ML20137S132
| ML20137S132 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1985 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Asselstine, Bernthal, Roberts NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8512060169 | |
| Download: ML20137S132 (41) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSIONSECRETAR 6
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November 20, 1985 CHAIRMAN MEMORANDUM FOR:
Cormiissierer Peberts Ccamissioner Asselstine Commissicrer Eernthal Commissioner Zech g
FROM:
Nunzio J. Palladino l
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SUBJECT:
DRAFT 1986 POLICY AND PLANNING GUIDANCE (PFG)
Attached is the draft 1986 PPG for your review and for discussion at the Ccmmission meeting scheduled fcr November 26, 1985.
I believe that the PPG dcct.r.ent is one of the most important pieces of work performed by the Commission annually. While I realize that we are in a transition pericd to a five year planning process, I think that.it is essential that you give careful consideration to this year's PPG.
I believe that the Corr.issica review should concentrate on policy formula-tion and overall agency management direction.
Th'.s, I seggest that we focus er the regulatory philosophy in Chapter II, :be strategic goals enumerated in Chapter III, and the policies and p'.arning guidance presented in Chapter IV.
I regard the specific divisions into mission areas to be somewhat flexib'.e.
1 view your comments on the agency's philosophy, strategic goais, anc pciicies to be of greatest importance.
I suggest that we review these carefully so as to give clear directier to the staff.
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TABLE OF CONTENTS i
Page I.
INTRODUCTION.....................
1 1-Purpose 1
Background.........................
3 II. PHILOSOPHY CF REGULATION.....
4 Supportirig Principles 7
III. STRATEGIC C0ALS Goal 1...........................
7 Goal 2...........................
8 9
Goal 3...
9 Gcal 4 9
Goal 5..........
IV. POLICIES AND PLANNitlG GUICAhCE...............
10 A.
Oversee Operating Reactor Performance 12 B.
Analyze Reactor Operaticral Experience....
16 C.
License Currert and Future Reactor Designs.......
'7 D.
Predict the Extent to which Abnormal Operat;ng.....
Conditions will Cagrade Safety.............
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E.
Resolve Reactcr Safety Concerns 23 F.
License and Monitcr Materials Licensees / Fuel Cycle...
Facilities.......................
78 29 G.
Regulate High Level Waste H.
Regulate Low Level Waste.
32 I.
Perferr Safeguards Regulatory Activities.
.....32 J.
Peview Allegations ar.c Ccr.cuct Investigations 35 K.
Take Enforcement Actions................
36 L.
Adequately Manage and Screert Technical Progrars....
38 Conaitions
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I.
INTRODUCTION
- Purpose, The purpcses' of the Policy and Planning Cuitarce document are:
to set forth the reSulatory philosophy of the huclear Regulatory Comission are its supporting principles; to state the strategic goals ard major policies of the Correission; and to prcvide guidance f'r the developnent of plans and programs, for the o
establishment of priorities, and for the allocation of resources.
The Ccmissier believes that the publicaticn, oistribution, and careful indi.idual review of this document will result in focusing efforts within the agercy or the implementation cf a regulatcry process that is more effective and effic4en*. in protecting the public health and sa#ety, the comon deferse and security, and the environment.
Background
The Policy and Planning Guidance is organized into four major secticns:
Irtrcduction; Philosophy of Regulation; Strategic Goals; and Policies ard Planning Guidance. The policies ano planning guidance are set 'crth in the centext of twelve mission areas which cover the entire agency.
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Tre intent of the philosophy section of the dccument is to establish the framework within which strategic goals, regulatory policies, plars, and priorities are developed. Thc intent of the succeeding section is to set forth the Commission's strategic goals. The policies in the last section flow from these strategic goals, anc the planning guidance provides an expression of specific Commission priorities.
The Ccomission is planning to publish a Five Year Plan in 1986. That plan will ddentify the programs and resources needed to attain the Commission's strate-ric grals. The Commission intencs the Five Year Plan to be a living decurent.
It will be' reviewed annually and revised to reflect changes in the regulatory envirorment and budget realities. This Policy and Platnirc Guidance will serve as the departure point for formulating the Five Year Plan.
. II. PHILOSOPHY OF REGULATION The Commission's fundamental mission is to regulate these who ccmmercially use or produce nuclear material so that the public health and safety, the common defense and security, and the environment are protected.
The Commission recognizes that its actions can affect the nation's energy rix and inter-dependert energy supply system of which nuclear energy is a significant part.
The way the Commission carries out its fundamental mission must be consistent with and complementary to the cetermination of the Congress that the safe use of nuclear crergy for peaceful purposes, particularly in the production of electricity, is c legitimate and important national scal. While the Commissier reccgr.i:es that its functions do not include the promotion of nuclea* energy, it also believes that Commission acticrs sFeuld reflect the broad objectives set fcrth by the Congress in the Atomic Energy Act of 1954, as amenced, and the Energy Reorganization Act cf 1974, as amended.
Although the Commission ard tFe nuclear industry fulfill necessarily different ecles anc have different responsibilities. they share the responsibil'ty for assuring that the public health and safety is adequately protected.
In meeting this mutual responsibility, excellence should be the standard for performance. Excellence can be achieved by having c clear sense of purpose through. honest assestrert, by valid analysis and effective decisionmaking, by developing strong and vigilant management, and by continually searching for ways te de things better. The Commission urges industry to strive for such excellence and, in committing itself to the same standards, hopes te serve as an example as well as an overseer.
