ML19308C975
| ML19308C975 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19308C972 | List: |
| References | |
| NUDOCS 8002130027 | |
| Download: ML19308C975 (14) | |
Text
-
l
.O FISCAL YEARS 1982-86 POLICY, PLANNING, AND PROGRAM GUIDANCE (PPPG)
I.
INTRODUCTION This document ("PPPG") provides guidance from the Comission to the staff on policies, plans and programs for the fiscal years 1982-1986.
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, but, 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 comon flaw revealed in' the events that have led to these i
reassessments, it is complacency.
The current reappraisals must be seen as an opportunity to orient nuclear regulation away from any sense of complacency andtowardanoutlookbefittingatechnologythatcombinesremotepossibilitiesl 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.
i 8002130 h j
r 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 l
informed participation in nuclear decision-making. As part of this process, the Commission must state.its basic assumptions and criteria i
clearly, amend them when the f acts so require, and live by them consistently and forthrightly in all of its activities.
II. POLICY AND PLANNING GUIDANCE A.
Policy Guidance i
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.
j is adequate based on statutes, public input, and NRC's sub.
3ective and quantitative evaluations.
b.
In the course of its work, NRC will describe to the public the risksofnuclearactivitiesandtheuncertaintiesinthejudgmentsj of risk.
Through interactions with Congress and through rulemaking, and hearings, NRC will seek public judgments on the acceptability of the risks of licensed nuclear activities.
i e
f
2.
Achievino Adecuate 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 ccnnot achieve and maintain this level of protection will not be permitted to operate.
Explicit consid' ration of costs which the licensee'or its b.
e
~
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 tha+ 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 b.
Some consideration of costs which the licensee or its customers mightincur"+sfppYopriateindecidingwhetheranadequate 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 a.ffecting tne level of risk -- little or no consideration can be given to costs.
c.
In deciding whether an operating nuclear facility provides 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 radiologica.1 or other hazards associated with its operation.
DRAFT 1/9/80 4
d.
Recognizing that accidents, theft or diversion of nuclear materials ~
and sabotage or other illegal acts can occur, NRC will place increased emphasis on measures that can minimize their harmful effects on the public health and safety.
e.
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 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 designed and constructed to achieve and maintain an adequate level of protection must also have high priority, I
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 benefits and costs of alternative ways to achieve regulatory objectives.
NRC will systematically review all safety regulations for content and structure.
Resources permitting, this initial review will be completed by 1984 and 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 of protection of the public health and safety.
t l
w w
w,,
P m
M
DRAFT 1/9/80
, h.
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 j
facility unless the NRC is confident that, after termination of the license, the level of protection of the public health and i
safety from the potential hazards of the decommissioned facility itself as well as the wastes it generates, will be at least equal to the level of protection provided during the term'of the facility license.
3.
Other Policids In dealing with licensees who are enable or unwilling to comply a.
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
(
achievable (ALARA) under normal (routine) conditions is a fundamenta objective of NRC's radiation protection activities.
i With respect to its international responsibilities, the NRC l
c.
recognizes that the proliferation of nuclear explosive devices poses a direct threat to the security interests of the United States and continued internati,onal progress toward world peace.
Hence, the NRC will continue to discharge its statutory licens-l ing responsibilities to help ensure that effective U. S. controls 1
are applied to the import and export of nuclear materials, equip ment, and facilities; the NRC will also reek to confinn the reli-ability of the U.S. in meeting its supply commitments to nations which adhere to effective nonproliferation policies by implement-I ing procedures that facilitate the timely processing of export licenses.
Concerning its statutory role in other U.S. nuclear l
activities, the NRC will provide independent assessments and l
valiciations of Executive Bnanch decisions.
DRAFT 1/9/80 B.
Plannino Guidance The material that follows expands on these general policy statements, provides more guidance on certain activities that the staff should undertake to implement the policy guidance, and contains additional information for use in planning NRC programs.
1.
Priorities for regulating nuclear power' reactors are:
a.
The safety of operating power reactors will receive first oriori y based upon the potential consequences of reactor t
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 i.ssues and implementing any changes to all reactors.
oc cAdc (3) Requiring older reactors where necessary to the level of protection of public health and safety NRC ccn5ider; :dequ:tc.
(4) Requiring accountability of individual licensee employees and management for important safety functions.
1 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.
9 l
~
DRAFT 1/9/80
-7
'l 2.
Greater NRC presence is needed 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.
Greater presence at nuclear power plants and other selected a.
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 licensees will be attained pri$arilythroughincreasedfrequencyofinspectionwhere warranted by licensee performance on either an individual or generic (licensee-type) basis.
