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AVAILABILITY OF REFERENCE MATERIALS 

IN NRC PUBLICATIONS

NRC Reference Material 

As of November 1999, you may electronically 

access NUREG-series publications and other 

NRC records at NRC's Public Electronic Reading 

Room at www.nrc.gov/NRC/ADAMS/index.htmil. 

Publicly released records include, to name a few, 

NUREG-series publications; Federal Register 

notices; applicant, licensee, and vendor 

documents and correspondence; NRC 

correspondence and intemal memoranda; 

bulletins and information notices; inspection and 

investigative reports; licensee event reports; and 

Commission papers and their attachments. 

NRC publications in the NUREG series, NRC 

regulations, and Title 10, Energy, in the Code of 

Federal Regulations may also be purchased from 

one of these two sources. 

1. The Superintendent of Documents 

U.S. Government Pdnting Office 

P. O. Box 37082 

Washington, DC 20402-9328 

www.access.gpo.gov/su_docs 

202-512-1800 

2. The National Technical Information Service 

Springfield, VA 22161-0002 

www.ntis.gov 

1-800-533-6847 or, locally, 703-805-6000 

A single copy of each NRC draft report for 

comment is available free, to the extent of 

supply, upon written request as follows: 

Address: Office of the Chief Information Officer, 

Reproduction and Distribution 

Services Section 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

E-mail: DISTRIBUTION@nrc.gov 

Facsimile: 301-415-2289 

Some publications in the NUREG series that are 

posted at NRC's Web site address 

www.nrc.gov/NRC/NUREGS/indexnum.html 

are updated periodically and may differ from the 

last printed version. Although references to 

material found on a Web site bear the date the 

material was accessed, the material available on 

the date cited may subsequently be removed 

from the site.

T

Non-NRC Reference Material 

Documents available from public and special 

technical libraries include all open literature 

items, such as books, journal articles, and 

transactions, Federal Register notices, Federal 

and State legislation, and congressional reports. 

Such documents as theses, dissertations, foreign 

reports and translations, and non-NRC 

conference proceedings may be purchased from 

their sponsoring organization. 

Copies of industry codes and standards used in a 

substantive manner in the NRC regulatory 

process are maintained at

The NRC Technical Library 

Two White Flint North 

11545 Rockville Pike 

Rockville, MD 20852-2738 

These standards are available in the library for 

reference use by the public. Codes and 

standards are usually copyrighted and may be 

purchased from the originating organization or, if 

they are American National Standards, from

American National Standards Institute 

11 West 42d Street 

New York, NY 10036-8002 

www.ansi.org 

212-642-4900

The NUREG series comprises (1) technical 

and administrative reports and books 

prepared by the staff (NUREG-XXXX) or 

agency contractors (NUREG/CR-XXXX), (2) 

proceedings of conferences 

(NUREG/CP-XXXX), (3) reports resulting 

from international agreements 

(NUREG/IA-XXXX), (4) brochures 

(NUREG/BR-XXXX), and (5) compilations of 

legal decisions and orders of the Commission 

and Atomic and Safety Licensing Boards and 

of Directors' decisions under Section 2.206 of 

NRC's regulations (NUREG-0750).
NUCLEAR REGULATORY COMMISSION 

FY2000-2005 STRATEGIC PLAN APPENDIX 

VOLUME 2, PART 2
TABLE OF CONTENTS 

Nuclear Reactor Safety ........................................................ 1 

Nuclear Materials Safety ...................................................... 19 

Nuclear Waste Safety ......................................................... 39 

International Nuclear Safety Support ............................................ 59 

Corporate Management Strategies .............................................. 67 

Links to other Planning Documents, Program Evaluations, and 

Management Challenges ..................................................... 79 

Cross-Cutting Functions with Other Government Agencies ........................... 95 

Strategic Plan Component Schematic ........................................... 105 

Endnotes .................................................................. 107

NRC FY 2000 STRATEGIC PLAN

VOLUE 2, PART 2l
I *OUE2,PR

NUCLEAR 

REACTOR SAFETY 

STRATEGIC GOAL: Prevent radiation.rde ated deaths and illnesses, 

promote the common defense and security, and protect the environment 

in the use of civilian nuclear reactors

This strategic goal represents the focus of 

the Nuclear Reactor Safety arena. The goal is 

to achieve our statutory mission to ensure that 

civilian nuclear power reactors, as well as 

non-power reactors, are operating in a manner 

that adequately protects public health and 

safety and the environment and that safeguards 

special nuclear material used in reactors. The 

NRC regulates 103 civilian nuclear power 

reactors and 37 non-power reactors. 

Under Atomic Energy Commission (AEC) 

and NRC case law, reasonable assurance of 

adequate protection of public health and safety 

is, as a general matter, defined by the 

Commission's health and safety regulations 

themselves. That is, unless otherwise 

provided, there is reasonable assurance of 

adequate protection of public health and safety 

when the applicant or licensee demonstrates 

compliance with the Commission's 

regulations. The regulations were established 

using defense-in-depth principles and 

conservative practices that provide a degree of 

margin to unsafe levels. 

The collective efforts of the NRC and the 

nuclear industry are needed to maintain safety. 

The NRC licensees1 have the responsibility to 

safely design, construct, and operate civilian 

nuclear reactors. Regulatory oversight of 

licensee safety is the responsibility of the 

NRC. Thus, safe performance reflects the 

results of the collective efforts of the NRC and 

the nuclear industry.

i

Measures 

We will use the following measures2 to 

assess results in achieving the Nuclear Reactor 

Safety Strategic Goal: 

"* No nuclear reactor accidents.3 

"* No deaths resulting from acute radiation 

exposures from nuclear reactors. 

* No events at nuclear reactors resulting in 

significant radiation exposures.

4 

"* No radiological sabotages at nuclear 

reactors. 

" No events that result in releases of 

radioactive material from nuclear 

reactors causing an adverse impact5 on 

the environment. 

These measures represent abnormal 

occurrences that are reported to Congress and 

that are critical indicators of whether the 

strategic goal has been realized. Any 

occurrence would trigger a self-assessment of 

the NRC's Nuclear Reactor Safety activities to 

determine if changes are needed. 

The Commission recognizes the risks to 

the public from nuclear power plant operation. 

Therefore, in 1986, it promulgated the Safety 

Goal Policy (51 FR 28044) which expresses 

an acceptable level of the risk from nuclear

NRC FY 2000 STRATEGIC PLAN
NCERRATRSAFT VOL NI ,PRB

power plant operation by comparison with 

other societal risks. Notwithstanding that risk 

is inherent in reactor operations, the first three 

measures are being used as indications of 

whether we are achieving the strategic goal of 

preventing radiation-related deaths or 

illnesses. The fourth measure indicates 

whether radiological sabotages have occurred 

since such acts could result in core damage, 

radioactive releases, and significant radiation 

exposures. Lastly, we will measure how well 

the environment is protected by whether 

offsite releases have occurred that caused an 

adverse impact on the environment. 

PERFORMANCE GOAL.- Maintain 

safety, protection of the environment,, 

and the common defense and security.

Maintaining safety, protection of the 

environment, and the common defense and 

security is the preeminent performance goal 

and takes precedence over all other 

performance goals. In working toward this 

goal, the NRC will apply its Principles of 

Good Regulation. Principles applicable to this 

goal are related to independence, openness, 

efficiency, regulatory clarity, and reliability. 

The safety performance of the nuclear 

power industry has improved substantially 

over the past ten years, and nuclear reactors, 

collectively, are operating above acceptable 

safety levels consistent with the agency's 

Safety Goal Policy. The NRC believes this 

level will be maintained. If substantial safety 

improvements are identified, additional 

requirements should only be imposed 

consistent with the Commission's Backfit Rule 

(10 CFR 50.109). Allowing small-risk 

increases 6 may be acceptable when there is 

sufficient conservatism and reasonable

assurance that sufficient defense-in-depth and 

safety margins are present. Small-risk changes 

that reduce unnecessary burden will allow 

more efficient use of licensee and the NRC 

resources as well as bring into focus those 

areas that are more critical to the safety of the 

public and environment. We will use the body 

of domestic and international knowledge, 

experience, and research to determine when 

changes that could affect risk are acceptable. 

The NRC licensees will continue to have 

the primary role in maintaining safety and are 

expected to identify, through mechanisms such 

as operating experience feedback and 

integrated risk assessments, the design and 

operational aspect of their plants that should 

be enhanced to maintain acceptable safety 

performance levels. For nuclear power plants 

to continue operating, safety performance 

must be at or above acceptable levels. The 

NRC will take action to improve safety 

performance before it falls below acceptable 

levels and will require the shutdown of plants 

when their safety performance is identified as 

unacceptable. This principle is inherent in the 

NRC's new oversight process. 

Strategies 

The NRC will employ the following 

strategies to maintain safety, the protection of 

the environment, and promote the common 

defense and security: 

We will sharpen our focus on safety to 

include a transition to a revised NRC 

reactor oversight program for our 

inspection, assessment, and enforcement 

activities. 

We will increase the focus of inspections 

on those activities with the greatest 

potential impact on safety through the new 

reactor oversight program. Inspection

I

< NRC FY 2000 STRATEGIC PLAN
results will be evaluated routinely to 

determine the risk importance of the 

findings. These inspection results will be 

used along with pre-defined performance 

indicators (e.g., safety system 

unavailability) to provide an assessment of 

a licensee's safety performance. This 

assessment process is expected to be more 

objective, predictable, and risk-informed 

than the method previously in place. 

Allegations regarding licensee 

performance will be appropriately and 

objectively addressed in a timely manner. 

Allegations of potential wrongdoing will 

be thoroughly and objectively investigated 

in a timely manner. Enforcement sanctions 

for violations of regulatory requirements 

will be commensurate with the safety 

significance. The enforcement program is 

also being changed to be better linked to 

the safety significance of inspection 

findings and to emphasize the importance 

of the licensee's corrective action program. 

The improved safety performance of the 

nuclear industry is reflected in this strategy 

as discussed in the first two Major 

External Factors. We will coordinate with 

DOL and DOJ regarding discrimination 

and civil enforcement actions as reflected 

in the section on Cross-cutting Functions 

With Other Government Agencies. 

We will respond to operational events 

involving potential safety or safeguards 

consequences. 

We will provide timely, accurate, and 

complete assessments of events by 

evaluating recommendations of the 

licensees for actions to protect the public 

and by coordinating with other federal 

agencies, state and local governments, and 

the licensee. We will maintain and operate 

a continuously staffed Incident Response 

Operations Center to support the agency in

I

responding to operational events. We will 

conduct periodic exercises to ensure that 

response organizations are proficient and 

experienced and that staff are trained to 

respond to operational events according to 

their safety significance. We will also 

maintain incident investigation 

capabilities. We will work closely with 

FEMA, DOE, EPA, USDA, HHS, NOAA, 

and State Governments to maintain 

incident response capabilities and during 

actual incident response under the Federal 

Radiological Emergency Response Plan. 

We will work closely with FBI and CIA 

for response to a suspected terrorist or 

criminal initiated threat or incident. These 

alliances are reflected in the section on 

Cross-cutting Functions With Other 

Government Agencies. 

" We will evaluate operating experience and 

the results of risk assessments for safety 

implications. 

We will evaluate the risk significance of 

operational events and trends in data in 

conjunction with risk assessments so that 

safety vulnerabilities can be identified, 

prioritized, communicated, and resolved 

on a timely basis. Operational experience 

will also be used by the staff to improve 

our regulatory activities including 

licensing, inspection, and risk assessments. 

We will also review operating experience 

of foreign plants for safety insights. We 

will monitor for potential adverse effects 

on nuclear safety from the economic 

deregulation and restructuring of the 

electric power industry. 

" We will identify, evaluate, and resolve 

safety issues, including age-related 

degradation, and ensure that an 

independent technical basis exists to 

review licensee submittals to ensure that 

safety is maintained.

NRC FY 2000 STRATEGIC PLAN

I OUE2 AT2NCERRATRSFT
R R R V M 2, P

We will conduct research to improve our 

knowledge in areas where uncertainties in 

our knowledge exist and may be 

significant to risk and where safety 

margins are not well characterized. 

Priorities for these activities will consider 

risk significance and cost/benefit analyses. 

For example, we will evaluate potential 

degradation of plant systems as they age 

and ensure that data and methods, 

including international lessons learned, are 

available to evaluate this degradation and 

the effectiveness of corrective strategies. 

We will continue our international efforts 

to collect and evaluate information that 

contributes to the efficient resolution of 

domestic safety issues. We will conduct 

research in cooperation with domestic and 

international entities to ensure that an 

adequate independent technical basis, as 

well as related codes, standards, and 

methods, exists to review and approve 

licensee or industry proposals. This will be 

especially important as new technologies 

are introduced. For complex technical 

issues, we will develop a better 

understanding of existing safety margins, 

resulting in more informed regulatory 

decisions. We will maintain our program 

for generic safety issue prioritization based 

on consideration of potential risk reduction 

and cost. 

° We will ensure that changes to operating 

licenses and exemptions to regulations 

maintain safety and meet regulatory 

requirements. 

We will issue license amendments and 

approve license transfers for nuclear 

reactors only after determining that there is 

reasonable assurance that the authorized 

activities can be conducted without 

endangering the health and safety of the

public and the environment. This includes 

emergency planning, physical protection, 

quality assurance, training, financial 

assurance, and other requirements. We will 

give priority to those licensing actions and 

exemptions that provide the greatest safety 

benefit to the public. We will maintain an 

effective regulatory infrastructure to assure 

maintenance of safety during the 

construction of envisioned advanced 

reactors and we will encourage applicants, 

vendors, and others to inform the NRC at 

the earliest opportunity of planned future 

reactor activities so that we will be 

prepared to respond. 

° We will ensure that safety is maintained as 

licenses are renewed by ensuring that 

aging effects will be adequately managed 

and that the licensing basis related to the 

present plant design and operation will be 

maintained. 

We will authorize license renewal only 

after we have determined that aging effects 

have been and are being adequately 

managed. We will ensure that the licensing 

basis related to the present plant design 

and operation will be maintained 

throughout the period of extended 

operation. We will perform inspections to 

support the review of license renewal 

applications by verifying the acceptability 

of licensee aging management control 

processes. 

* We will maintain safety by ensuring that 

operator licenses are issued and renewed 

only to qualified individuals. 

We will maintain an operator licensing 

program for the issuance and renewal of 

licenses to operators and senior operators 

of nuclear reactors. The NRC licenses will

0 NRC FY 2000 STRATEGIC PLAN
VOLUE 2,PART2 NULEARREACOR SFET

only be issued to individuals following a 

finding of adequate health and successful 

demonstration of their ability to operate a 

facility competently and safely and, 

additionally, in the case of senior 

operators, a demonstrated knowledge of 

directing the licensed activities of licensed 

operators competently and safely. 

We will continue to develop and 

incrementally use risk-informed and 

where appropriate, less prescriptive 

performance-based regulatory approaches 

to maintain safety. 

Stated succinctly, risk-informed, 

performance-based regulation is an 

approach in which insights, engineering 

analysis and judgment, and performance 

history are used to (1) focus attention on 

the most important activities, (2) establish 

objective criteria based on risk insights for 

evaluating performance, (3) develop 

measurable or calculable parameters for 

monitoring system and licensee 

performance, and (4) focus on the results 

as the primary basis of regulatory 

decision-making. 7 As part of our agency

wide Risk-Informed Regulation Imple

mentation Plan (to be completed by FY 

2001), we will implement an incremental 

approach to risk-informing the reactor 

oversight process and risk- informing the 

scope of 10 CFR Part 50. We will also 

assess the technical requirements 

associated with 10 CFR Part 50 and make 

changes to ensure that safety is maintained 

by sustaining our regulatory focus on plant 

equipment and technical requirements that 

contribute to nuclear reactor safety. We 

will consider and use international 

experience in developing approaches to 

risk-inform our regulations. Mindful of the

limitations in risk assessment methods, we 

will improve these methods and tools in 

areas where there needs to be a better 

understanding of contribution to plant risk 

through research and through cooperative 

programs with international partners. 

Measures 

The NRC will use the following 

measures2 to assess results in our efforts to 

maintain safety, and protection of the 

environment, and promote the common 

defense and security: 

" No more than one event per year 

identified as a significant precursor of a 

nuclear accident.8 

" No statistically significant adverse 

industry trends in safety performance.9 

" No events resulting in radiation 

overexposures1 ° from nuclear reactors 

that exceed applicable regulatory limits. 

" No more than three releases per year to 

the environment of radioactive material 

from nuclear reactors that exceed the 

regulatory limits. 11 

" No breakdowns of physical security that 

significantly weaken the protection 

against radiological sabotage or theft or 

diversion of special nuclear materials in 

accordance with abnormal occurrence 

criteria. 

The threshold for a reportable event is 

more stringent for performance goal measures 

than the strategic goal measures. They provide 

the opportunity to detect programmatic 

weaknesses before the strategic goals would 

be exceeded. However, since target values are

NRC FY 2000 STRATEGIC PLAN 0
N R S V 2, P

numbers of events reported, the targets for 

strategic goal measures could be exceeded 

without exceeding performance goal measures 

which allow a higher number of events (e.g., a 

substantial event could cause NRC to exceed 

the no event target value for the strategic goal 

measure, but not exceed the target value for 

the performance goal measure which has a 

target value greater than zero. Accidents that 

involve substantial core damage or a release of 

radionuclides can be minimized by 

maintaining a low frequency of events that 

have the potential to lead to a nuclear reactor 

accident or large early release; therefore, we 

will measure such precursor events. To ensure 

that the nuclear industry as a whole is 

maintaining safety, we will monitor industry 

performance to identify any adverse trends. To 

prevent radiation-related deaths and illnesses, 

we will measure the number of radiation 

overexposures. We can measure our 

effectiveness in protecting the environment by monitoring radiological releases and by 

preventing radiological sabotage or theft or 

diversion of nuclear materials. If the metrics 

are not met, the agency will review its 

regulatory practices and licensee actions to 

determine whether corrective action is 

necessary to maintain safety.

