ML20039B930
| ML20039B930 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1981 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20039B926 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8112280058 | |
| Download: ML20039B930 (26) | |
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s Draft December 7, 1981 Policy and Planning Guidance TABLE OF CONTENTS Subject Page 1.
Introduction 1
2.
Safe Operation of Licensed Plants 4
3.
Near-Tenn Licensing Problems and Responses 7
4.
Getting Control of Requirements 10 14 5.
Improving the Licensing Process 15 6.
Supporting New Initiatives 15 Waste Management 17 TMI-2 Cleanup 7.
Improving Related Regulatory Tools 19 Safety Goal 19 Risk Assessment 20 21 Siting Policy 22 s
Quality Assurance 23 Research 25 8.
Other Policies International Activities 25
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-POLICY AND PLANNfNG GUf0ANCE INTRODUCTION The purpose of this document is to provide guidance to the staff for establishing priorities and for improving the regulatory process --
starting immediately.
It is therefore more than just a document to be used for preparing the FY 84-86 budget request. It is management guidance intended to focus on specific areas where the Commission believes additional
. emphasis is required.
Guidance with respect to each and every activity within NRC is not furnished, since it is not intended that the document be all inclusive.
However, this should not be perceived as a Commission belief that other areas are not equally as important to protecting the public health and safety.' fany of these other areas have effective ongoing programs where major problems do not exist but adequate management attention and initir.tive are still important. Specific areas where policy and planning guidan.e is not provided, yet top management attention is still required, include:
emergency planning and preparedness, safeguards, radiation protection, fuel cycle licensing and inspection, and materials licensing and inspection.
These and other support functions are vital to accomplishment of the overall agency mission and objectives.
. The document is o. % ized in terms of.seven major themes: Safe Operation of Licensed Plants; Near-Term Licensing Problems and Responses; Getting Control of Requirements; Improving the Licensing Process; Supporting Initiatives in Nuclear Waste and the Cleanup of Three Mile Island; Improving Related Regulatory Tools; and Other Policies. 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 Comission believes more detail is warranted to meet specific concerns about schedules and priorities or where major assumptions are needed for program development.
Specific. guidance involving programs will be provided by the Executive Director for Operations. The EDO will also develop and provide a
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management system for the Comission to keep track of the major 1982 program accorrplishments and resource expenditures that support this policy and planning guidance.
l It is the Comission's intention that nuclear regulation reflect a f
continuing comitment 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 comitment requires not only an open and effective approach within the agency, but an approach to the public (including the regulated public) that permits more efficient decisionmaking. As part of thic
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process, the Coi:rnission must state its basic assumptions and criteria clearly, amend them wnen the facts so require, and live by the'm consistently and forthrightly in all activities.
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To carry out the policy of the Commission will require the dedicated Of. fort of all employees as well as the effective and efficient use of all NRC resources.
Innovative, attentive and responsive management effort will be required to accomplish the Commission's goals.
NRC's greatest resource is its employees.
Retention of our most creative and productive talent and the recruitment of new personnel with fresh insights and perspectives should be a management priority. Any factor which erodes jobs satisfaction can defeat the attainment of the Commission's program goals and can result in the loss of staff in whose work product the Commission and the public has confidence.
To maintain a highly qualified and informed staff, the Commission's most creative and productive employees should.be recognized and provided
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fur'ther opportunity for development.
Increased effort should be expended, in the face of highly competitive conditions, to hire the best qualified s
individuals essential to the future ability of the NRC to carry out its regulatory responsibilities.
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. SAFE OPERATION OF LICENSED PLANTS Policy A.
NRC's fundamental task is to make sure that existing plants and those coming on-line operate safely. To this end, the highest priority will be given to assuring that operating facilities achieve and maintain adequate levels of protection of public health and safety.
Plannino Guidance L
1.
NRC on-site inspection of operating reactors will focus directly on the activities and operations of licensees, licensee contractors, and vendors. NRC will im' prove its own capabilities for independent and confirmatory measurements. The analysis of operational data and systematic assessment of licensee performance will be used to help focus inspections and to allocate inspection resources.
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2.
The NRC and the industry must continue to learn the lessons that i
only experience can teach. Efforts to collect, analyze, disseminate.
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l and act upon operational data relevant to the safe operation of major licensed facilities must continue to receive priority attention.
