ML19347F329

Notification of 810414 Commission Meeting to Review Draft Policy,Planning & Program Guidance for FY83-89

ML19347F329
Person / Time
Issue date:	04/10/1981
From:	Ahearne J NRC COMMISSION (OCM)
To:	Bradford P, Gilinsky V, Hendrie J NRC COMMISSION (OCM)
Shared Package
ML19347F327	List: ML19347F326 ML19347F329
References
REF-10CFR9.7 NUDOCS 8105180398
Download: ML19347F329 (17)

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8 NUCLEAR REGULATORY COMMISSION h

E WASHINGTON,0.C. 20555 April 10,1981

%.....,o OFFICE OF THE COMMISSIONER MEMORANDUM FOR:

Chainnan Hendrie Commissioner Gilinsky i

Comissioner Eradford FRG4:

John Ahearne REVIEW OF DR ! PPPG 5UBJECT:

Our next meeting to continue the review of the draf t PPPG is scheduled for 10:00 am, Tuesday, April 14, 1981.

To expedite that review, I have developed alternative wording (attached) which hopefully accommodates some of the concerns expressed by the written comments of Chirman Hendrie and Comissioner Bradford.thr.ough Section III.B.2.7.

The alternative wording, starting with where we left off at our last session (Section III.B.l.1) is not meant to preclude discussion, but to facilitate agreement.

The proposed changes are asterisked to assist your review.

If any of you provide additional coments by mid-day Monday, I would be happy to develop wording to accomodate them.

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8105180 39T

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.ac;s 1.1 New Reactor Applications.

Except for operating licensas, no new reactor applications are likely to be received AM.

I J4) before FY 82 at the earliest.

However, capability to process new CP applications as well as to deal with site reviews, special projects, and standard design reviews is to be maintained. The NRC will encourage the submittal e

of standardized plant designs by continuing the process of reviewing and approving such applications in a timely manner.

1.1.1 Consistent with the NRC's role to assure an adequate level of safety for nuclear power

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facilities, the NRC will cr

i. g the safety advantage to be gained by including within the standardization program, the option to submit for agency review co=bincd nuclear steam supply and balance-of-plant designs as a single entity.

This type of standardized review would either replace or provide an optica to the existing standardized plant review processes which entail separate review of the nuclear: steam supply and balance-of-plant portions of the i

plant.

Consideration will also be given to the advantages of structuring the review of such combined nuclear steam supply and balance-of-l plant applications so that, except for those l

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I aspects of a proposed facility which relates directly to the site, if an approved si:andardized design is referenced in an applic.ation, a single stage licensing r ocess will be used.

A plan to accomplish this will be submitted to the Comnission for consideration by the end of FY 1982.

1.2 Priorities for regulating nuclear power'reaccors are:

1.2.1 The safety of operating power reactors will based on the fatt receive first priority /etr-che.-extent that thesa reactors represent actual rat * - than potential risk to the public h:.th and safety. The TM1-2 cleanup.and recovery operations are included in this highest priority category.

1.2.2 (See insert on following page) 3 1.2.2 Consistent with maintaining safety of operating plants, OL reviews will be ce=pleted on a AIRc. s4 9i

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g schedule that assures that the review process l

will not be a critical path item which would.

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delay reactor fuel load and startup testing The staff should assume a 10 month hearing process.

Asatl1rget I

activities. //CP reviews will be coupleted within 00jective, I

j 24 months cf the date of docketing.

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The staff should proceed with 4

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1. 2. fh=tr/1=provements in the reactor operatorg. licensing

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The NRC Boards and staff should imolement directlives programgeve-been-mace-mvagn--i.ns -Alu.ia% wuss.

and rule changes as soon as possible.

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f should be ce=piered-by-hce Ler--l%1, Other initiatives' which would make the licensing process more efficient anb effective should also be explored.

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s INSERT 1.2.2 Resources allocated for power reactors under constructior, will be directed at assuring.that these reactors are designed and constructed i

so as to incorporate the lessons learned from TMI and provide adequate public protection after they are licensed to operate.

