ML20112C552
| ML20112C552 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| NUREG-0885, NUREG-0885-I04, NUREG-885, NUREG-885-I4, NUDOCS 8503220005 | |
| Download: ML20112C552 (25) | |
Text
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NUREG-0885 issue 4 U.S. Nuclear Regulatory Commission Policy and Planning Guidance 1985 ateYu shed e ry 1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 p." s,,
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TABLE OF CONTENTS SUBJECT PAGE I.
INTRODUCTION 1
Purpose 1
Background
1 General Administrative Direction............
2 II. REGULATORY PHILOSOPHY 2
Supporting Principles 3
Special Regulatory Objectives 4
III. ASSURING THE SAFE OPERATION OF LICENSED FACILITIES....
5 IV.
IMPROVING REGULATION OF THE NUCLEAR INDUSTRY.......
8 New Requirements 8
Preparing to License Future Facilities.........
9 Standardization 10 Investigations 11 Enforcement 11 Timely Licensing of Facilities.............
12 Safety Goals......................
13 Radioactive Source Terms and Siting Policy 13 Transportation.....................
14 Advanced Reactors 14 V.
NUCLEAR MATERIALS AND FACILITIES.............
15 Domestic Safeguards 15 Nuclear Materials 15 International Safeguards................
16 VI. CLEANING UP TMI-2 17 VII. MANAGING NUCLEAR WASTE..................
17 VIII.RESEARCH....................'.....
19 e
POLICY AND PLANNING GUIDANCE I.
INTRODUCTION Purpose The purpose of the Policy and Planning Guidance document is:
to set.forth the regulatory approach of the Nuclear Regulatory Commission and to provide the supporting principles to that approach; to state the major policies and planning objectives of the Commission; and to provide a common basis for the development of programs, for the establishment of priorities, and for the allocation of resources.
The Commission believes that the publication, distribution, and careful review of this document will result in a more focussed individual and collective effort within the agency.
In this way it is hoped that NRC's regulatory process will become more effective and efficient in protectina the public.
Background
This year the document incorporates the Commission's basic philosophy of regulation coupled with specific objectives which should be met within a definite time frame. The intent of the philosophy section of the document is to establish the framework within which regulatory policies, plans, and priorities are developed. The philosophy and principles are based on the l
Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of l
1974, the National Environmental Policy Act of 1969, and related law and Commission regulations.
The Policy and Program Guidance is organized into six themes: Assuring the Safe Operation of Licensed Facilities; Improving Regulation of the Nuclear Industry; Nuclear Materials and Facilities; Cleaning Up TMI-2; Managing Nuclear Waste; and Research. 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 j
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 the NRC is not furnished, since I
it is not intended that the document be all-inclusive.
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. However, the Consnission believes that the majority of NRC activities should fall within one or more of the Policy and Program Guidance themes.
General Administrative Direction The Executive Director for Operations (EDO) will develop specific program
. guidance and assure that agency resnurces are appropriately balanced to implement this document. The EDO will maintain a management system for the Consnission to track major program accomplishments that support the policy and planning guidance. With respect to the specific objectives resulting i
from the Commission's statement of its philosophy and principles, the Office of Policy Evaluation in cooperation with the ED0 should prepare by i
mid-1985 for Commission approval a five-year plan which describes the approach the staff should take in achieving the objectives.
NRC's greatest resource is its employees. NRC managers should give high priority.to training and assigning employees in ways that make the most of actual and potential expertise including creative affirmative action and upward mobility strategies that take full advantage of employee's skills and abilities.
In order to facilitate information flow, the Commission intends to meet with the staff on a regular basis in areas of particular interest; for example, to discuss progress in implementing specific regulatory programs, to receive reports on serious safety concerns, to explore activities in the regions, and to hear from various advisory panels.
l II. REGULATORY PHILOSOPHY The Cnemission's fundamental mission is to regulate those who consnercially ase or produce nuclear material so that the public health and safety, the common defense and security and the environment are protected. The Consnission recognizes that its actions can affect the nation's energy mix and interdependent energy supply system of which nuclear energy is a i
significant part. How the Consnission carries out its fundamental mission must be consistent with and complementary to the determination of the i
Congress that the safe use of nuclear energy for peaceful purposes, l
particularly in the production of electricity, is a legitimate and important national goal. While the Commission recognizes that it is not to i
be promotional, it also believes that its actions should reflect the broad objectives set forth by the Congress in the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act.
