ML20087D897
| ML20087D897 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1984 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| NUREG-0885, NUREG-0885-I03, NUREG-885, NUREG-885-I3, NUDOCS 8403150211 | |
| Download: ML20087D897 (23) | |
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NUCLEAR REGULATORY COMMISSION ANNOUNCEfAENT NO. 4 DATE:
January 12, 1984 TO:
ALL NRC EMPLOYEES
SUBJECT:
1984 POLICY AND PLANNING GUIDANCE l
s Attached is your personal copy of the Commission's 1984 Policy and Planning Guidance (PPG).
NRC's greatest resource is its employees.
A primary purpose of the PPG is to state clearly the major policies and planning objectives of the Commission so that all employees will know where the Agency is headed.
I hope you will read it carefully.
Let me again express my appreciation for your efforts in achieving NRC's mission to protect public health and safety.
./h Nunzio J.
Palladino Chairman
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I U S. Nuclear Regulatory Commission l
Policy and Planning Guidance 1984 U.S. Nuclear Regulatory Commission Y
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Available from GP0 Sales Program Division of Technical Information and Document Control U.S. Nuclear Regulatory Commission Washington, DC 20555 Printed copy price: $3.00 and I
National Technical Information Service Springfield, VA 22161 j
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NUREG-0885 issue 3 U.S. Nuclear Regulatory Commission i
Policy and Planning Guidance 1984 Manuscript Completed: January 1984 Date Puolished: January 1984 I
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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l POLICY AND PLANNING GUIDANCE TABLE OF CONTENTS Subject Page 1
I.
INTRODUCTION............................................
II. ASSURING THE SAFE OPERATION OF LICENSED FACILITIES.......
3-III. RAISING THE QUALITY OF NUCLEAR PLANTS....................
5 IV.
IMPROVING REGULATION OF THE NUCLEAR IND~rv............
6 A. New Requirements.....................................
6 B. L i cen s i n g R ef o rms....................................
8 C. Standardization......................................
9 D. Decentralization.....................................
9 E. Investigations.................
2....................
10 F. Enforcement..........................................
11 G. Timely Licensing of Facilities.......................
12 H. Transportation.......................................
12 V.
PROTECTING NUCLEAR MATERIAL AND FACILITIES..............
13 A. Domestic Safeguards..................................
13 B. Interna tional Sa fegua rds.............................
14 VI.
CLEANING UP TMI.2.......................................
14 VII. MANAGING NUCLEAR WASTE..................................
15 VIII. SHARPENING RELATED REGULATORY TOOLS.....................
16 A. Safety Goals.........................................
16
- 8. Severe Accidents.....................................
17 C. Risk Assessment......................................
17 D. Radioactive Source Terms and Siting Policy...........
18 i
E. Research.............................................
-19 O
i POLICY AND PLANNING GUIDANCE i
I.
INTRODUCTION Purpose l
The purposes of the Policy and Planning Guidance document are as fol-lows:
to state, clearly and succinctly, the major policies and planning objectives of the Commission so that all employees will know where the Agency is headed; I
to provide a comon basis within NRC for the davelopment of pro-grams, the establishment of priorities, and the allocation of resources; to furnish guidance that can be used to develop Agency budget -
requests; and to help fulfill the requirement that NRC's annuul report to the President for submission to Congress contain a clear statement of the short-range and long-range goals, priorities, and plans of the Commission as they relate to the benefits, costs, and risks of commercial nuclear power.
The Comission believes that the publication, distribution, and careful review of this document will lead to a better focusing of individual and collective efforts within the agency. In this way it is hoped that the regulatory process will be more effective and efficient in fulfilling NRC's mission to protect the public.
Background
For this year the document has been reorganized somewhat to take into account the progress that has been made in several major areas in the past two years and to reflect the changing environment in which the agency must perform its regulatory job. Some structural changes have been made within the agency and its way of doing business. The issuance of regulatory requirements has been put under tighter control to foster promulgation of cost-effective requirements and prevent the issuance of unjustified or counterproductive demands on licensees.
Selected NRC operations have been decentralized in the belief that there would be advantages to bringing regult, tory functions as close as practicable to the people and f acilities afncted by them.