NRC will place increased emphasis on licensee QA/QC programs that ensure plants are built to achieve this objective.

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" Unresolved safety issues" will be promptly j

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i pursuedrand. when eauh-isrca-is resolved,

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M wherever modificatiens to optrxtit:g -frcilnivt f.

M and 2E5 ase -f+vad -to -b e-nec ess ary3-wi1 be / impl emen ted.

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i NvTn~'tNe*Ibov'e*YrYc7rities, the staff should devote a

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effort to programs which have a high potential of reducing risl g

1.3 NRC will develop and implement a comprehensive plan for

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the systematic safety evaluation of all currently operating E

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nuclear power plants as provided' for in Subsection 110 of

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Public Law 96-265 (NRC IT 1980 Authorization).The plan

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will integrate the current SEP. IREP, and KPIP. An

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essential element of the plan will be the development of

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July a revision to the SRP scheduled to be co=pleted by AytII /

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E 1981.

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1.4 A1J. generic issues will be integrated in an agency-wide i

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generic issues program.

Issues included in the present a

program, which are no %e related to NRC regulatory r

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vill be eli=inated.

Emphasis will be placed on implementing reco== ended solutions to generic safety issues which have been resolved.

As a first step in resolving generic issues, W 1Lu.pAnud a fully integrated priority list wil

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g be est lished and-

[hoseissueswhichlac ificance or are of marginal g

importance to the regulatory program should be dropped from the list. The revised program will establish criteria for adding new issues to the program.

Issues will be added to the program only after' careful evaluation to assure that they warrant Co==ission attention and resource expenditures.

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2.0 Implementing New Reactor Safety Recuirements Future regulatory requirements which. are necessary to provide the minimum leve 1

of protection of public health and safety will be applied to a.U plants and a

where it is infeasible to apply these recuirenents, the plant w'ill be closed.

ggggf For requirements that go beyond the minimum level, cost and feasibility of Oh implementation will be considered.

In applying

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-l Future {riquire3ents 'f b rpplidtooperatingplants tid k f,

and to plants under construction, we+n due consideratic l

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• f design or other differences among plants.

Requirements i

a will be implemented in an order that gives greatef weight to actions with a high potential'for risk reduction.

(Coese.nt :

NRR seeks'Com=ission guidance on the backfitting of new requirements on plants that were licensed before the requirements were adopted).

2.1

[I= mediate actions will be taken to assure that operating plants can operate with adequate safety pending the development of a long-term generic solution to the safety-related problen.

If adequate safety cannot be assured, remedial short-term measures will be adopted including, if necessary, shutdown of the facility.]

s 2.2 Public co= ment on the substance and scheduling of implementation of new licensing criteria will be obtained prior to issuance.

In nost cases, the opportunity for such review will be e

i the for=al public co= ment period for a Regulatory Guide, I

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Standard Review Plan revision, or regulation.

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2.2.1

[A value/ impact analysis vill be prepateil for l

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i will be established i

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'2.3 Implementation scheduls4 consistent with the safety j

Licensees should be allowed l

importance of the requirement /viu-be-estab1:ishedpin l

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such-s-manner-ttr1mi-itne-bicenseer suf ficient time for in-i

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depth engineering, evaluation and design, procurement of

, to the extent i P,6 c high quality equipment, and its proper installation-/

I compatible with public health and safety.

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2.3.1 In setting schedule, industry capability (i.e.,

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engineering resources and =anuf acturing capacity) i 1

to i=plement the new requirenant for operating t

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l plants and plants under construction vill be l

l considered. NRC's ability to review licensees'

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proposals and to inspect i_ple=entation for all operating plants and plants under construction I

i will also.be considered.

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l To the extent consistent with safety i

2.3.2

[ In -erder -to -mini =iz e-th e-co sts-of-safq /

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Lee e:sente, implementation schedules for new I

P. B' requirements will be set so as to avoid dcnintime i

j on operating plants or delay in startup of new plants.