PERFORMALNCE GOAL: Increase 

public confidence. I i

The NRC views building and maintaining 

public trust and confidence that the NRC is 

carrying out its mission as an important 

performance goal for the agency. To reach this 

goal, the NRC must be viewed as an 

independent, open, efficient, clear and reliable 

regulator. This will be accomplished by 

providing our stakeholders with clear and

accurate information about, and a meaningful 

role, in our regulatory programs. The NRC 

desires that diverse stakeholder groups (i.e., 

general public, Congress, NRC licensees, 

other Federal agencies, States, Indian Tribes, 

local governments, industry, industry workers, 

technical societies, the international 

community, and citizen groups) increasingly 

recognize that NRC actions assure that public 

health and safety, the common defense and 

security, and the environment are, and will 

remain, adequately protected from hazards 

resulting from the use of nuclear reactors. 

Public concern about nuclear safety has at 

times been high, particularly for the public 

who live near nuclear facilities. The methods 

provided by the NRC for members of the 

public to express their views have been 

perceived by some members of the public to 

be insufficient in some circumstances. This 

goal reflects the NRC's desire to improve in 

this area, which would include explaining the 

NRC's roles and responsibilities and how 

public concerns are considered. 

This performance goal stems from the 

recognition that the NRC must be candid with 

the public about reactor safety incidents and 

issues, provide opportunities for meaningful 

public participation, and demonstrate through 

our performance that we are capable, 

independent, and objective regulators. It also 

stems from recognition that, while the public 

may not always agree with NRC actions, 

public confidence in the NRC is enhanced 

when the agency consistently carries out its 

mission in a thorough, disciplined, and timely 

manner. 

Strategies 

The NRC will employ the following 

strategies to increase public confidence:

i

0 NRC FY 2000 STRATEGIC PLAN
We will make public participation in the 

regulatory process more accessible. We 

will listen to the public's concerns and 

involve our stakeholders more fully in the 

regulatory process. 

One of the attributes of strong, fair 

regulation of the nuclear industry involves 

consistent and timely public involvement. 

The agency recognizes the public interest 

and concern in the proper regulation of 

nuclear activities, and recognizes its 

responsibility to provide opportunities for 

meaningful public interaction and 

involvement. We will listen to, and be 

responsive to, requests, inquiries, and 

concerns from the public. We will consider 

public views in planning changes and 

making decisions relating to our practices, 

rules, and processes through holding open 

meetings in the vicinity of the nuclear 

facilities; providing adequate notice of 

meetings; developing communications 

plans for major regulatory activities; and 

holding workshops. 

We will communicate more clearly. We 

will add more focus, clarity, and 

consistency to our message, be timely, and 

present candid and factual information in 

the proper context with respect to the risk 

of the activity. 

Public confidence in the NRC will be 

enhanced if information is presented in a 

manner that is easily understood and 

placed in its proper safety context. We will 

respond to the requests, inquiries, and 

concerns of our stakeholders in a timely, 

courteous, and professional manner. 

Whenever possible, we will use quick, 

personalized forms of contact with our 

stakeholders. Our communications with

the public will be designed to foster 

greater understanding of the NRC's role in 

protecting public health and safety and 

thereby enhancing public confidence in 

our regulatory program. The information 

we disseminate, both domestic and 

international, will be clear, technically 

sound, accurate, reliable, objective, and 

timely. We will take full advantage of the 

Internet and new technology for 

information dissemination. We will protect 

the private, proprietary, and classified 

nature of information. All stakeholders 

should be able to rely on our statements 

and information. 

We will continue to enhance the NRC's 

accountability and credibility by being a 

well-manage4 independent regulatory 

agency. We will increase efforts to share 

our accomplishments with the public. 

The public's confidence that nuclear power 

is safe is influenced by the public's 

perception of the NRC as a well-managed, 

independent regulator. As part of 

implementing a Planning, Budgeting, and 

Performance Management (PBPM) 

process, we will prepare a Strategic Plan 

that focuses on desired outcomes and 

provides visibility to our goals and 

measures. We will manage to outcomes 

and establish goals to measure and report 

on our performance. We will use 

performance feedback in our planning 

process, and identify the work necessary to 

produce the desired outcomes. We will 

meet our commitments in a predictable 

and timely manner. 

We will report on the performance of 

nuclear power facilities in an open and 

objective manner.

NRC FY 2000 STRATEGIC PLAN

VOUE2* AT2NCERRATRSFT

0
NUCLAR EACTR SFETY VOUME , PRT

Public confidence is influenced by 

information about the operation of nuclear 

facilities. The NRC will collect infor

mation about the safety performance of 

nuclear reactors and report that infor

mation objectively to the public. Where 

licensee performance is outside established 

criteria, the appropriate remedial action 

will be communicated to the public. The 

NRC will communicate to the public the 

resolution of generic safety issues. The 

NRC will also report on significant 

international events and will clearly 

describe any safety implications applicable 

to U.S. reactors. 

We will continue to foster an environment 

in which safety issues can be openly 

identified without fear of retribution. 

Public confidence is enhanced in an 

environment where safety issues can be 

raised and addressed without fear of 

retribution. Examples of how this strategy 

will be implemented include conducting 

the 10 CFR 2.206 petition process, 

responding to allegations and safety 

conscious work environment concerns, 

investigating alleged wrongdoing, and 

implementing the NRC's programs for 

Differing Professional Opinions and 

Generic Safety Issues. We will conduct a 

pilot program to solicit feedback from 

individuals raising safety issues to assess 

the NRC's effectiveness of handling of 

allegations. 

Measures 

We will use the following measures to 

assess the results in our efforts to increase 

public confidence:

" Complete the milestones in the annual 

Performance Plan relating to collecting, 

analyzing, and trending information for 

measuring public confidence. 

" Complete all of the public outreaches as 

scheduled in the annual Performance 

Plan. 

" Complete the milestones specific to the 

agency allegation program effectiveness 

assessment plan as identified in the 

annual Performance Plan. 

" Issue Director's Decisions for petitions 

filed to modify, suspend, or revoke a 

license under 10 CFR 2.20612 within an 

average of 120 days.13 

The staff is increasing the number, and 

improving the quality, of its interactions with 

external stakeholders. We intend to take 

advantage of these interactions by requesting 

feedback from the stakeholders that participate 

in them. The staff believes that the 

combination of (1) being more proactive in 

interacting with external stakeholders, 

(2) improving our interactions with these 

stakeholders, (3) improving our responsive

ness to stakeholder concerns, and (4) 

systematically monitoring feedback will allow 

the staff to assess changes and trends in public 

confidence. 

Public outreach was chosen as a 

performance measure for public confidence 

based upon NRC experience from well 

conducted public outreaches. In response, the 

need for communication plans is recognized in 

this Strategic Plan and will be completed in 

FY 2000. The Annual Performance Plan will 

identify the specific metrics that will be used 

in assessing results.

I

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2,PR -ULA ECO SAFT

The future focus of the outreach effort for 

significant regulatory issues will be on 

keeping the public in the vicinity of the 

facility informed. The NRC will monitor plant 

specific activities for issues that meet the 

significant regulatory issue definition. The 

process will ensure that appropriate outreach 

activities are being effectively initiated. 

The agency is currently developing an 

agency allegation program effectiveness plan 

(to be completed by FY 2002) and has not yet 

identified the specific milestones for the years 

covered by this Strategic Plan. Specific 

milestones will be identified each year in the 

NRC's Annual Performance Plan. NRC will 

be developing criteria for the choice of the 

specific milestones and for the monitoring 

processes. Milestones for the development and 

implementation of these criteria and the 

monitoring process will be included in the 

Annual Performance Plan, so that progress on 

this activity will be reported to Congress on an 

annual basis. 

The assumption that the public and other 

stakeholders will continue to provide 

substantial feedback to and interact with the 

NRC to improve our programs and processes 

is inherent in the above strategies and 

measures (See Major External Factors).

jPERFORMrANCE GOAL: Make NRC 

;Iactivities and decisions more effective, 

Sefficient, and realistic. 

By maintaining the quality of the technical 

base for our decisions and by optimizing our 

regulatory activities, while maintaining safety 

and increasing public confidence, the NRC 

will ensure adequate protection of public

health and safety and the environment. In 

working toward this performance goal, the 

NRC will apply its Principles of Good 

Regulation, which include improved 

efficiency, clarity, and reliability. 

The cost of most NRC activities and 

decisions contribute to our licensees' 

operating and maintenance costs and 

ultimately are borne by the public. As the 

electric utility industry is in transition from a 

rate-regulated to a market-based business 

environment, the NRC must keep its costs 

reasonable and predictable by being effective, 

efficient, and realistic in activities and 

decision-making while continuing to maintain 

safety. Effectiveness, efficiency and realism 

are supported by the analysis and use of 

domestic and international research results and 

operational experience. 

Feedback from stakeholders, 

self-assessments, international experience, and 

research results suggests that we should 

capitalize on advances in technology, 

implement efficiencies to improve our internal 

processes, and improve the quality and bases 

for decision-making. Feedback and our own 

analyses suggest that we should improve the 

consistency and predictability of our 

regulatory decisions by evolving to a more 

risk-informed and performance-based 

approach. 

Effectiveness means performing the work 

necessary to support the NRC missions and 

goals in a thorough, disciplined, and timely 

manner. We must periodically challenge the 

value of NRC programs and activities based 

on how they contribute to the achievement of 

goals. Our business processes and regulatory 

decisions should reflect high standards of 

quality and be technically sound. Specific

I

NRC FY 2000 STRATEGIC PLAN 0
NUCLAR EACOR SFET VOUME , PRT

challenges in this regard involve (1) risk

informing the NRC's regulatory programs, 

(2) preparing to address evolving technologies 

and a changing regulatory environment 

including the deregulation of the electric 

utility industry, and (3) improving the 

predictability and consistency of agency 

decisions. We will also pursue international 

cooperative research in order to leverage our 

research resources, share research facilities 

whenever possible, and maintain our 

involvement in international committees and 

working groups that can best further our 

interests and minimize unnecessary 

duplication of effort. 

Efficiency means conducting our work 

productively and on time. Efficiency can be 

enhanced by closely examining internal 

processes to learn from experience, reducing 

costs, and becoming more timely and 

predictable in delivery of services and 

decisions. 

The NRC decisions can be made more 

realistic by eliminating excessive 

conservatism. Realism is supported by the 

analysis and use of risk information, domestic 

and international research results, and 

operational experience, and by improvements 

in the timeliness, consistency, and 

predictability of regulatory decisions and 

actions. 

Strategies 

The NRC will employ the following 

strategies to make NRC activities and 

decisions more effective, efficient, and 

realistic:

We will use risk information to improve 

the effectiveness and efficiency of our 

activities and decisions. 

As part of our agency-wide Risk-Informed 

Regulation Implementation Plan (to be 

completed by FY 2001), we will conduct 

an integrated evaluation of risk 

information, inspection findings, operating 

experience, domestic and international 

research results, and cost data to identify 

ways to improve the effectiveness of NRC 

regulatory requirements, guidance, and 

processes. We will improve our ability to 

conduct effective plant safety assessments 

by employing risk-informed methods and 

data, including international experiences 

and approaches, which allow for early 

identification of changes in plant risk. We 

will develop the tools and information 

needed to support realistic (versus overly 

conservative) decision making. We will 

ensure that our regulatory focus is on those 

activities that pose the greatest risk to the 

public by using Probabilistic Risk 

Assessment (PRA) techniques and other 

approaches for differentiating between 

high- and low-risk activities. To improve 

efficiency in our use of risk information in 

our activities and decisions, we will 

leverage our knowledge of risk 

information through participation in 

international regulatory information 

exchanges and cooperative research 

programs. We will improve predictability 

and stability in our use of risk assessment 

methods through participation in national 

standards activities. Likewise, we will 

develop guidance to ensure that the 

application of risk assessment methods is 

suitable and that there is consistency in 

their use in our decision-making process.

i

0 NRC FY 2000 STRATEGIC PLAN
0 We will make agency decisions based on 

technically sound and realistic 

information. 

We will focus resources in those areas 

where important gaps in information still 

exist, where uncertainties exist about the 

significance to risk, and where the degree 

of conservatism in safety margins has not 

been quantified. Insights gained from the 

maturity of the nuclear industry will be 

recognized. We will maintain tools and 

methods used for decision-making that 

reflect recent scientific information and 

consider remaining uncertainties. We will 

ensure that our decisions on significant 

safety issues are supported by high-quality 

expertise, experiments, data, tools, and 

methods. 

* We will anticipate challenges posed by the 

introduction of new technologies and 

changing regulatory demands. 

We will seek information, both domestic 

and international, about new technologies 

and will develop the knowledge and tools 

to evaluate the implications of these new 

technologies on the safety of nuclear 

reactors. In addition, we will participate in 

international regulatory information 

exchanges and cooperative research 

programs and will exchange information 

with universities to leverage resources and 

share research facilities. Mindful of our 

respective roles, we will seek opportunities 

to interact with and, where appropriate, 

initiate cooperative programs with industry 

and the international community to 

minimize duplication. We will take these 

steps to ensure that our regulatory process 

does not impede the use of new technology 

to improve safety, increase productivity, or 

reduce costs.

We will identify, prioritize, and modify 

processes based on effectiveness reviews 

to maximize opportunities to improve 

those processes. 

We will explore opportunities to prioritize 

work. We also will systematically review 

key business processes and will document, 

standardize, measure, and track, and then 

analyze and improve the core processes 

that are critical to achieving our outcomes. 

We will seek opportunities for improve

ment and continue to apply lessons learned 

including that from the revised reactor 

oversight program and other risk-informed 

initiatives to improve the efficiency and 

effectiveness by bringing coherence 

among these programs. We will modify 

our regulatory processes to keep pace with 

the challenges associated with the 

economic deregulation of the electric 

power industry. 

Measures 

The NRC will use the following measures 

to assess results in our efforts to make NRC 

activities and decisions more effective, 

efficient, and realistic: 

" Complete those specific reactor 

milestones in the Risk-Informed 

Regulation Implementation Plan 

identified for completion in the annual 

Performance Plan. 

" Complete at least two key process 

improvements per year in selected 

program and support areas that increase 

efficiency, effectiveness, and realism. 

" Complete all license renewal application 

reviews within 30 months.

a

NRC FY 2000 STRATEGIC PLAN

VOUE20 AT2ULA ECO A
NUCLAR EACOR SFEý VOUME , PRTS

These measures are intended to help us 

assess our progress in improving the efficiency 

of the NRC's operations, increasing the 

effectiveness of our regulations, and 

improving realism in our regulatory decisions. 

Since risk-informed regulation will help 

improve both our efficiency and effectiveness, 

the first measure is intended to measure our 

success in moving toward risk-informed 

regulation in a timely and integrated manner. 

The agency is currently developing a 

Risk-Informed Regulation Implementation 

Plan (FY 2001) and has not yet identified the 

specific milestones to be completed during the 

years cover by this Strategic Plan. Specific 

milestones will be identified each year in the 

NRC's Performance Plan. In this way, 

Congress will be informed in a timely manner 

of the completion goals of the agency. NRC 

will be developing criteria for the choice of 

the specific milestones and for the monitoring 

processes. Milestones for the development and 

implementation of these criteria and the 

monitoring process will be included in the 

Performance Plan, so that progress on this 

activity will be reported to Congress on an 

annual basis. The second measure addresses 

improvements that simplify, streamline, or 

improve the timeliness of regulatory 

processes. The measure of at least two key 

process improvements per year was selected in 

addition to the risk-informed measure to focus 

on other areas to seek improvement. The 

intent of the measure is to annually develop a 

list of key process improvements. The list will 

be prioritized based on the estimated 

effectiveness of the improvement and the 

completion of the two key process 

improvements would be tracked in the 

Performance Plan. The number of key 

processes, two, was chosen as a starting figure 

and as experience is gained, that metric may 

be revised.

The third measure addresses efficiency and 

effectiveness of our license renewal process 

which is a major agency initiative. The NRC 

will continue to gain experience and seek 

efficiencies where possible to improve on 

future schedules. An understanding that there 

will be no major change in our understanding 

of issues affecting reactor safety and no 

unexpected significant increase in workload is 

inherent in these measures (See Major 

External Factors).

PERFORMANCE GOAL.- Reduce 

unnecessary regulatory burden on 

stake holders.

By reducing unnecessary regulatory 

burden, both the NRC and licensee resources 

may be made available to more effectively 

focus on safety issues. Unnecessary regulatory 

burden for NRC licensees may be defined as 

requirements that go beyond what is necessary 

and sufficient for providing reasonable 

assurance that public health and safety, the 

environment, and the common defense and 

security will be protected. For example, recent 

risk-informed initiatives for inspection and 

testing (ISI and IST) have allowed the 

licensees to focus resources more directly on 

the high risk significant systems and 

components, and reduce the attention on low 

risk-significant systems and components 

thereby contributing to safety and improving 

effectiveness. The costs associated with NRC 

activities can impact a variety of NRC 

stakeholders. This performance goal supports 

the NRC mission of ensuring adequate 

protection of public health and safety and the 

environment in the use of nuclear reactors. In

SNRC FY 2000 STRATEGIC PLAN
VOUE20 AT2NCERRATRSFT

working toward this goal, the NRC will apply 

its Principles of Good Regulation for being an 

independent, open, efficient, clear, and reliable 

regulator. 

During the past 30 years, an ever

increasing body of technical knowledge and 

operational experience has been accumulated, 

both domestic and international, that allows 

for refinements and enhancements in NRC 

requirements and programs that can reduce 

unnecessary regulatory burden, while assuring 

maintenance of safety. The NRC believes that 

for some areas of NRC regulations and 

practices, the burden is not commensurate 

with the safety benefit. Not all of our 

requirements and programs have been 

updatedto take into account these 

advancements, and thus they may not be as 

efficient and effective as possible. Reduction 

in unnecessary regulatory burden may 

contribute to the NRC effectiveness and 

efficiency by allowing more focus on safety 

and risk-significant issues. For example, the 

new reactor oversight process is allowing 

more effective staff focus on safety significant 

issues related to licensee performance. 