4-Supporting Principles While safety regulation is its primary responsibility, the Commission recog-nizes that regulatory predictebility and stability are extremely impor ant to achieving overall safety and the statutory goal of supporting the expansion ci the peaceful uses of nuclear energy. The Ccrnissicn continues to pursue predictability and stability ir its internal processes. New requirements will be imposed on existing licensees only in accordance with the Ccomission's backfit ru'e.
i The Ocmmission will attempt, thrcu5h greater emphasis on defense-in-depth, to develop a le'ts prescriptive regulatory process. Cctsistent with its goal to achieve stability in the licensing process, the NRC t/'l also erccurage the ceclear industry to develop stanoarcized plant designs.
When NRC's comprehensive review of a qualified applicant's plars for a ruclear power plant ber satisfied the Commission that it can be built and operated safely, the Cermission has an obligation to license trat plant. At the same time, NRC's review process should provide an accer:"ble aver.ue for the ex-pression of public concerns and an adequate resperse to those concerns.
The hearing process is te be used to resolve genuine, factuai cisputes that are material to the case. The right to participate carries with it the responsibility to do so in a business-like manner. While the Commissien will I
r.ct allow the deliberative process tc be cred as a mechanism for unnecessary i
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t delay, it will continue to respect and ccrsider differing viewpoints and constructive criticisc.
The t'PC has a responsibility to audit the ccr.struction and operation of a nuclear power plant and to thoroughly resiew material submitted in support of a license application ard amenoments. Hcwever, quality cannot be inspected into a plant.
It is the responsibility of utility managerent to assure the cuality of design, construction, recordkeeping, procedural adherence. and operation, and to assure the quality of service and equipment supplied by venders.
- t is the responsibility of the f$C tc see that the utilities pericnn this task.
The Commission has deterriced thet the control of quality is closely corre-latec with management involvement and experierce crc inerefore intends to ensure, early in the ccrstruction process, that the applicant has the required expertise at its disposal. The Commission will aisc assure thct this in-volver.cr.t ard expertise is retained throughcut design, construction and piant cperation. Requiring a more complete design prior to construction perr.it epproval, mandating assistance from a more experienced organi ctier, er cther initiatives will be considered Ly the Conmissica in the event that an in-experienced utility applies for a license.
Regulatory oversight mu t be based on sound technical judgments and must include timely ard decisive action. The regulatory process should be con-ducted in an atmosphere cf cccperation and trust. Voluntary ccepliance l
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' erc' ir.dustry initiatives to improve safety are to be encouraged. NeverthelEst, erforcement is a necessary fur.ction of regulation. The Commissior's enforcerrer.t pclicy and its implementation shall be firm and fair. The overall performance of a licensee will be a factor in considering erfercement action.
Public informatien and education enhance public awareness ar.d :an provide meaningful public participation in the regulatcry process. The public should be infcrmed of the Comission's activitics ar.d responsibilities in a factual, timely, and objective manner.
The Censnission intends to shift its regulatory emphasis away frort detailed, prescriptive requirements toward performance criteria. The severe accident policy, and the develcpmer.t of the revised safety gtt' trd adverced reactor policy, are aimed at furtherance of this objective. The Ccmission believes that this approach will result in more effective reculation, i
i III. STRATEGIC GOALS The Commission is establishing a set of strategic goals to be emphasizec in hRC's regulatory activities. Each goal and varicts supporting objectives are ennumerated belcw.
GOAL 1.
To Assure Safe Operation cf Licensed Facilities and Proper Ccnstruction of Facilities te be Licersed o
Ensure that NRC and licensees cpply cperational experience Ensure high standards of quality assurance o
o Ensure adequate training of licensee personnel o
Achieve technical resolution of unresrived safety issues o
Enforce applicable resulttiers o
Investigate significant allegations e.vpeditiously o
Implement Ccmmission policy on severe accider.ts o
Conduct surperting confirmatory research o
Allocate NF.C resources tc reflect the mi of operating
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facilities and facilities under.constructicr i
i G0AL 2.
To Improve Regulation of the Nuclear Industry c
Control backfitting o
Eliminate ur.warrarted regulatory delays and pursue hearing process efficiencies c
Ccerlete the reassessment of radicactive source terms and, if appropriate, irplement revised source terms and change existing regulaticrs Pely on industry self-improvement, where justifiable c
Encourage star.dardization and issue a revised star.dardization o
policy o
Implement the. safety goal policy Prepare to license new types cf pcwer plants o
Prepare for requests to reactivate deterrea construction c
projects and to extend plant cperatinr: licenses c
Suppcrt licensing reform legislation o
Complete a comprehensive review of NRC regulatiers o
Amend reguictiers te reduce prescriptive elenen:s
_9 GOAL 3.
To Assure Adequate Prctcction of Nuclear Materials Ensure sateguards measures are cerrersurate with threats c
o Ensure recessary controls are applieo to expcrts of strategic nuclear material o
Reduce overexposures of radiographers G0AL 4.
To Assure Radicactive Waste is Managed Safely o
Review CCE's repositcry program in a timely fashion o
Assist states to select sites and technology for low level waste e
Clean up TMI-2 expeditiously GOAL 5.