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[ Consideration will be given to issuing new requirementsinacoordinatedfashionhnee-a-w)ratherthanindividuallythroughoutthe

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year.]

2.4 A management system vill be developed which accounts for I

all new requirements issued, their relationship to the

.I revised Standard Review Plan, and the status of their

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implementation.

2.5 The a'gency shall have by FY 1984 a project manager responsible for no more than one operating reactor, or for no more than one reactor. design at a site with reactors,of different designs.

2.6 The Com:nission is concerned about the capability of certain utilities, especially small utilities undertaking their first nuclear project, to own and operate nuclear I

power plants safely. The staff will study this issue and g

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2.7 NRC will require key licensee employees including certain management and maintenance personnel to be adequately examine qualified.

NRC will/take a direct role in training and testing of these key employees and develop ing some form g @'[~ f of licensing for individual key employees not already Yd h d. >

hh licensed.

3.0 The emerg'ancy response capabi.ilties of NRC and licensees 1

I need additional improvement.

NRC will determine'the j

i appropriate bases for emergency response plans and actions

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NRC will h~ ve the capability to collect, verify and j

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avaluzts data from multiple sources to assure that appropriate I

I operational measures are being taken by the licensee I

during an incident and that appropriate recommendations

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I for protective actions are being made.

NRC will determine what licensee data concerning plant conditions during an accident should be available to State and local authorities for public prote'ction purposes and'will assure that means for licensee dissemination of those data are in place.

NEC will design, construct and operate data collection and communications facilities to support its role in off-l site emergency response and to determine and co=municate I

generic lessons learned.

The NRC operations center will be expanded so that computer hardware for the nuclear data l

i on a schedule consistent with available funding g link can be installed /1= he masl.y.. pace..cf..EZ..'.8J g

i and Congressional guidance.

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4.0

[NRC will review, update, and maintain its radiation protection standards to ensure that workers, the general public, and the environment are adequately protected from the effects of ionizing radiation and that radiation exposures are maintained ALARA.

In this regard, the NRC M

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will revise its regulations, as appropriate, to, reflect (1) the generally applicable environmental radiation t

l standards and Federal radiation protection philosophy and f

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methodology, and (2) the latest research findings on the health effects of ionizing' radiation. NRC will ansure i

3 that its efforts are coordinated with the overall Federal program for radiation protection and radiological health research by partich.pating in the activities of the U.S.

I Radiation Policy Council and the Interagency Radiation 4

Research Revieu Committee.]

5.0 NRC will continue to study and improve its human factors acceptance criteria using data from appropriate disciplines and conducting its own research where necessary. A long-range integrated hu=an factors program vill be developed.

NRC human factors efforts will focus on developing human factors guidelines for the following areas: current and future control room design (including integratien of information on plant status, com=unications, and information I

retrieval as required by operators); plant procedures aJ l

(normal, emergency, test, surveillance); the nuclear I

(dh plant outside the control room,I 8

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G m &c.w w fu l y wl..cici Mht. As part of the effort to improve safety, the NRC will develop methods for judging the " competency" of a utility, its management.

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Other Planning Guidanca 1.0 L'aste Management. During FY 83-87, five Site Citaracterization Reports for a highlevel vaste repository will be submitted l

for review. A permaner.t repository site vill be selected and a license application vill be submitted to the NRC to i

obtain construction authorization as early as 1987. By

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FY 1986, legislation vill be enacted to extend NRC regulatory authority to all new transuranic and new non-defense and low-level vaste disposal facilities.

During FT 83-87 NRC expects four 'new applications to be submitted to Agreement f

States for licensed co=mercial low-level vaste burial in which significant NItC technical assistance vill be requested.

Due to encertainty, interruptions and limitations in the r

availability of low-level vaste disposal capacity at existing ec=mercial disposal sites, operating reactor licensees are expected to request approval of contingency storage facilities to provide capacity for several years i

storage of low-level vaste generated on site.