Although regulation, by its nature, is a 

burden, we will impose on licensees only the 

necessary level of burden required to maintain 

safety. While our current performance goal is 

to reduce unnecessary regulatory burden, our 

long-range plans are to eliminate unnecessary 

regulatory burden to the extent feasible and 

cost-effective. We will pursue risk-informed 

and performance-based approaches, if 

justified, so that we can focus our attention on 

those areas of highest safety priority. We will 

make more realistic decisions through 

reducing excessive conservatism. The ever 

increasing body of domestic and international 

technical knowledge and operational

experience will be used to refine and enhance 

NRC requirements and programs. 

Strategies 

The NRC will employ the following 

strategies to reduce unnecessary regulatory 

burden on stakeholders: 

"We will utilize risk information and 

performance-based approaches to reduce 

unnecessary regulatory burden. 

As part of our agency-wide Risk-Informed 

Regulation Implementation Plan (FY 

2001), we will modify or delete 

regulations that provide little or no safety 

benefit. We will focus on less prescriptive 

and more risk- informed and performance

based regulatory approaches to provide 

licensees with flexibility in meeting 

regulatory requirements. The scope and 

priority of changes in our regulatory 

processes will consider lessons learned 

from the revised reactor oversight 

program, stakeholder initiatives, 

international experience, and the 

cumulative effect on agency and licensee 

burden reduction. 

"We will improve and execute our 

programs and processes in ways that 

reduce unnecessary costs to our 

stakeholders. 

As we execute our programs, we will 

make improvements to those aspects of our 

regulatory processes that have resulted in 

unnecessary regulatory burden to our 

stakeholders. In particular, we will 

evaluate the timeliness of actions and the 

necessity for multiple rounds of requests 

for additional information. As we make

I

NRC FY 2000 STRATEGIC PLAN # A
NOU

licensing decisions, conduct inspections, 

and take enforcement actions, we will 

consider the necessity of any additional 

burden imposed on licensees. 

" We will improve our reactor oversight 

program by redirecting resources from 

those areas less important to safety. 

We are implementing a revised reactor 

oversight program that focuses NRC 

inspection resources on licensees with 

performance problems, reduces regulatory 

attention on licensees that perform well, 

evaluates violations of regulations in a 

predictable and consistent manner that 

reflects the safety impact of the violations, 

and provides the nuclear industry and 

public with timely, objective, and 

understandable assessments of plant 

performance. 

" We will actively seek stakeholder input to 

identify opportunities for reducing 

unnecessary regulatory burden. 

We will encourage stakeholders to identify 

concerns with the NRC's regulatory 

programs, such as untimely, inadequate, or 

inappropriate staff actions, that have 

resulted in unnecessary cost. In addition, 

we will continue initiatives to interact with 

stakeholders to ensure a mutual 

understanding of existing regulatory 

requirements, guidance, or licensing 

decisions. Such interactions will provide 

opportunities for stakeholders and 

international regulatory bodies to identify 

problems and suggest improvements. The 

NRC will also be able to clarify or explain 

the basis for requirements, guidance, or 

licensing decisions, and why we believe 

they are necessary and sufficient. Where

guidance is being developed or used for 

the first time, we will invite stakeholder 

feedback to identify aspects of the 

guidance that might be unclear, 

unnecessary, inflexible, or otherwise 

considered excessively burdensome. 

Where licensees are using new 

requirements or guidance for the first time, 

we will interact with them upon request to 

resolve implementation questions or 

technical issues. 

Measures 

We will use the following measure to 

assess our results in reducing unnecessary 

regulatory burden on stakeholders: 

Complete those specific milestones to 

reduce unnecessary regulatory burden as 

identified in the annual Performance 

Plan. 

The objective of the forthcoming burden 

reduction plan (to be completed by FY 

2001) is to develop and implement a 

process for collecting data for identifying 

activities that have the greatest impact on 

reducing unnecessary regulatory burden 

while maintaining safety. The agency is 

currently developing milestones for 

reducing unnecessary burden while 

maintaining safety and has not yet 

identified the specific milestones to be 

completed during the years covered by this 

Strategic Plan. Specific milestones will be 

identified each year in the NRC's Annual 

Performance Plan. The NRC will be 

developing criteria for the choice of the 

specific milestones and for the monitoring 

processes. Milestones for the development 

and implementation of these criteria and 

the monitoring process will be included in

I

# NRC FY 2000 STRATEGIC PLAN
VOUE2 AT2NCERRATRSFT

the Annual Performance Plan, so that 

progress on this activity will be reported to 

Congress on an annual basis. 

STATUTORYA UTHORITY 

- Atomic Energy Act as amended 

- Energy Reorganization Act as amended 

- National Environmental Policy Act 

- National Historic Preservation Act 

- Endangered Species Act 

- Clean Water Act 

- Clean Air Act as amended 

- Nuclear Non-Proliferation Act 

- Energy Policy Act 

MAJOR EXTERNAL FACTORS 

We have identified several external factors 

that could significantly affect achievement of 

our Strategic or Performance Goals. However, 

as maintaining safety is our preeminent 

performance goal, we will devote and 

reprogram sufficient resources to maintain 

safety at the expense of the other performance 

goals. The following key assumptions have 

been made regarding the external factors: 

• There are no nuclear reactor accidents. 

Based on the improved safety 

performance of the nuclear industry, we 

believe the probability of a nuclear reactor 

accident is very low and will remain at 

this level. Furthermore, we believe that 

the threat of terrorism has not changed 

and therefore the probability of sabotage 

initiating an accident at a nuclear power 

reactor will remain unchanged. The safe 

use of nuclear reactors is the 

responsibility of NRC licensees and

______________________ i

regulatory oversight of licensees is the 

responsibility of the NRC. Therefore, we 

are not in direct control of this external 

factor. A nuclear reactor accident could 

affect our strategic goals through the 

potential for deaths, illnesses, or releases 

of radioactive material to the 

environment. In addition, an accident 

would impact our performance goals in 

that safety was not maintained and public 

confidence in the NRC pursuing its 

mission would wane. As a result, 

resources devoted to our other 

performance goals (e.g., increasing 

effectiveness, efficiency, and realism, and 

reducing unnecessary regulatory burden) 

would be redirected to evaluate NRC 

programs to determine the needed 

improvements in safety. 

There are no significant adverse trends 

in the safety performance of nuclear 

reactors. 

Over the past ten years, the safety 

performance of the collective nuclear 

industry has greatly improved. We believe 

this safety performance will remain 

stable, if not continue to improve. This, in 

part, has allowed the NRC to transition to 

a revised reactor oversight program for its 

inspection, assessment, and enforcement 

activities that is more risk-informed and 

performance-based. Beyond the baseline 

inspection program that all nuclear 

reactors will receive, additional NRC 

resources will be directed to those 

licensees with performance problems. 

Through the revised reactor oversight 

program, we anticipate that adverse trends 

in the safety performance of nuclear 

reactors will be identified prior to 

becoming significant. Although not 

directly affecting our strategic goal, if 

significant adverse trends occur, our

NRC FY 2000 STRATEGIC PLAN
NUCLEAR REACTOR S,: -Yi VOLUME 2J, PART 2

performance goals of maintaining safety 

and increasing public confidence may not 

be achieved. As a result, we would 

redirect resources to further assuring 

maintenance of safety, while continuing to 

develop and improve the revised reactor 

oversight program to meet our safety 

needs. This redirection would impact our 

ability to meet our other performance 

goals of increasing effectiveness, 

efficiency, and realism, and reducing 

unnecessary regulatory burden. 

Economic deregulation and 

restructuring of the electric power 

industry will continue. 

The pace of the deregulation of the 

electric power industry will increase and 

there is potential for considerable change 

in the nuclear power industry. Although 

we do not believe economic deregulation 

will affect our strategic goals, the effect of 

deregulation on maintaining nuclear 

safety is unclear. Deregulation could 

result in improvements to safety through 

standardization of best practices, 

maintenance of the status quo, or 

degradation of safety through excessive 

efforts to reduce costs. We will continue 

to rely upon our inspection, assessment, 

and enforcement programs as the primary 

tool for evaluating and ensuring safe 

operations at our licensed facilities. The 

potential impact of deregulation on our 

other performance goals of increasing 

public confidence, increasing 

effectiveness, efficiency, and realism, and 

reducing unnecessary regulatory burden is 

also unclear. The general public may have 

increased concerns about the safety of 

nuclear power plants in a more 

cost-competitive environment, thereby

affecting our efforts to increase public 

confidence. On the other hand, to remain 

cost-competitive, licensees put pressure 

on the NRC to accelerate reform efforts to 

increase efficiency and effectiveness and 

reduce unnecessary regulatory burden. 

Large conglomerates may emerge from 

consolidation of the nuclear power 

industry and may necessitate changes in 

our management and organizational 

structure to effectively and efficiently 

regulate the industry. Our corporate 

management strategies discuss our 

strategy for modifying our management 

and organizational structure from such 

external factors as economic deregulation 

and restructuring of the electric power 

industry. 

The public and other stakeholders will 

continue to provide substantial 

feedback and interact with the NRC to 

improve our regulatory programs and 

processes. 

Public and other stakeholder feedback and 

interaction are vital elements of the 

identification and implementation of 

needed improvements to our regulatory 

programs and processes. The NRC has 

historically focused its efforts and 

resulting regulations, programs, and 

processes with reactor safety as essentially 

the sole goal. However, over the past 

several years, we have aggressively 

pursued feedback from the public and 

other stakeholders on methods by which 

we can maintain safety, while increasing 

public confidence, reducing unnecessary 

regulatory burden, and making NRC 

activities and decisions more effective, 

efficient, and realistic. Without the 

public's and other stakeholders' continued

I

0 NRC FY 2000 STRATEGIC PLAN
substantial participation in these efforts, 

we may not achieve our performance 

goals relating to public confidence, 

unnecessary burden reduction, and 

effectiveness, efficiency, and realism. 

Substantial interaction with the public and 

other stakeholders is vital to identifying 

those programs and processes that should 

be improved on a priority basis, providing 

recommendations on alternatives, and 

reporting results of these evaluations. 

Through continued public and other 

stakeholder interactions, we can leverage 

our efforts to meet our performance goals. 

There is no major change in our 

understanding of issues affecting 

reactor safety, no major change in our 

understanding of the threat of 

terrorism, and no unexpected 

significant increase in workload from 

activities such as an application for a 

new nuclear power reactor or an early 

site permit. 

These factors reflect our view that we are 

sufficiently knowledgeable about nuclear 

reactor safety and safeguards issues. 

Although these factors would not affect 

our Strategic Goals, they could impact our 

ability to fully meet our performance 

goals relating to public confidence,

i

unnecessary burden reduction, and 

effectiveness, efficiency, and realism. A 

change in our understanding of reactor 

safety issues could result in resources 

being reprogrammed to efforts to 

maintain safety. 

While there will be sufficient nuclear 

energy-related skills, experimental 

facilities, or other resources to 

accomplish our goals in the near future, 

there is likely to be a longer term 

shortfall in these areas. 

The lack of nuclear energy-related skills, 

experimental facilities, or other resources 

could affect our ability to achieve 

improvements in our regulations and 

supporting programs and processes 

needed to reduce unnecessary burden to 

increase effectiveness, efficiency, and 

realism, and to ensure the safety of new 

technologies. Recent studies indicate that 

the availability of expertise and facilities 

will lag demand. The expected increase in 

the pace of introduction of new 

technologies (i.e., introduction of digital 

instrumentation and controls system to 

replace the existing analog systems at 

nuclear power plants) will challenge our 

existing expertise and necessitate 

increased attention in this area.

NRC FY 2000 STRATEGIC PLAN

I 0OUEAT ULERRATRSFT
VOUE2,PR0

NUCLEAR 

M[ATERIALS SAFETY 

STRATEGIC GOAL: Prevent radiation -related deaths and illnesses, 

promote the common defense and security, and protect the environment in 

the use of source, byproduct, and special nuclear material. 14

The Nuclear Materials Safety arena 

encompasses regulatory activities associated 

with uranium recovery, nuclear fuel cycle 

facilities, and nuclear materials users. It 

includes 26 operating uranium recovery sites, 

21 uranium recovery sites under 

decommissioning, 10 major fuel cycle 

facilities and several other smaller licensed 

facilities, and more than 20,000 specific 

materials licensees regulated by either the 

NRC or Agreement States.15 In addition, there 

are estimated to be 100,000 general licensees 

within the arena. This diverse regulated 

community includes uranium extraction; 

uranium conversion; uranium enrichment; 

nuclear fuel fabrication; fuel research and pilot 

facilities; and large and small users of nuclear 

material for industrial, medical, or academic 

purposes. The latter group includes 

radiographers, hospitals, private physicians, 

nuclear gauge users, large and small 

universities, and others. 

This strategic goal represents the principal 

focus of the Nuclear Materials Safety arena. 

The goal is to achieve our mission and fulfill 

our statutory requirements as stated above. For 

fuel cycle activities, the NRC is the primary 

regulatory body. For materials activities, the 

NRC currently shares its regulatory authority 

with 32 Agreement States throughout the 

country. As well, uranium recovery activities 

function under concurrent jurisdiction between 

NRC and the Environmental Protection

i

Agency (EPA). The NRC Regions also play an 

important role in inspecting NRC licensees, 

reacting to events, and licensing material 

activities. Throughout the arena, it is 

recognized that licensees1 and other 

stakeholders are key participants in the 

collective efforts that will be necessary to 

achieve program success. We also recognize 

and will use domestic and international 

research, technical studies, operating 

experience, and risk information to ensure that 

the regulatory framework 16 is based on 

technically sound and realistic information. 

Measures 

We will use the following measures to 

assess results in achieving the Nuclear 

Materials Safety strategic goal. To the extent 

applicable, measures include the NRC and 

Agreement States licensee events. With 

respect to the second measure and metric, the 

NRC and Agreement States' licensees have 

reported a small number of such exposures 

nearly every year for which reporting was 

required. Each exposure is a cause of concern, 

prompting us to analyze its root cause and to 

determine appropriate follow-up actions. We 

will always strive to prevent such events from 

occurring, but it is possible that a few such 

events will occur. The NRC and Agreement 

States regulate more than 20,000 materials 

licensees who conduct millions of medical 

procedures annually and thousands of

NRC FY 2000 STRATEGIC PLAN

0
NUCLEA•Rd MAVTERIALS]l Sindustrial processes for nuclear materials daily. 

Failure to meet this metric, or any of the 

others, would trigger a self-assessment of the 

NRC's materials arena activities to determine 

if changes are needed. The measures2 are as 

follows: 

" No deaths resulting from acute radiation 

exposures from civilian uses of source, 

byproduct, or special nuclear materials, 

or deaths from other hazardous materials 

used or produced from licensed material. 

" No more than six events per year resulting 

in significant radiation or hazardous 

material exposures"7from the loss or use 

of source, byproduct, and special nuclear 

materials. 

" No events resulting in releases of 

radioactive material resulting from 

civilian uses of source, byproduct, or 

special nuclear materials that cause an 

adverse impact on the environment5 

" No losses, thefts, or diversion offormula 

quantities of strategic special nuclear 

material; radiological sabotages; or 

unauthorized enrichment of special 

nuclear material regulated by the NRC.1 8 

" No unauthorized disclosures or 

compromises of classified information 

causing damage to national security. 19 

The Commission recognizes that activities 

associated with the use and disposal of nuclear 

materials could pose risks to the public. Given 

the risk inherent in these activities, the first 

two measures are being used as indications of 

whether we are achieving the strategic goal of 

preventing radiation-related deaths or 

illnesses. 

These measures identify events that would 

result in significant adverse impacts on public

health and safety, the national security, or the 

environment. They include events from the 

NRC and Agreement States. They relate to 

events associated with regulated activities that 

must be reported accurately by licensees to the 

NRC and Agreement States in accordance 

with NRC regulations. These could result from 

NRC licensee fuel cycle safety and safeguards 

program activities, or from activities of the 

NRC or Agreement State licensees related to 

the use of nuclear materials for medical, 

academic, or industrial purposes. Sometimes 

events are difficult to quantify because some 

events require medical estimates of the 

probability of functional damage to an organ 

developing in later years. Any occurrence 

would trigger a self-assessment of the NRC's 

Nuclear Materials Safety activities to 

determine if changes are needed.

PERFORM4NCE GOAL.- Maintain 

safety, protection of the environment, 

and the common defense and security.

The NRC will continue to protect the 

public, workers, and the environment and 

ensure that licensed and authorized activities 

will not be inimical to the common defense 

and security. This protection will be 

accomplished by ensuring that regulated 

materials14,20 activities are undertaken 

consistent with applicable statutes and 

regulations. In so doing, the NRC will 

continue to provide reasonable assurance that 

adverse impacts from licensees' use of 

byproduct, source, and special nuclear 

material will be prevented. This protection 

also entails maintaining a high assurance 

against loss, theft, diversion, or unauthorized 

enrichment of nuclear material; sabotage of 

nuclear facilities; and disclosure of classified 

information.

0 NRC FY 2000 STRATEGIC PLAN

I

M
This is the NRC's preeminent performance 

goal, which has a higher priority than the other 

Nuclear Material Safety performance goals. In 

working toward this goal, the NRC will apply 

its Principles of Good Regulation. Principles 

applicable to this goal are related to 

independence, openness, regulatory clarity, 

and reliability. 

Although the goal is to maintain rather 

than to increase safety and safeguards, this 

represents a composite approach for the many 

categories of licensees represented in this 

arena. Because of the diversity within and 

among licensed activities in this arena, and the 

risks involved in the activities, additional 

safety improvements in certain areas may be 

warranted. Most nuclear material facilities and 

a large majority of materials licensees have 

operated safely and securely for many years. 