To Manage Agency Resources More Effectively ard Eff'ciently o
Recogni:t vclee of NRC employees e
Consolidate headquarters staff in ene lccation Improve management accountability tracking of planned c
accomplishments ar.d schedules o
Enhance infermhtien processing and distribu'.icr I
. IV. FOLICIES AND PLANNING GUIDANCE The hRC's major policies and p!arrirg guidance are organized under twelve general mission areas: (A) Oversee Operating Reacter Performance, (B) Analyze Reactor Cperaticnal Experience, (C) License Currcr.t and Future Reactor Designs, (0) Predict the Extent to khich Abnormal Operating Conditions Will Degrade Safety, (E) Resolve Reactnr Safety Concerns, (F) License and Monitor Materials Licensees / Feel Cycle Facilities, (G) Regulate high Level Waste, (H) Regulate Low Level Waste (I) Perform Safeguards Regulatory Activities, IJ) Review Allegations and Corduct Ir.vestigations, (5) Take Enforcement Action, and (L) Adequately hanage and Support Technicci Programs.
Withir each rission area there is a policy secticr thich establishes a general framework for shapirig hRC plans and programs. Planning cuidance is furnished in those areas where the Conmassion believes more detail is warranted to reet specific priorities or schedules, or where rajor assurptiens are needed for program develcpment. While the mission areas cover the entire agency, specific policies or planning guidarce with respect to each and every activity within the NRC is not furnished, since it is not intended that this dccument be all-inclusive.
The P.esearch Program is an essential element in many of the Agency's missions.
As such the Commission believe: it is important to highlight general guidance as it pertains to the Research Program. The research prcgram should continue to provide the technical Dasis'for rulemaking and regulatery decisions; to l
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' support licensing and inspecticn activities; to assess the feasibility and effectiveness of safety improvements; and to increase our understarding of phenomena fcr which analytical methods are reeded in regulatory activities.
There should be continued erphasis on using research results in the regulatory process and on obtaining results that are useful thereir.. The staff should be alert tu research which shows that we ought to charSe Ghr regulations.
NRC regulations should be changed when resea. ch shews them to be either r
too stringent er oct stringent enough to adequately protect the public health ard safety.
NRC will continue to maintain a long-range research plan which is consistent with the ager.cy's r.-andate and directed toward areas c# importance to the licensing and inspecticn processes. The long-range *esearch plan and the NRC's Five Year Pier will be cunsistent with each other.
Research resources should be allocated to support a balanced progran between research to reinforce or revise the current regulatory base ano ccrceptual research for improved reactor safety, waste managemer.t, ard other licensed activities.
The cajor resource commitment fcr NRC research efforts will be light water reactor safety. The priority for research should be assigned in acccrdance with its safety significance.
s'cirt or coordinated research programs with industry groups, other government agencies arn foreign gecups should be pursuec when pcssible, both to expand the technical breadth provided to projects and tu maxirhe the berefit to be 1
derived from limited resources. Due consideration shculd be given to questions cf conflict of interest when contemplatirg joint or coordinated research with industry.
A.
OVERSEE OPERAT:NG REACTOR PERFORMANCE Policy 1.
NRC's fundamental task is to assure that existing nuciecr reactors and those ccmirg en-line operate safely. Consequently, the highest priority will be given to assuring that reactors are adequately designed, built, and tested prict tc operation and that operating facilities maintain adequate levels of prctection of public health and safety.
2.
The staff should. carry out NRC regulatory activities in a way that reccgnizec that licensees have the primary responsibility for the scfe design, construction, and operaticn of nuclear facilities.
3.
The Ccmmission intends to emphasi:e performance monitoring to ensure that potential operaticnal prcblems are identified as early as practical and that action is taken before problems beccme critical.
4.
NRC's goal is to enccurage a high level of quality ir reacter cperations ano maintenance. The NRC needs to better understano the causal factors leading to problems and.o work to decrease the probability cf rcpetition of past cittakes.
. t 5.
The Ccmmission continues to believe in emergency backup systems, containment integrity and emergency planning as essential pr~ts cf the deferre-ir.-depth philosophy. Emergency plar.ning should be Jased on realistic assumptions.
6.
The Commission cor.tinues to believe that radiation protection of werkers should be censidered when making engireering and operational decisions for nuclear facilities.
t 7.
Expeditious and safe cleanup of the TitI-2 reactor is an important tiRC priority. While direct responsibility for cleanup rests with the licensee, NPC will provide oversight and, if necessary, direction to ensure decontaminaticn of the facility as well as safe and timely remo<al of radicective products from the site.
8.
The Commission places eersiderable importance on the neec for the industry to properly train their staff in prevertive, corrective, and all other areas of mainter.ar.ce.
Planning Guidance 1.
The staff's inspection of operating rcacters shou'Id continue to focus cr. -he plant operations of licensees, including maintenance activities.
The analysis of operational data, risk-based analysis, systematic assessments of licensee perferrarce ar.d the monitoring of performance ir.cicators will be used to help fccus NPC activities, to allocate
% agency resources, and to esscss the licensee's management of its plant.
Priority attention will be giver. tc licensees with low performarce ratings. The staff will provide inicreation gained from performance appraisais to licensees. The staff will ersure that licensees implement appropriate acton.
2.
The staff shculd centinue to closely monitor the first two years of operation cf new plants coming on line, particularly those of licensees who have no pricr experience with nuclear plants.
3.
Licensees have the resper.s*bility to assure that their vendors and equiptcr.t are adequately inspected. The staff'should emphasize to licensees ard ir.dustry that there is a neeo for their increased involvement in assuring the quality of vendor-supplied ecuipment and services. The staff should assure itself thrcush its cwn selective inspection effiirt that Loth licensees and vendor organi r.tiens are meeting their responsibilities.