In response I'

to such requests se.parate 10 CFR Part 30 licenses vill be i

issued for on-site interim low-level vaste storage facilities upon demonstration that the construction and operation l

I will not affect the safety of re tor operations.

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fecefw.1-gvlong-term (life-of-piant) storage of lovj j

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el vastes at reactor site [ c 11 h h ll 1..

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vironmental impacts that ce? :::r ;e may have, pa#ti:21.lf I

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t T-1.1 NRC waste management efforts will focus on the dpvelopment i

of licensing criteria for waste repositories.

These criteria vill be based on a defense-in-depth strategy that requires thorough consideration of various types of site, demonstrated capabilities of the waste form delected,

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and the interaction of the waste form and packaging with the geological, hydrological, and engineered systems mid g

invo' RC will publish a proposed regulation in-early/

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.h fh 1981 (2:;p..im- ;;

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P-c -b-- 'o'9-) covering the technical criteria, and will

.inlizetheene4+d Ein e rule by early FY 82.

NRC will have in place by mid

'86 all regulatory guidance and criteria so that the licensing of waste repositories will provide for adequate protection of the public and is not unnecessarily delayed.

l.2 Spent Fuel Storage Capacity.

An away-from-reactor storage facility application will be submitted for licensing so

.that the reviews can be co=pleted by the end of CY 1983.

1.3 GESMO.

Resources to support GESMO should be requ4 sed in the FY 1983/84

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budget and should be consistent with the Administration's program.

2.0 Achieving and maintaining NRC presence at licensed facilities i

f will provide a better basis for NRC to determine adequacy of licensee performance.

Moreover, facilities and s

licensees need a better awareness of regulatory requirements i

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to improve licensee performance.

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2.1 Presence at nuclear power plants will be achieved through I

an appropriate mix of Region-based inspectors and resident l

operating reactor project managers.PNerdd..C inspectors with good ce==unications to licensing and 3trd-rq The

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18 h assi n

^at least o e resident inspector to each construction, (JA,)

pre-operational and operating reactor site.

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p *au M * --Ges F:::rd inspectors vill be te sdes assigned on the basis of past licensee erformance, plant tLe availabel,G e4* <defod fresned personns)

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_'.. icn design, and esc:

g Win vill 1. ::d by k gion-based inspectors who. provide

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additional support and coverage, specialized technical expertise and NRC responses to =ajor event.i.

2.2

[NRC vill ensure rapid dissemination of information I

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II.C. "Other pertinent to safety and draw rctention to new safety-Policies" related information and events.]

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2.3

[NRC will take action to ensure that infor=at. ion supplied by licensees in response to NRC bulletins, letters, or i

other requests is pro =pt, accurate, and adequate to allow the staff to make regulatory decisions in a ti=ely fashion.)

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2.4 NRC on-site inspection vill focus more on the direct verification of the activities and operations of ' licensees, license,e contractors, and vendors.

NRC, vill i= prove its own capabiliites for independent and confirmatory measure-Operational data evaluation results should focus IE inspections. %

ments.

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2.5 The goal of NRC's enforcement program vill be in co=pliance

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with NRC regulations and license conditions.

In dealing with licensees who do not co= ply with NRC requirements, whose prompt and vigorc,us action vill be taken.

Licensees sho-/

4ee-cooble..oc.-unwilling-se-eemply-or-whose operations l

ser30us represent a / threat to the public health and safety vill

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not be permitted to operate.

NRC will continue its

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efforts to i= prove the enforcement program by (1) maintaining i

an aggrer.,sive enforcement strategy that seeks r. ore frequent use of stronger enfcrcement measures, such as NRC's

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increased civil penalty authority, when situations i

l varrant, (2) notifying the Justice Depart =ent of possibla i

criminal acts as they arise, (3) processing enforcement cases rapidly, (4) asuring that non-co=pliance is more expensive than compliance, (5) delegating certain enforcement i

i activities to regional directors, and (6) assuring that NRC requirements and licensee commitments are explicit, unambiguous, and are enforceable.