Although the Commission and the nuclear industry fulfill discretely different roles and, therefore, have differing responsibilities in some respects, assurance of the public health and safety is a mutual responsibility of both.
In meeting this mutual responsibility, excellence I
should be the standard for perfonnance.
Excellence can be achieved by having a clear sense of purpose through honest assessment, by effective analysis and decisionmaking, by developing strong management, and by
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- -_ continually searching to do things better. The Commission urges industry to strive for such excellence and commits itself to the same standards, so that the Commission will serve as an example as well as an overseer.
Supporting Principles While safety regulation is its primary responsibility, the Commission recognizes that regulatory predictability and stability are extremely important to achieving the Congress' intent to permit the expansion of peaceful uses of nuclear energy. The Comission continues to pursue predictability and stability in its internal processes. New requirements will be imposed on existing licensees only in accordance with the Commission's backfitting policy.
The Commission will attempt, through greater emphasis on defense-in-depth, to develop a less prescriptive regulatory process. Consistent with its goal to achieve stability in the licensing process, the NRC will also encourage the development of standardized plant designs by the industry.
1 When NRC's thorough review of a qualified applicant's plans for a nuclear project has satisfied the Comission that it can be built and operated safely, the Commission has an obligation to license that project. At the same time, NRC's review provides an accessible avenue for the expression of public concerns and an adequate response to those concerns.
The hearing process is to be used to resolve genuine, factual disputes that are material to the case. The right to participate carries with it the responsibility to do so in a meaningful manner. While the Comission will not allow the deliberative process to be used as a mechanism for unneces.sary delay, it will continue to respect and consider differing viewpoints and constructive criticism.
The NRC has a responsibility to audit the construction process and to thoroughly review material submitted in support of a license application.
However, the Commission believes that quality cannot be ihspected into a plant.
It is the responsibility of utility management to assure the quality of construction, recordkeeping, procedural adherence and operation.
The Comission has determined that the control of quality is close,1y correlated with management involvement and experience and therefore intends to ensure early in the construction process that the applicant has the required expertise at its disposal. Reguirement of a more complete design prior to CP approval, mandated assistance from a more experienced organization, or other initiatives may be considered by the Comission in the event of application by an inexperienced utility.
Regulatory oversight must be based on sound technical judgments, and must include timely and decisive action. The Commission recognizes the desirability of conducting the regulatory process in an atmosphere of cooperation and trust. Voluntary compliance and industry initiatives to improve safety are encouraged. Nevertheless, enforcement is a necessary function of regulation. Commission enforcement policy and its L
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implementation sn.11 be firm and fair. The overall performance of a licensee will be a factor in considering enforcement action.
Public information and education enhance public awareness and can serve to enhance. meaningful public participation. The public should be informed of the Commission's activities and responsibilities in a factual and objective manner.
The Commission intends to shift its regulatory emphasis away from detailed, prescriptive requirements toward performance criteria. The revised safety goal, advanced reactor policy statement, and severe accident policy are being developed in furtherance of this objective. The Commission believes that this approach will result in more effective regulation.
Special Regulatory Objectives In support of a balanced and complete regulatory program, the Concission is establishing a special set of objectives to receive emphasis in nuclear power regulation. Associated time frames are also established for carrying out these objectives during the balance of this decade. Depending on the availability of resources, in the next two years these objectives include:
implementina a safety goal; achieving technical resolution of current unresolved safety issues; seeking licensing reform legislation and I
implementing licensing reforms which have been identified; completing the reassessment of radioactive source terms I
and, if appropriate, implementing a revised and more realistic source term and revising existing regulations as warranted; completing development of and implementing a policy on severe accidents; setting forth a procedare for review and approval of standard plant desigrs and preapproval of plant sites; developing procedures for proceeding with projects should a utility desire to reactivate a project after construction and licensing has stopped; determir,fng an appropriate way to incorporate industry safety initiatives in nuclear regulation;
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pursuing improvements in construction quality assurance policy; ensuring that adequate and timely actions are taken to carry out NRC's responsibilities under the Nuclear Waste Policy Act of 1982; and implementing a policy for early review of advanced reactor concepts and designs.