The industries, the NRC, and the Agreement 

States have recognized that certain elements of 

the fuel cycle and materials industries are 

mature, and practices and standards already in 

place have been tested over time and found to 

be acceptable in maintaining safety and 

security. Even in this climate, regulators must 

resist any tendency toward complacency. On 

the other hand, other elements of this arena 

involve newer technologies and practices. As 

new technologies and other advances are 

introduced by applicants or licensees, the 

NRC will determine, on a case-by-case basis, 

when early notification of the States is 

warranted. In both cases, regulators must 

pursue risk-informed and performance-based 7 

approaches, where justified, to focus attention 

on those areas of highest safety and security 

priority. We will ensure that our decisions are 

scientifically-based; risk-informed; and shaped 

by operational experience, new information, 

and research, from domestic and cooperative 

international activities. Furthermore,

protecting future generations is an aspect 

pertaining to uranium recovery site 

remediation. This protection is accomplished 

through maintaining requirements for such 

protection in our regulations and authorizing 

licensee activities only after determining that 

proposed activities will protect both current 

and future generations. This approach is 

embodied in the first and second strategies for 

this arena. 

For our uranium recovery activities, most 

of the work supporting the safety oversight of 

DOE's remedial actions to clean up inactive 

mill sites is completed. Thus, the program's 

focus will be on controlling the radiological 

and non-radiological hazards of mill tailings 

sites and assuring the safe operation of 

uranium extraction facilities. 

The arena also recognizes the NRC's 

shared regulatory responsibility with the 32 

Agreement States. The NRC has to ensure that 

the State programs are adequate and 

compatible with its own regulatory programs 

to attain a uniform nuclear safety policy 

throughout the Nation. This uniformity will 

take on increased significance as more States 

assume regulatory authority for materials 

safety over the next several years. In 

recognition of the important contributions of 

the Agreement States toward maintaining 

safety, the NRC will encourage States to 

pursue a more active role in the implemen

tation of strategies that contribute to the safety 

performance goal. The NRC and Agreement 

States will take decisive action to improve the 

safety performance of licensees identified as 

operating below acceptable levels for ensuring 

public health and protection from undue 

hazards. 

Finally, this goal recognizes the NRC's 

mandate to promote the common defense and

NRC FY 2000 STRATEGIC PLAN

4VLUME1,.A112 NUCLEAR MATERAL SAFETY
I NLaM ZPR I

security. The NRC's safeguards, physical 

protection, and threat assessment activities all 

combine to provide high assurance that 

commercial activities involving special 

nuclear material (SNM) are not inimical to 

this purpose and do not constitute an 

unreasonable risk to public health and safety. 

The NRC's threat assessment function 

contributes to national and international 

programs designed to identify and limit the 

risk of proliferation of weapons of mass 

destruction and weapons-usable materials and 

threats posed by terrorists, criminals, and 

foreign regimes determined to commit hostile 

acts against NRC-regulated facilities and 

activities. Our safeguards system monitors and 

ensures that NRC licensees maintain nuclear 

material protection, control, and 

accountability, and our physical protection 

component represents the principal barrier for 

those who would attempt to sabotage, steal, or 

divert SNM. Such an important function has 

continued to be an effective deterrent against 

these threats, but our activities will take on 

increased priority as the availability of 

weapons-usable material and the information 

technology to build nuclear explosives 

continues to become more widespread, and the 

increasing vulnerabilities to cyber-terrorism 

continue as systems become more automated. 

Strategies 

The NRC will employ the following 

strategies to maintain safety, protection of the 

environment and promote the common 

defense and security: 

We will continue to improve the regulatory 

framework to increase our focus on safety 

and safeguards, including incremental use 

of risk-informed7 and, where appropriate, 

less prescriptive performance-based7 

regulatory approaches to maintain safety.

In the materials arena programs, the 

regulatory framework continues to evolve, 

even though many parts of the fuel cycle 

and nuclear materials industries are in a 

mature state. The regulations contain some 

prescriptive requirements, where 

necessary, while other sections of the 

regulations are more performance-based. 

As appropriate for the individual Nuclear 

Materials arena programs, risk-informed 

and performance-based approaches will be 

incorporated incrementally to improve the 

focus on safety of the regulations and 

related guidance making up the regulatory 

framework. We will ensure, by using risk 

assessment techniques for differentiating 

between high- and low-risk activities, that 

our regulatory focus is on those activities 

that pose the greatest risk to the public. We 

are continuing to focus on those areas 

where important gaps in information are 

present and where uncertainties exist about 

the significance to risk. We are developing 

guidance to ensure that specific 

applications of risk assessment methods 

are suitable and that there is consistency in 

their use in our decision-making process. 

Because of the diversity of programs 

within the Nuclear Materials Safety arena, 

risk assessment techniques will be used 

only where the subject matter is amenable 

to the risk assessment strategy and where 

the greatest benefit could be derived. 

For programs where new technology is 

involved or where regulations or guidance 

are new or evolving, interactions with 

potential applicants will be important to 

discuss acceptable ways to comply with 

regulatory requirements. More prescriptive 

requirements may be appropriate for some 

new technologies.

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2, P 2 NUCLEA M .ATERIALS SAFET

Finally, we will evaluate potential new 

information from our domestic and 

cooperative international research 

programs as well as from our participation 

in international committees and 

workshops, new safety issues, changing 

external factors, and licensee operational 

experience so that improvements can be 

made to maintain an adequate regulatory 

framework. In this regard, we will be 

quick to share relevant generic safety 

information (e.g., Bulletins, Information 

Notices) with Agreement States and 

licensees so we can learn from each other's 

experiences. Related guidance will be 

updated periodically, taking into account 

risk information, whenever possible, and 

allowing flexibility for licensees to 

develop performance-based solutions, 

when these solutions are shown to be 

acceptable from a safety and safeguards 

perspective. For medical uses, the NRC 

and the Food and Drug Administration 

share information of mutual interest 

related to the approval of medical devices, 

radioactive drugs, and radioactive 

biologics when these products contain 

NRC-regulated material. 

We will continue authorizing licensee 

activities only after determining that these 

proposed activities will be conducted 

consistent with the regulatory framework 

In the Nuclear Materials Safety arena, the 

NRC issues several hundred new licenses 

each year and terminates about the same 

number. The NRC approves more than 

3,000 amendment requests and makes 

decisions on license renewals as the 

licenses approach their expiration dates. 

Some of these actions are fairly routine in 

nature, and these decisions can be reached 

in a relatively short period of time.

Conversely, some major materials 

licensees, including the fuel facilities, 

engage in more complex operations. 

Therefore, the decisions associated with 

these licenses require a more rigorous 

review of licensee personnel 

qualifications, safety and safeguards 

programs, systems, and facilities. On some 

occasions, these evaluations include safety, 

safeguards, or environmental reviews; 

issue resolution; and documentation of the 

technical bases and findings in publicly 

available safety and safeguards evaluation 

reports and either environmental 

assessments or environmental impact 

statements. 

Licensing submittals and approvals are 

often made easier when licensees and 

reviewers use available guidance 

documents. These documents are not 

intended to supplant regulatory 

requirements. They are intended to serve 

as tools to assist licensees and license 

reviewers in their understanding of the 

license application and review process. 

Therefore, they will be updated at regular 

intervals to maintain currency. Regulations 

will be applied to independently evaluate 

the licensees' demonstrations that 

proposed activities comply with 

regulations. While conducting these 

evaluations, we will employ risk-informed 

methods and data, where appropriate. In 

addition, the adjudicatory hearing process 

will support final licensing decisions. 

Technical assistance will be provided to 

the Agreement States, when requested, to 

help them in conducting their reviews. 

We will confirm that licensees understand 

and carry out their primary responsibility 

for conducting activities consistent with 

the regulatory framework

NRC FY 2000 STRATEGIC PLAN 0
I6 NULA0AEIL AEýY IVLM ,PR

For fuel cycle and materials licensees, 

investigations, inspections, or other 

independent approaches (e.g., third-party 

reviews) will continue to be important 

methods to verify that licensees understand 

their responsibility for safety and that their 

activities remain in compliance with 

regulatory requirements. Inspections must 

identify any safety and safeguards issues 

and resolve them before they affect safe 

and secure operations. We will use the 

risk-informed regulatory framework to 

inspect licensees at varying frequencies 

and with varying techniques, depending on 

the relative risks of the activities. 

Increased attention will be given to 

licensees with marginal performance, by 

focusing inspection resources on the basis 

of licensee performance. Finally, we will 

share relevant generic safety information 

(e.g., Bulletins, Information Notices) with 

Agreement States, licensees, and other 

involved federal agencies so we can learn 

from each other's experiences. Allegations 

regarding licensee or Agreement State 

performance will be appropriately and 

objectively addressed in a timely, 

systematic manner. Allegations of 

potential wrongdoing will be appropriately 

and objectively investigated in a timely 

manner. Enforcement sanctions for 

violations of regulatory requirements will 

be commensurate with the safety 

significance. 

We will respond to operational events 

involving potential safety or safeguards 

consequences. 

We will provide timely, accurate, and 

complete assessments of safety and 

safeguard events by evaluating licensees' 

recommendations for actions to protect the

public or national defense and security and 

by coordinating with other Federal 

agencies, State and local governments, 

international entities, and the licensee. In 

the event of an emergency involving an 

NRC-regulated entity, this would include 

working closely with one or more of the 

following agencies: FEMA, DOE, EPA, 

USDA, HHS, NOAA. The technical staff 

will have sufficient skills and knowledge 

to support the agency or State in 

responding to operational events. 

Additional support will be provided by the 

continuously staffed Incident Response 

Operations Center. Periodic exercises will 

be conducted to ensure that response 

organizations are proficient and 

experienced and that staff are trained to 

respond to operational events according to 

their safety or safeguards significance. 

Incident investigation capabilities also will 

be maintained. 

We will maintain safety by continuing to 

evolve along with Agreement States 

materials program into a single "National 

Materials Program" by encouraging the 

States to continue to pursue a more active 

role in the regulatory process. 

Safety is a shared responsibility among the 

NRC, the 'Agreement States, and licensees. 

A total of 32 States regulate more than 

15,000 specific radioactive materials 

licenses, as compared to 5,300 regulated 

by the NRC. Several other States are 

working towards becoming Agreement 

States in the next few years. This trend 

will continue to shift more of the licensees 

from the NRC to the States, and will 

require more cooperation and coordination 

between the NRC and the States to ensure 

safe licensee activities throughout the 

country. To this end, the Commission

i

1 NRC FY 2000 STRATEGIC PLAN
I VOLUM 2, PAR 2 NULAAERASSFT

recently approved the formation of a 

working group to coordinate with the 

Conference of Radiation Control Program 

Directors to address the impacts of this 

trend and to provide advice to the 

Commission. Defining and implementing 

future NRC and State roles under a 

national strategy and infrastructure for 

regulating materials licenses in this new 

environment will help ensure a more 

consistent and effective national focus on 

safe licensee performance for all of the 

20,000 specific materials licensees 

throughout the country. 

We will continue to conduct Integrated 

Materials Performance Evaluation 

Program (IMPEP) reviews to verify the 

adequacy and compatibility of Agreement 

State materials programs and the technical 

quality and consistency of the NRC's 

materials program licensing and inspection 

activities. The process is also designed to 

identify performance strengths and 

weaknesses. 

Over the past several years, increased 

cooperation between the NRC and the 

Agreement States has helped identify 

solutions to common program issues. The 

NRC will encourage the States to continue 

to take on a larger share of program 

responsibilities in the future. 

Measures 

The NRC will use measures to assess 

results in our effort to maintain safety and 

protect the environment and to promote the 

common defense and security. These include 

events involving the NRC and Agreement 

States. Many of the events that are counted in 

these measures do not, on an individual basis, 

have a public health and safety impact. For 

example, most of the losses of control of

I

licensed material are of shielded material, 

unlikely to result in overexposures or releases 

to the environment. Others are medical events 

that include underexposures (i.e., radiation 

treatments involving less radiation than the 

physician intended). These events are included 

because they may indicate program 

weaknesses, which, if ignored, could later 

trigger a more significant problem. The NRC 

will use the following measures2: 

* No more than 350 losses of control of 

licensed material per year. 21 

* No occurrences of accidental criticality. 

No more than 20 events per year resulting 

in radiation overexposures22 from 

radioactive material that exceed 

applicable regulatory limits. 

No more than 45 medical events per 

year.

23 

" No more than 40 releases per year to the 

environment of radioactive material from 

operating facilities that exceed the 

regulatory limits.24 

" No non-radiological events that occur 

during the NRC-regulated operations that 

cause impacts on the environment that 

can not be mitigated within applicable 

regulatory limits, using reasonably 

available methods. 25 

" No more than five substantiated cases per 

year of attempted malevolent use of 

source, byproduct, or special nuclear 

material. 

" No breakdowns of physical protection or 

material control and accounting systems 

resulting in a vulnerability to radiological 

sabotage, theft, diversion, or unauthorized 

enrichment of special nuclear material 20

NRC FY 2000 STRATEGIC PLAN 0
NUCLAR MTERALS AFEY VOUME2, PRT

Maintaining nuclear materials safety and 

safeguards is the primary goal for the various 

activities in the Nuclear Materials Safety 

arena. The metrics for these measures would 

maintain safety performance at about the same 

level as prior years. The threshold for a 

reportable event is more stringent for 

performance goal measures than the strategic 

goal measures. They provide the opportunity 

to detect programmatic weaknesses before the 

strategic goals would be exceeded. However, 

since target values are numbers of events 

reported, the targets for strategic goal 

measures could be exceeded without 

exceeding performance goal measures which 

allow a higher number of events. Safety 

measures will include data from the NRC and 

Agreement State licensees, where appropriate. 

This arena involves a range of activities 

that, during the course of normal day-to-day 

operations, places radioactive material in 

medical or industrial settings that provide 

more opportunities than other arenas for 

overexposures, medical events, and/or releases 

to occur. In the medical field alone, several 

million procedures take place each year that 

involve radioactive material used to diagnose 

or treat diseases. While the NRC and Agree

ment States continue to support a regulatory 

philosophy that places safety as the pre-eminent 

consideration, this plan acknowledges that the 

above numbers represent the most realistic set 

of metrics, based on available performance 

data. The metrics include some events of 

limited safety significance, such as a number 

of lost portable moisture density gauges, 

tracked under measure 1, even though few 

such events have resulted in overexposures. 

These events are included, since they could be 

indicators of potential weaknesses that could 

later result in a failure to achieve the strategic 

goals in this arena.

In addition, the sixth measure is limited to 

non-radiological environmental impacts from 

operations, including remediation, of uranium 

recovery and fuel cycle facilities regulated by 

the NRC. For uranium recovery facilities, 

under the Uranium Mill Tailings Radiation 

Control Act, the NRC regulates releases of 

certain non-radiological hazardous 

constituents to the environment in addition to 

radiological releases. Therefore, for these 

facilities, examples of events include 

non-radiological releases to the environment 

(e.g., to groundwater and surface water) 

resulting from excursions at in situ leach 

facilities and leaks from tailings cells at 

conventional uranium mills.

PERFORAMANE GOAL: Increase 

public confidence. I

The NRC views building and maintaining 

public trust and confidence that the NRC is 

carrying out its mission as an important 

performance goal for the agency. To reach this 

goal, the NRC must be viewed as an 

independent, open, efficient, clear and reliable 

regulator. This will be accomplished by 

providing our stakeholders with clear and 

accurate information about, and a meaningful 

role, in our regulatory programs. The NRC 

desires that diverse stakeholder groups (i.e., 

general public, Congress, NRC licensees, 

other Federal agencies, States, Indian Tribes, 

local governments, industry, industry workers, 

technical societies, the international 

community, and citizen groups) increasingly 

recognize that NRC actions assure that public 

health and safety, the common defense and 

security, and the environment are, and will 

remain, adequately protected from hazards 

resulting from the use of nuclear materials.

I

* NRC FY 2000 STRATEGIC PLAN
I *OUE2 ATiNCERMTRASSFT

The NRC must continue to forthrightly 

inform the public about nuclear safety and 

safeguards incidents and issues and provide 

avenues for meaningful input and dialogue. 

However, discussing in a public forum issues 

involving nuclear security or related to 

national defense is not usually prudent. 

Because of the diversity of stakeholder and 

public interests within this arena, the goal 

includes recognition that the NRC may not 

always be able to obtain a consensus among its 

stakeholders. This goal also includes 

recognition that, although the public may not 

always agree with the NRC's actions, public 

confidence in the NRC is enhanced when the 

agency listens to all interested parties, 

provides appropriate feedback, and makes its 

decisions in a thorough, disciplined, and 

timely manner. 

Although the NRC has conducted its 

regulatory oversight openly and has provided 

information to a variety of stakeholders, it 

recognizes the need for continued 

improvement, especially with respect to future 

regulatory changes and interactions with 

Agreement States. This means that continued 

dialogue between the NRC and the Agreement 

States is required to develop solutions to 

common problems. The NRC recently 

completed a variety of initiatives to better 

inform stakeholders and to obtain their input 

on significant issues. Based on the initial 

efforts, the NRC's goal is to expand efforts 

and achieve greater improvement in this area. 

This may include more public meetings and 

more workshops with important sectors of the 

regulated community. The NRC will increase 

its efforts for public outreach through an 

integrated communications plan to implement 

strategies to effectively communicate with and 

involve the diverse stakeholders early in 

regulatory activities.

i

Strategies 

The NRC will employ the following 

strategies to increase public confidence: 

We will make public participation in the 

regulatory process more accessible. We 

will listen to their concerns and involve 

them more fully in the regulatory process. 

One of the attributes of strong and fair 

regulation in the materials arena involves 

consistent and early public involvement. 

The agency recognizes the public interest 

and concern in the proper regulation of 

materials arena activities. The agency 

further recognizes its responsibility to 

provide opportunities for meaningful 

public interaction and involvement. The 

NRC will listen to, and be responsive to, 

requests, inquiries, and concerns from the 

public. We will provide opportunities for 

stakeholders to bring information and 

issues to the NRC by holding open 

meetings in the vicinity of those affected, 

providing adequate notice of meetings, 

developing and implementing communi

cations plans for major regulatory 

activities, and holding workshops. We will 

consistently consider this input in planning 

changes and making decisions relating to 

our practices, rules, and processes. 

