respect to its international responsibilities, the NRC recognizes that the proliferation of nuclear explosive devices poses a direct threat to the security interests of the United States and continued international progress toward world peace.
Hence, the NRC will continue to discharge its statutory licens-ing responsibilities to help ensure that effective U. S. controls are applied to the import and export of nuclear materials, equip-ment, and facilities; the NRC will also seek to confirm the reli-ability of the U.S. in meeting its supply commitments to nations which adhere to effective nonproliferation policies by implement-ing procedu-es that facilitate the timely processing of export licenses.
Concerning its statutory role in other U.S. nuclear I
activities, the NRC will provide independent assessments and l
valida'tions of Executive Branch decisions.
Significant changes.
' Minor changes.
l No changes.
l l
e DRAFT 12/20/79
~
B.
Plannino Guidance The material that follows expands on these general policy statements, orovides more gsidance on certain activities that the staff should undertake tc implement the policy guidance, and contains additional information for use in planning NRC programs.
1.
Priorities fcr regulating nuclear power reactors are:
a.
The safety of operating power reactors will receive first priority based upon the potential consequences of reactor accidents and the realization of the greater uncertainty in the probabilities of these accidents.
Specific actions required to improve the safety of operating power reactors include:
(1) Applying the lessons learned from the Three Mile Island accident to all operating reactors.
(2)
Resolving important generic safety issues and implementing any changes to all reactors.
(3)
Requiring older reactors where necessary to meet the level of protection of public health and safety NRC considers adequate.
(4)
Requiring accountability of individual licensee employees and management for important safety functions.
b.
Resources allocated for power reactors under construction will be directed at assuring that these reactors are designed and constructed so as-to provide adequate public protection after they are licensed to operate.
NRC will require QA/QC programs that ensure plants are built to achieve this objective.
i l
DRAFT 1/9/80 E.
Plannina Guidance #
The material that follows exoancs en these general policy statements, provides more guidance en certain activities that tne staff should uncertake to implement the policy guidance, and contains acditional information for use in clanning NRC crograms.
1.
Priorities for regulating nuclear power reactors are:
a.
The safety of operating power reactors will receive first priority based upon the potential consequences of reactor accidents and the realization of the greater uncertainty in the probabilities of tnese accidents.
Specific actions required to improve the safety of operating power reactors include:
(1) Applying the lessons learned from the Three Mile Island accident to all operating reactors.
(2)
Resolving important generic safety issues and implementing any changes to all reactors.
t C,4.
v-Ad e.
(3) Requiring older reactors where necessary to the level of protection of public health and safety NRe i
censider; 2dc;uctr.
(4) Requiring accountability of individual licensee employees and management for important safety functions.
b.
Resources allocated for power reactors under construction will be directed at assuring that these reactors are designed and constructed so as to provide adequate public protection after they are licensed to operate.
NRC will require QA/QC l
programs that ensure plants are built to achieve this objective.
Except for the few minor changes noted, this section is the same as l
l Section B of the 12/20/79 draft.
i
DRAFT 12/20/79
- 2.. Greater NRC presence is needec at major licensec facilities, anc licensees net letter awareness of regulatory recuirements botn to provide a better basis for NRC to determine adequacy of licensee performance and.to improve licensee performance.
a.
Greater presence at nuclear power plants and other selected facilities will be attained primarily througn the Resident Inspection program.
The staff will carefully consider the need to increase its presence at other locations, sucn as vendor facilities.
b.
Greater presence at materials licensees will be attained primarily through increased frequency of inspection where warranted by licensee performance on either an individual or generic (licensee-type) basis.
c.
Enhancement of licensee awareness of, regulatory requirements will be attained primarily through increased use of bulletins, circulars, information notices, and generic letters.
l
.d.
NRC on-site inspection will focus more on the direct verifi-cation and observation of licensee activities and operations and less on audit of licensee records.
NRC will continue to improve its own capabilities for independent and confirmatory measurements as a means of d.irect verification of licensee l
operations and performance.
l
DRAFT 1/9/80
_7 2.
Greater NRC presence is neeceo at major licensed facilities, and licensees need better awareness of regulatory requirements both to provide a better basis for NRC to determine adequacy of licensee performance and to improve licensee performance.
a.