During the. remainder of the 1980's, the NRC will revise its regulations to
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- base them more on performance than on prescriptive requirements for nuclear plants, finalize a procedure for review and approval of standardized plant designs, consider organizational cha,nges to reflect long-range objectives, and if supported by the earlier determinations, continue to modify applicable regulations based on new source terms and to increase reliance on industry self-regulation.
Specific details concerning the above-mentioned objectives may be found in the body of'this document highlighted by an asterisk.
III. 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 facilities are adequately l
designed, built, and tested prior to operating and that operating facilities maintain adequate levels of protection of public health and safety.
2.
The staff should carry out NRC regulatory activities in a way that recognizes that licensees have the primary responsibility for the safe design, construction, and operation of nuclear facilities.
3.
The NRC and the industry must continue to learn the lessons that only experience can teach. Accordingly, a high priority should be given to the development of (a) a capability to foresee safety problems through analysis of operational data, and (b) commercial reactor operating expertise within the agency through training, hiring, and promotion practices and communication with the industry.
4.
NRC's goal is to encourage a high level of quality in reactor design, construction, operations, and maintenance. For both construction activities and operating facilities, the NRC needs to better understand the causal factors leading to problems and to work to decrease the probability of repetition of past mistakes.
- 5.
The Commission supports implementation of a severe accident policy.
In order to bring about regulatory stability and timely application of severe accident research, the Commission supports early resolution of c
. outstanding technical issues. Further, the Commission supports initiation of any necessary regulatory activities to address severe accident considerations directed to operating reactors, reactors under construction, future plants including standard plants, and safety characteristics of advanced reactors.
Where data permit, probabilistic risk assessment is a useful tool for 2.
assessing the' reliability of safety systems and for weighing risks 4
against one another. Quantitative risk assessment techniques will be used judiciously by the staff and the boards to estimate risks as an aid to decisionmaking.
7.
The Commission continues to believe in emergency backup systems, I
containment integrity and emergency planning as essential parts of the defense-in-depth philosophy.
Emergency planning should be based on realistic assumptions.
8.
The Commission continues to believe that radiation protection should be considered when making engineering and operational decisions for i
nuclear facilities.
'9.
Unresolved safety issues should be promptly pursued. Priorities for l
implementation should be established in light of the safety l
significance of the issue and all other requirements imposed on the licensee.
'l Planning Guidance 1.
NRC on-site inspection of operating reactors should continue to focus on the plant operations of licensees, including maintenance activities. The analysis of operational data and systematic assessment of licensee performance will be used to help focus NRC
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activities, to allocate agency resources, and to assess the licensee's l
management of its plant.
Priority attention will be given to licensees with low performance ratings.
2.
The NRC will continue to closely monitor the first two years of operation of new plants coming on.line, particularly those of i
licensees who have no prior experience with nuclear plants.
3.
Throughout 1985, the NRC should continue to pursue a program to provide agency personnel with applicable experience. Mindful that NRC's recruitment efforts should avoid having adverse effects on
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industry programs to train and maintain experienced operators, the NRC should continue the effort to employ individuals with commercial reactor operating experience. A progress report on this effort should be provided to the Commission by the staff by the end of 1985.
4.
Efforts to collect, analyze, disseminate, and act upon operational data must continue to receive priority attention without hindering plant operation.
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- 5.
NRC must continue to improve its activities that affect the quality o*
design and construction particularly with respect to the translation of applicants' design connitments in the licensing process into plan-hardware, procedures, staffing and training. NRC's design and construction inspection programs should continue to be integrated to assure that applicants' connitments are carried out in the construction process.
