ML19350C337

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Forwards Revised Version of Sections I & II of Policy, Planning & Program Guidance Document Based on Commission Last Two Meetings on Subj
ML19350C337
Person / Time
Issue date: 03/20/1981
From: Hanrahan E
NRC OFFICE OF POLICY EVALUATIONS (OPE)
To: Bradford P, Gilinsky V, Hendrie J
NRC COMMISSION (OCM)
Shared Package
ML19350C335 List:
References
REF-10CFR9.7 NUDOCS 8103310947
Download: ML19350C337 (12)


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March 20,1981 MEMORANDUM FOR:

Chairman Hendrie Comissioner Gilinsky Comissioner Bradford Comissioner Ahearne FROM:

Edward J. Hanraha

SUBJECT:

REVISED POLICY, PLANNING, AND PROGRAM GUIDANCE DOCUMENT based on the Comission's last two meeting's on the su lines in the margin indicate sections of the document concerning which Vertical as we understand it, the Comission has not reached final agreement.

Attachment:

As Stated cc:

Leonard Bickwit Sam Chilk William Dircks

I.

INTRODUCTION The purpose of this Policy, Planning and Progra: Guidance (PPPG) document is to provide guidance fro: the Cc==ission to the Staff.on policies, plans, and progra=s for the fiscal yearc 1983-1987.

Guidance with respect to each and every activity within the NRC is not furnished, since it is not intended that the document be all inclusive and since it would be impractical to address all the issues here.

Rather the Com=ission has selected the specific areas which are the most important.

This is more than just a document to be used for budget preparation, it is management guidance.

The policy section is intended to establish a general framework for NRC managers to shape their own particular programs. Planning guidance is furnished in those areas where the Commission believes more detail is needed to meet its specific concerns about schedules and priorities or where major assu=ptions are needed for progra= development.

Based on the PPPG the Co--4ssion will also forward a separate document to the staff containin's fiscal guidance to aid in the development of the FY 83 and FY 84 budgets.

It is the Com=ission's intention that nuclear regulation reflect a continuing cor-dtment to come to grips with the reality of nuclear technology and of its relationship to those who control it, to those who work with it, to those who live near it, and to the general public.

This conm:itment requires not only an open and

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l' questioning approach within the agency, bu: an approach Oc :he i,

public (including the regulated public) that encourages dialogue i

i t.nd infcrned participation in nuclear decisice-naking. As pnr: of

his process, the Co=nission c:ast state its basic assunp ion and criteria clearly, amend the= when the f acts se require, and live by them consistently and forthrightly in all activities.

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? ::.1 0Y C ! m ;; I Tne f ollowing are s:a:e=ents of NRC policies auf practices which are te serve as guidelines for agency activities.

A.

Level of Protection 1.0 Through its licensing actions, the NRC has implicitly determined on a case-by-case basis the level of protection of the public health and safety that it deens adequate and is to be maintained by the nuclear industry.

The NRC vill seek to define as clearly as possible the level of protec: ion of the public health and safe:y that it believes is adequate based on statu:es, public and Congressional co==ent, and NRC's subjective and quantitative evaluations.

Che licensee has the responsibility to maintain this adequate level of protection of the public health and

' safety.

The NRC has oversight responsibility to assure that the licensee is in fact maintaining an adequate level of protection at his facilities.

l 2.0 in the course of 'its work, NRC vill speak frankly about i

l the risk of nuclear activities and the uncertainties in l

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the judgments of risk.

Through interac:foas with Congress j

and through ru1===k4ng and hearings, NRC vill seek advice on the acceptability of the risks of licensed nuclear i

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activities.

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E.

Achievine Adecuate Protection of Public Health and Scf erv 1.0 Priori:y in regulation, in ter=s of resources and schedules, will be given to NRC activities :ha: are ec ac:ed to have the greates: effect on redue:1on 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 public health and safety.