In addition, an Office of Investigations was established in order to improve NRC's capability to perform thorough, timely and objective investigation of alleged I
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2 violations of regulations or other improper actions with safety implica-tiens by licensees or their agents.
Other policy Scals have been or are in the process of being achieved.
The Commission has submitted proposed legislation to the Congress which, if enacted, would involve three closely-related concepts: the use of standardized power plants with designs that would be valid for many years ir the future; the availability of preselected plant sites ap-pro" '.n advance of specific applications; and the authority to issue a combined construction pennit and operating license so that as many issues as possible can be resolved early in the licensing process.
Ir March 1,983, the Comission issued a Policy Statement on Safety Goals for the Operation of Nuclear Power Plants. The Policy Stattment contains preliminary safety goals and preliminary numerical design objectives that are intended to be consistent with the goals.
The document is organized into seven themes: Assuring the Safe Operation of Licensed Facilities; Raising the Quality of Nuclear Plants; Improvirg Regulation of the Nuclear Industry; Protecting Nuclear Material and Facilities; Cleaning Up TMI-2; Managing Nuclear Waste; and Sharpening Related Regulatory Tools.
For each theme there is a policy section which establishes a general framework for shaping NRC plans and programs.
Planning guidance is furnished in those areas where the Commission believes more detail is warranted to meet specific priorities or schedules or where major assumptions are needed for program development. 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, the Commission believes that the majority of NRC activities should fall within one or more of the Policy and Planning Guidance themes.
General Administrative Direction The Executive Director for Operations will develop specific program guidance to implement this policy and planning guidance. The ED0 will l
also maintain a management system for the Commission to track major program accomplishments that support the policy and planning guidance.
The ED0 should assure that agency resources are appropriately balanced l
l to carry out the guidance in this document.
To carry out the policies of the Comission, the dedicated effort of all employees and the effective and efficient use of all other NRC resources is essential. Managers should recognize that NRC's greatest resource is its employees. The commission's most creathe and productive employees should be recognized and provided opportunity fcr development.
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Coordination of programs and the elimination of marginal programs should be considered in making the optimal use of limited resources.
It is the Commission's intention that nuclear regulation reflect a continuing commitment 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 commitment 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 this process, the Commission must state its basic assumptions and criteria clearly, amend them when the facts so require and live by them consis-
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tently and forthrightly in all activities, i
The consolidation of NRC's operations in either a single building or several buildings closely co-located as soon as possible continues to be an important goal for the Commission. The urgency of this need has been documented by every study that has addressed the NRC and its operation in the last several years. NRC will cooperate to the fullest with the General Services Administration on defining options to achieve the consolidation objective. The staff will develop options to consider locations in both downtown ~and suburban areas to achieve an interim consolidation at an early date.
II. ASSURING THE SAFE OPERATION OF LICENSED FACILITIES Policy 1.
NRC's fundamental task is to make sure that existing nuclear facilities and those coming on-line operate safely. Consequently, the highest priority will be given to assuring that operating facilities maintain adequate levels of protection of health and safety.
4 2.
The staff should carry out NRC regulatory activities in a way that recognizes that licensees and vendors have the primary responsibil-ity for the safe design, construction, and operation of nuclear facilities.
3.
The NRC and the industry must continue to learn the lessons that i
only experience can teach. Accordingly, a high priority should be given to the development of commercial reactor operating expertise I
within the agency through training, hiring, and promotional prac-tices and communication with the industry.
Changes to the NPC's regulatory basis must be supported by close study of operating experiences.
4 4.
The Commission continues to believe in containment integrity and emergency planning as essential parts of the defense-in-depth philosophy.
Emergency planning should be based on realistic assumptions regarding severe accidents.
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.Planr no Guidance i
1.
NRC on-site.aspection of operating reactors should continue to focus on the operations of licensees, including maintenance activ-ities. The analysis of operational data and systematic assessment of licensee performance will be used to help focus NRC activities, to allocate agency resources, and to access the licensee's manage-ment of its plant. Priority attention will be given to licensees with poor performance histories.
2.
Efforts to collect, analyze, disseminate, and act upon operational data must continue to receive priority attention without hindering plant operation. AE0D should meet with the Commission as necessary (at least semi-annually) to report on any serious safety concerns.