Enhancement of licensee awareness of, regulatory requirements c.
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 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 direct verification of licensee operations and performance.
O
DRAFT 1/9/80
~
j I
b i
3.
To support its oversight of the licensed nuclear industry and I
recognizing the probability of resource limitations, NRC will consider development of inspection assistance programs with third parties, s'uch 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 employees.
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 r-i tothepublicwillhaveanNRCggy.Ljjfapprovedemergency plan. An NRC rul.emaking procedure h.as been initiated to fer~ mu s w 6 c-require this approval (k.c.r@ addition, the Presiqg%t has directed In f
FEMA to take the lead in off-site emergency planning and response and to review State emergency plans for operating reactors by June 1980.
i o
DRAFT 1/9/80
.g.
b.
Providing the communications, upgrading the communications and other equipment required for prompt and appropriate NRC response to emergencies.
c.
Delineating specific responsibilities of NRC people anc 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. event of an accident.
6.
NRC 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 NRC inspection and other regulatory attention on those licensee systems and activities that a.re judged to be the greatest potential contributors to risk.
7.
NRC needs major improvements in its efforts to collect,, analyze, disseminate, and act upon coerational data relevant to the safe operation of major licensed f acilities.
NRC will take steps to ensure that licensee-provided data is ccmplete 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 maintanance programs, and plant and equipment designs.
The analysis of operational cata
DRAFT 1/9/80 1o.
will also be used to help identify those licensees whose activities present greater risks, so that appropriate remedial action can be taken.
8.
The-purposes of NRC's enforcement program are to obtain prompt correction of licensee weaknesses and to deter 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) assuring that noncompliance is more expensive than compliance.
9.
NRC will reemphasize research efforts that' support tne 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 numoer of different types of matertals licensees are not sufficiently 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.
11.
NRC waste management 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 of the waste form selected and the interaction of the waste form and packaging with the geological, hydrological, and engineered
D RAFT 1/9/80 P
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 ana is not unnecessarily delayed.
12.
NRC safeouards efforts will focus on the development 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 fcr safeguard-related incidents.
13.
The staff will conduct periodic evalucatiols of NRC programs.
NRC will accelerate ongoing self-examinat ons in the following d
areas, answering such questions as:
i a.
Segulatory requirements and standards.
Are they adequate to protect the public, as:uming licensee compliance? Are they easily understood and consistent?
Should some requirements be added or eliminated?
b.
Licensing.
Is the licensing process structured and managed
[
i in a way that leads to adequate public protection yet provides 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
~
l effort or areas that should be eliminated or reduced?
Is
'the research program well planned over the long term and i
managed so that its results are incorporated into NRC programs?
l
DRAFT 1/9/80
' C.
Managing NRC External Affairs NRC's relationships with people and organizations outside the agency are important because NRC serves the public in regulating thousands of licensees, receives oversight from Congress, supports national policies of the Executive Branch, and shares regulatory responsibilities with other Federal agencies and with State and local governments.
The following policies. support the previously stated policies and
[
provide guidance for NRC's interactions with the groups described above.
1.
NRC is dedicated to cond ting its activites openly.
Consequently, NRC will make its deliberations and products readily accessible to any interested persons or or.ganizations limited only by con-sideration of applicable laws.
NRC will provide complete and 1
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-l 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 public and to NRC.
A Ccmmission majority has endorsed the principle of providing technical and i
financial assistance to members of the public who wish to partici-pate in NRC proceedings and are able to do so effectively. Implementation of this endorsement must be consistent with Congressional action and guidance.
DRAFT 1/9/80 l
l 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 to insure that NRC regulation is, when possible, consistent and compatible with that of.other agencies.
5.
NRC will provide to t.he Department of Energy or other developmental agencies advice and consultation concerning licensing of'new nuclear technology.
D.
Internal NRC Manaaement 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.
O D
m
DRAFT 1/9/80
.,, - E.
For each of a number of program areas, this section will provide:
-- Background information
-- Long-term program goals
-- Specific objectives and planned accomplishments (current, FY S2-85)
-- Planning assumptions C.
The program areas described in his section will also be tracked in the
' Decision Unit Tracking System (DUTS). Altnough the preceding pclicy and planning guidance may eventually require changes in NRC's current list of major program areas, the programs currently being tracked by DUTS in FY 80 are:
Decommissioning Waste Management Spent Fuel Storage Qualification of Safety-Related 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 Fuel Cycle and Material Safety Long-Range Research Plan Transportation International Efforts Operational Data Analysis Domestic Safeguards
,e