4.
The Commission will consider alternate regulatory cor.cepts wnich recognize-the contributions of industry programs to the extent that such programs are effect've erd cersistent with NRC regulatcry responsibilities.
The Commissden supports such industry efforts as lhPG's Training Accreditation Program Operating Plar.c ivaluations, the Nuclear Plant Reliability Detc System, and fitness for duty arc maintenance improvements.
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% 5.
The staff should develop performance indicators to moniter cperating reactors.
6.
The staff must continue tc prcvice for the timely review and irplerenta-
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tico cf char.ges to power plant licenses necessary to assure safe oper-ation, e.g., amendments, technical specification changes ar.d approved new recuirenents; continue to provide timely responses to the public under 10 CFR Part 2 206; and continue to provide for replacement a'rd rectalification examinations to nuclear pcuer plant personnel so that operations are not unnecessarily impacted.
7.
NRC should continue to closely monitor its ecrecr:ent with DOE which relates to the receva! ard disposition of solid nuclear wastes form the cleanup of THI-2. The objective of PP.C's r..criitoring is to help assure that the wastes are safely ard expeditiously removed frcm the
- ite. FRC should also assist DOE ir development of plans for the safe er.d timely offsite disposition cf the demaged core.
8.
The staff sbculd continue to monitor the ef fectiveness o' the accred-itation program by performing independent reviews c' reirtenance training programs.
. 8.
ANALYZE REACTOR OPERAT:0NAL EXPERIENCE Policy 1.
The NRC and the industry must ccr. inLe to learn the lessons that only experience can teach. Accorair. gly, a high priority should be given tc the development of capabilities to foresee problems through monitoring performance ar.d analysis of operational data.
2.
Analysis of domestic and fereign operational data will be used to help identify potential accident precursors.
3.
The NRC will continue to seek to understand the e'fects of aging and irradiatier. cn materials and components in reac:cr containments.
4 Provisions for prcmpt ano effective investigaticr cf majer incidents must be mairtained with appropriate training of tecns to carry out the incident investigation.
Planning Guidance 1.
Efforts to collect, analyze, oisseminate, and act upcn cperational data must contirue tc receive priority attention withcut hindering plant operation. The NRC will rapicly provide licensees with infcrmation gaineo frun pertermance appraisals.
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. 2 The staff should continue to interact closely with INP0 and other industry organizations te assure the most efficient cr.d effective utliization of NRC's resources in the treatrent cf cperational data.
3.
The staff will conduct research to identify measures which can be taken to correct deficiencies attributable te aging and irradiation and to reduce safety risks inherert to degraded equipment.
4 The staff will implement the program for investigation of significant cperational events recently approvcd by the Commission.
C.
,LJ(EMSE CURRENT AND FUTURE REACTOR, DESIGNS Policy 1.
The NRC intends that its regulatory processes be efficient and cost effective. Actions shculd continue to be taken to eliminate unwarranted delay in reachirg decisions consistent with not comprcmising safety, safeguards, or environmental requirements or the preper and effective functioning of the hearing process.
The Corniss'en reaffirms its statement of policy cf May 1981 on licensing prcctedirgs which urged licensing boards tc take actions needed to assure :he efficient conduct of hearings.
C.
hRC's seal is to encourage a high level of quailty in reactor design and construction. The NRC needs te be:ter understand the causal factors
. leading to problems and to cecrease the probability that past mistakes w'1 be repeated.
3.
The Commission intencs to make its requirements kncwn for both maintaining plants (including documentation requirements) and reactivating projects whose construction and licensing have stepped.
a.
The problems to be faced when a request for an operating license extension is received are complex and require advanced planning. The Ccomission intends to begin develcpment of the policies and criteria to defire requirements for. operating license extensions to help assure that
'rdustry's efforts in this area are fccused on the primary regulatory cercerns.
5.
The Commission's scal is the approval of essentially ccmplete standard plant designs.
There are advantages to the develcpment and use of standardi:ed nuclear steam supply system and balance of plant desicns.
Such designs can benefit public health ano safety by cercentrating the resources of designers, engineers and vendors on particular approaches, by stimulating stardardized programs of constructicr. practice and quality assurance, by improving the training of perscnr.el ard by fostering more effective mainterarce end improved operation. The use of such designs car, also permit more effective and efficient liccrsirg and inspection
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processes. Therefere, the Ccnmission endorses regulatory actions that will strongly encourage industry to pursue starderdization in future reactor designs.
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. 6.
The NRC will maintain the capability to respctd to innovative and advanced reactor designs that might be presented for Cornission review.
Advancea reactcr cencepts shall be pursued within the fracewor!- developed in the Advanced Reacter Pelicy Statement and consistent with programs adoptec by the Executive Branch, tne Congress, er a fccused private sector effort alone or ir cerbination with the goverrtent.
Planning Guidance 1.
Consistent with maintain 1n5 acequate levels of protection and withcut meetirg legal requirements for operating facilities, staff reviews and public hearings shouic be ccn.pleted on a schedule that assures the licensing process will not be a critical path item which could unnecessarily delay reactor star:cp.
E.
The staff will continue to imprcse ticse activities that affect the quality of design and construction, fr.rticularly with respect to tlie translation of applicants' design ccrmitments in the licensing process ir.to plant hardware, procedures, staffing and training.