We will communicate more clearly. We 

will add more focus, clarity, and 

consistency to our message, be timely, and 

present candid and factual information in 

the proper context with respect to the risk 

of the activity. 

Public confidence in the NRC will be 

enhanced by avoiding raising stakeholder 

concerns unnecessarily. We can avoid 

concerns if the information is presented in 

a manner that is easily understood and

NRC FY 2000 STRATEGIC PLAN
NI F

placed in its proper safety context. 

Whenever possible, we will use quick, 

personalized forms of contact with 

stakeholders. Communications with the 

public will be designed to foster greater 

understanding of, and confidence in, our 

regulatory program. The information we 

disseminate will be clear, technically 

sound, accurate, reliable, objective, and 

timely. We will take full advantage of the 

Internet and new technology for 

information dissemination. We will protect 

the private, proprietary, and classified 

nature of information. All stakeholders 

should be able to rely on our statements 

and information as being objective and not 

promotional. The NRC will clearly 

communicate to and educate stakeholders 

about its precise role in the materials 

arena. 

" We will continue to enhance the NRC'S 

accountability and credibility by being a 

well-managed, independent regulatory 

agency. We will increase efforts to share 

our accomplishments with the public. 

We will explore additional opportunities to 

convey our actions and activities, 

including achievements, to a broader 

audience. This may include expanding our 

reports to Congress, increasing our 

information exchange with the media 

outlets, and enhancing our external and 

internal home pages. 

"* We will continue to foster an environment 

in which safety issues can be openly 

identified without fear of retribution. 

Public confidence is enhanced in an 

environment where safety and security 

issues can be raised and addressed without 

fear of retribution. Examples of how this

strategy will be implemented in this arena 

include conducting the NRC's 10 CFR 

2.206 petition process, responding to 

allegations, addressing safety-conscious 

work environment concerns, and 

implementing the NRC's programs for 

differing professional views/opinions. We 

will also participate in the agency's pilot 

program to solicit feedback from 

individuals raising safety or security issues 

to assess the NRC's effectiveness in 

handling allegations. Finally, we will 

encourage licensees and applicants to be 

open and responsive to the public affected 

by their regulated actions. 

Measures 

The NRC will use the following measures 

to assess the results in our efforts to increase 

public confidence: 

" Complete the milestones in the annual 

Performance Plan relating to collecting, 

analyzing, and trending information for 

measuring public confidence. 

"* Complete all of the public outreaches as 

scheduled in the annual Performance 

Plan. 

" Complete the milestones specific to the 

agency allegation program effectiveness 

assessment plan as identified in the 

annual Performance Plan. 

" Issue Director's Decisions for petitions 

filed to modify, suspend, or revoke a 

license under 10 CFR 2.20612 within an 

average of 120 days.13 

The staff is increasing the number, and 

improving the quality, of its interactions with 

external stakeholders. We intend to take 

advantage of these interactions by requesting

k

1 NRC FY 2000 STRATEGIC PLAN
feedback from the stakeholders that participate 

in them. The staff believes that the 

combination of (1) being more pro-active in 

interacting with external stakeholders, 

(2) improving our interactions with these 

stakeholders, (3) improving our responsive

ness to stakeholder concerns, and (4) sys

tematically monitoring feedback will allow the 

staff to assess changes and trends in public 

confidence. 

Public outreach was chosen as a 

performance measure for public confidence 

based upon NRC experience from well 

conducted public outreaches. In response, the 

need for communication plans is recognized in 

this Strategic Plan and will be completed in 

FY 2000. The annual Performance Plan will 

identify the specific metrics that will be used 

in assessing results. 

The agency is currently developing an 

agency allegation program effectiveness plan 

(to be completed by FY 2002) and has not yet 

identified the specific milestones for the years 

covered by this Strategic Plan. Specific 

milestones will be identified each year in the 

NRC's Annual Performance Plan. NRC will 

be developing criteria for the choice of the 

specific milestones and for the monitoring 

processes. Milestones for the development and 

implementation of these criteria and the 

monitoring process will be included in the 

Annual Performance Plan, so that progress on 

this activity will be reported to Congress on an 

annual basis. 

The assumption that the public and other 

stakeholders will continue to provide sub

stantial feedback to and interact with the NRC 

to improve our programs and processes is 

inherent in the above strategies and measures.

I

IPERFO

activities and decisions GOAL: more Make effective., NRC 

efficient, and realistic. 

The NRC will continue to improve its 

regulatory processes so that they become more 

effective, efficient, and realistic. The NRC and 

the Organization of Agreement States will 

identify and focus on necessary and sufficient 

regulatory activities that are linked to its goals. 

In those regulatory activities, the NRC will 

strive to optimize regulatory programs and 

processes, where possible, while assuring 

safety and security and improving public 

confidence. In working toward this 

performance goal, the NRC will apply its 

Principles of Good Regulation, which include 

efficiency, clarity, and reliability. 

The NRC will ensure its decisions are 

scientifically-based, risk-informed, and shaped 

by operational experience, new information, 

and research, including cooperative 

international activities. As a result, the NRC's 

decisions will be realistic, will be systematic, 

and will appropriately treat areas of 

uncertainty. The NRC will ensure that its 

procedures, processes, and expectations are 

better-defined, clearer, and more transparent. 

The NRC's regulatory actions will support 

more consistent, reliable, predictable, and 

timely decision-making. Furthermore, the 

NRC will seek to minimize duplication of 

efforts with stakeholders to achieve this goal, 

while relying on the technical and managerial 

competence of its staff to achieve success. 

By striving to become more effective, 

efficient, and realistic while continuing to 

assure adequate protection of the public health 

and safety and the common defense and 

security, the NRC intends to keep regulatory 

burden and related costs to licensees and

NRC FY 2000 STRATEGIC PLAN

I 0OUE2 AT2NCERMTRASSFT
NULA MAEIL SAT VOUM 2, PAT

applicants as low as practical. The NRC will 

capitalize on advances in technology and 

implement changes to improve internal 

processes related to regulatory actions. As part 

of this effort, the NRC will continue its efforts 

to develop and update licensing and inspection 

guidance in order to improve the consistent, 

effective, and efficient implementation of its 

policies in the field. Furthermore, the NRC 

will strive to be less prescriptive and will 

apply risk-informed, performance-based 

approaches where it is appropriate to do so. 

Effectiveness means producing the 

necessary and sufficient work to achieve our 

goals. The NRC must periodically challenge 

the value of its programs and activities based 

on how they contribute to the achievement of 

goals. The NRC business processes and 

regulatory decisions will reflect high standards 

of quality and be technically sound. Specific 

challenges in this regard involve: (1) risk

informing the NRC's regulatory programs, 

(2) preparing to address evolving technologies 

and a changing regulatory environment, and 

(3) improving the predictability and con

sistency of agency decisions. We will also 

pursue international cooperative research in 

order to leverage our research resources, share 

research facilities wherever possible, and 

maintain our involvement in international 

committees and working groups that can best 

further our interests and minimize unnecessary 

duplication of effort. 

Efficiency means conducting work 

productively and on time. Efficiency will be 

enhanced by simplifying or streamlining our 

internal processes based on self-assessment 

and experience, using improved tools, and 

becoming more timely and predictable in 

delivery of services and decisions. 

To become more effective and efficient, 

the NRC will plan and schedule its work

activities and identify key milestones to 

monitor progress. When issues emerge, the 

NRC will readjust plans, schedules, and 

resource allocations, if necessary, to ensure 

that attention is focused on the highest priority 

activities so they are conducted efficiently. 

The NRC decisions will be made more 

realistic by eliminating excessive 

conservatism. Realism is supported by risk 

information, research results, and operational 

experience. 

Strategies 

The NRC will employ the following 

strategies to make NRC activities and 

decisions more effective, efficient, and 

realistic: 

We will continue to improve the regulatory 

framework to increase our effectiveness, 

efficiency, and realism. 

We will make improvements to our 

regulatory framework or take other agency 

actions (e.g., seek legislative changes) to 

resolve circumstances that reduce our 

effectiveness or efficiency. For example, 

improvements would be needed for 

circumstances such as: (1) overlapping 

regulatory responsibility or dual 

regulation, (2) conflicting positions 

regarding regulatory jurisdiction, and 

(3) conflicting standards that impact 

finality of licensing decisions. 

Furthermore, we will incorporate 

risk-informed and performance-based 

approaches, as appropriate, into our 

regulatory framework when they can 

substantially improve our effectiveness, 

efficiency, and realism (i.e., reduce 

excessive conservatism). This will be 

accomplished, in part, by conducting an

i

0 NRC FY 2000 STRATEGIC PLAN
*OUEAT NUCEA MAEIL SAET

integrated evaluation of risk information, 

inspection findings, operating experience, 

research results, and cost data as part of 

the agency-wide Risk-Informed 

Regulation Implementation Plan (to be 

completed by FY 2001). In addition, we 

will continue to incorporate, where 

applicable, existing consensus standards 

into our regulatory framework. We will 

also encourage stakeholders to develop and 

use new consensus standards. 

Furthermore, we will develop and revise 

appropriate licensing and inspection 

guidance so that applicants and staff have a 

clear and consistent understanding to 

develop and review licensing applications, 

respectively. This guidance should 

minimize the staff's requests for additional 

information, subsequent license revisions, 

and additional rounds of staff review. It 

will also help the staff prepare for and 

conduct inspections. 

Finally, we will anticipate, through 

research, participation in international 

committees and workshops, and technical 

studies, opportunities for regulatory 

improvements that may come from 

industry's introduction of new 

technologies. Similarly, we will use 

domestic and international research, 

technical studies, and risk information to 

reduce excessive conservatism and ensure 

that the regulatory framework is based on 

technically sound and realistic 

information. In addition, to improve 

decision-making, we will develop 

processes that will assess the skills and 

tools needed by the staff to allow the 

appropriate level of decision-making for 

specific types of decisions consistent with

I

our statutory and regulatory authority. 

Staff will be authorized to take the 

appropriate and necessary action and make 

decisions that are within the scope of their 

assigned responsibilities and will be 

accountable for those actions and 

decisions. 

" We will identify, prioritize, and modify 

processes based on effectiveness reviews 

to maximize opportunities to improve 

those processes. 

We will continually improve and 

standardize our processes through a robust 

program of self-assessment and application 

of lessons learned. In particular, 

effectiveness reviews of program and 

program support areas will be conducted 

to determine what work needs to be added, 

maintained, reduced, or eliminated to 

deliver the desired outcomes. Efficiency 

reviews of key processes in program and 

program support areas will be conducted 

to determine the most efficient means of 

delivering the desired outcomes. 

" We will improve efficiency and 

effectiveness by continuing to evolve 

along with Agreement States materials 

programs into a single "National 

Materials Program" by encouraging the 

States to continue to pursue a more active 

role in the regulatory process. 

Development of a more national strategy 

and infrastructure for regulating materials 

licenses consistently will take on increased 

emphasis and ultimately will make all 

parties more efficient and effective 

regulators, as several other States continue 

to work toward becoming Agreement 

States in the next few years.

NRC FY 2000 STRATEGIC PLAN
NUCLAR MTERILS S_ 0

NRC Headquarters has traditionally led the 

activities that established and improved the 

regulatory framework, while the NRC's 

Regions and Agreement States 

implemented the programs within this 

common framework. Over the past several 

years, increased cooperation between the 

NRC and the Agreement States has helped 

identify solutions to common program 

issues. The NRC will encourage the States 

to continue to take on a larger share of 

program responsibilities in the future. 

Examples include Agreement State partici

pation in the NRC/Agreement State work

ing groups, Agreement State participation 

in IMPEP and in the Nuclear Materials 

Events Database, and the assumption of 

responsibility by the Organization of 

Agreement States for planning and hosting 

the annual All Agreement States meeting. 

This increased interaction will allow the 

NRC to gain additional insights from the 

comments and input of Agreement States, 

individually and collectively, especially 

when substantive program changes are 

being considered. The periodic IMPEP 

lessons learned and good practices reports 

provide examples so that one regulator can 

upgrade the effectiveness and efficiency of 

its program based on findings about 

another regulator. By expanding the 

States' participation in various work 

groups, the NRC and Agreement States 

can avoid duplication of effort. 

Collectively, these activities reflect an 

evolution toward a more unified and 

cohesive national program. 

Measures 

The NRC will use the following measures 

to make NRC activities and decisions more 

effective, efficient, and realistic:

" Complete those specific materials 

milestones in the Risk-Informed 

Regulation Implementation Plan 

identified for completion in the annual 

Performance Plan. 

" Complete at least two key process 

improvements per year in selected 

program and support areas that increase 

efficiency, effectiveness, and realism. 

These measures are not applicable to 

Agreement States, since it is not within the 

NRC's purview to evaluate States' 

efficiency, effectiveness, or realism, except 

when the activities are needed to demon

strate program adequacy and compatibility. 

Together, these measures were chosen to 

identify the conditions under which the 

NRC would make continuous progress to 

assure that its regulatory processes (i.e., 

rulemaking, licensing, inspections, and 

enforcement) are executed in a timely and 

business-like fashion and that its decisions 

are technically sound and based on 

realistic information. 

The agency is currently developing a 

Risk-Informed Regulation Implementation 

Plan (to be completed by FY 2001) and 

has not yet identified the specific 

milestones for the years covered by this 

Strategic Plan. Specific milestones will be 

identified each year in the NRC's Annual 

Performance Plan. NRC will be 

developing criteria for the choice of the 

specific milestones and for the monitoring 

processes. Milestones for the development 

and implementation of these criteria and 

the monitoring process will be included in 

the Annual Performance Plan, so that 

progress on this activity will be reported to 

Congress on an annual basis.

I _______________________________________________

0 NRC FY 2000 STRATEGIC PLAN
VOLUME 2, PART 2 SAFETY

The measure of at least two key process 

improvements per year was selected in 

addition to the risk-informed measure to 

focus on other areas to seek improvement. 

The intent of the measure is to annually 

develop a list of key process 

improvements. The list will be prioritized 

based on the estimated effectiveness of the 

improvement and the completion of the 

two key process improvements would be 

tracked in the Performance Plan. The 

number of key processes, two, was chosen 

as a starting figure and as experience is 

gained, that metric may be revised. 

IPERFORMANCE GOAL: Reduce 

junnec~essary regulatory burden on 

Sstake holders. 

The NRC will strive to reduce unnecessary 

regulatory burden and associated costs if 

possible, while achieving the other three 

performance goals. Unnecessary regulatory 

burden for the NRC licensees may be defined 

as requirements that go beyond what is 

necessary and sufficient for providing 

reasonable assurance that public health and 

safety, the environment, and the common 

defense and security will be protected. The 

costs associated with the NRC activities can 

impact a variety of the NRC stakeholders. For 

some stakeholders, such as States and the 

public, costs could potentially result from 

actions by States or other federal agencies 

with concurrent jurisdiction, to augment the 

NRC regulatory program, clean up sites, or 

dispose of radioactive material that are paid 

for with public funds. For others, such as 

applicants and licensees, unnecessary burden 

may be imposed by an overly detailed

1 III

technical review that could result in increased 

costs that are passed on to the consumer. 

Although regulation, by its nature, is a 

burden, the NRC will ensure that only the 

level of burden necessary to maintain safety is 

imposed on licensees. This burden reduction 

can be achieved by using risk-informed and 

performance-based approaches, if justified, to 

focus attention on those areas of highest safety 

priority and by making more realistic 

decisions without excessive conservatism. We 

will use domestic and international research 

and technical studies to evaluate new 

information in order to identify areas in our 

regulatory programs where unnecessary 

burden and duplication can be reduced. 

Consideration will be given to making 

regulatory burden commensurate with the risk 

of the regulated activity and the enhanced 

benefit to the workers, the public, and the 

environment. Furthermore, regulatory burden 

associated with a safety enhancement will be 

considered in light of a cost/benefit analysis 

prior to the imposition of a new regulatory 

requirement. Regulatory oversight will be fair, 

consistent, effective, and timely in its appli

cation. Costs associated with the regulatory 

infrastructure must be fair, equitable, and 

shared by all users. In particular, we will 

assure that NRC actions minimize the 

potential for future bankruptcies that could 

impose burden on the public (e.g., actions 

involving the remediation of uranium recovery 

sites). 

Strategies 

The NRC believes that some of the 

regulatory burden in the Nuclear Materials 

Safety arena associated with the regulations 

and practices in place over the years was not 

commensurate with the safety benefit. During 

these years, an ever-increasing body of

NRC FY 2000 STRATEGIC PLAN
NUCLAR MTERALS AFEY VOUME2, PRT

technical knowledge, operational experience, 

and risk assessment tools has been accumu

lated both domestically and internationally. 

Within this arena, a risk review study is being 

conducted. Also, a risk review group has 

recently been established to implement a more 

risk-informed regulatory framework for these 

programs. These efforts are expected to 

provide the bases for reducing unnecessary 

regulatory burden in some areas, but perhaps 

increasing burden in others. The NRC will 

employ the following strategies to reduce 

unnecessary regulatory burden on 

stakeholders: 

We will continue to improve our 

regulatory framework in order to reduce 

unnecessary regulatory burden. 

We will use risk-informed and 

performance-based approaches, where 

appropriate, to ensure that all elements of 

our regulatory programs (i.e., regulations, 

guidance, licensing, assessment, 

inspection, and enforcement) are 

conducted commensurate with the level of 

risk. This will provide licensees with 

flexibility in meeting regulatory 

requirements. The scope and priority of 

changes in our regulatory processes will 

consider stakeholder input, the effects of 

dual regulation with other Federal and 

State entities, and the cumulative effect 

each has on agency and licensee burden 

reduction. In addition, we will use 

domestic and international research and 

technical studies to evaluate new 

information in order to identify areas in 

our regulatory programs where 

unnecessary burden and duplication can be 

reduced. New information includes 

improvements in knowledge, advances in

technology, and insights gained from 

operational and regulatory experience both 

domestically and internationally. Research 

will focus on identifying where excessive 

conservatism can be eliminated or reduced. 