Recommendations for resolving these concerns should also be pre-sented together with a report on the status of implementation.
3.
The staff should continue the efforts approved in the NRC Humai.
Factors Plan (hUREG-0985). Effective use should be made of avail-able human factors data. The staff should develop by April 1984 for Commission review a human factors program plan element which proposes alternative NRC regulatory approaches with respect to maintenance activities.
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4.
Prior to implementation the staff should submit for approval of the Commission a proposal describing the need for and nature of the Integrated Safety Assessment Program.
5.
The staff should investigate the need for and benefits of General Operating Criteria for nuclear power plants and submit the results for Commission consideration by the end of FY 1984.
In this effort, consideration should be given to INP0 activities on this subject.
6.
In reviewing new.and operating facilities, the staff should care-fully consider the need for some reactor operators with commercial experience at every plant.
In addition, it should carefully censider the competence and experience of the management and staff of that facility. The staff should also consider the need for, and benefits of, additional requirements for assuring an adequate level of experience and competence in licensee management.
5 7.
The Commission will consider alternative regulatory concepts which recognize the contributions of industry self-policing programs to the extent that such programs are effective and consistent with NRC regulatory responsibilities.
8.
Since many decisions of the Commission are based on the judgment that something is or is not "important to safety", the staff shoi.a develop criteria which could be used to determine, on a plant specific basis, what is important to safety. In developing these a
criteria, the staff should explore the problems associated with application of the criteria. The scope and schedule for developing such criteria shculd be provided to the Commission by February, 1984 9.
Inspection activities should focus more attention on maintenance and surveillance activities in plant operations, including preven-tive maintenance.
III. RAISING THE QUALITY OF NUCLEAR PLANTS Policy 1.
The NRC must improve its activities that affect quality in the nuclear industry.
NRC's goal is to assure a high level of quality in management of reactor design, construction, operations, and maintenance.
2.
For both construction activities and operating facilities the NRC needs to understand the causal factors leading to problems and to develop a modified institutional and legislative framework for future nuclear plants which will decrease the probability of repetitien of past mistakes.
The theme of "do it right the first time" should be adopted to ensure plants are built properly and can operate safely.
3.
In order to reduce operational problems including maintenarce and modification activities, the NRC needs to pursue more aggressively efforts (1) to assure utilities provide the appropriate management framework and capability for safe operation and maintenance of nuclear power plants; (2) to improve quality in utility operations and in procedures, systems, and components used in operations; and (3) to develop better guidance for the treatment of plant systems, components, and equipment that can adversely affect safe operation.
4.
NRC should highlight the necessity for highly trained and qualified professionals for licensees, contractors and vendors to manage those functions that relate to safety.
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Planning Guidance 1.
NRC's quality assurance (QA) program should include continued integration of the QA licensing, inspection, standards, and re-search functions into a comprehensive and cohesive agency program which provides cleer direction on QA matters to the NRC regions and to the industry. NRC should develop a Quality Assurance program which identifies overall program goals and objectives and provides task oriented framework for program implementation.
2.
NRC will complete the Congressionally-mandated study of existing and alternative programs for improving quality assurance and quality centrol in the construction of commercial nuclear power plants. The study should provide the lessons learned from past quality problems in design and construction and approaches to prevent recurrence.
i 3.
NRC should begin implementation of the improvements identified as a result of the Congressional study and continue development of related regulatory actions. NRC should al.o initiate drafting any legislative proposals resulting from the study.
4.
Lessons learned from the study of design and construction problems should be examined for applicability to known or potential problems in operations and maintenance.
5.
Coordination between NRC and INP0 should continue in areas of assessing the design, construction, and operation of nuclear facilities.
Exchange of information in order to identify early warning signals and corrective measures should be encouraged in order to prevent major problems.
6.
New empnasis cheuld be placed on vendor inspection.
The staff should report to the Commission any new significant deficiencies discovered after implementation of the upgraded program.
IV.
IMPROVING REGUL ATION OF THE NUCLEAR INDUSTRY A.
NEW REQUIREMENTS i
Policy l
1.
NRC must be sensitive to the fact that there is a large volume of
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requirements imposed on licensees.
Effective measures must 1
7 continue to be taken to provide for the issuance of necess ~ new requirements in a timely manner.