Inspecticn prcgrams associated with desier ar.d construction should continue tc be integrated to assure that applicant!' ccmmitments are carried cut in the construction process.
3.
The sta'f shceld carefully consider, cr. a piar.t-specific basis, the aecessity for some. reactor cperators with commercial experience 'at every
. plant.
In addition, it should consider the competence and experience of the management and staff before licensing each facility.
4.
In view of the r.trber of plants that have been postponed in the miost of construction, the staff will consider the legal and technical ramificattuns shculd a utility desire to reactivate a proje'ct after constructicn and licensing have stopped. The staff should propose pclicy guidance and develop precedures and requirements for mothbal-ling and for proceeding with such projects by the end of 1986. The IMC inspection approach for such plants should reflect lessons le.arned.
Eeginning in FY 1987, the staff shculd be prepared for a possible a
rec,uest to restart construction on ceferred plants.
5.
In view cf irdustry initiatives to address plant life extensions, the staff should propcse policy guidance and develop licensirg criteria to defire requ'rer.ents for operating license extensions. The staff should work with industry to ensure that key regulatory issues are identified.
6.
The staff shculd propose revisions to the Commicsicr's 1978 Policy Statement on Star.dard Plants and associated regulatices to reflect the Commissien's sesere accident policy.
7.
The staff should prepare for Ccemission consideration prcpesed Ccenission cctiers which will encourage industry to prcceed witn standardization.
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. An option that should be considered is formal NRC certification of standard designs (including balance of plant) and limiting applicaticrs for a license to certified standarc cesigns.
8.
Curing 1986, the staff should develcp revised procedures for the review and licensing of new standardized nuclear power plant designs and to review and preapprove potential plant sites by revising our licensing procedures as necessar,v.
9.
Through the remainder of the 1960's, the NRC should continue to maintain its capability to review, in a timely manner, applicaticns for stardardized plants and preapprcved sites.
.G.
The stiff will develop draft guidelines on chat:ses to general design criteria and to the regulations to accommodate advanced reacters.
- 11. Staff should evaluate and explore the scfety characteristics of new reactor types as such new reactor concepts evolve and core befcre the Commission.
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PREDICT THE EXTENT TO WHICh ABNORMAL OPERATING CONDITIONS WILL DEGRADE SAFETY Policy 1.
The NRC will develop and maintain an adequate understanding of hcw reactor safety systems ard ccmponents behave under postulated accident conditions. The NRC will evaluate majcr reactor safety systems so that the agency can identify potential weaknesses and provide alternatives or identify necessary backups to prevent accidental releases of radic-activity. Revisions to reculet4cns or licenses should be developed to it.piement any needed regulatory recuirements.
2.
The PRC will assess the ability of containmen:
prevent accidental releases under pcstula ed acc1 cent conditions so that the public can be assured that, in the event of an accident, racioaccivity is contained within the facility.
In this connection, the severe accident research program must provide timely information in the Cccrission's decision-making process on severe accicents.
Diannino Guidance 1.
The staff shculd expecitiously carry out those activ* ties necessary to irplement the Commission's severe accident policy.
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In its safety systems evaluation, including postulated accident secuences, the NRC will conduct research on complex operational cod thermal-hyraulic transierts.
E.
RESOLVE REACTOR SAFETY CONCERNS Policy 1.
NRC must be ser.sitive te the large number of rrquirements imposed on licensees.
Requirements imposed on the regulated industry by NRC are to previde a positive ccr.tribution to the public health and safety or cona.cr. defer.se and security, not only irtividually, but also when the requirements are taken as a whcle. Recuirements proposed to achieve increcental reductions in risk sbculd be evaluated on a cost-benefit J
basis, insofar as practicable. New reouirements will be imposed en existtr.g licensees only in accordance with the Commission's backfit rule.
There should be no unnecessary regulatory burdens. NRC regula:icns shculd allcw individual licensees the flexib111ty to select the most ccst-effective ways to satisfy NRC safety objectives, particularly for plant specific requirements.
In cases s,here there are conflicting priorities in establishing and implementing new requirements, pricrities will be based on the expected safety-benefit potential and costs associated with the new requiremert.
2.
To the extert practicable, issues which affect runerous licensees should be addressed in the consex of rulemaking or standard orders as cppesed
. to case-by-case review.
Insofar as practical, an effort thculd be made to avoid requirements which would build in more cifferences among plants than already exist.
O.
Where cata permit, probabfiistic risk assessment is a useful teci for assessing the reliability cf safety systems and for weighing risks against one another. Quantitative risk assessment techniques will be used judicicusly by the staff and the boards to estimate risks
- as an aid to decisionmaking.
4.
Unresolved safety issues should' be promptly pursued.
Friorities
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for implemertation should be establis. Sed in light of the safety significance of the issue and all other requirements imposed en the licensee.
5.
The Commission has decided to improve its characteri ation of radioactive source terms before proceeding with related changes te regulations.
1 Changes to current regulatory policies will be consicerea if the reassessment of the radioactive scurce terms arc their risk importance so warrants.
6.
The Ccmmission has developed preliminary safety goals and related safety guidance. These preliminary safety goals and ouartitative design objectives will not be used as a basis icr making regulatory decisions during the evaluaticn period.
. P?anning Guidance 1.
The ED0 has overall authority and responsibility for managing backfitting. The staff shculd diligently manage backfitting 'or reactors under construction or in operation in acccraance with the backfit rule.
2.