The framing of affective regulations must be based on a close study of operating experience.
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3.
NRC will continue to operate and improve, as needed, a Licensee Event Reporting (LER) system. NRC should continue to work with the Institute of Power Operations (INPO) in its operation and development
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of the Nuclear Plant Reliability Data System (NPRDS). NRC she'uld continue to support INP0 in the operation of an industry-wide screening service to identify LERs and other operating experiences
. of significance to nuclear power plant licensees.
4.
The NRC must develop a long range human facters program plan by mid 1982.
INPO and the NRC both have programs for developing standards and requirements in the human factors area. These programs should be coordinated.
In some areas it nay be sensible to conduct activities in parallel and in others it may be appropriate to drop the NRC program should INP0's efforts be acceptable.
(a) The NRC should make maximum use of available human factors data.
f (b) Alternative approaches exist for resolving certain human factors concerns, e.g., in the operator licensing area either the NRC or its contractors could administer examinations or individuals in the industry approved by NRC could undertake this activity. Where fundamentally different approaches are possible, the staff should prepare policy papers as soon as practicable for Commission consideration which recommend a course of action.
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' (c) The staff should continue to evaluate and improve the licensing and training requirements for reactor operators. Resource efficient methods should be pursued which will provide improved initial and requalification testing of operators.
5.
Utility management performance needs to be evaluated to assure the quality of operation of nuclear facilities. Utility managers and supervisors as well as operators should be encouraged to improve their ability to promptly diagnose and deal with off-normal conditions. -
6.
As applie'd to operating reactors, the goal of NRC's enforcement program will be to assure compliance with NRC regulations and
' license conditions and to use experience gained from application of the enforcement policy to evaluate and revise the policy and make it more effective. For licensees who do not comply with NRC requirements, prompt and vigorous action will be taken; a licensee must not benefit by violating NRC requirements. Licensees who cannot achieve and maintain an adequate level of protection of public health and l
safety will not be permitted to operate.
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The Commission supports the systematic e' aluation program for operating v
reactors. The program should continue at its current pace. The goals and objectives of the program should be met expeditiously.
8.
The staff should expedite the assessment of pressurized thermal shock, so that the Commission can consider if actions need to be taken to protect the public hea.lth and safety.
NEAR-TERM LICENSING PROBLEMS AND RESPONSES Policy A.
The NRC intends that its regulatory processes be efficient and cost effective. Unnecessary regulatory burdens are to be avoided, and NRC regulations should allow licensees to select the most cost effective ways to satisfy NRC safety objectives. At the same time, pressure 'to issue new licenses will not be allowed to compromise safety.
4 Plannino Guidance 1.
Actions should be taken to eliminate all unwarranted delay in reaching regulatory decisions.
2.
Consistent with maintaining safety of oprating plants, staff I
reviews and public hearings should be completed on a schedule that assures the licensing process will not unnecessarily be a critical l
path item which would delay reactor startup.
Recognizing that the l
l length of hearings may depend on the number of contested issues, i
normally it should take not more than 11 months from issuance of the final supplemental safety evaluation report to an operating license decision by the Commission in contested cases.
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O in order to, reach timely decisions, while preserving individual
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rights of the public to pursue valid safety issues. The Commission I
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reaffirms 'its Statement of Policy on the Conduct of Licensing Proc'aedings of May,1981, which urged Boards to take firm hold of hearings and keep them moving.
4.
Since the President has directed that government agencies proceed with the demonstration of breeder reactor technology, the NRC must be prepared to review the Clinch River Breeder Reactor license application to assure adequate protection of public safety and the environment while, at the same time, striving to avoid having the reg &latory process unnecessarily delay the decision whether to permit the start of c'onstruction activities. The NRC will assist
. consistent with its statutory regulatory responsibilities.
1 5.
NRC will maintain an internal project management structure to versee project reviews on an integrated plant basis, and ensure
'that decisions and commitments made ea ly in the project are not abrogated or forgotten, thereby requiring the same issue to be resolved more than once during a project.
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6.
NRC must continue to work with FE!G to resolve the difficulties in securing the findings for off-site emergency plans for a proposed nuclear plant site in a timely fashion.
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7.
The staff is encouraged to urge applicants to conduct independent design reviews prior to selection of major systems. The purpose should be to get applicants to understand more fully the equipment and systems which are offered by the vendors and architect-engineers, a function which has been assumed largely by the NRC.