1.1 The Co==1ssion also has an obligation to carry out its licensing activities efficiently. k'hile the need to issue new licenses cannot be allowed to compro=ise adequate protection in the operating plants, the Com=ission review process and public hearings should not delay the operation of acceptable facilities.

Priorities of NRC activities that involve those NRC resources not engaged in assuring adequate levels of protection for operating facilities will be assigned primarily according to risk reduction potentials.

It is expected this will lead to deferral or cancellation of some activities that would be i.

undertaken in the absence of resource limitations.

I 2.0 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 an adequate level of protection of public health and saf ety vil1~ not be per=1::ed :o operate.

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. 1.1 in takin; decisions concerning the cperatic Of a nuclea facility, NR1 vill censide aceng c her i

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things the public h-ith and safety and ce==:n i

defense and security 1 plica icns of nc: cpera:ing the f acility as well as the potential radiclogical or other hacards associated with its operation.

Any application of these consideraticus must be s:ated explicitly.

2.2 Consideration of costs to the licensee or its customers is always appropriate in deciding among alterna:ive ne: hods for achieving a given level of safety.

Considerations of costs and ether non-safety factors nay be appropriate, depending on the circu= stances, in deter =ining adequ..:e levels of safety.

NRC should for=ulate its require =ents so tha: the indus:ry is free to select the most cost-effective route to the satisfaction of safety objectives and so that licensees are encouraged to propose initiatives that provide a higher level of protection of the public health and safety than the =ini=u= required.

3.0 in emergencies NRC will monitor closely the course of events onsite and act as the primary gover==ent source of infer =ation about the probable extent of public risk resulting from the accident.

In coordination with the

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licensee, NRC vill prepare recc==endations fer eff-site pre:ective acticas, in the absence of applicable preplanned responses.

In addition, NRC will analyce the i=plications cf the event fer other licensed f acilities and co==unicate advice and ins: rue: ions te preven: si=ilar accidents.

NRC will not manage the accident on-site or implement protective measures off site.

The licensee has pri=ary responsibility for protecting the safety of verkers and notifying civil authorities of the need for protective actions by the public.

However, in unusual cases NEC may need to issue orders to the licensee te ensure prompt actions are taken to provide adequate protection or warning to the public.

State and local authorities must take appropriate action to limit public risk from radioactivity-released by an accident, based on ti=ely, securate and co=plete information concerning the plant c onditions provided by the licensee and the NRC.

Federal agencies under FEMA leadership will provide support to the off-site authorities.

4.0 Maintenance of radiation exposures as low as reasonably achievable (ALAnA) under' normal (routine) conditions is a fundamental objective of NRC's radiation protection activities.

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4.1 Te pr::ect the public health and safe:y, nuclear i

regulation =us be concerned no: enly with licensed

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l opera:ing nuclear facilities, but also with the deco =nissioning of such f acilities and the disposc1 of vastes resulting from their operation.

NRC will license and regulate so that the vastes and structures re=aining after the active period of the license are not a hazard.

5.0 Co=mercial nuclear power plants have not been sufficiently designed or operated based on human factors considerations.

However, competent and experienced operating, maintenance, and management personnel are essential to safe operation.

Therefore, in association with industry, NRC vill develop and apply standards for these positions.

C.

Other Policies 1.0 The NRC waste management program is critical to the success of an urgent national task.

NRC will organize and plan its vaste management progra to be consisten:

with the Executive Branch's progra= as approved by Congress.

i NRC's vaste management program will be based on the premise that, in the absence of unresolved safety concerns, the NRC regulatory progra= will not delay implementation of the Executive Branch's progra=.

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2. C-in decling with licensees who are unabic c: unwilling :c cc ply with NRC requirements, URC vill e=phasice prc=p:

and vigorous enforce =en:.

The enforce =en progran vill be ccrried out in accordance with NRC regula:icns and license conditions.