Greater presence at nuclear power plants and other selected facilities will be attained primarily through the Resident Inspection program.
The staff will carefully consider the need to increase its presence at other locations, such as vendor facilities.
b.
Greater presence at materials iicensees will be attained primarily through increased frequency of inspection where warranted b'y licensee performance on either an individual or generic (lic'ansee-type) basis.
~
c.
Enhancement of licensee awareness of regulatory requirements will be attained primarily through increased use of bulletins, circulars, information notices, and generic letters.
d.
NRC on-site inspection will focus more on the direct verifi-cation and tbservation of licensee activities and operations and less on aedit of licensee records.
NRC will continue to improve its own capabilities for independent and ccnfirmatory f
measurements as a means of direct verification of licensee operations and performance.
l em
DRAFT 12/20/79 l
i 3.
To support its oversight of the licensed nuclear industry and recognizing the probability of resource limitations, NRC will consider development of inspection assistance programs with third parties, such as national standards organizations, provided their capabilities are judged adequate for the proposed tasks.
4.
NRC will require key licensee employees including certain management and maintenance personnel to be adequately qualified.
NRC staff will consider taking a direct role in training and testing of these key empicyees.
5.
The emergency response capabilities of NRC and licensees need improvement.
Specific near-term priorities includes:
.a.
Improving NRC, licensee and State / local emergency procedures.
Every facility or activity that could pose significant risks to the public will have an NRC and FEMA-approved emergency plan. An NRC rulemaking procedure has been initiateo to require this approval.
In addition, the Presidnet has directed FEMA to take the lead in off-site emergency planning and response and to review State emergency plans for operating reactors by June 1980.
DRAFT 1/9/80
-B-t 3.
To support its oversight of the licensed nuclear industry and recognizing the probability of resource limitations, NRC will consider development of inspection assistance programs with third parties, such as national standards organizations, provided their capabilities are judged. adequate for the proposed tasks.
4.
NRC will require key licensee employees including certain management and maintenance persor.nel to be adequately qualified.
NRC staff will consider taking a direct role in training and testing of these key employees.
5.
The emergency response capabilities Qf NRC and licensees need improvement.
Specific near-term priorities includes:
a.
Improving NRC, licensee and State / local emergency procedures.
Every facility or activity that could pose significant risks 3
to the public will have an NRC y3. Cjjpapproved emergency d
plan.
An NRC rulemakinc precedure has beec initiated to for mu[eg.r paw rk16 require this approval in addition, the Presidg%t has directed g
FEMA to take the lead in eff-site emergency planning and response and to review State emergency clans for cpera:ing reactors by June 1930.
i
DRAFT 12/20/79 b.
Providing the comunications, upgrading the cc=unications and other eauipment required for prompt and accropriate NRC response to emergencies.
c.
Delineating specific responsibilities of NRC people and organizations, licensees, States, and others in an emergency.
d.
Requiring instrumentation that will function properly and provide needed information on the status and condition of key equipment during an accident.
e.
Requiring instrumentation that can measure radiation releases around major nuclear facilities.
f.
Developing and implementing an emergency planning zone concept and consequence mitigation strategies that will allow NRC to assist FEMA to plan for actions to minimize public harm in the & vent of an accident.
6.
NRC risk assessment activities will continue with high priority-directed to understanding more fully the individual and collective l
risks posed by nuclear activities.
As this knowledge develops, it will be used as a means of focusing NRC inspection and other regulatory attention on those licensee systems and activities that are judged to be the greatest potential contributors to risk.
7.
NRC needs major improvements in its efforts to collect, analyze, disseminate, and act upon operational data relevant to the safe operation of major licensed facilities.
NRC will take steps to ensure that licensee-provided data is complete and accurate, that.this data is systematically and thoroughly analyzed to identify possible precursors or generic problems, and that the results of this analysis are promptly and appropriately acted upon, e.g. coordinated feedback of current operating data into the licensing process, operator and maintenance programs, and plant and equipment designs.
The analysis of operational data
DRAFT 1/9/80
-g.
b.
Providing the communications, upgrading the communications and other eculpment required for promst &nd appropriate tiRC res;:ense to emergencies, c.
Delineating specific responsibilities of f4RC pecole and crganizations, licensees, States, and others in an emergency.
d.