8.
For the FY 84-86 time period, staffing proposals should decline consistent with the completion of existing reactor casework.
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4 GETTING CONTROL OF REQUIREMENTS Policy A.
NRC must be sensiti.ve to criticism that there is a large volume of r'equirements imposed on licensees, that frequently these requirements are not coordinated, and that sufficient time is not allowed for proper implementation of issued requirements. Strong measures need to be taken to control the issuance of new requirements.
B.
In cases where there are conflicting priorities in establishing and implementing new requirements, priorities will be based on the expected risk reduction potential associated with the new requirement.
d C.
Requirements imposed on the regulated industry by NRC are to have a positive contribution to safety, not only individually, but also when the requirements are taken as a whole.
Requirements proposed to achieve incremental reductions in residual risk should be evaluated 3
on a cost-benefit basis.
D.
Unresolved Safety Issues should be promptly pursued, and the solutions implemented based on a careful analysis of the costs and benefits of implementation.
Priorities for implementation should be established in light of all other requirements imposed on licensees.
E.
Issues which affect numerous licensees should be addressed in the context of rule-making as opposed to case-by-case review.
s Planning Guidance 1.
In order'to control and coordinate requirements imposed on ifcensees, a Comittee for Review of Generic Requirements (CRGR) has been established to review proposed requirements and recomend action by the EDO. The CRGR, chaired by the Deputy Executive Director for Regional Operations and Generic Requirements (DEDROGR), is expected to assume a powerful role in reviewing and recommending action in
.the full ' range of generic requirements considered by the agency, including backfitting. The EDO, assisted by the OEOROGR, will exert strong management control over operating reactor ifcensing actions in order to redure the existing backlog. Priorities and
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procedures must be developed for eliminating the backlog expeditiously (i.e., by FY 84). Since the scope of the regional offices has been
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expanded to create agency wide regional operations that include licensing as well as inspection and enforcement functions, a significant I
portion of the reactor license amendment reviews should be transferred to the regional offices to assist in cleaning up the large backlog.
2.
All generic issues will be integrated in an agency-wide program.
Issues included in the present program which are not directly related to NRC regulatory requirements will be eliminated.
Emphasis will be placed on implementing approved solutions to generic safety issues which have been resolved. As a first step in resolving generic issues, a priority list based on the potential significance and cost of implementation of each issue will be established.
Those issues which lack significance and are of marginal importance
. i to the regulatory program will be dropped. The revised program will e'stablish criteria for adding new issues.
Issues will be added to the program only after careful evaluation to assure that they warrant resource expenditures.
i 3.
A management system will be developed to account for all new requirements issued, their relationship to the revised Standard Review Plan, and the status of their implementation. The manage-ment system to be developed should be coordinated with the systems currentli in use and should be capable of incorporating existing, ongoing regulatory requirements..
4.
Implementation schedules for new requirements, will be established consistent with the safety importance of the requirement.. Licensees should be allowed sufficient time for in-depth engineering, evaluation I
and design, procurement of high quality equipment, and its proper installation, to the extent compatible with public health and
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In setting schedules, industry capability (e.g., engineering i
resources and manufacturing capacity) to implement the new require-ment will be considered. NRC's ability to review licensees' l
proposals and to inspect implementation will also be censidered.
To the extent consistent with safety implications, schedules for requirements will be set so as to avoid downtime on operating plants or delay in startup of new plants. The staff should work e
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through owners groups to establish realistic schedules. The nuclear
.. industry must be responsible for providing realistic estimates of time needed to achieve compliance. Once compliance dates have been establishec, the Commission will vigorously enforce such dates.
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, IMPROVING THE LICENSING PROCESS Policy A.
The Commission intends to make the present licensing process more efficient. The main elements of the new process will be based on concepts already studied such as one-step licensing, standardization, early site reviews, and changes in hearing formats. Thc Commission intends to consider a legislative package for submittal to the Congress 'and also a set of reforus which can be implemented by the Commission without the need for legislation.
plannine Guidance 1.
A special task force will identify the issues which should be addressed in a legislative proposal as well as the specific changes that should be made internally to facilitate streamlining. A I
senior Advisory Group will assist the Chairman in making specific recomnendations to the Commission as a result of the task force's work. By January,1982 legislative prop'osals will be prepared. By April,1982 recommendations for administrative remedies, together with the necessary paper work to implement them, will be ready.