2.
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 i
to achieve incremental reductions in risk should be evaluated on a cost-benefit basis, insofar as practicable. Unnecessary regulatory burdens are to be avoided, and NRC regulations should allow indivi-dual licensees the flexibility to select the most cost-effective ways to satisfy NRC safety objectives particularly for plant specific requirements with due consideration of item 3.
3.
Issues which affect numerous licensees should be addressed in the context of rule-making as opposed to case-by-case review to the extent practicable and insofar as practical, an effort should be made to avoid building in more differences among plants than already exist. The safety advantages of uniform solutions which permit greater standardization of hardware, procedures and training should be taken into account.
4.
Unresolved safety issues should be promptly pursued, and the solutions should be based on a careful analysis of the costs and benefits of implementation. Priorities for implementation should be established in light of the safety significance of the issue and all other requirements inposed on the licensee.
5.
In cases where there are conflicting priorities in establishing and implementing new requirements, priorities will be based on the expected safety-benefit potential and costs associated with the new requirement.
Planning Guidance 1.
With the goal of enhancing the levels of protection of public health and safety, the Comittee for Review of Generic Requirements (CRGR) should continue to review and make recomendations to the ED0 on proposed generic requirements for reactor licensees. The CRGR should continue to assure that proposed requirements (a) contribute significantly to the health and safety of the public, and (b) provide for the utilization of both NRC and licensee resources in a manner which effectively and efficiently achieves protection of the public health and safety.
2.
.The staff should implement the recommendations in SECY-83-321 to manage the plant-specific backfittinc of operating reactors. After one year of experience gained from the application of these
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procedures, the staff should provide the Commission with an eval-uation of the results of managing plant-specific backfit require-4 ments.
3.
Existing regulatory requirements that have a marginal importance to safety should be eliminated.
4.
An integrated implementation schedule for new and existing require-ments reflecting relative priorities should be established for each power reactor licensee. The results of cost-benefit analysis should be used where practical and where the degree of understanding and data permit as one tool for evaluating new requirements. Cost estimates for these requirements must be reasonably accurate.
The schedules should reflect the importance of the safety requirement to the public health and safety and consider the licensee's ability to complete the necessary engineering, evaluation and design. Once compliance dates have been established, the Commission will vigorously enforce license conditions associated with such schedules.
s 5.
By the end of FY 1985, the staff will issue for public comment draft technical resolutions for all currently identified unresolved safety issues.
6.
The staff should continue to assess the priorities for generic safety issues and control the addition of new generic safety issues i
in accordance with SECY-83-221, 7.
Cost estimates for regulatory actions must be reasonably accurate.
Where costs estimates are provided by industry, they should La independently and carefully evaluated for accuracy.
8.
Detailed guidance on performing cost-benefit analyses must be developed and used.
Revisions of the current cost-benefit manual should be submitted to,and approved by, the Commission, 9.
On major issues presented to the Commission by the staff, the rationale for accepting or rejecting principal alternatives should be described.
B.
LICENSING REFORMS Policy 1.
The Commission achieved through consensus an agreement on licensing reform legislation and forwarded that legislation to Congress in February 1983. The Congress is new considering the legislative package. Administrative reforms proposed by the Regulatory Reform i
a
9 Task Force (RRTF) include revision to the backfit rule, revising the role of the staff as a party and ex parte communications, and a number of revisions to the administrative hearing process. These reforms should receive high priority and will require additional consideration before implementation.
Planning Guidance 1.
The Commission will monitor the effectiveness of reforms as they are implemented by the staff. The Commission expects to complete its first round of deliberations with respect to the remaining administrative reform by March 1984 C.
STANDARDIZATION P.ol[cy 1.
The NRC recognizes that there are advantages to the development and use of standardized nuclear power plant designs. Such designs can benefit public health and safety by concentrating the resources of designers, engineers and vendors on particular approaches, by stimulating standardized programs of construction practice and quality assurance, by improving the training of personnel and by fostering more effective maintenance and improved operations. The use of such designs can also permit more effective and efficient licensing and inspection processes.
Planning Guidance 1.
NRC should continue to review standard plant design applications and maintain the necessary licensing capability.
D.
DECENTRALIZATION Policy 1.