6.
Licensees have the responsibility to assure that their vendors and equipment are adequately inspected. NRC should emphasize to licensees and industry that there is a need for their increased involvement in assuring the quality of vendor-supplied equipment and services. NRC i
should assure itself through its own selective inspection effort that both licensees and vendor organizations are meeting their responsibilities.
7.
The staff should continue the efforts approved in the NRC Human Factors Plan. The staff should make effective use of available human factors data and take industry efforts (such as INPO) into account in l
developing NRC programs.
- 8.
By the end of 1985, to the extent practical, the staff will issue for public comment draft technical resolutions for currently identified unresolved safety issues. The staff should continue to review and approve the addition of new generic safety issues in accordance with current Commission policies, and given resource constraints, resolve the high priority issues first.
9.
In reviewing new and operating facilities, the staff should carefully consider the necessity for some reactor operators with commercial experience at every plant.
In addition, it should consider the competence and experience of the management and staff of each facility.
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- 10. The staff should expeditiously carry out those activities necessary to implement the Commission's severe accident policy.
- 11. The staff should implement the Commission Policy Statement on Training i
and Qualification of Nuclear Power Plant Personnel.
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- 12. Attention should be given to refining the use of probabilistic assessment techniques to implement Commission policy on safety goals.
as directed.by the Commission, and in other regulatory applications especially amenable to risk assessment, e.g., in dealing with generic safety issues, fonnulating new regulatory requirements, assessing and revalidating or eliminating existing regulatory requirements, evaluating new designs, and setting reactor research and inspection priorities.
- 13. Whenever probabilistic risk assessment is used in the decision-making process, there must be clear statements of the models used in the 1
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- 14. Extra attention should be given to fostering the improvement of a coherent data base for use in risk assessments.
- 15. The Conunission will consider alternate regulatory concepts which recognize the contributions of industry programs to the extent that such programs are effective and consistent with NRC regulatory responsibilities. The Commission supports such industry efforts as INP0's Training Accreditation Program and the INPO operating plant evaluations.
IV.
IMPROVING REGULATION OF THE NUCLEAR INDUSTRY A.
NEW REQUIREMENTS,
Policy i
1.
NRC must be sensitive to the fact that there is a large volume of requirements imposed on licensees. Requirements imposed on the regulated industry by NRC are to have a positive contribution to the public health and safety, not only individually, but also when the l
requirements are taken as a whole. Requirements proposed to achieve i
incremental reductions in risk should be evaluated on a cost-benefit basis, insofar as practicable. There should be no unnecessary regulatory burdens. NRC regulations should allow individual licensees the flexibility to select the most cost-effective ways to satisfy NRC safety objectives, particularly for plant specific requirements.
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.
2.
To the extent practicable, issues.which affect numerous licensees should be addressed in the context of rule-making or standard orders as opposed to case-by-case review.
Insofar as practical, an effort should be made to avoid building in more differences among plants than already exist.
Planning Guidance 1.
With the goal of enhancing the levels of protection of public health and safety, the Consnittee for Review of Generic Requirements (CRGR) should continue to review and make recommendations to the EDO on proposed generic requirements for reactor licensees. The CRGR should continue to assure that proposed requirements (a) contribute 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.
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8 2.
The EDO has overall authority and responsibility for managing backfitting. The staff should diligently manage backfitting for reactors under construction or in operation. Based on experience gained from managing backfitting, the EDO should periodically provide the Commission with an evaluation of the results.
2 3.
Existing regulatory requirements should be reviewed to see if some could be eliminated without compromising safety.
For those t
requirements that are necessary, effective measures should be taken to ensure that they are implemented in a timely manner.
4.
An integrated implementation schedule for new and existing requirements 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. The schedules should reflect the importance of the safety requirement tc the public health and safety and consider the licensee's ability t1 complete the necessary engineering, evaluation and design. Once compliance dates have been established, the Commission will vigorously enforce license conditions associated with such schedules.
- 5.