Requiring instrumentation that.will function properly and provide needed information on the status and condition of key equipment during an accicent, e.
Requiring instrumentation that can measure radiation releases around major nuclear facilities.
f.
Developing and implementing an emergency planning zone concept and consequence mitigation strategies that will allow NRC to assist FEMA to plan for actions to minimize public harm in the event of an accident.
6.
tiRC risk assessment activities will continue with high priority.
directed to understanding more fully the individual and collective risks posed by nuclear activities. As this knowledge develops, it will be used as a means of focusing tiRC inspection and other regulatory attention on those licensee systems and activities that are judged to be the greatest cotential contributors to risk.
7.
f4RC needs major improvements in its efforts to collect, analyze, disseminate, and act upon coerational cata relevant to the safe operation of major licensed facilities.
tiRC will take steps to ensure that licensee-provided data is complete and accurate, that.this data is systematically and thoroughly analyzed to ideritify possible precursors or generic problems, and that tne results of tnis analysi.s are promptly ano appropriately acted upon, e.g. coordinated feedback of current operating data into the licensing process, operator and maintenance programs, and plant and equipment designs.
The analysis of operational data
will also be used to helo identify those licensees whose activities present greater risks, so that appropriate remedial action can be taken.
8.
The purposes of NRC's enforcement crogram are to obtain pr r.;pt correction of licensee weaknesses and to ceter future noncompliance through the threat of strong corrective measures.
NRC will con-tinue its efforts to improve the enforcement program by:.(1) adopting an aggressive enforcement strategy that seeks more frequent use of stronger enforcement measures, such as NRC's increased civil penalty authority, when situations warrant, (2) processing enforcement cases much more rapidly, and (3) a!.suring that noncompliance is more expensive than compliance.
9.
NRC will reemphasize research efforts that support the safety of operating nuclear reactors.
Particular attention will be devoted to the support of:
reactor licensing, inspection and regulations development activities; human factors; analysis of transients; and structural and seismic qualification.
It is important that research be focused on identifiable needs; however, the originators of research must also have flexibility in directing work that has potential longer-term payoffs.
10.
Risks associated with the large number of different types of materials licensees are not sufficient'ly known.
Concurrent with its efforts on power reactors, NRC will try to define more pre-cisely'the nature and extent of risks posed by these licensees.
Based on the results of these efforts, NRC will assess its regu-lations'and make appropriate improvements.
i 11.
NRC waste manacement efforts will focus on the development of licensing criteria for waste repositories.
These criteria will be based on a defense-in-depth strategy that requires thorough consideration of various types of sites, demonstrated capabilities j
of the waste form selected and the interaction of the waste form and packaging with the geological, hydrological, and engineered
DRAFT 1/9/80
+ will also be used to help identify those licensees whose activities present greater risks, so that apprcpriate remedial action can be taken.
8.
The purposec of NRC's enforcement orogram are to ebcain prem;;
correction of licensee weaknesses and to cecer future noncemoliance through the threat of. strong corrective measures.
NRC will con-tinue its efforts to improve the enforcament program by:
(1) adopting an aggressive enforcement strategy that seeks more frequent use of stronger enforcement measures, such as NRC's increased civil penalty' authority, when situations warrant, (2) precessing enforcement cases much more rapidiy, and (3) assuring that noncompliance is more expensive than compliance.
9.
NRC will reemphasize research efforts that support the safety of operating nuclear reactors.
Particular attention will be devoted to the support of:
reactor licensing, inspection and regulations development activities; human factors; analysis of transients; and structural and seismic qualification.
It is important that research be focused on identifiable needs; however, the originators of research must also have flexibility in directing work that has potential longer-term payoffs.
10.
Risks associated with the large number of different types of materials licensees are not sufficiently known.
Concurrent with its efforts on power reactors, HRC will try to define more pre-cisely the nature and extent of risks posed by these licensees.
Based on the results of these efforts, NRC will assess its regu-lations and make apprcpriate improvements.
11.
NRC waste management efforts will focus en :ne_develcpment of licensing criteria for waste repositories.
These criteria will be based on a defense-in-depth strategy that requires thorough consideration of various types of sites, oemonstrated capabilities of the waste form selected and the interaction of the waste form and packaging with the geological, hydrological, and engineered
DRAFT 12/20/79 systems involved.