The staff should continue to implement the policy goals approved by the Commission in October, 1981.
Planning Guidance
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1.
The staff should continue to discuss the nature and extent of decentralization with licensees in order to promote better informa-tion flow and improve regulatory interaction.
The Commission's March 25, 1983 Policy Statement on Regionalization i
should be revised to reflect Commission action on the staff's
10 proposal for a pilot program for decentralizir.g licensing activ-ities of operating power reactors and any Commission action or legislative direction.
Headquarters offices are responsible for assuring that NRC programs 3.
are applied consistently in each region in conformance with Commis-Assessments of the implementation of the regional sion policies.
inspection and licensing programs should be performed to determine the effectiveness of the program.
I E.
INVESTIGATIONS Policy 1.
The Office of Investigations shall investigate significant alle-gations o' wrongdoir.g by other than NRC employees and contractors as requested by the Commission, EDO, Regional Administrators, or on their own initiative.
Investigations should be thorough and should try to identify the root causes and reasons for violations.
2.
Investigations shall be conducted when regulatory violations appear to be deliberate. When initial collection of evidence indicates that the matter involves criminality, appropriate referrals will be made to the Department of Justice.
Planning Guidance 1.
The Office of Investigations, in coordination with the EDO, should develop criteria tc determine the threshold for initiating an investigation in order to better establish priorities of investiga-tions to pursue based on their impact on public health and safety.
1 2.
The EDO should provide technical support in the conduct of inves-tigations.
3.
Investigations should be performed in a timely manner and findings and conclusions provided to other Offices. Findings of potential safety significance should be immediately referred to the cognizant i
office.
4.
Close coordination should be established between the Offices of Investigation, Inspectior. and Enforcement, Nuclear Reactor Regu-lation, Nuclear Material Safety and. Safeguards, and the Regional Of fices to assure the results of investigations are followed by appropriate action.
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11 F.
NRC should maintain an effective enforcenent program with uniform application of enforcement policy throughout the regional offices.
The enforcement program should be firm but fair.
The goals of NRC's enforcement program will be to assure compliance with NRC safety and safeguards requirements.
2.
NRC e
). arent activities must be directed to assure that licensee correctise ac tions for performance deficiencies are appropriate and that future compliance with requirements is encouraged.
For licensees that dc not comply, prompt and vigorous action will be taken. A licensee must not benefit by violating NRC regulations.
Licensees whc cannot achieve and maintain an adequate level of protection of the public health and safety will not be permitted to operate.
3.
Inspections on which enforcement activitics are based should be thorough and should seek to identify the basic reasons why vio-lations and deficiencies occurred.
4 Enforcement actions should encourage an aggressive safety approach by licensees and credit should be given for prompt reporting of deficiencies by licensees and for prompt, thorough, and whole-hearted corrective actions.
Planning Guidance 1.
The staff should initiate a study to evaluate present enforcement practices in the nuclear power industry along with an appraisal of alternative enforcement programs to ascertain their impact on nuclear plant safety and in motivating management and operating personnel engaged in nuclear plant operations to strive for higher standards of safety. The staff should examine various enforcement options by which greater attention can be directed toward the performance of licensed operators. Enforcement policies in other government agencies should be considered in this study.
2.
The staff should expedite enforcement actions to achieve a goal of issuance of proposed civil penalty actions within eight weeks after completion of the inspection or investigation.
3.
Experience gained from application of enforcement policy shculd be used to evaluate that policy. An evaluation report shall be l
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12 provided to the Commission during the first quarter of each fiscal year.
G.
TIMELY LICENSING 0F FACILITIES Policy 1.
The NRC intends that its regulatory processes be efficient and cost effective. Actions should continue to be taken to eliminate unwar-ranted delay in reaching decisions consistent with not compromising safety. The Commission reaffirms its statement of policy on the conduct of licensing proceeding of May 1981, which urged licensing boards to take actions needed to assure the efficient conduct of hearings.
Plannin,1 uidance G
1.
Consistent with maintaining the safety of operating facilities, staff reviews and public hearings should be completed on a schedule that assures the licensing process will not be a critical path item which could unnecessarily delay reactor startup.
2.
NRC must continue to work with FEMA to resolve difficulties in securing the findings for off-site emergency plans for nuclear power plant sites in a timely fashion.
i H.