3.0

[NRC will support the IAEA safety mission to the extent g

practicable within available resources.]

' ' 3. 0 Resources to support a fast breeder reactor application should be requested

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in the FY 83/84 budget, consistent with Aaministration plans.

It snould be assumed that Clinch River Breeder Reactor will not be licensed. but follow t breeder reactors will be licensed.

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4.0 :IEC vd'7 davalop a=d =a1=.ad= a 1c=g-rs=;;e ssaarch piz:

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to assure tha: agency resourcas are bai=g pu.r :17 direc:ad e

id_c -** r a=d i= spec:ic=

toward areas of i= porta =ca to the jj officas.. Tha rassarch plan vill ha Eavised a=d updatad 7 a=d subjected to age =cy-wida revier a=d be

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approved,by tha % 4=sio=.

Therasaarchprogrs=vd1 t

sw for: od tha safary of cperati=g react = s a=d

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other cpara:ing facili:iss.

5.0 NRC safec.:.ards efferts vd'1 fec=s e=

he develey m e le=n=ta:1c= s=d==fc:ce=a=t of =aasuras which vdiT 4 --

provida c==sista=c a=d adaquata lavels of perfc==a=ca to

=aac the requi a===ts for each of tha various uas of I=..'

activi.:Las subj ect to. HEC safaguards res"7 =-d m.s.

this regard, N2C staff has bar= sper'*d-='77 direc:ad by the C.

issic tha: 1:s-Jamsary 16, 1980, decisio= on RF5-E=v =.is =mt.to be. taan: as ad-*d$54-m.7==phasis.

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c= =atarial c=== o1 and account 1=g at

=y echar NEC licensed pla== cr facil1=y.

Partic=lar atta= dm ud'7 ba given to reduci=g the unce: a1=:7 associated vi:h de a d-d g the ca=sa of i=ve====y differe=cas and to em=:1=ge=cy pla==i=g for achar safeguard-:alated i= cide =cs.

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P00R ORIGINAL

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NRC will establish a program in the NRC licen' sed nuclear industry to fulfill the U.S. Presidential offer to apply IAEA safeguards in the U.S.

Revicus and assessments

' i relating to the applications of IAEA safeguards as mandated t

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intheNuc[earNon-ProliferationActof1978willbe

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conducted.

6.0, NRC will continue its current policy of delegating more authority to perform certain functions in regional offices.

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j A Denver offica vill be established by FY 83y

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( j h) m 7.0 hfor=atien and the Public The following support the previously stated policies and provide guidance for NRC's interactions with the Congress, the Executive Branch, other Federal agencies and state and local goverr.ments.

7.1 NRC will systematically review and revise each of its r e gulations -io.oooosdan ee -wi th -I,0, 12044 to determine MOVE TO 8.0 anc that (1) the regulation is needed; (2) the direct and titit. " Review <

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indirect effects of the regulation have been adequately considered; (3) alternative approaches have been considered and the least burdensome of the acceptable alternatives e

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I has been chosen; (4) public co=nents have been considered and adequate response has been prepared; (5) the regulation f

is writ' ten in plain English and is understandable to those who must comply with it; *(6) an estimate has been i

l made of the new reporting burdens or record keeping s

l raquirements necessary for compliance with the regulation; (7).c specific person is designated as official contact;

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and (8) a plan for evaluating the regulation af ter its issuance has 'aean developed. Tae initial review will be i

completed by 1985 and subsequent reviews will be made on

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a five-ywar cycle.

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7.27 Active participation in the NRC regulatory process by an infor=ed public is beneficial. The Comnission has endorsed

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the principle of providing technical and financial assistance to me=bers of the public who wish to participate in KRC proceedings and are able to do so effectively.

Implementation is restricted by of this endorsement Ns4e-sensissent-with Congressional g

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, which prohibits NRC providing financial A

action and guidance r/

assistance to intervenors.

2 7.fr/ Active participation and cooperation with state and local

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government officials is essential. The Consission has l

l endorsed this principle and in particular affirms such as l

Commission policy.

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