The staff, in accordance with the five-year plan to be developed by j
OPE and the EDO (see p. 2) and approved by the Commission, should propose or modify regulations that take into account the reevaluation of existing regulations in light of new source term data if and when they become available.
6.
Existing guidance on performing cost-benefit analyses should be further developed. The cost-benefit manual should address techniques for ensuring that reasonable estimates of cost are obtained, and 4
should be used in implementing the cost-benefit and risk assessment portions of the Commission's safety goal policy.
7.
The Commission intends to pursue the proposed backfit rule.
B.
PREPARING TO LICENSE FUTURE FACILITIES Policy
- 1.
The Commission intends to reconsider the legislative package which was forwarded to the Congress in February 1903 prior to resubmittal of a proposal to the new Congress in 1985.
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Planning Guidance
-1.
The Regulatory Reform Task Force (RRTF) will support the Commission's reconsideration of the legislative package.
- 2.
In view of the number of plants that have been postponed in the midst of construction, the staff will consider the legal and technical ramifications should a utility desire to reactivate a project after construction and licensing has stopped.
Procedures for proceeding with such projects should be developed by the end of 1985. Beginning in FY 1987, the staff should be prepared to deal with the possible restoration of construction on deferred plants.
3.
The Connission intends to forward a report to the Congress on the role of the staff in hearings and on ex parte considerations.
C.
STANDARDIZATION Policy 1.
The Connission's goal is the approval of essentially complete standard plant designs. The NRC recognizes that there are advantages to the development and use of star dardized nuclear power plant and balance of plant designs. Such designs can benefit public health and safety by concentrating the resourcer, 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 operation. The use of such designs can also permit more effective and efficient licensing and inspection processes. Therefore, the Commission strongly encourages industry to pursue standardization in future reactor designs.
Planning Guidance
- 1.
By 1986, the NRC should improve the process to review and license new standardized nuclear power plant designs and to review and pre-approve potential plant sites by revising our licensing procedures as necessary.
- 2.
Through the remainder of the 1980's, the NRC should continue to maintain its capability to review, in a timely manner, applications for standardized plants and pre-approved sites.
- 3.
The staff should present proposals to the Commission which will i
encourage industry to proceed with standardization. An option that i
should be considered is certification of standard designs (including balance of plant) and limiting applications for a license to such standard designs.
In accordance with the five-year plan presently in preparation, the staff should develop the regulatory approach best suited for standardized plants.
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4.
The staff should propose revisions to the Commission's 1978 Policy Statement on Standard Plants and associated regulations to reflect the Commission's Severe Accident Policy.
D.
INVESTIGATIONS Policy 1.
The Office of Investigations (OI) shall investigate significant allegations of wrongdoing by other than NRC employees and contractors as requested by the Commission, EDO, Regional Administrators, or on its own initiative.
2.
Investigations should be thorough and should try to identify the root causes and reasons for violations. When initial collection of evidence indicates that the matter involves criminality, appropriate referrals will be made to the Department of Justice.
Planning Guidance 1.
By mid-1985, the Office of Investigations, in coordination with the EDO, should develop appropriate threshold levels and the priorities for initiating and terminating investigations.
2.
The EDO should provide technical support to the Office of i
Investigations in the conduct of investigations with due regard to their mutual priorities.
i 3.
Consistent with available resources, investigations should be 4
performed in a timely manner and findings and conclusions provided together with their bases on questions of intent, willfulness and other matters to cognizant offices.
Findings of potential safety significance should be immediately referred to the cognizant office.
4.
Close coordination should be maintained as appropriate between the Offices of Investigation, Inspection and Enforcement, Nuclear Reactor Regulation, Nuclear Material Safety and Safeguards, AE00 and the Regional Offices. The results of investigations should be followed by appropriate action on the part of cognizant offices and the EDO.
E.
NRC should maintain an effective enforcement program with uniform and timely application.of enforcement policy throughout the regional offices. The enforcement policy should be firm but fair. The principal goals of NRC's enforcement program will be to assure safety through compliance with NRC safety and safeguards requirements.
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2.
NRC enforcement activities must be directed to assure that licensee corrective actions for performance deficiencies are appropriate and that future compliance with requirements is encouraged.