TRANSPORTATION Policy 1.
The Commission considers the regulation of the transportation of nuclear and radioactive materials to be an important ongoing element of its responsibilities.
Planning Guidance 1.
The staff should assere that NRC responsibilities in regulating the transportation of nuclear and radicactive materials are clearly i
enunciated and should coordinate with other Federal agencies to l
achieve an integrated Federal program for protecting the public health and safety of the environment.
1
13 V.
PR01ECTING NUCLEAR MATERIAL AND FACILITIES 4
A.
DOMESTIC SAFEGUARDS a
Policy e
1.
Safeguards are an integral and ongoing element of the Commission's responsibility. Safeguards regulation should be conducted with the e
l same defense-in-depth philosophy as safety regulation and should assure that each licensee establishes and maintains an adequate system of safeguards to protect licensed facilities, special nuclear materials, and related activities. The system must be designed to protect against acts of sabotage as defined in 10 CFR I
Part 73 and to prevent the theft of special nuclear material.
2.
Emphasis should be given to performance requirements rather than prescriptive requirements to allow licensees to select the most j
cost-effective ways to satisfy NRC requirements.
3.
Implementation of safeguards requirements shall not be contrary to the safe operation of a facility. Safety impacts of all new safeguards requirements shall be evaluated.
Planning Gu_idance 1.
Evaluation of safeguards events will serve as a basis for regulato-ry change and response. This evaluation should include domestic events -- within both the defense and the regulated community --
and foreign events. However, the staff should not wait for signifi-cant events to occur before undertaking safeguards changes _that are considered ne~cessary. The staff shall not engage in any intelli-j gence activities but rely on the intelligence community for infor-mation.
2.
Staff, in addition to assuring that safeguard plans are in place at operating facilities and for transportation, will continue its independent assessment that these implemented plans meet safeguards objectives and that safeguards regulations adequately support those objectives. An annual report shall be provided to the Conmission detailing the results of the previous year's assessments. The report shall contain recommendations for continuing or discontinu-ing the assessment.
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B. INTERNATIONAL SAFEGUARDS l
Policy 1.
The proliferation of nuclear explosive devices poses a threat to the security interests of the United States. Hence, the NRC will carefully discharge its statutory licensing responsibilities to ensure that effective controls are applied to the import and export of nuclear materials, eouipment, and facilities.
s 1
Planning Guidance 1.
The NRC should continue to facilitate the timely processing of export license applications to nations which adhere to effective non-proliferation policies. The NRC will also continue to meet its commitments for the implementation of IAEA safeguards at U.S.
licensed facilities and to work with the Execu'.ive Branch as the U.S. pursues improvements in international safi: guards.
2.
The staff should continue to pursue obtaining timely, accurate and complete information from the Executive Branch regarding exports so that the Commission can carry out its international responsibili-ties.
3.
NRC will pursue efforts to convert foreign and domestic research reactors away from highly enriched uranium fuel as stated in the Commission's Policy statement of August, 1982. These efforts should recognize the legitimate needs of the research community.
VI. CLEANING UP TMI-2 Policy 1.
The radioactive materials at TMI-2 remain a potential health and safety hazard to the public and workers.
Expeditious and safe cleanup of the TMI-2 reactor is one of NRC's highest safety pri-orities.
While direct responsibility for cleanup rests with the licensee, NRC will provide oversight and, if necessary, direction to ensure prompt decontamination of the facility as well as safe and timely removal of radioactive products from the site.
2.
NRC should work closely with DOE to obtain technical information on severe accidents that may be available from the TMI-2 core.
b 15 Planning Guidance 1.
NRC will continue monitoring site cleanup activities through a dedicated TMI program office.
4 2.
NRC shculd closely monitor its agreement with DOE which relates to the removal and disposition of solid nuclear wastes from the clear up of TMI-2. The objective of NRC's monitoring is to help assure that the wastes are safely and expeditiously removed from
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the site. NRC should also assist DOE in development of plans for
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the safe and timely offsite disposition of the damaged core.