The enforce =ent progran should assure that a licensee vill not benefit by violating NRC regulations.

3.0 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. Hence, the NRC will continue to discharge its statutory licensing responsibilities to ensure that effective U.S. controls are applied to the i= port and export of nuclear materials, equipnent, and facilities; the NRC vill also seek to support the reliability of U.S. in meeting its supply com=itments to nations which adhere to effective non~-proliferation policies by implementing procedures that facilitate the timely processing of export licenses.

Concerning its statutory. role in other U.S. nuclear activities, the NRC will provide independent assessments and validations of Es:ecutive Branch decisions.

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4.! The funda
ental cbjectives :f the lU.: research prcgran f

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cre te assis: the standards, licensin;, and inspe::ict ani i

enforcement effices in carrying ou: the Cc= issien's I

.. i resp nsibilities under the s:a:::es.

in carryin; cu: these i

resp nsibilities the Ce==issien believes thc: =cs: cf the research should be on public health and safety =atters.

The i

research progra: =ust consis: of a balance a=ong research in: ended to confir= existing regula: cry practices, research to explore areas where new concerns =4y exist or where existing regulatory approaches =ay be inadequate, and research to exa=ine concep:s for i= proving safety.

It is i=portant tha: the research progra= be focused on identifiable needs, and that its relevance to the agency's regulatory activities be the paramount basis for its progra=s.

The research progra= should include so=e verk en areas with po:ential broader or longer-ter= paycffs as well as verk addressed to shorter-range scals and the needs arising out of the current activities of the NRC.

The research progra= should include work on the safety of advanced reactor concep:s commensurate vi:h develop = ental efforts by the Depart =ent of Energy.

Cooperative funding should be encouraged ~for those elenents of the research prcgra=

which can be supported in par: by the priva:e sector or by foreign regulatory entities.

The NRC'research progra=

should not include ite=s that ought to be supported exclusively by the private sector.

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0 5.0 Lecogni:ing that accidents, :hef: c diversier cf nu: lear i

=cteria's, and sabo: age er c:her tile;c; a::s can :: ur, i

NRC vill c phasize =easures tha: can miniti e their harmful censequences.

I n adfitien, N?.: vill emphasize 1

i the development and i=ple=en stien of i= proved me: hods of I

=aterial control and accounting. With respect to IAEA I

I safeguards, NRC will plan and establish a progra: in the l

l licensed nuclear industry to i=pleman: IAEA safeguards as required i

i by the US/lAEA Safeguards Agreement.

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I 6.0 Since NRC licensees are geographically dispersed, some of NRC's regulatory responsibilities can be carried out more efficiently and effectively by locating NRC personnel closer to licensees. NRC's regional activities vill be expanded by relocating seme cf the headquarters functions.

7.0 NRC will work with other agencies and organizations /

councils -- Federal, state, and local -- to assure that the public is adequately protected in areas where responsibility is shared, to assure that NRC regulation is, when possible, consistent and compatible vi h that of other agencies.

S.0 Inferna:1on and the Public

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!aC is dedicated to conducting 1:s activi:ies openly, consisten: vith applicable laws.

Enere the lav per=1ts 22C to restrie: access to its deliberctions and documents !GC vill decidc :: restri:: er per:1:

public access based on considerations of the public interest and the policies which underlie the lavs.

8.2 130 vill solicit diverse views -- both from inside and outside NRC - on major regulatory issues, proposed actions, and technical products.

ImC vill give consideration to public and staff concerns on subjects that have significant potential impact on protecting the public. NRC vill maintain a working environment that encourages employees to make known their best professional judgments even though they may differ from prevailing staff view, disagree with a management decision or policy position, or take issue with established agency practices.

Each i

differing professional opinion of an NRC employee vill be evaluated on its own merit.

Further, each m.s differing professional opinion vill be pursued to resolution and the e ployee's statement of differing prcfessional opinion, together vith the agency's final response, will be made available to the public.

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