The Committee for Review of Ger.eric Requirements (CRGR) shall continue to review and make reconmendations to the EDO on proposed generic requirements for reactor licensees.
The CRGR shall continue to assure that proposed requiremer ts (a) contribute to the protection of public health ard safety or ccmnon defense and security, and (b) provide for the utilizatfor, of bcth fRC cod 'icensee resources in a manner which effectively ard efficiently achieves prctection cr the public.
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3.
Existing regulatcry requirerents should be reviewed te see if some could be elimirtted without compromising safet; cr safeguaros or environmental protection. For those requirements that are necessary. effective measures shculd be taken to ensure that they are implemented in a timely manner.
4 The staff should continue its ef#crts to establish an integrated icplementation scheoule for rew and existing requirements reflecting relative priorities for each pcwer reactor licensee. Where practical, and where the degree of uncerstanding and data permit, the results of cost-benefit analysis should be used as cr.e tool for evaluating new
. requirenents. The schedules should reilect the importance cf the requirecert to safety or safeguards, as well cs the licensee's ability to complete the necessary engineering, evaluation and desien. Or.ce compliance dates have been established, the Ccamission will vigorously enforce license requirements associated with such schedules.
5.
The staff shocid centinue to assure that licensees implement all existing and new requirements which are imposed and to verify licensee imple-mentation as appropriate.
6.
The Commission reccgnizes the value of foreign experferce in helping NRC identify ard eva'uate possible approaches tc resolving regulatory issues and char.ges to improve U.S. regulatory prccesses ard reoufre-ments. The Staff should continue to maintain ar understanding of regulatory practices cf fcreign countries with respect tc subject areas of spe.cial interest.
7.
Attention should be given to refindng the use of probabilistic risk assessment techniques to implerent Ccmmission policy on saf'ety sccis, as directed by the Commission, and in cther regulatory applications especially amenable to risk assesscent. Whenever probabilistic risk assessnient is used in the decision-makf r.c process, there must be clear statenents of the scope and depth. cf the assessment, clear identification cf the most significant assun>pticns, and a systematic evaluation cf the' rust important uncertainties.
E.
Attention should be given to cevelcping an integrated program for the cellection, analysis and distribution of data needed for risk assessment.
9.
The staff should continue the efforts approved in the NRC Human Factors Program Plan. The staff shcuiu make effective use of available Feran facters data and take industry efforts (such as INP0 and NUMARC) into r
account in developing NPC prcgrams.
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- 10. The radicactive source terms and their risk irportance should be better characterized by a systeratic analysis of accident sequer.ces, contain-A ment perforrance and the release and trarsrcrt cf radioactivity.
reassessment of radiccctive scurce terms should be cenpleted in 1986.
If suppcrted by the reassessment, the staff shcu'd develop a *eviseo, more realistic source terr ard draft modified reyilations, as justified by the rev scurce tena and risk data.
- 11. In 1986, the staff will provice the Commission with reccrrerdetions on proposed safety Scals resulting from the two-year evaluat on period.
The i
recommendations shculo ciscuss in detail the regulatcry frplications of Liie safety goal.
Ic.
By the end of 1986, to the extr:nt practical, the staff will issue for public ccreent draft technical resciutions for currently identifiec unresolved safety issues. The Staff shculd continue to review and
- pprove the addition of rev ger.oric safety issues in accorcarce with current Ccnmission policies, and giver. rescurce constraints, resolve the high priority issues tirst.
4 F.
LICENSE AND MONITOR MATERIALS LICENSEES / FUEL CYCLE FACILITIES Policy 1.
Byproduct, source and special nuclear materials must receive regulatory attention cerrmersurate with their potential hazards tc the public and to the users of these materials.
Efforts to achieve greater standardization f
of material licensing reviews and consistency in application of regulatory requirements should be continued.
i 2.
The Coninission intencs to pursue regulatory efforts aimed at improving radicgraphy safety.
3.
The Comissict consicers the regulation of the trcnsprrtation of l
ruclear crc radioactive materials to be an important part of its responsibilities.
Planning Guidance i
1.
Applicable regulations shnuld be revieweo anc upcated to provide the necessary degree of regulation wi-h a fccus on performance requirerents.
E.
Peculations to consolidate and streamline the safety requirements i
associated with medical use of Dyprccuct riaterials and well-leggirq sbculd be promulgated along with c sociated regulatory guidance, standard review plans and inspection procedures by the end cf 1986.
- 2.
Regulatory efforts to improve radiography safety, in particular thrcuch the establishment of perforcance stancaras, as well as more effective training and inspection programs, shculd be completed by July 1986.
Rulemaking to improve safety sFculd Le cocrainated through the ad hoc Radiography Steering Committee.
4.
The statf shall continue oevelepr.er.t of regulations to implement the Environmental Protectier M ercy (EPA) mill tailings standarcs for groundwater protection. Efforts to ceveler alternate concentration limits methodology,icir+'; with EPA should receive high priority.
5.
The staff shoulu assure that NRC respcnsibilities in regulating the transportation of special ruc1ccr related and racioactive materials cre ccordinatec with other Federal agencies te achieve an integrated Federcl Program for protecting the putl'c health and safety, conEcn oefense ced security, and environment, uh'!c mirimizing unnecessary inpacts on the regulated incustry.
G.
REGULATE HIGH LEVEL WASTE Policy 1.