VII. MANAGING NUCLEAR WASTE Policv 1.
The HRC waste managen.ent program is critical to the success of an urgent national task. NRC will provide the necessary licensing and regulatory oversight for the Executive Branch's program as required by the Nuclear Waste Policy Act of 1982 (NWPA) or otherwise ap-proved by Congress. NRC's programs will be based on the premise that, in the absence of unresolved safety concerns, the NRC regu-latory program will r.ct delay implementation of the Executive Branch's program.
2.
The staff should continue to maintain close communications with DOE, the states and affected Indian tribes so that required activ-ities and lead times are identified early in the planning process.
As part of this activity the staff should be prepared to accommo-date state and Indian tribe participation in NRC high level waste activities.
3.
To the extent possible, and consistent with NRC's independent role, research required to support programs to implement the NWPA should be performed by CCE. NRC will continue its technical program to support the development of licensing criteria and the early identification of technical issues.
I 4
The NRC will monitor the activities associated with the Low Level Radicactive Paste Policy Act and provide advice as necessary to the Congress and technical assistance to the States as necessary.
Planning Guidan,ce 1.
The staff should develop a memorandum of understanding with DOE to cover the NRC's interactions with DOE in implementing the pro-l visions of the NWPA.
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16 2.
The staff should review the existing and proposed regulations that are covered by areas addressed by the NWPA, and make conforming changes as necessary. When EPA standards are published, regulations should be reviewed to determine whether any changes are required.
3.
The NWPA has established that nuclear utilities have the primary responsibility for interim storage of spent fuel, pending reposito-ry operation or availability of monitored retrievable storage. The NRC should review in a timely manner utility proposals for adding spent fuel storage capacity to assure that, in the absence of unresolved safety concerns, regulatory delays do not affect reactor L
operation. NRC must also be prepared to conduct licensing reviews specified by the NWPA for limited federal interim storage capacity of spent fuel which may be proposed by D0E. The NRC should continue to develop the basis for rulemaking that would to the extent practicable enable use of dry spent fuel storage casks without site-specific licensing reviews.
4.
The staff shall report to the Commission on the changes required in our regulations to implement the EPA mill tailing standards with the objective of meeting the statutory deadline for promulgating NRC conforming regulations. The report should include a discussion of other changes the staff believes are needed to the regulations.
VIII. SHARPENING RELATED REGULATORY TOOLS A.
SAFETY G0ALS Pol icy 4
1.
The Commission has developed preliminary safety goals and related safety guidance with emphasis on individual and societal risks which might arise from reactor accidents in order to have a general approach to the question of "how safe is safe enough?" A two-year evaluation period of the proposed safety goals began in 1983.
2.
The preliminary safety goals and quantitative design objecticas will not be used as the basis for making regulatory decisions l
during the two year trial period.
Planning Guidance 1.
The staff will provide the Commission with periodic progress reports on the safety goal Evaluation Plan.
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v 17 2.
Applicants and licensee will not be required to perform probabilis-tic risk assessment for safety goal purposes during the evaluation period.
B.
SEVERE ACCIDENTS e
Policy 1.
The Commission suppo'rts continued development of a severe accident policy. In order to bring about regulatory stability and timely application of severe accident research activities, the Commission supports early resolution of outstanding technical issues. Further, the Commission supports initiation of any necessary specific rulemaking proceedings or other regulatory changes to address severe accident considerations. This activity is to be directed to operating reactors as well as future standard plants.
Planning Guidance 1.
The Commission should pursue the severe accident activities in close cooperation with similar industry activities such as the IDCOR program and similar foreign activities such as those in France and Germany.
2.
An important and highly visible element in the NRC activities should be uncertainty analysis. Any conclusions drawn should reflect the impact cf uncertainties.
3.
Coordination between the ASTOP office developing the source terms, the PRA technology development effort and the safety goal study is imperative to ensure a consistent and rational resolution of severe accident issues.
4.
The staff should make the clostre of technical issues for severe accidents a high priority effort during 1984.
E.
The Commission should complete and adopt a Policy Paper on Severe Accidents by July 1, 1984.
C.
RISK ASSESSMENT 4
Policy 1.
Where data permit probabilistic risk assessment is a useful tool i
l for assessing the reliability of safety systems and for weighing risks against one another.
Quantitative risk assessment techniques
,m-
v 18 will be used judiciously by the staff and the boards, to estimate relative risks.