For licensees that do not comply, prompt and vigorous action will be taken. A licensee must not benefit by violating NRC regulations. Licensees who cannot achieve and maintain an adequate level of-protection of the public health and safety, safeguards, and the environment will not be permitted to operate.
3.
Inspections on which enforcement activities are based should be thorough and should seek to identify the basic reasons why violations and deficiencies occurred.
4.
Enforcement actions should encourage an aggressive approach by licensees to ensure adequate protection, and credit should be given for prompt reporting of deficiencies by licensees and for prompt, thorough, and voluntary corrective actions.
Planning Guidance 1.
The Commission has established an Ad-Hoc Advisory Committee for Review of the Enforcement Policy composed of individuals with diverse backgrounds. A report will be published in 1985 after the Committee receives information from the staff, licensees, and the public on the effectiveness of the enforcement policy. The Commission will conside.-
the comittee's recommendations for changes in the enforcement policy.
F.
TIMELY LICENSING OF FACILITIES Policy 1.
The NRC intends that its regulatory processes be efficient and cost effective. Actions should continue to be taken to eliminate unwarranted delay in reaching decisions consistent with not compromising safety, safeguards, or environmental protection and all applicable legal proceedings (e.g. hearings). The Commission reaffims its statement of policy on the conduct of the licensing proceedings of May 1981, which urged licensing boards to take actions needed to assure the efficient conduct of hearings.
l Planning Guidance i
1.
Consistent with maintaining adequate levels of protection and meeting legal requirements for 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 l
delay reactor startup.
G.
SAFETY GOALS Policy 1.
The Comission 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 answer 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 objectives will not be used as the basis for making regulatory decisions during the two-year trial period.
Planning Guidance 1.
The staff will provide the Commission, by early 1985, recomendations on proposed safety goals resulting from the two-year evaluation period. The recommendations should discuss in detail the regulatory implications of the safety goal.
- 2.
The NRC will continue to work on a safety goal with the objective of defining to the industry and the public the acceptable limits for nuclear plant risks.
- 3.
In accordance with the five-year plan the staff should revise NRC regulations based on the safety goal, where applicable, to reflect more general perfomance-based requirements and less prescriptive requirements for nuclear power plants.
1 H.
RADI0 ACTIVE SOURCE TERMS AND SITING POLICY Policy 1.
The Commission has decided to improve its definition of safety goals l
and characterization of radioactive source terms before proceeding l
with changes to regulations such as siting. Changes to current i
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. A draft reassessment of radioactive source terms should be developed in I
1985. If supported by the reassessment, the staff should implement a revised, more realistic source term by July of 1985 and draft modified regulations, as justified by the new source term data.
2.
Based on the revised radioactive source tem data, and after completion of the two-year evaluation of the safety goals, the need i
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for a revised siting rule should be evaluated. Effects on other existing and proposed regulations (e.g., emergency preparedness) should also be evaluated when the revised source terms have been validated through an effective peer review process.
I.
TRANSPORTATION Policy 1 ~.
The Commission considers the regulation of the transportation of l
nuclear and radioactive materials to be an important ongoing element of its responsibilities.
l Planning Guidance 1.
The staff should assure that NRC responsibilities in regulating the transportation of nuclear and radioactive materials are coordinated with other Federal agencies to achieve an integrated Federal program for protecting the public health and safety with the least possible impact on the regulated industry.
J.
ADVANCED REACTORS Policy i
l 1.
While the NRC itself does[not develop new designs, the Comission will maintain the capability to respond to innovative and advanced designs that might be presented forcComission review. The Commission intends to make known the factors it considers important for advanced reactor concepts in order to minimize complexity and uncertainty in the regulatory process.
Planning Guidance l
1.
The Comission will establish an advanced reactor policy during 1985.
2.
The. staff will develop draft guidelines on changes to general design criteria and the regulations for advanced reactors by the end of 1986.
- 3.
Staff should evaluate and explore the safety characteristics of new reactor types, as such new reactor concepts evolve and come before the t
Comission.