2.
Staff should plan for increased use of standardization and early siting in connection with one-step licensing starting in FY 84.
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SUPPORTING NEW INITIATIVES Waste Fknagement Poliev A.
Development and demonstration of a high-level waste repository is a task for the Department of Energy, or its successor.
It is important that the issues of the disposition of spent fuel accumulating at reactors and the ultimate disposal of nuclear waste be resolved.
NRC waste management efforts will focus on the development of-p licensing criteria for high level 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 was.te form and packaging with the geological, hydrological, and engineered systems involved.
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Planning Guidance i
i 1.
The Commission will complete the rulemaking on the storage and disposal of nuclear waste (Waste Confidence Proceeding).
2.
The planning basis for waste management activities will be that during FY 82-85, three sites will be characterized for a high level waste repository. NRC should publish a final rule before January, 1983 covering the technical criteria for high-level waste repositories.
The staff should work with the technica1 connunity and the public I
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to develop methods and tests needed to dcaonstrate compliance with the regulations. By mid-FY S4 the flRC will have in place all regulatory guidance and criteria so that the licensing of waste repositories will provide for adequate protection of the public and will not be unnecessarily delayed. A per:nanent repository site I
will be selected and a license application to obtain construction authorization may be submitted to the NRC as early as mid-FY 85.
Duration of the NRC review and hearing process should permit a decision on issuing a construction authorization within three and one half years of receiving the license application from DOE.
3.
published projections of spent fuel storage requirements indicate that, using currently approved technology, existing reactor storage basins can be modifie'd to acco::inodate discharged fuel until about the mid 1980s. Longer-term storage will involve proposed new storage pools and the development of dry storage technologies. A s'
licensing capability for independent spent fuel storage facilities should be in place in FY 82 to permit the NRC to act pro::ptly on applications for new storage facilities. The NRC must be prepared to review industry or government proposals for away-fro:n-reactor or at-reactor independent spent fuel storage facilities. Because of the lead time for design, licensing and construction, at least one application for a new spent f6el storage facility is expected by 1983. Licensing review will also be required for developmental facilities and work involving the storage of spent fuel in dry storage casks.
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TMI-2 Cleanup Policy A.
The content of the containment at THI '2 is a potential safety and health hazard to the public. Expeditious cleanup of' the TMI-2 reactor is one of NRC's highest safety priorities. While direct responsibility for cleanup rests with the licensee, NRC will provide oversight and support to ensure decontamination of the facility as well as safe and timely removal of radioactive products from the site.
B.
-NRC_ should work closely with DOE to reach timely decisions on the disposition of reactor fuel.
Planning Guidance 1.' 'NRC-will continue monitoring site cleanup activities through a dedicated TMI program office. Thrt staff should encourage timely congletion of reactior building water processing and timely start of f
containment decontamination (both by mid FY 82). NRC should urge the licensee to submit plans and schedules in mid-FY 83 for reactor head removal. The NRC staff will review these plans and make
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recommendations to the Comission within three months.
Planning for upper internals removal should begin by the end of FY 83, with a goal of having the upper internals removed during FY 84.
Since the pace of cleanup is dependent upon licensee's funding ability, the licensee's financial condition will be monitored closely by NRC.
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NRC will closely monitor the agreement with DOE which calls for remova'l of high specific activity wastes for research and development, q
including complete removal of the Epicor liners remaining from the processing of auxiliary building water and the submerged demineralizer system liners after completion of water processing. The objective of NRC's monitoring is to help assure that the wastes are expeditiously removed from the site. NRC should work toward the goal of assuring that DOE will assume responsibility for offsite disposition of the damaged core.
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IMPROVING RELATED REGULATORY TOOLS Safe:ty Goal Policy A.
NRC must develop a safety goal with initial emphasis on individual and societal risks which might arise from reactor accidents. The purpose of this project is to develop a general. approach to risk acceptability and safety-cost tradeoffs, and, to the extent possible, to specify quantitative safety goals and standards for review of new rules and practices.
Plannino Guidance 1.
Simultaneously with obtaining public comment on a safety goal, the a
staff should prepare for Commission review a step-by-step action plan describing how it intends to use the goals and numerical guidance within the regulatory process.
2.