NRC will promulgate its criter,ia as soon as possible so that the licensing of waste repositories will provide for adequate protection of the public ano is not unnecessarily delayed.
12.
NRC safecuards efforts will focus on the development and enforcement of adequate, consistent, requirements for ecch of the various types of activities subject to NRC safeguards regulations.
Particular attention will be given to reducing the uncertainty associat9d with determining the cause of inventory differences and contingency planning for safeguard-related incidents.
13.
The staff will conduct periodic evalucations of NRC programs.
l NRC will accelerate ongoing self-examinations in the following areas, answering such questions as:
a.
Regulatory requirements and standards.
Are they adequate to protect the public, assuming licensee compliance? Are they easily understood and consistent?
Should some requirements be added or eliminated?
.b.
Licensing.
Is the licensing process structured and managed in a way that leads to adequate public protection yet provides i
timely reviews of license applications?
c.
. Inspection and' enforcement.
Is the inspection program oriented to focus on the most important aspects of each licensee's activity?
Is the level of effort expended on various activities of licensees appropriate?
d.
Research.
Are there important areas that require additional effort or areas that should be eliminated or reduced?
Is the research program well planned over the long term and managed so that its results are incorporated into NRC programs?
9
.~
D RAFT 1/9/80
-11 systems involved.
NRC will promulgate its criteria as soon as possible so that the licensing of waste repositories will provide for adequate protection of the public anc is not unnecessarily delayed.
12.
NRC safecuards efforts will focus on the oevelopment and enforcement of adequate, consistent, requirements for each of the various types of activities subject to NRC safeguards regulations. Particular attention will be given to reducing the uncertainty associated with determining the cause of inventory differences and contingency planning for safeguard-related incidents.
- 13. The staff will conduct periodic evalucations of NRC programs.
NRC will accelerate ongoing self-examinations in the following areas, answering such questions as:
a.
Segulatory requirements and standards.
Are they adequate to protect the public, assuming licensee compliance? Are they easily understood and consistent? Should some requirements be added or eliminated?
I b.
Licensing.
Is the licensing process structured and managed in a way that leads to adequate public protection yet provides timely reviews of license applications?
l c.
Inspection and enforcement.
Is the inspection program l
oriented to focus on the most important aspects of each licensee's activity?
Is the level of effort expended on various activities of licensees accropriate?
O d.
Research.
Are there important areas that require additional effort or areas that should be eliminatec or reduced?
Is the research program well planned over the long term and managed so that its results are incorporated into NRC programs?
DRAFT 12/20/79 C.
Manacinc NRC External Affairs NRC's relationships with people anc organi:ations outside the~ agency are important because NRC serves the public in regulating thousancs of 1.icensees, receives oversight fr:m Congress, succorts national pol'icies of the Executive Branch, ano shares regulatory resconsibilities withotherFederalagenciesandwithStateandlocalgovernments.
The following policies support the previously stated policies anc provide guidance for NRC's interactions with the groups described above.
1.
NRC is dedicated to conduring its activites openly.
Consecuently, NRC will make its deliberations and products readily accessible to any interested persons or organizations limited only by con-sideration of applicable laws.
NRC will provide complete and timely information -- in " plain English" -- on significant regu-latory activities to licensees, Congress and the public.
To assist the general public in its understanding of NRC policies and programs, NRC will develop and distribute basic information about NRC licensing activities.
~
2.
NRC will solicit diverse views -- both from inside and outside NRC -- on major regulatory issues, proposed actions, and technical products.
NRC will give consideration to public and staff con-cerns that have significant potential impact on protecting the public.
3.
Active participation in the NRC regulatory process by an informed public is beneficial both to the puclic and to NRC.
A Commission majority has endorsed the principle of providing technical and
- ~
financial assistance to members of the public who wish to partici-pate in NRC proceedings and are able to do so effectively. Imolementation g
of this endorsement must be consistent with Congressional action and guidance.
O
DRAFT 1/9/80 3g.
C.
Manacinc NRC External Affairs
- NRC's relationshios with oecple and organizati:ns outside the agency are imoortant because NRC serves the public in regulating thousands of licensees, receives oversign fr = Concress, su:perts national poli:ies of the Executive Eranch, and shares regulatory responsibilities with other Federal agencies.and with State and local governments.