" We will improve and execute our 

programs and processes in ways that 

reduce unnecessary costs to our 

stakeholders. 

As we execute our programs, we will 

make improvements to those aspects of our 

regulatory processes that had resulted in 

unnecessary costs to our stakeholders. In 

particular, we will evaluate the timeliness 

of actions and the necessity for multiple 

rounds of requests for additional 

information. As we make licensing 

decisions, conduct inspections, and take 

enforcement actions, we will take into 

account the necessity of any additional 

burdens imposed on licensees and other 

stakeholders. 

" We will actively seek stakeholder input to 

identify opportunities for reducing 

unnecessary regulatory burden. 

We will encourage licensees to identify for 

NRC consideration concerns with the 

NRC's regulatory programs, such as 

untimely, inadequate, or inappropriate staff 

actions, that have resulted in unnecessary 

cost, In addition, we will continue 

initiatives to interact with stakeholders to 

ensure a mutual understanding of existing 

regulatory requirements, guidance or 

licensing decisions. Such interactions will 

provide opportunities for stakeholders to 

identify problems or suggest improve

ments. The NRC will also be able to 

clarify or explain the basis for 

requirements, guidance, or licensing

0 NRC FY 2000 STRATEGIC PLAN
decisions, and why we believe they are 

necessary and sufficient. Where guidance 

is being developed or used for the first 

time, we will invite stakeholder feedback 

to identify aspects of the guidance that 

might be unclear, unnecessary, inflexible, 

or otherwise considered excessively 

burdensome by the licensee. Where 

licensees are using new requirements or 

guidance for the first time to prepare 

specific submittals, we will be available to 

interact with them upon request during the 

development of the submittals. We will be 

able to provide guidance concerning 

implementation questions or technical 

issues they identify relating to 

understanding NRC requirements that 

might help them prepare an acceptable 

application. 

Measures 

The NRC will use the following measures 

to assess results in reducing unnecessary 

regulatory burden: 

Complete those specific milestones to 

reduce unnecessary regulatory burden as 

identified in the Annual Performance 

Plan. 

Reduce paperwork and record keeping 

imposed by the NRC on its licensees by at 

least 25 percent over a period of 5 years. 

The NRC wants its regulatory programs to 

be protective at reasonable cost and without 

excessive conservatism. The NRC seeks 

opportunities to reduce existing unnecessary 

regulatory burden and will strive to ensure that 

any new actions by the NRC do not impose 

any new unnecessary regulatory burden. These 

performance goal measures are designed to 

assess how the agency is meeting these

objectives and apply only to the NRC. They 

exclude Agreement States. The objective of 

the first measure is to develop a program (to 

be developed by FY 2001) that will track 

instances where the NRC may have 

overlooked a potential unnecessary regulatory 

burden associated with implementation of new 

or revised regulations or regulatory guidance 

that became effective during the reporting 

period. It includes instances of license review, 

inspection, or enforcement activities where 

new or existing regulations and regulatory 

guidance may have been inappropriately 

applied. The program will identify methods 

for licensees or other external stakeholders to 

inform the NRC of a potential regulatory 

burden. The program will also develop a 

screening process and criteria so that only 

valid concerns are forwarded to responsible 

management who will be required to evaluate 

each item as a potential example of 

unnecessary regulatory burden and 

recommend an appropriate course of action 

within a defined time period. The program 

will also track and trend the valid cases to 

identify any adverse trends. The milestones in 

the Performance Plan will identify when the 

program will be developed and implemented. 

Then future milestones will indicate actual 

performance measures based on realistic but 

challenging goals. In addition, the first 

measure provides an indication of quality of 

work. Any NRC activity that imposes new 

unnecessary regulatory burden indicates that 

the work process failed to identify the new 

burden. 

Because of the number and size of 

licensees in the Materials Arena, paperwork 

requirements impose a large burden making 

paperwork reduction a meaningful measure. 

Therefore, the second measure recognizes the 

specific burden represented by excessive 

paperwork and record keeping requirements.

NRC FY 2000 STRATEGIC PLAN

VOUE26 AT2NCEA AEIL AEY
NUCLAR ATEIALSSAFTY VOLME , PRT

No additional metric for reducing any 

current burden was used because the efforts 

for completing the milestones for 

risk-informing activities should, in addition to 

increasing effectiveness, efficiency, and 

realism, reduce unnecessary burden. Further 

opportunities to identify unnecessary 

regulatory burdens will be sought through 

interactions with external stakeholders. 

STATUTORYAUTHORITY 

- Atomic Energy Act as amended 

- Energy Reorganization Act as amended 

- Energy Policy Act 

- Clean Air Act as amended 

- National Environmental Policy Act 

- Nuclear Non-Proliferation Act 

- Convention for the Physical Protection of 

Nuclear Material 

- Uranium Mill Tailings Radiation Control 

Act, as amended 

- National Environmental Policy Act 

MAJOR EXTERNAL FACTORS 

Listed below are assumptions about major 

external factors and how they might affect 

achieving the goals of the Nuclear Materials 

Safety arena. 

There will be no change in the threat of 

terrorism in the use of source, byproduct, 

and special nuclear material. With that 

assumption, the current security and 

safeguards requirements are adequate.

One important external factor is whether 

or not the NRC takes on the regulatory 

oversight responsibility of the Department 

of Energy (DOE) facilities. Currently, the 

NRC provides regulatory assistance to 

DOE under a Memorandum of 

Understanding (MOU) for the Hanford 

Tank Waste Remediation System 

privatization that may be transitioned to 

NRC regulation. Although this MOU 

allows the NRC to advise DOE on the 

appropriate regulatory framework 

necessary for the rigors of commercial 

licensing expectations, DOE is not 

obligated to adopt any of our 

recommendations. 

Thus, an early transition to the NRC would 

require a phased and graded 

implementation strategy or possibly a 

reassessment of measures and strategies. 

The NRC also participated jointly with 

DOE and the Occupational Safety and 

Health Administration (OSHA) to conduct 

pilot programs on the feasibility of 

external regulation of DOE facilities. 

Although no significant issues were found 

during the pilot phase that would impede 

NRC regulation of these facilities, the pilot 

sites selected were not representative of 

the entire DOE nuclear complex. In 

addition, the NRC raised concerns over the 

possible shared infrastructure, legacy 

materials disposition, site-specific 

regulatory aspects, and the necessary 

interfaces with OSHA and the Environ

mental Protection Agency (EPA). 

Although no decision has been reached at 

this date, all of these issues would impact 

the safety goal, and would likely require a 

phased and graded implementation 

schedule.

I

# NRC FY 2000 STRATEGIC PLAN
In the Nuclear Materials Safety arena, 32 

States have formal agreements with.the 

NRC by which those States have assumed 

regulatory responsibility over byproduct, 

source, and small quantities of special 

nuclear material. There are more than 

15,000 specific radioactive materials 

licenses regulated by these States, as 

compared to 5,300 regulated by the NRC. 

Several other States, including 

Pennsylvania and Wisconsin, continue to 

work toward becoming Agreement States 

in the next few years. 

Although the NRC has frequent contact 

with each of the Agreement States, and has 

developed budget estimates based on these 

contacts, there are a number of 

uncertainties that can lead to schedule 

slippages over time. If these slips occur, 

the budget forecasts of the NRC licensing 

and inspection workloads could be 

affected. This could result in delays in 

licensing and inspection efforts, or force 

tradeoffs in other areas that would 

compromise our effectiveness and 

efficiency, or slow our implementation of 

the strategies. 

The number of uranium recovery 

licensees and licensing actions will 

decrease because the value of uranium 

will remain low and result in uranium 

mills remaining shut down or operating 

on a limited basis. Nevertheless, there will 

be a significant increase in the number 

and complexity of petitions for hearings 

and litigation concerning cleanup of sites 

and long-term monitoring and 

maintenance. However, the number, 

complexity, and timing of such actions is 

uncertain. This change results from 

greater public opposition and increased

involvement by environmental 

organizations. This external factor will 

cause a shift of resources from licensing 

reviews to support for hearings and 

litigation. Uncertainty in these types of 

changes could make planning and 

efficient execution of plans difficult. 

There will continue to be substantial 

public interest and involvement in the 

different elements of the Nuclear 

Materials Safety arena. Opposition may 

require specific attention to program or 

licensee-specific factors. 

Public confidence in the NRC and the 

regulated nuclear industry has varied over 

the years, and has varied across program 

arenas. This confidence is based on the 

public's perceptions regarding the 

regulator and the industry. Some of these 

perceptions are based on: (1) actual 

experience with the NRC and its 

performance, (2) external factors (e.g., 

media reports, political commentaries, 

special interest group efforts, and industry 

group statements) that may or may not be 

closely linked to our actual performance, 

and (3) operational events such as 

accidents at Three Mile Island and 

Chernobyl, even though the impact on 

health and safety of the first accident was 

minimal and the facility involved in the 

second accident was outside the NRC's 

regulatory control. To many, confidence 

(or lack of confidence) in the regulator and 

in the regulated industry cannot be clearly 

separated. Therefore, we recognize the 

potential that our activities and the 

licensees' activities jointly contribute to, 

or erode, the public's confidence and may 

cause us to take additional measures to 

assure the public.

NRC FY 2000 STRATEGIC PLAN

VOUEAT ULARMTRASSFT
NULA -AEIL SA~T VOUE2,PR

To the extent that these factors influence 

public confidence, the NRC could be 

challenged to readjust its activities, or 

extend its current efforts to respond or 

react to these factors. The impacts of 

operational events are particularly difficult 

to predict. Depending upon their nature 

and consequence, the NRC and/or the 

Agreement States could be forced to 

immediately redirect resources away from 

public confidence, effectiveness, 

efficiency, and realism, or burden 

reduction strategies in order to evaluate the 

safety or safeguards impact, and 

appropriate action levels needed to address 

the incidents in a timely and thorough 

manner. 

There are several major external factors

impacting the effectiveness, efficiency, 

and realism performance goal. Actions by 

Congress, Agreement States, or licensees 

as well as technology advances may 

impact our ability to improve in 

effectiveness, efficiency, and realism. 

If applicants submit significantly more 

requests for approvals than we forecast 

(new applications, amendments, or 

renewals) in the near term, this could 

cause backlogs that would impact the 

agency's ability to become more effective 

and efficient. Similarly, if new tech

nologies arise that must be reviewed, 

approved, and inspected, it may be 

necessary for the NRC to first become 

knowledgeable in the new areas before we 

can meet this goal.

I ____

* NRC FY 2000 STRATEGIC PLAN
VOUE2,PR*

NUCLEAR 

WASTE SAFETY

STRATEGIC GOAL: Prevent significant adverse impactsfrom radioactive waste 

to the current andfuture public health and safety and the environment, and 

promote the common defense and security.

The scope of the Nuclear Waste Safety 

arena encompasses regulatory activities 

associated with decommissioning of nuclear 

reactors and other facilities, storage of spent 

nuclear fuel, transportation of radioactive 

materials, and disposal of radioactive wastes. 

Nuclear waste is a byproduct of the use of 

radioactive materials. Such waste is produced 

by nuclear reactors that generate electric 

power, as well as fuel processing plants, and 

institutions such as hospitals and research 

facilities. It also results from decommissioning 

nuclear reactors and other facilities that are 

permanently shut down. High-level 

radioactive waste results primarily from the 

fuel used by reactors to produce energy. 

Low-level radioactive waste results from 

reactor operations, from fuel processing, and 

from medical, academic, industrial, and other 

commercial uses, and generally contains 

relatively limited concentrations of 

radioactivity. The term radioactive waste 

includes byproduct, source, and special 

nuclear material. 

This strategic goal represents the principal 

focus of the Nuclear Waste Safety arena. The 

goal is to achieve our mission and fulfill our 

statutory requirements. The NRC licensees1 

are responsible for safe transport, storage, and 

disposal of radioactive waste. The NRC 

licensees are also responsible for designing, 

constructing, operating, and remediating the 

wide variety of facilities or sites within the

i

scope of this arena. Regulatory oversight of 

licensee activities is the responsibility of the 

NRC; however, the NRC has relinquished its 

regulatory authority for some activities in this 

arena to Agreement States. Thus, performance 

reflects the results of the collective efforts of 

the NRC, its licensees, and the Agreement 

States. We will use domestic and international 

research, technical studies, and risk 

information to ensure that the regulatory 

framework 16 is based on technically sound 

and realistic information. 

The Commission recognizes that activities 

associated with the use and disposal of nuclear 

materials could pose risks to the public. Given 

the risk inherent in these activities, the first 

two measures are being used as indications of 

whether we are achieving the strategic goal of 

preventing significant adverse impacts to the 

current and future public health and safety. 

Measures 

We will use the following measures2 to 

assess results in achieving the Nuclear Waste 

Safety strategic goal: 

"• No deaths resulting from acute radiation 

exposures from radioactive waste. 

* No events resulting in significant 

radiation exposures4 from radioactive 

waste.

NRC FY 2000 STRATEGIC PLAN *

[
I ULA AST SAEYIIVLM ,PR

" No releases of radioactive waste causing 

an adverse impact on the environment.5 

" No losses, theft, diversions, or radio

logical sabotages18 of special nuclear 

material or radioactive waste. 

These strategic measures represent events 

that could result in adverse impacts on public 

health and safety, the environment, and 

national security. The above four measures 

would identify occurrences from activities 

regulated in this strategic arena, including 

decommissioning of nuclear reactors and other 

facilities, storage of spent nuclear fuel, 

transportation of radioactive materials, and 

disposal of radioactive wastes. Any occurrence 

would trigger a self-assessment of the NRC's 

nuclear waste safety activities to determine if 

changes are needed.

The NRC will continue to protect the 

public, workers, and the environment and 

ensure that licensed and authorized activities 

will not be inimical to the common defense 

and security. This protection will be 

accomplished by ensuring that regulated waste 

arena activities are undertaken consistent with 

applicable statutes and regulations. In doing 

so, the NRC will continue to provide 

reasonable assurance that adverse impacts 

caused by radiological exposure will be 

prevented for facilities and activities 

associated with decommissioning, storage of 

spent nuclear fuel, transportation of 

radioactive materials, and disposal of nuclear 

waste. This also entails maintaining a high 

assurance against loss, theft, diversion,

sabotage, and protection of classified matter to 

protect the common defense and security. 

This is the NRC's primary performance 

goal, which has a higher priority than the other 

Nuclear Waste Safety performance goals. In 

working toward this goal, we will apply the 

NRC's Principles of Good Regulation. 

Principles applicable to this goal are related to 

independence, openness, regulatory clarity, 

and reliability. 

The Nuclear Waste Safety arena consists 

of a diverse set of regulatory programs and 

activities for assuring safety and protecting the 

environment from the activities the NRC 

regulates. For this arena, the NRC will 

structure its activities to ensure that current 

levels of safety are maintained. The current 

levels of attention and activities vary because 

of the diversity of our programs, the type of 

oversight activities, and associated issues. For 

fature disposal of high-level waste, the 

Department of Energy (DOE) continues to 

characterize the candidate geologic repository 

site at Yucca Mountain, Nevada, to support a 

potential site recommendation and submittal 

of a license application to the NRC for 

construction authorization. Consistent with 

DOE's schedule for the next few years, the 

NRC is applying a regulatory framework to 

prelicensing reviews and consultations with 

DOE to resolve issues most important to 

repository safety and preparing to address the 

licensing phase of this process if the 

Presidential and congressional decisions are 

made regarding site approval and a license 

application is submitted. For the low-level 

waste program, no new disposal facilities have 

been opened, and the three operating facilities 

are in Agreement States. As a result, the 

NRC's focus will be to maintain a consistent 

national program and provide support to the 

States, as requested, to resolve specific

I

SNRC FY 2000 STRATEGIC PLAN

PERFORMA4NCE GOAL.- Maintain 

safety, protection of the environment, 

and the common defense and security.
VOUM 2,PR ULARWSESFT

technical issues and to review requests for 

onsite disposal. In contrast to the low-level 

waste program, our program for 

decommissioning nuclear reactors and fuel 

cycle facilities will receive more attention as 

the NRC considers options, including (1) an 

integrated, risk-informed rulemaking for 

decommissioning nuclear reactors that 

addresses emergency planning, insurance, 

safeguards, operator staffing and training, and 

other potential areas and (2) activities related 

to the release of solids. In addition, 

decommissioning will be impacted as the NRC 

makes a transition to a more risk-informed 

and streamlined process through the 

preparation of implementing guidance for the 

recently finalized license termination rule. 

Protecting future generations is an aspect 

of the Nuclear Waste Safety arena. This 

protection is accomplished through main

taining requirements for such protection in our 

regulations and authorizing licensee activities 

only after determining that proposed activities 

will protect both current and future 

generations. This approach is reflected in the 

first and second strategies for this arena. 

For certain waste arena activities located in 

Agreement States (i.e., low-level waste 

disposal, and non-reactor decommissioning), 

the NRC has relinquished regulatory authority 

to those States. The NRC has to ensure that 

these State programs are adequate and 

compatible with its own regulatory programs 

to attain a uniform nuclear safety policy 

throughout the Nation. Therefore, safety 

performance reflects the results of the 

collective efforts of the NRC, the Agreement 

States, and the regulated community. 

The NRC will assure that storage of spent 

nuclear fuel and transportation of 

radioactive materials are maintained at the

highest levels of safety commensurate with the 

risks associated with such activities. In this 

regard, as the amount of spent nuclear fuel 

increases and more licensees begin 

decommissioning, increased reliance on 

storage will become necessary for continued 

plant operation and for decommissioning of 

nuclear power plants. As a result, the NRC 

will continue to review and license 

independent spent fuel storage installations, 

and will continue to review and certify dry 

cask storage designs. Similarly, to meet the 

nation's transportation needs for nuclear 

commerce and for transportation of spent 

nuclear fuel and other radioactive materials, 

the NRC will review transportation package 

designs and approve shipment routing and 

related safeguards information. 