I i
4.
Advanced reactor. concepts including the HTGR shall be pursued within the framework developed in the Advanced Reactor Policy Statement and consistent with programs adopted by the Executive Branch, the Congress, or a focused private sector effort alone or in combination with the government.
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NUCLEAR MATERIALS AND FACILITIES i
A.
DOMESTIC SAFEGUARDS Policy 1.
Safeguards are an integral and ongoing element of the Commission's responsibility. Safeguards regulation should be conducted with the same defense-in-depth philosophy as safety regulation.
- 2.
Emphasis should be given to performance requirements rather than prescriptive requirements to allow licensees to select the most 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 Guidance 1.
Evaluation of safeguards events will serve as a basis for regulatory 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 significant events to occur before undertaking safeguards changes that are considered necessary.
2.
Staff, in addition to assuring that safeguards 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 Comission detailing the results of the previous year's assessments. The report shall contain recommendations for continuing or discontinuing the assessment.
3.
The staff will review coments on the proposal to convert non-power reactors to low enriched uranium fuel and expeditiously provide the Commission with a proposed final rule. The staff should also complete development of a draft rule to apply upgraded physical security i
measures to research reactors.
B. NUCLEAR MATERIALS Policy 1.
Byproduct, source and special nuclear materials must receive regulatory attention commensurate with their potential hazards to the public and to the users of these materials.
- 2.
Nuclear materials regulations should emphasize perfomance requirements rather than prescriptive requirements.
3.
Efforts to achieve greater standardization of material licensing reviews and consistency in application of regulatory requirements should be continued.
Planning Guidance 1.
Applicable regulations should be reviewed and updated to provide the necessary degree of regulation with a focus on performance requirements.
2.
Regulations to consolidate and streamline the safety requirements associated with medical use of byproduct materials and well-logging should be promulgated along with associated regulatory guidance, standard review plans and inspection procedures by the end of 1985.
3.
Regulatory efforts to improve radiography safety, in particular through the establishment of performance standards, as well as more effective training and inspection programs, should be completed by July, 1986. Rulemaking to improve safety should be coordinated through the ad hoc radiography steering committee.
4.
The uranium mill tailings regulations shall be completed as follows:
(1) non-discretionary changes necessary to conform to EPA standards shall be completed by July, 1985; (2) Table S-3 and its supporting narrative shall be completed by January, 1986; and (3) the remaining changes for implementing EPA's standards shall be completed by January,1988.
C.
INTERNATIONAL SAFEGUARDS Policy l
1.
The proliferation of nuclear explosives technology poses a threat to l
the security interests of the United States. Hence, the NRC will carefully discharge its statutory licensing responsibilities to ensure that necessary controls are applied to the. import and export of nuclear materials, equipment, and facilities.
l Planning Guidance 1.
The NRC should continue to facilitate the timely processing of export l
license applications to nations which adhere to effective non-proliferation policies.
The NRC will also continue to meet its commitments for the implementation of international safeguards at U.S.
licensed facilities and to work with the Executive Branch as the U.S.
pursues improvements in international safeguards.
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The staff should continue to pursue obtaining timely, accurate and complete information from the Executive Branch regarding exports so 4
that the Comission can carry out its international responsibilities.
3.
The Commission, as noted in its policy statement of August, 1982, continues to believe in reducing to the maximum extent possible the use of highly enriched uranium in both domestic and foreign reactors.
The staff should continue to review license applications in light of this policy statement.
VI. CLEANING UP TMI-2 Policy-1.
Expeditious and safe cleanup of the TMI-2 reactor is an important NRC priority. While direct responsibility for cleanup rests with the licensee, NRC will provide oversight and, if necessary, direction to ensure decontamination of the facility as well as safe and timely removal of radioactive products from the site.
2.
NRC should work closely with Department of Energy (DOE) to obtain technical infomation on severe accidents that may be available from the TMI-2 core.
Planning Guidance l.
NRC will continue monitoring site cleanup activities through the use of a field office.
2.