Qualitative safety goals and associated quantitative numerical guidance, when approved by the Commission, should be used in the evaluation of proposed and existing NRC reactor safety requirements.
. Risk Assessment Policy A.
P'robabilistic risk assessment is an important tool for weighing risks against one another and for defining achieved safety levels.
Quantitative risk assessment techniques will be used to estimate the relative importance of potential nuclear power plant accident i
sequences.
Planning Guidance 1.
Special attention should be given to using probabilistic assessment techniques in areas especially amenable to risk assessment, e.g.,
in licen31ng reviews as appropriate, dealing with generic safety issues, formulating new regulatory requirements, assessing and I
revalidating or eliminating existing regulatory requirements, evaluating new designs, and formulating reactor safety research and inspection priorities.
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Siting Policy fo'licy A.
Siting criteria for nuclear power plants and other major r. clear facilities need imp' ovement. The staff has been working to prepare
' in the very near term modified regulations concerning the siting of nuclear power plants. The Comission now believes that preparation of a safety goal and a better characterization of the radioactive source term must precede new siting regulations.
Further, siting regulatics should take account of engineered safety features curren'tly in use, tuch as containment and emergency core cooling systems.
Planning Guidance 1.
The radioactive source term should be reassessed by early 1983.
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Based on the safety goal and the formulation of a new radioactive i
source term, a proposed siting rule should be published by late f
1983.
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Quality Assurance i
Policv The NRC and the industry must strengthen their Quality Assurance programs with specific attention to their implementation. The NRC must encourage 4
the industry to be more aggressive in assuring the adequacy of design, construction, and operation. Quality Assurance programs for plants under construction and awaiting licensing review must receive priority attention to ensure that the plants can be operated with minimum risk to
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the public hea.ith and safety and that costly licensing delays are avoided.
planning Guidance 1.
' The NRC staff will review its Quality Assurance efforts and propose an agency-wide plan by early 1982.
2.
NRC will develop a program for the systematic review of its Quality Assurance requirements and licensing guidelines.
3.
NRC will coordinate with industry to the maximum extent possible in i
seeking solutions to the Quality Assurance problems currently plaguing plants under design and construction.
Steps should be taken to see that industry has certified independent performance audits of their QA activities.
4.
The NRC staff will develop improved inspection and licensing initiatives to ensure the increased effectiveness of utility management control systems. This may include obtaining contracted assistance to evaluate the effectiveness of utility management control systems at selected plants presently under construction.
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Research policy A.
The research program will continue to emphasize support of the safety of operating reactors and other operating facilities. The
. purpose of the research program is to assist in establishing regulations for existing and future facilities.
Plannino Guidance 1.
In -view of general budgetary considerations, the agency must be prepared to carry out its research mission with fewer resources.
This can be accomplished through more business-like methods.
consolidation and coordination of programs with industry and other agencies, and the elimination of marginal programs.
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The first priority for NRC research efforts will be light water i
l reactor safety.
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Resource requests to support fast breeder reactor application in the FY 84-85 budget should be consistent with Administration plans.
l The staff should identify its research and information needs related to:
the licensing of breeder reactors, waste, and reprocessing l
facilities; notify the Department of Energy of these requirements; and to the maximum extent possible, have DOE provide the needed research and information.
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NRC will develop and maintain a long-range research plan to assure that agency resources are being properly directed toward areas of importance to the licensing and inspection processes.- The research plan will be revised and updated annually and subjected to agency-wide review and be approved by the Comission.
Research undertaken by the staff will be consistent with the approved long-range research plan.
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OTHER POLICIES International Activities Policy A.
With respect to its international responsibilities, the NRC re-cognizes that the proliferation of nuclear explosive devices poses a threat to the security interests of the United States. Hence, the NRC will continue to discharge its statutory licensing responsibilities l
to ensure that effective controls are applied to the import and export of nuclear materials, equipment, and facilities; the NRC will also seek to support the reliab'ility of the U.S. in meeting' its supply commitments to nations which adhere to effective nonproliferation policies by implementing procedures that facilitate the timely processing of export licenses. NRC supports the Presidents commit-
' ment to work with other nations to help the IAEA improve the international safeguards regime.
Planning Guidance 1.
Reviews and assessments relating to the applications of IAEA safe-guards as mandated in the Nuclear Non-Proliferation Act of 1978 will be conducted in order to suggest improvements in these safeguards.
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