Finally, the Nuclear Waste Safety arena 

programs and activities will continue to focus 

on protecting the environment now and in the 

future. Protecting the environment will 

continue to be accomplished by assuring that 

the NRC's actions comply with its statutory 

obligations. 

Strategies 

The NRC will employ the following 

strategies to maintain safety and protection of 

the environment and to promote the common 

defense and security: 

* We will continue developing a regulatory 

framework to increase our focus on safety, 

including the incremental use of 

risk-informed7 and, where appropriate, 

less prescriptive performance-based7 

regulatory approaches to maintain safety. 

For the waste arena programs, the 

regulatory framework that defines 

adequate safety for current and future 

generations is in various stages of revision

a

NRC FY 2000 STRATEGIC PLAN 0
NUCLAR WSTESAFEY VOUME2, PRT

or development. For some programs, such 

as storage, transportation, and low-level 

waste, the regulations and guidance are 

relatively mature, but must be maintained. 

For other evolving programs, such as 

high-level waste and decommissioning 

reactors and other facilities, regulations are 

being revised or have been recently 

finalized to establish requirements and 

reflect risk-informed and performance

based approaches as well as insights 

gained from our research programs. As 

appropriate for the individual Nuclear 

Waste Safety arena programs, 

risk-informed and performance-based 

approaches will be incorporated 

incrementally to improve the focus on 

safety of the regulations and related 

guidance making up the regulatory 

framework. We will ensure, by using risk 

assessment techniques for differentiating 

between high- and low-risk activities, that 

our regulatory focus is on those activities 

that pose the greatest risk to the public 

now and in the future. We will focus on 

those areas where important gaps in 

information exist and where uncertainties 

exist about the significance to risk. We will 

develop guidance to ensure that specific 

applications of risk assessment methods 

are suitable and that there is consistency in 

their use in our decision-making process. 

Because of the diversity of programs 

within the Nuclear Waste Safety arena, 

risk assessment techniques will only be 

used where the subject matter is amenable 

to the risk assessment strategy and where 

the greatest benefit could be derived. 

For these programs, it is also important to 

develop the technical basis to confirm the 

adequacy of our regulations and guidance. 

This is particularly important in areas of 

uncertainty such as groundwater flow and

radionuclide transport through the 

environment and the effectiveness of 

engineered barriers to prevent releases 

over long time periods. As a result, 

research programs to support guidance and 

review methods, such as numerical 

modeling that will be used for determining 

compliance with these regulations, also 

need continued development and revision 

to reduce uncertainties and incorporate 

new information. Finally, for programs 

where new technology is involved or 

where regulations or guidance are new or 

evolving, interactions with applicants will 

be important to discuss acceptable ways to 

comply with the regulatory requirements. 

We will continue authorizing licensee 

activities only after determining that these 

proposed activities will be conducted 

consistent with the regulatory framework 

Authorizations such as licenses, certifi

cates of compliance, and amendments or 

renewals will be issued only after safety 

and environmental regulations have been 

addressed adequately and the licensee has 

demonstrated that the licensed or 

authorized activity can be carried out in a 

safe manner and, as appropriate, will 

protect future generations as required by 

regulations. This includes decommission

ing, emergency planning, physical 

protection, quality assurance, training, 

financial assurance, and other require

ments. The regulations and guidance 

making up the regulatory framework will 

be applied to independently evaluate the 

applicant's demonstration that the 

proposed activities comply with 

regulations and can be performed safely. 

These evaluations will include conducting 

safety analyses, environmental reviews, 

and the necessary and sufficient safety

I

S5NRC FY 2000 STRATEGIC PLAN
VOUM 2,. PAR 2 ULA ASESFT

and safeguards inspections. This 

evaluation and verification process will 

facilitate early identification of any 

existing or potential safety- or 

safeguards-significant issues and allow for 

timely implementation of appropriate 

actions. In addition, the adjudicatory 

hearing process will support final licensing 

decisions. Furthermore, as the Agreement 

States conduct their licensing reviews, we 

will consider providing technical 

assistance when requested. 

We will confirm that licensees understand 

and carry out their primary responsibility 

for conducting activities consistent with 

the regulatory framework 

For licensees who have operating facilities 

or who are conducting decommissioning 

or reclamation activities, inspections or 

other independent approaches (e.g., 

third-party reviews) will continue to be 

important methods to verify that licensees 

understand their responsibility to safety 

and that their activities remain in 

compliance with regulatory requirements. 

Inspections help identify safety issues 

before they affect safe operations. We will 

use the risk-informed regulatory 

framework to inspect licensees at varying 

frequencies and with varying techniques, 

depending on the particular operation and 

its relative risk. Increased attention will be 

given to licensees with marginal 

performance by focusing inspection 

resources on the basis of licensee 

performance. Allegations regarding 

licensee performance or potential 

wrongdoing will be appropriately and 

objectively addressed in a timely manner. 

Enforcement sanctions for violations of 

regulatory requirements will be used if 

appropriate.

We will respond to operational events 

involving potential safety or safeguards 

consequences. 

We will provide timely, accurate, and 

complete assessments of safety and 

safeguards events by evaluating 

recommendations of the licensees for 

actions to protect the public or national 

defense and security and by coordinating 

with other Federal agencies, State and 

local governments, and the licensee. 

Depending on the nature of the event, we 

will share information with other countries 

and international organizations. The 

technical staff will have sufficient skills 

and knowledge to support the agency or 

State in responding to operational events. 

Additional support will be provided by the 

continuously staffed Incident Response 

Operations Center. Periodic exercises will 

be conducted to ensure that response 

organizations are proficient and 

experienced and that staff are trained to 

respond to operational events according to 

their safety or safeguards significance. 

Incident investigation capabilities also will 

be maintained. 

We will evaluate potential new 

information from research, new safety 

issues, changing external factors, 

international programs, and licensee 

operational experience so that 

improvements can be made to maintain an 

adequate regulatory framework 

A wide variety of changes to the external 

environment are expected to have the 

potential for impacting future waste arena 

activities. We will evaluate this new 

information and make appropriate changes

I

NRC FY 2000 STRATEGIC PLAN
NULA WAT SAET VOUM 2,PR

to the regulatory framework. Political and 

economic factors could redirect waste 

arena programs. For areas of technical 

uncertainty, improvements in knowledge 

or advances in technology that might 

identify or resolve safety issues are 

possible. In addition, the operational and 

regulatory experience that will be gained 

both domestically and internationally 

could raise new safety issues as well as 

suggest approaches to resolve them. As a 

result, research and technical studies can 

identify where improvements are 

necessary to maintain the adequacy of the 

regulatory framework and its technical 

basis. Finally, we will share relevant 

generic safety information (e.g., Bulletins, 

Information Notices, and pertinent 

international reports) with Agreement 

States and licensees, as well as the 

international community, so we can learn 

from each other's experiences. 

We will keep pace with the national 

high-level waste management program. 

We will apply the regulatory framework to 

prelicensing reviews and consultations 

with DOE to resolve the issues most 

important to repository safety and prepare 

for addressing a licensing decision within 

the statutory time period. 

Consultations with DOE and prelicensing 

reviews of DOE's program at the Yucca 

Mountain site will continue to focus on 

resolving the key technical issues most 

important to safety of the repository. These 

reviews will apply the regulatory 

framework and will be further 

risk-informed by results of the staff's 

independent safety assessments of both 

preclosure and postclosure repository

performance. Feedback from our 

assessments and reviews will provide DOE 

with timely guidance regarding the 

sufficiency of its program for providing a 

complete license application for the 

geologic repository. This approach will 

support a licensing decision within the 

three-year statutory time period. These 

reviews and consultations will prepare the 

Commission to comment on the 

sufficiency of DOE's site characterization 

and waste form which is required by the 

Nuclear Waste Policy Act (NWPA) to be 

included in the President's site 

recommendation to Congress. 

Measures 

The NRC will use the following measures 

to assess results in maintaining safety, 

protecting the environment, and promoting 

common defense and security: 

" No events resulting in radiation 

overexposures22 from radioactive waste 

that exceed applicable regulatory limits. 

"* No breakdowns ofphysical protection 

resulting in a vulnerability to radiological 

sabotage, theft, diversion, or loss of 

special nuclear materials or radioactive 

waste.20 

"* No radiological releases11 to the 

environment from operational activities 

that exceed the regulatory limits. 

" No instances where radioactive waste and 

materials under the NRC's regulatory 

jurisdiction cannot be handled, 

transported, store4 or disposed of safely 

now or in the future. 26

I

# NRC FY 2000 STRATEGIC PLAN
These measures utilize regulatory limits 

and standards and represent more conservative 

thresholds to preclude violating the strategic 

goal measures data. They were chosen to 

identify processes or procedures that have led 

to events of limited significance but could be 

indicators of potential weaknesses. They were 

chosen to identify events where the NRC can 

monitor its success in assuring that all 

radioactive waste and materials under NRC 

responsibility can be handled, transported, 

stored, or disposed of safely; no events occur 

that result in public or worker overexposures 

or releases that exceed applicable regulatory 

limits; no losses of control of radioactive 

waste and regulated materials occur; and no 

events occur during NRC-regulated operations 

that cause an impact on the environment. 

In particular, the fourth measure addresses 

two items. First, all waste and materials which 

the NRC is responsible for can be appro

priately and safely addressed at the present 

time, i.e., no loss of control. Second, the NRC 

would not authorize activities related to waste 

and materials (e.g., reclamation, decom

missioning, storage, or disposal) without 

reasonable assurance that public health and 

safety and the environment will be protected 

in the future as required by applicable 

regulations. This second item addresses 

protection of future generations for 

compliance time periods specified in the 

regulations (e.g., 10,000 years for high-level 

waste disposal). 

The fifth measure is limited to 

non-radiological environmental impacts from 

operations, including remediation/decom

missioning/storage/disposal at high- and 

low-level waste, spent fuel, and decom

missioning sites regulated by the NRC. 

However, this measure applies to the NRC in a

I

limited way that is consistent with the NRC's 

responsibilities under applicable statues 

including NEPA and NWPA for disposal in a 

geologic repository. For licensed facilities and 

sites other than disposal in a geologic 

repository, the NRC evaluates potential 

non-radiological environmental impacts as 

part of its review of proposed licensing actions 

and determines whether a categorical 

exclusion under 10 CFR Part 51 (51.22) 

applies. If a categorical exclusion does not 

apply, the NRC prepares an environmental 

assessment (EA) that documents a finding of 

no significant impact, or an environmental 

impact statement (EIS) as required by NEPA 

before activities proposed by the licensee can 

begin. For either of these two cases, the EA or 

EIS would identify any events with a potential 

for significant impact that cannot be mitigated 

using reasonably available methods. If the 

NRC identifies environmental impacts 

associated with a proposed activity, the NRC 

will seek to take appropriate action within its 

authority to mitigate or eliminate those 

impacts. In addition for decommissioning, 

prior to and during remediation of a site, EPA 

or the EPA permit state is responsible for 

protection of the environment from 

non-radiological events. IPERFOR

NCE GOAL: Increase 

public confidence. 

The NRC views building and maintaining 

public trust and confidence that the NRC is 

carrying out its mission as an important 

performance goal for the agency. To reach this 

goal, the NRC must be viewed as an 

independent, open, efficient, clear and reliable 

regulator. This will be accomplished by 

providing our stakeholders with clear and

NRC FY 2000 STRATEGIC PLAN

VOLUME2,PART2 NUCLEAR WASTE SAFETY
NUC LEAR WASTE SAFETY~'- kVOlLUIE2,P

accurate information about, and a meaningful 

role, in our regulatory programs. The NRC 

desires that diverse stakeholder groups (i.e., 

general public, Congress, the NRC licensees, 

other Federal agencies, States, Indian Tribes, 

local governments, industry, industry workers, 

technical societies, the international 

community, and citizen groups) increasingly 

recognize that the NRC actions assure that 

public health and safety, the common defense 

and security, and the environment are, and will 

remain, adequately protected from hazards 

resulting from the activities in the Nuclear 

Waste Safety arena. 

The NRC must forthrightly inform the 

public about nuclear safety incidents and 

issues and provide avenues for meaningful 

input and dialogue. Because of the diversity of 

stakeholder and public interests within this 

arena, the goal recognizes that there may not 

always be a consensus. This goal also 

recognizes that although the public may not 

always agree with the NRC's actions, public 

confidence in the NRC is enhanced when the 

agency listens to all interested parties and 

makes its decisions in a thorough, disciplined, 

and timely manner. 

Public concern about the safety of nuclear 

waste arena activities is high, particularly for 

those who may live near these regulated 

activities. Although the NRC has conducted its 

regulatory oversight openly and has provided 

information to a variety of stakeholders, it 

recognizes the need for improvement through 

an integrated communications plan to 

implement the strategies. 

Strategies 

The NRC will employ the following 

strategies to increase public confidence:

We will make public participation in the 

regulatory process more accessible. We 

will listen to their concerns and involve 

them more fully in the regulatory process. 

One of the attributes of strong and fair 

regulation involves consistent and early 

public involvement. The agency 

recognizes the public interest and concern 

in the proper regulation of waste arena 

activities. The agency further recognizes 

its responsibility to provide opportunities 

for meaningful public interaction and 

involvement. The NRC will listen to and 

be responsive to requests, inquiries, and 

concerns from the public. We will provide 

opportunities for the public to bring 

information and issues to the NRC by 

holding open meetings in the vicinity of 

those affected, providing adequate notice 

of meetings, developing and implementing 

communications plans for major 

regulatory activities, and holding 

workshops. We will consistently consider 

this input in planning changes and making 

decisions relating to our practices, rules, 

and processes. 

We will communicate more clearly. We 

will add more focus, clarity, and 

consistency to our message, be timely, and 

present candid and factual information in 

the proper context with respect to the risk 

of the activity. 

Public confidence in the NRC will be 

enhanced by avoiding raising stakeholder 

concerns unnecessarily. We can avoid 

concerns if the information is presented in 

a manner that is easily understood and 

placed in its proper safety context. 

Whenever possible, we will use quick, 

personalized forms of contact with our 

stakeholders. Our communications with

I ______________________________________________________

0 NRC FY 2000 STRATEGIC PLAN
VOUE2,PR NUCEA WSTESFT

the public will be designed to foster 

greater understanding of and confidence in 

our regulatory program. The information 

we disseminate will be clear, technically 

sound, accurate, reliable, objective, and 

timely. We will take full advantage of the 

Internet and new technology for 

information dissemination. We will protect 

the private, proprietary, and classified 

nature of information. All stakeholders 

should be able to rely on our statements 

and information as being objective and not 

promotional. The NRC will clearly 

communicate to and educate stakeholders 

about its precise role in the waste arena. 

We will continue to enhance the NRC'S 

accountability and credibility by being a 

well-managed, independent regulatory 

agency. We will increase efforts to share 

our accomplishments with the public. 

The public's confidence in Nuclear Waste 

Safety arena activities is influenced by its 

perception of the NRC. We will candidly 

acknowledge our mistakes and our failures 

to meet our commitments. Finally, as part 

of implementing a Planning, Budgeting, 

and Performance Management (PBPM) 

process, we will provide visibility to our 

performance goals and measures. We will 

manage to that performance and will 

measure and report on achieving 

performance goals as they relate to public 

health and safety and the environment. 

We will explore additional opportunities to 

convey our actions and activities, 

including achievements, to a broader 

audience. This may include expanding our 

reports to Congress, increasing our 

information exchange with the media 

outlets, and enhancing our external and 

internal home pages.

___________________________ I

We will continue to foster an environment 

where safety issues can be openly 

identified without fear of retribution. 

Public confidence is enhanced in an 

environment where safety issues can be 

raised and addressed without fear of 

retribution. Examples of how this strategy 

will be implemented in this arena include 

conducting NRC's 10 CFR 2.206 petition 

process, responding to allegations, 

addressing safety-conscious work 

environment concerns, and implementing 

the NRC's programs for differing 

professional views/opinions. We will also 

participate in the agency's pilot program to 

solicit feedback from individuals raising 

safety issues to assess the NRC's 

effectiveness in handling allegations. 

Finally, we will encourage licensees and 

applicants to be open and responsive to the 

public affected by their regulated actions. 

Measures 

We will use the following measures to 

increase public confidence: 

" Complete the milestones in the annual 

Performance Plan relating to collecting, 

analyzing, and trending information for 

measuring public confidence. 

" Complete all of the public outreaches as 

scheduled in the annual Performance 

Plan. 

" Complete the milestones specific to the 

agency allegation program effectiveness 

assessment plan as identified in the 

annual Performance Plan. 

" Issue Director's Decisions for petitions 

filed to modify, suspend, or revoke a 

license under 10 CFR 2.20612 within an 

average of 120 days.13

NRC FY 2000 STRATEGIC PLAN
NUCLAR WSTESAFEY VOUME2, PRT

The staff is increasing the number, and 

improving the quality, of its interactions with 

external stakeholders. We intend to take 

advantage of these interactions by requesting 

feedback from the stakeholders that participate 

in them. The staff believes that the 

combination of (1) being more pro-active in 

interacting with external stakeholders, 

(2) improving our interactions with these 

stakeholders, (3) improving our 

responsiveness to stakeholder concerns, and 

(4) systematically monitoring feedback will 

allow the staff to assess changes and trends in 

public confidence. 

Public outreach was chosen as a 

performance measure for public confidence 

based upon NRC experience from well 

conducted public outreaches. In response, the 

need for communication plans is recognized in 

this Strategic Plan and will be completed in 

FY 2000. The Annual Performance Plan will 

identify the specific metrics that will be used 

in assessing results. 

The agency is currently developing an 

agency allegation program effectiveness plan 

(to be completed by FY 2002) and has not yet 

identified the specific milestones for the years 

covered by this Strategic Plan. Specific 

milestones will be identified each year in the 

NRC's Annual Performance Plan. NRC will 

be developing criteria for the choice of the 

specific milestones and for the monitoring 

processes. Milestones for the development and 

implementation of these criteria and the 

monitoring process will be included in the 

Annual Performance Plan, so that progress on 

this activity will be reported to Congress on an 

annual basis. 