The NRC Figh Level Waste Managemert Prcgrem is critical to the success of an urgent national task. hkC will provide the necessary pre-licensing ccnsultation, and licensing and regulatcry oversight and guidance for
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the Executive B:anch's program as requireo by the Nuclear Waste Policy Act of 1982 (NWPA), the Atomic Energy Act, Energy Reorganization Act, the t:ational Environmental Policy Act, ano the Commission's regulaticts.
NRC's programs, including the necessary research and development, will te directed to an effect;ve and efficient discharge of its responsibilities based or tFc premise that, in the absence of unresolved safety concerns, the NRC regulatory progrcm will ut delay implementation cf the Executive Branch's precrm as reflected in the Department of Energy (DOE) project decision schedule and mission plan.
If it becomes clear that NRC cannot maintain its schedule due to the unavailability of resources or other factors, the staff will promptly inform the Commission se that the required notification of 00E and the Cergress can be made.
C.
TPe staff should continue to maintain close communications with COE, the etates and affected Indian tribes 50 that required activities and lead times are identified early in the planning process.
3.
To the extent pcssible, and consistent with NRC's irdcpendent role, system development reoufred to support programs to implement the NWPA should be performed by COE. NRC will continue its technical program to support the development of licensing criteria and evaluation methods, and the early ioentification and resolution of techricel and quality assurance or ccrtrel issues.
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. Planning Guidance 1.
The staff st. cult review the existing and prcpcsed regulations that are covered by areas addressed by the NWPA, and make conferring changes as necessary. The staff should formalize the procecures for documenting agreements between the AP.C and 00E staffs on the resolutice cf technical issues that wculo otherwise be open issues during the license review.
2.
The hWPA has established that nuclear utilities have the primary responsibility for irterim storage of spent fuel, pending repository operation or avaiicbility of monitored retrievable storage. The NRC should review in c tirely manner, consistent with safety and legal requirements, utility proposals for adding spent fuel storage capacity to assure that, in the abserce of unresolved safet; concerns, regulatory actions ao nct urmecessarily affect reactor operaticr.. NRC cust also be prepared to conduct' licensing reviews specified t) the hhfA for limited federal interim s:crage capacity of spent fuel whicF r.ay be prop'osed by 00E. The hRC should certinue to develop the basis for rulemaking that would, to the extent practicable, enable use cf try spent fuel storage casks without site-specific licensing reviews.
3.
The staff should establish licensing requirements and be ready to r; view proposals for monitored retrievable storage facilities in the evect the Ccrgress authorizes the Departr.cnt of Energy to proceed with such facilities.
i
t.
- 4.
The NRC will continue its research efforts to develop methods for repository and waste packesirg performance assessment in suppcrt of tne agency's high-level "aste regulations and asscciated regulatory guides.
i 5.
The staff shculd certinue to coordinate with DOE in defining the requirements for a licensing informatier renagement system to be implemented by 00E to suppcrt a three year high level waste repository construction authorization review. The staff wiil identify its needs to DOE so that NRC will not develer a redundant system.
H.
REGULATE LOW LEVEL WASTE Policy 1.
The NRC will continue to regulate luw-leve? waste in accordance with its regulations anc applicablo law.
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Plannir.c Ce'tance 1.
The staff shall monitor the activities assceiated with the implementa-ico cf the Low Level Radioactive Fatte Policy Act and shall apprise the Cetmissicn of any problems requiring Ccrmission action along with reconmendations for each acticn.
f.
. 2.
The staff shall continue to develop the necessary technical cuidance for applicants who may wish to pursue approaches other than shallow lanc burial fcr the disposal of low level veste.
3.
The staff shall be prepared tc review or assist Agreement States in the review of applications for low-level waste disposal facilities.
I.
FERFORM SAFEGUARDS REGULATORY ACTIVITIES
?*)1SX 1.
Safeguards are an integral and onscing element of the Commission's respcosibility. Safeguards regulaticn shculd ha conducted with the same defense-in-depth philosophy as safety regulatior.. Impler.entaticr cf safecuards requirements shall not be contrcry to the safe operation of a facility. Safety inpacts cf all new safeguards requirecents shall be evaluatec. Emphasis snould be given to perferracce requirements rather than prescriptive requirements to allow licensees to select the rest cost-effective ways to satisfy hRC requirecen'.s. Safeguards must be effective and commensurate with threat levels as approved by the Contiission.
2.
The proliferation cf nuclear explosives technologj pcses a threat to the security interests of the United States. Hence, the f.EC will carefully discharge its stctutory licensing responsibilit'er. te ersure that
+
. necessary controls are applied to the import and expert of nuclear materials, equipment, and facilities.
3.
Steps should be taker expeditiously to convert, to the extent practi-cable, non-pcwer reacters to the use of low-enriched cranica rather than highly-onriched uranium.
Planning..uidance G
1.
Evaluation of scfeguards events will serve as a basis for regulatory change and response. This evaluation should include ocnestic events
-- within both the ecferse and the regulated corrunity -- anc foreign events. Hcwever, the staff should not wait fer rignificant events to occur before undertakire safeguards changes that are constderea The staff should continue te evaluate th'reat levels basea necess6ry.
on intelligence infcreaticn received from other governnen: ager.ctes as well as on experience.
2.
The staff, in addition to assuring that safeguards plans are in place at operating facilities and for trarsportation, will contirrc its independent assessment that these implemented plans meet safeguards objectives and that safeguards regulations adequately surrrrt those cbjectives. An annual report shall be providtc to the Commission detailing the results of the previous year's assessrects.
The report shall contain rcccreendations for continuing cr discontinuing the assessment.