The following policies support the pravicusly stated policies and provide guidance for NRC's interactions wita the groups described above.
c l
l.
NRC is dedicated to ccnduting its activites openly.
Consequently, NRC will make its celiberations and procucts readily accessible to any interested persons or organizations limited only by con-sideration of applicable laws.
NRC will provide complete and timely information -- in " plain English" -- on significant regu-latory activities to licensees, Congress and the public.
To assist the general public in its understanding of NRC policies and programs, NRC will develop and distribute basic information about NRC licensing activities.
1 2.
NRC will solicit diverse views -- both frem inside and outside NRC -- on major regulatory issues, proposed actions, and technical i
products.
NRC will give consideration to public and staff con-cerns that have significant potential impact on protecting the public.
3.
Active participation in the NRC regulatory process by an informed I
I public is beneficial both to the public and to NRC.
A Commissicn majority has endorsed the principle of providing technical anc financial assistance to members of the public who wish to partici-pate in NRC proceedings and are able to do so effectively. Imolementation of this endorsement must be consistent with Congressicnal action and guidance.
- This section is the same as Section C of the 12/20/79 dra'(t.
DRAFT 12/20/79 4
NRC will work with other agencies and organizations / councils --
Federal, State, and local --to insure that the public is ace-quately protected in areas wnere responsioility is shared and to
-insure that NRC regulation is, when possible, consistent and comoatible witn that of otner agencies.
5.
NRC will provide to the Department of Energy or other developmental agencie. advice and consultation concerning licensing of new nuclear technology.
D.
Internal NRC Management Deleted.
III.
PROGRAM GUIDANCE Note:
A.
This section will be provided in phases, tied principally to the schedule of program presentations by lead office directors to the EDO.
b
DRAFT 1/9/80
. 4.
NRC will work with other agencies and organizations / councils --
Federal, State, and local --to insure that the public is ade-quately protected in areas where responsibility is shared and c insure that NRC regulation is, when possible, consistent and compatible with that of.other agencies.
5.
NRC will provide to the Department of Energy or other deve'lopmental agencies advice an.d consultation concerning licensing of new nuclear technology.
D.
Internal NRC Manacement*
Deleted.
III.
PROGRAM GUIDANCE
- Note:
A.
This section will be provided in phases, tied principally to the schedule of program presentations by lead office directors to the EDO.
- These sections are the same as in the 12/20/79 draft.
9
DRAFT 12/20/79 B.
For each of a numoer of program areas, this section will provide:
-- Background information
-- Long-term program goals Specific objectives and pl.anned. accomplishments (current, FY 82-85) i Planning assumptions C.
The program areas described in this section will also be tracked in the Decision Unit Tracking System (DUTS). Although the preceding policy and planning guidance may eventually require changes in NRC's current list of major program areas, the programs currently being tracked by DUTS in i
FY 80 are:
Waste Management Decommissioning Spent Fuel Storage Qualification of Safety-Related Equipment Unresolved Safety Issues Health Effects from Low-Level.
l Operating Reactor Amendments Radiation i
Systematic Evaluation Program Fire Protection Revised Inspection Program Power Reactor Casework Emergency Planning Risk Assessment Fuel Cycle and Material Safety Long-Range Research Plan Transportation International Efforts Domestic Safeguards Operational Data Analysis em 4
9 e
DRAFT 1/9/80
=
(
. 5.
For each of a number of program areas, this section will provide:
-- Backgrounc information
-- Long-term program goals
-- Specific objectives and planned accomplishments (current, FY 82-85)
-- Planning assumptions C.
The program areas described in this section will also be tracked in the Decision Unit Tracking System (DUTS).
Although the preceding policy and planning guicance may eventually require changes in NRC's current list of major program areas, the programs currently being tracked by DUTS in FY 30 are:
1 Decommissioning Waste Management Qualification of Safety-Related Spent Fuel Storage Equipment Unresolved Safety Issues Health Effects from Low-Level Operating Reactor Amendments Radiation Systematic Evaluation Program Fire Protection Revised Inspection Program Power Reactor Casework Emergency Planning Risk Assessment Long-Range Research Plan Fuel Cycle and Material Safety Transportation International Efforts Operational Data Analysis Domestic Safeguards Y
e 9