2.
The use of probabilistic risk assessment (PRA) methodology in regulatory decision-making must take into account the limitations of PRA. Consideration will be given to the uncertpinties associ-ated with the existing probabilistic risk assessment techniques whenever used in regulatory decisions.
Planning Guidance 1.
Special attention should be given to using probabilistic assessment techniques in the evaluation period for safety goals, as directed by the Commission, and in other regulatory applications especially amenat!O to risk assessment, e.g., in dealing with generic safety issues, formulating new regulatory requirements, assessing and revalidating or eliminating existing regulatory requirements, evaluating new designs, and setting reactor research and inspection priorities.
2.
Unen probabilistic risk assessment is used, there must be clear statements of the assumptions and models used in the analysis with a clear identification of the most significant assumptions and a systematic evaluation of the uncertainties.
If this cannot be done in a particular case, then the PRA results should not be used in l
the decision-making process.
3.
A report on the " state-of-the-art" of PRA methodology will be prepared in early 1984.
4.
Special attention should be given to fostering the improvement of a coherent data base for use in risk assessments, s
D.
RADI0 ACTIVE SOURCE TERMS AND SITING POLICY Policy 2
1.
The Commission has decided to better define its safety objectives and better characterize radioactive source terms before proceeding with new siting regulations. Changes to current regulatory policies will be considered if the reassessment of the radioactive source terms so warrants.
Planning Guidance 1.
The radioactive source terms should be better characterized by a systematic analysis of the release and transport of radioactivity.
y v
J 19 A draft reassessment of radioactive source terms should be devel-oped by December 1984 for selected regulatory analysis.
2.
Based on new radioactive source terms and after completion of the two year evaluation of the safety goals, the need for a revised 8
siting rule should be evaluated.
Effects on other existing and proposed regulations (e.g., emergency preparedness) should also be evaluated when the new source terms have been validated through an f
effective peer review process.
E.
RESEARCH Policy 1.
The purpose of the research program is to provide the technical basis for rulemaking and regulatory decisions; to support licensing and inspectior, activities; to assess the feasibility and effective-ness of safety improvements; and to increase our understanding of phenomena for which analytical methods are needed in regulatory activities.
2.
There should be continued emphasis on using research results in the regulatory process and on obtaining results that are useful there-in. Staff should not engage in research merely to postpone tackling difficult regulatory issues.
3.
The highest priority for NRC research efforts will be light water reactor safety. Staff should be prepared to evaluate and explore the inherent safety characteristics of new reactor types.
4.
The severe accident research program must be supportive of the Conunission's decisionmaking process on severe accidents.
Planning Guidance 1.
The research resources identified in NRC's budget should be al-located to support a balanced program between research to reinforce or revise the current regulatory base and conceptual research for improved reactor safety. The staff should be alert to research which shows that we ought to change our regulations. NRC regu-lations shoalo be changed when research shows them to be either too stringent or not stringent enough.
o l
2.
Advanced reactor concepts shall be pursued consistent with programs adopted by the Executive Branch, the Congress or a focused private l
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v 20 sector effort alone or in combination with the government.
Special emphasis should be given to the HTGR.
3.
tiRC will continue to maintain a long-range research plan which is consistent with the agency's mandate and 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. Resear.ch undertaken by the staff will be consistent with the long-range research plan.
j 4.
The staff should continue to provide to the Commission an annual report which lists regulations.likely ot'o be substantively modified or substantiated by the research programs. Target dates for review of these regulations and the completion.of changes.:to them should be specified. The particular research programs that relate to each
~
of these regulations should be identified.
Any remaining research programs should be listed along with a brief explanation of their Resources allocated to the latter category should also be purpose.
provided.
5.
Joint or coordinated research programs with industry groups, other government agencies and foreign g'roups should be pursued when possible~, both.to expand the technical breadth provided.to projects and to maximize the benefit to be derived from limited resources.
Due consideration should be given to questions of conflict of-interest when contemplating joint or coordinated research with indust ry.
6.
The staff will: (1) conduct annual assessments, with input from appropriate user offices, of the progress and usefulness of speci-fic research topics; (2) consider the marginal utility (of addition-al research given the licensing status of plants; -and J)make
~
l greater use of Research Review Groups.,
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