. 3.
The staff will implement the rule convertirg non-power reactors to lev erriched uranium fuel. The staff shoulo expedite rulemaking to irpreve physical security measures at researen reactors.
4.
The NRC will centf rue to meet its commitments fcr the implementation of international safeguards at U.S. Ifcensing facilitics and to work with the Executive Branch as the U.S. pursues improvements in international safeguards.
J.
REVIEW ALLEGATIONS AND CONCCCT IhVESTIGATIONS Policy 1.
The Office of Ir%Ettiretions shall investigate r:gnificant allegations of wrongdoing by other than NRC erployees and contractors as requested by the Comnission. ECO. Regional Administratcrs, or on its own initiative.
2.
Investigations should be -hercugn and should try to identify the root causes and reasons for violations. When initial collection of evidence indicates that the matter ir.sclves criminality, appropriate referrals will be made to the Department of Justice.
Planning Guidance 1.
The Office of Investigaticns, in coordination with the ECO, should exped't'ously develop appropriate threshold levels and the priorities for initiating and terminating investigations.
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l 2.
The EDO should provide technical support to the Cffice of Investigations in the conduct of innstigations with due regard to their trutuai priorities.
3.
Censistent with available rescurces, investigations should be per< creed ir, a tir:ely manner.
Findings anc conclusicns en questions of intent e
end willfulness should be prcvided ;o cogr.izant offices.
Findings of potential safety significar.c6 shculd be imediately referred to the cegrizant office.
i 4
Close ccorcination should be maintained as apprcpriate between the Offices of Investication, !nspaction and Enforcement, f uclear Reactor Regulaticr, Nuclear Material Safety and Safeguares. Analysis and Evaluation of Operaticnal Data, and the Regionai Offices. The results of investigeticris shculo be followed by appropriate acticn or the part of cognizant offices and the EDO.
K.
TAKE ENFORCENEf(T_ ACTIONS Folicy 1.
NRC should tr. air.tair er effective enforcement progrerr with ur.1 form and timely applicaticri of enforcerent policy throughcut tFe regicnal offices.
Enforcement pclicy will be firm but fair.
The principal goals of NRC's enforcement prograr,i w111 Le to assure safety through cerpliarce with NRC safety ar.d safeguards requirements.
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. 2.
NRC enforcement activities rust be directed to assure that licersee ccrrective actions of deficiencies in performance are appropriate and that future ccmpliance with recuirerents is ensured.
For licensees that have a history of noncompliance, prcept and vigorous action will be taken. A licensee must ret cer,efit by violating NRC regulaticns.
Licensees who cannot achieve and maintain an adeccate level of protectier of the public health and safety, safeguards, and the environment will ret be perr.ittea to operate.
Inspections cr vbich enforcement activities are based should be thorough and stet 1d seek to identify the basic reasors why v1clations and deficiencies occurred.
3.
Enforcerent actions should encourage an aggres:4ve approach by licensees to ensure cdeque e prctecticn, and credit shouic be given fer prompt reportirt cf ceficiencies by licensees ard for recept, thorough, and voluntary corrective actions.
Planning Guidance 1.
The Commission bas establisned an Ad-Hoc Advisory Ccnr.f t+.ee fer Review of j
the Enforcement Policy ccr.403ed of incividuals witt, o her;e backgrounds.
The Commission will consider the Committee's reccrrendations for changes in the enforcen.ent policy.
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L.
ADEQUATELY MANAGE AFP SUFFORT TECHNICAL PROGRAMS Pelicy 1.
NRC's greatest resuurce is its employees.
2.
The Commissier reeds tc consolidate its staff and headquarters personnel in order to achieve more efficient and effective mar.rgement sf the Agency.
3.
The NP.C shcuic assure greater commercial reacter cperating expertise within the agency thrctgr training, hiring, and promotior, practices and ccmr.ur.ication internally and with the f eder*ry.
4 Irferraticn technology should be used tc more efficiently accomplish NRC's mission, if it is cost-effective.
Planning Guidance 1.
N?.C managers should give high priority to training art assigning erployees in ways that make the most cf actual ard potential expertise, including creetive affirmative action and upward nobility strategies that tche full advantage of employee's ski!!s and abilities. NRC managers should alsc give high priority to programs to provide agency personnel with r.ecded training and experience.
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2.
The Commission will continue tc pursue consolidation of its Fashingtcr, D.C. area operations in one location.
3.
Mindful that NRC's recruitrer.t c'# orts should avoid having acuerse effects on industry programs to trcin ard maintain experierced operators.
the stcff should centinue the effort te erplcy irdividuals with commercial reactor operating expericrce, d.
The staff should develop a plar, explaining how informatiun techtclegy will be used in meeting NRC's regulatory ctjectives. The plan should explain how teleccmmunicat cns, cccument storage and retrieval, ard data i
processintj will be integrated.
5.
The Executive Director for Cperations (E00) wil! assure that the The necessary agency resources are appl'ed to icplement this document.
ECG will maintain a management system for the Commission to track tajcr prc5 ram accorplishments that suppert ttc Policy and Planning Guidance, acc, when developed, the Five Yeer Plan 6.
In order to facilitate information flow, the Ccmmission intends to meet with the staff on a rugular basis in areas of particolar interest; for example, tc discuss progress in implement 1rg specific. regulatory programs, to receive reports cr serious safety concerns, to expicre activities in the regions, ano to hear frcr. various advisory panels.
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