NRC should continue to closely monitor its agreement with DOE which relates to the removal and disposition of solid nuclear wastes from the cleanup of TMI-2. The objective of NRC's monitoring is to help assure that the wastes are safely and expeditiously removed from the site. NRC should also assist DOE in development of plans for the safe and timely offsite disposition of the damaged core.
VII. MANAGING NUCLEAR WASTE Policy
- 1.
The NRC High Level Waste Management Program is critical to the success of an urgent national task. NRC will provide the necessary pre-licensing consultation and licensing and regulatory oversight for the Executive Branch's program as required by the Nuclear Waste Policy Act of 1982 (NWPA), the Atomic Energy Act, Energy Reorganization Act, and the Commission's regulations. NRC's programs will be directed to an effective and efficient discharge of its responsibilities based on the premise that, in the absence of unresolved safety concerns, the NRC regulatory program will not delay implementation of the Executive Branch's program as reflected in the DOE project decision schedule.
If it becomes clear that these schedules cannot be maintained due to the unavailability of resources or other factors, the staff will
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l l promptly infonn the Consnission so that the required notification of DOE and the Congress can be made.
2.
The staff should continue to maintain close consnunications with DOE, j
the states and affected Indian tribes so that required activities and lead times are identified early in the planning process.
f 3.
To the extent possible, and consistent with NRC's independent role, system development required to support programs to implement the NWPA thould be perfonned by DOE. NRC will continue its technical program to support the development of licensing criteria and evaluation methods, and the early identification and resolution of technical issues.
4.
The NRC staff shall monitor the activities associated with the implementation of the Low Level Radioactive Waste Policy Act and shall apprise the Commission of any problems requiring Commission action along with recommendations for each action.
5.
Staff shall continue to implement Environmental Protection Agency (EPA) standards in accordance with its statutory responsibilities including Section 84(c) of the Atomic Energy Act.
Planning Guidance 1.
The staff shall assess the need for a g,eneral memorandum of understanding with DOE to specifically cover the NRC's interactions with DOE in implementing the NWPA. Staff shall provide the results of that assessment to the Commission by mid-1985.
2.
The staff should review the existing and proposed regulations that are covered by areas addressed by the NWPA, and make confonning changes as necessary. When EPA standards are published, regulations should be reviewed to detennine whether any changes are required.
3.
The NWPA has established that nuclear utilities have the primary responsibility for interim storage of spent fuel, pending repository operation or availability of monitored retrievable storage. The NRC should review in a timely manner, consistent with safety and legal requirements, utility proposals for adding spent fuel storage capacity to assure that, in the absence of unresolved safety concerns, 1
regulatory actions do not affect reactor 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 DOE. 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 continue development of regulations to implement the EPA mil'1 tailings standards for groundwater protection. Efforts to develop alternate concentration limits methodology jointly with EPA should receive high priority.
l
19 -
5.
The staff should be ready to review proposals for monitored retrievable storage facilities in the event the Department of Energy and the Congress decide to proceed with such facilities.
VIII. RESEtRCH Policy 1.
The purpose of the research program is to provide the technical basis for rulemaking and regulatory decisions; to support licensing and inspection activities; to assess the feasibility and effectiveness 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 therein.
3.
The severe accident research program must provide timely information for the Commission's decisionmaking process on severe accidents.
Planning Guidance 1.
The research resources identified in NRC's budget should be allocated to support a balanced program between research to reinforce or revise the current regulatory base and conceptual research for improved reactor safety, waste management, and other licensed activities. The major resource commitment for NRC research efforts will be light water reactor safety. The staff should be alert to research which shows that we ought to change our regulations. NRC regulations should be changed when research shows them to be either too stringent or not stringent enough.
2.
NRC 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. The long-range research plan should continue to identify regulations likely to be substantively modified or substantiated by the research programs. Research undertaken by the staff will be consistent with the long-range plan.
3.
The staff will conduct annual assessments, with input from appropriate user offices, of the progress and usefulness of specific research topics and make greater use of Research Review Groups.
4.
Joint or coordinated research programs with industry groups, other government agencies and foreign groups 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 industry.
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