The assumption that the public and other 

stakeholders will continue to provide 

substantial feedback to and interact with the 

NRC to improve our programs and processes

is inherent in the above strategies and 

measures.

The NRC will continue to improve its 

regulatory processes so that they become more 

effective, efficient, and realistic. The NRC 

will identify and focus on necessary and 

sufficient regulatory activities that are linked 

to its goals. In those regulatory activities, the 

NRC will strive to optimize regulatory 

programs and processes, where possible, while 

assuring safety and improving public 

confidence. In working toward this 

performance goal, the NRC will apply its 

Principles of Good Regulation which include 

improved efficiency, clarity, and reliability. 

The NRC will ensure that its decisions are 

scientifically-based; risk-informed; and shaped 

by operational experience, new information, 

and research, including cooperative 

international activities. As a result, the NRC's 

decisions will be realistic, will be systematic, 

and will appropriately treat areas of 

uncertainty. The NRC will ensure that its 

procedures, processes, and expectations are 

better-defined, clearer, and more transparent. 

The NRC regulatory actions will support more 

consistent, reliable, predictable, and timely 

decision-making. Furthermore, the NRC will 

seek to minimize duplication of efforts with 

stakeholders to achieve this goal, while relying 

on the technical and managerial competence of 

its staff to achieve success. To avoid 

duplication of research activities being 

performed by other countries, we will 

coordinate our research programs with other 

countries, thus leveraging our research funds.

1 NRC FY 2000 STRATEGIC PLAN

PERFORMANCE GOAL: Make NRC 

activities and decisions more effective, 

efficient, and realistic.
By striving to become more effective, 

efficient, and realistic while continuing to 

assure adequate protection of the public health 

and safety, the environment, and the common 

defense and security, the NRC intends to keep 

regulatory burden and related costs to 

licensees, applicants, and ultimately the 

public, as low as practical. The NRC will 

capitalize on advances in technology and 

implement changes to improve internal 

processes related to regulatory actions. As part 

of this effort, the NRC will continue its efforts 

to develop and update licensing and inspection 

guidance in order to improve the consistent, 

effective, and efficient implementation of its 

policies in the field. Furthermore, the NRC 

will strive to be less prescriptive and will 

apply risk-informed, performance-based 

approaches as appropriate. 

Effectiveness means producing the 

necessary and sufficient work to achieve our 

goals. The NRC must periodically challenge 

the value of NRC programs and activities 

based on how they contribute to the 

achievement of goals. The NRC business 

processes and regulatory decisions will reflect 

high standards of quality and be technically 

sound. Specific challenges in this regard 

involve (1) risk-informing the NRC's 

regulatory programs, (2) preparing to address 

evolving technologies and a changing 

regulatory environment, and (3) improving 

predictability and consistency of agency 

decisions. We will also pursue international 

cooperative research in order to leverage our 

resources, share research facilities wherever 

possible, and maintain an environment in 

international committees and working groups 

which can best further our interests and 

minimize unnecessary duplication of effort. 

Efficiency means conducting our work 

productively and on time. Efficiency will be

i

enhanced by simplifying or streamlining our 

internal processes based on self-assessment 

and experience, using improved tools, and 

becoming more timely and predictable in 

delivery of services and decisions. 

To become more effective and efficient, 

the NRC will plan and schedule its work 

activities and identify key milestones to 

monitor progress. When issues emerge, the 

NRC will readjust plans and schedules, and 

resource allocations, if necessary, to ensure 

attention is focused on the highest priority 

activities and conducted efficiently. 

NRC decisions will be made more realistic 

by eliminating excessive conservatism. 

Realism is supported by risk information, 

research results, and operational experience. 

Strategies 

The NRC will employ the following 

strategies to make NRC activities and 

decisions more effective, efficient, and 

realistic: 

We will continue to improve the regulatory 

framework to increase our effectiveness, 

efficiency and realism. 

We will make improvements to our 

regulatory framework or take other agency 

actions (e.g., seek legislative changes) to 

resolve circumstances that reduce our 

effectiveness or efficiency. For example, 

improvements would be needed for 

circumstances such as: (1) overlapping 

regulatory responsibility or dual 

regulation, (2) conflicting positions 

regarding regulatory jurisdiction, and 

(3) conflicting standards that impact 

finality of licensing decisions. Further

more, we will incorporate risk-informed 

and performance-based approaches, as

NRC FY 2000 STRATEGIC PLAN 0

I VOLUME2,PART2 NUCLEAR WASTE SAFETY ý
NUCLAR WSTESAFEY II VOUME2, PRT

appropriate, into our regulatory framework 

where they can substantially improve our 

effectiveness, efficiency, and realism (i.e., 

reduce excessive conservatism). This will 

be accomplished, in part, by conducting an 

integrated evaluation of risk information, 

inspection findings, operating experience, 

research results, and cost data as part of 

the agency-wide Risk-Informed 

Regulation Implementation Plan (to be 

completed by FY 2001). In addition, we 

will continue to incorporate, where 

applicable, existing consensus standards 

and international guidance into our 

regulatory framework. We will also 

encourage stakeholders to develop and use 

new consensus standards. 

Furthermore, we will develop and revise 

appropriate licensing and inspection 

guidance so that applicants and staff have a 

clear and consistent understanding of how 

to develop and review licensing 

applications, respectively. This guidance 

should minimize the staff's requests for 

additional information, subsequent license 

revisions, and additional rounds of staff 

review. It will also help the staff prepare 

for, and conduct, inspections. 

Finally, through research and technical 

studies, and participation in international 

committees and workshops, we will 

anticipate opportunities for regulatory 

improvements that may come from 

industry's introduction of new 

technologies. Similarly, we will use 

domestic and international research, 

technical studies, and risk information to 

reduce excessive conservatism, and ensure 

that the regulatory framework is based on 

technically sound, and realistic 

information. 

We will identify, prioritize, and modify 

processes based on effectiveness reviews

to maximize opportunities to improve 

those processes. 

We will continually improve and 

standardize our processes through a robust 

program of self-assessment and application 

of lessons learned. In particular, 

effectiveness reviews of program and 

program support areas will be conducted 

to determine what work needs to be added, 

maintained, reduced, or eliminated to 

deliver the desired outcomes. Efficiency 

reviews of key processes in program and 

program support areas will be conducted 

to determine the most efficient means of 

delivering the desired outcomes. In 

addition, to improve decision-making, we 

will develop processes that will assess the 

skills and tools needed by the staff to allow 

the appropriate level of decision-making 

for specific types of decisions consistent 

with our statutory and regulatory authority. 

Staff will be authorized to take the 

appropriate and necessary action and make 

decisions that are within the scope of their 

assigned responsibilities and will be 

accountable for those actions and 

decisions. 

Measures 

The NRC will use the following measures 

to make NRC activities and decisions more 

effective, efficient, and realistic: 

Complete those specific waste milestones 

in the Risk-Informed Regulation Imple

mentation Plan identified for completion 

in the annual Performance Plan. 

Complete at least two key process im

provements per year in selected program 

and support areas (considering internal 

and external input) which increase 

efficiency, effectiveness, and realism.

I

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2,- PAT2NCERWSESFT

Complete all major prelicensing 

milestones needed to prepare for a 

licensing review of the Yucca Mountain 

repository, consistent with DOE 's 

schedules and before DOE submits its 

license application. The milestones are: 

(1) final regulation in 10 CFR Part 63, 

(2) Yucca Mountain Review Plan, (3) Site 

Characterization Sufficiency Comments, 

(4) comments on DOE's draft Environ

mental Impact Statement, and 

(5) resolution of key technical issues at 

the staff level.2 7 

Together, these measures were chosen to 

identify the conditions under which the NRC 

would make continuous progress to ensure that 

its regulatory processes (i.e., rulemaking, 

licensing, inspections, and enforcement) have 

appropriate safety and environmental impacts 

in accordance with applicable statutes and 

regulatory requirements, its regulatory duties 

are executed in a business-like fashion, and its 

decisions are technically sound and based on 

realistic information. In addition, a separate 

measure for completing major high-level 

waste prelicensing milestones is included to 

measure our effectiveness in keeping pace 

with the national high-level waste repository 

program without diminishing our focus on 

safety in preparing for a licensing review. 

The agency is currently developing a 

Risk-Informed Regulation Implementation 

Plan (to be completed by FY 2001) and has 

not yet identified the specific milestones for 

the years covered by this Strategic Plan. 

Specific milestones will be identified each 

year in the NRC's Annual Performance Plan. 

NRC will be developing criteria for the choice 

of the specific milestones and for the 

monitoring processes. Milestones for the 

development and implementation of these

I

criteria and the monitoring process will be 

included in the Annual Performance Plan, so 

that progress on this activity will be reported 

to Congress on an annual basis. 

The measure of at least two key process 

improvements per year was selected in 

addition to the risk-informed measure to focus 

on other areas to seek improvement. The 

intent of the measure is to annually develop a 

list of key process improvements. The list will 

be prioritized based on the estimated 

effectiveness of the improvement and the 

completion of the two key process 

improvements would be tracked in the 

.Performance Plan. The number of key 

processes, two, was chosen as a starting figure 

and as experience is gained, that metric may 

be revised. 

IPERFORMANCE GOAL: Reduce Iunnecessary regulatory burden on 

stake holders. 

The NRC will strive to reduce unnecessary 

regulatory burden and associated costs if 

possible, while achieving the other three 

performance goals. Unnecessary regulatory 

burden for the NRC licensees may be defined 

as requirements that go beyond what is 

necessary and sufficient for providing 

reasonable assurance that public health and 

safety, the environment, and the common 

defense and security will be protected. The 

costs associated with the NRC activities can 

impact a variety of the NRC stakeholders. For 

some stakeholders, such as States and the 

public, costs could potentially result from 

actions by States to augment the NRC 

regulatory program, clean up sites, or dispose 

of radioactive material that are paid for with

NRC FY 2000 STRATEGIC PLAN 014
NUCLAR WSTESAFEY VOUME2, PRT*

public funds. For others, such as applicants 

and licensees, unnecessary burden may be 

imposed by an overly detailed technical 

review that could result in increased costs that 

are passed on to the consumer. 

Although regulation, by its nature, is a 

burden, the NRC will ensure that only the 

level of burden necessary to maintain safety is 

imposed on licensees. This burden reduction 

can be achieved by using risk-informed and 

performance-based approaches, if justified, to 

focus attention on those areas of highest safety 

priority and by making more realistic 

decisions without excessive conservatism. We 

will use domestic and international research 

and technical studies to evaluate new 

information in order to identify areas in our 

regulatory programs where unnecessary 

burden and duplication can be reduced. 

Consideration will be given to making 

regulatory burden commensurate with the risk 

of the regulated activity and the enhanced 

benefit to the workers, the public, and the 

environment. Furthermore, regulatory burden 

associated with a safety enhancement will be 

considered in light of a cost/benefit analysis 

prior to the imposition of a new regulatory 

requirement. Regulatory oversight will be fair, 

consistent, effective, and timely in its 

application. Costs associated with the 

regulatory infrastructure must be fair, 

equitable, and shared by all users. 

The NRC believes that some of the 

regulatory burden in the Nuclear Waste Safety 

arena associated with the regulations and 

practices in place over the years was not 

commensurate with the safety benefit. During 

these years, an ever increasing body of 

domestic and international technical 

knowledge, operational experience, and

development of risk assessment tools has been 

accumulated. This has allowed recent 

refinements and significant enhancements to 

NRC regulations, programs, and guidance. 

Continuing these ongoing efforts and 

increasing the attention to implementing the 

new rules are critical to implementing a more 

risk-informed regulatory framework for these 

programs. These efforts will provide the basis 

for further reducing unnecessary regulatory 

burden. 

Strategies 

The NRC will employ the following 

strategies to reduce unnecessary regulatory 

burden on stakeholders: 

We will continue to improve our 

regulatory framework in order to reduce 

unnecessary regulatory burden. 

We will use risk-informed and 

performance-based approaches, where 

appropriate, to ensure that all elements of 

our regulatory programs (i.e., regulations, 

guidance, licensing, assessment, 

inspection, and enforcement) are 

conducted commensurate with the level of 

risk. This will provide licensees with 

flexibility in meeting regulatory 

requirements. The scope and priority of 

changes in our regulatory processes will 

consider stakeholder input, the effects of 

dual regulation with other Federal and 

State entities, and the cumulative effect 

each has on agency and licensee burden 

reduction. In addition, we will use 

domestic and international research and 

technical studies to evaluate new 

information in order to identify areas in 

our regulatory programs where 

unnecessary burden and duplication can be 

reduced. New information includes

52 NRC FY 2000 STRATEGIC PLAN
improvements in knowledge, advances in 

technology, and insights gained from 

operational and regulatory experience, 

both domestically and internationally. 

Research will focus on identifying where 

excessive conservatism can be eliminated 

or reduced. 

We will improve and execute our 

programs and processes in ways that 

reduce unnecessary costs to our 

stakeholders. 

As we execute our programs, we will 

make improvements to those aspects of our 

regulatory processes that had resulted in 

unnecessary costs to our stakeholders. In 

particular, we will evaluate the adequacy 

of guidance, the timeliness of actions, the 

necessity for multiple rounds of requests 

for additional information, and the 

necessity of dual regulation with other 

Federal and State entities. 

As we make licensing decisions, conduct 

inspections, and take enforcement actions, 

we will take into account the necessity of 

any additional burdens imposed on 

licensees and other stakeholders. 

We will evaluate the sufficiency of funding 

and sureties for remediation of sites. In 

addition, we will ensure that NRC actions 

minimize the potential for future 

bankruptcies of companies resulting from 

remediation and decommissioning of 

facilities. For example, we will ensure that 

NRC actions are timely and do not cause 

undue delays while waiting for an NRC 

decision or impose overly conservative 

solutions, both of which could result in 

higher costs from either maintaining or 

remediating a site.

We will actively seek stakeholder input to 

identify opportunities for reducing 

unnecessary regulatory burden. 

We will encourage licensees to identify for 

NRC consideration concerns with the 

NRC's regulatory programs, such as 

untimely, inadequate, or inappropriate staff 

actions, that have resulted in unnecessary 

cost. In addition, we will continue 

initiatives to interact with stakeholders to 

ensure a mutual understanding of existing 

regulatory requirements, guidance, or 

licensing decisions. Such interactions will 

provide opportunities for stakeholders to 

identify problems or suggest improve

ments. The NRC will also be able to 

clarify or explain the basis for 

requirements, guidance, or licensing 

decisions and why we believe they are 

necessary and sufficient. Where guidance 

is being developed or used for the first 

time, we will invite stakeholder feedback 

to identify aspects of the guidance that 

might be unclear, unnecessary, inflexible, 

or otherwise considered excessively 

burdensome by the licensee. Where 

licensees are using new requirements or 

guidance for the first time to prepare 

specific submittals, we will be available to 

interact with them upon request during the 

development of the submittals. We will be 

able to provide guidance concerning 

implementation questions or technical 

issues they identify relating to 

understanding NRC requirements that 

might help them prepare an acceptable 

application. 

Measures 

The NRC will use the following measure 

to reduce unnecessary regulatory burden on 

stakeholders:

I ______________________________

NRC FY 2000 STRATEGIC PLAN

6OUEAT ULERWSESFT
NULA WAT SAEYVLM ,PR

Complete those specific milestones to 

reduce unnecessary regulatory burden as 

identified in the annual Performance 

Plan. 

The NRC wants its regulatory programs to 

be protective at reasonable cost and without 

excessive conservatism. The NRC seeks 

opportunities to reduce existing unnecessary 

regulatory burden and will strive to ensure that 

any new actions by the NRC do not impose 

any new unnecessary regulatory burden. The 

performance goal measure is designed to 

assess how the agency is meeting these 

objectives and apply only to the NRC. They 

exclude Agreement States. The objective of 

this measure is to develop a program (to be 

developed by FY 2001) that will track 

instances where the NRC may have 

overlooked a potential unnecessary regulatory 

burden associated with implementation of new 

or revised regulations or regulatory guidance 

that became effective during the reporting 

period. It includes instances of license review, 

inspection, or enforcement activities where 

new or existing regulations and regulatory 

guidance may have been inappropriately 

applied. The program will identify methods 

for licensees or other external stakeholders to 

inform the NRC of a potential regulatory 

burden. The program will also develop a 

screening process and criteria so that only 

valid concerns are forwarded to responsible 

management who will be required to evaluate 

each item as a potential example of 

unnecessary regulatory burden and 

recommend an appropriate course of action 

within a defined time period. The program 

will also track and trend the valid cases to 

identify any adverse trends. The milestones in 

the Performance Plan will identify when the 

program will be developed and implemented. 

Then future milestones will indicate actual

performance measures based on realistic but 

challenging goals. In addition, the first metric 

provides an indication of quality of work. Any 

NRC activity that imposes new unnecessary 

regulatory burden indicates that the work 

process failed to identify the new burden. 

No additional measure for reducing any 

current burden was used because the efforts 

for completing the milestones for 

risk-informing activities should, in addition to 

increasing effectiveness, efficiency, and 

realism, reduce unnecessary burden. Further 

opportunities to identify unnecessary 

regulatory burdens will be sought through 

interactions with external stakeholders as a 

matter of policy. 

STATUTORYA UTHORITY 

- Atomic Energy Act as amended 

- Energy Reorganization Act as amended 

- Energy Policy Act 

- Hazardous Materials Transportation 

Uniform Safety Act 

- Low-Level Radioactive Waste Policy Act 

- Low-Level Radioactive Policy Amendments 

Act 

- Nuclear Waste Policy Act 

- Nuclear Waste Policy Amendments Act 

- West Valley Demonstration Project Act 

- Waste Isolation Pilot Plant Land Withdrawal 

Act 

- Endangered Species Act 

- National Historic Preservation Act 

- National Environmental Policy Act 

- Nuclear Non-Proliferation Act

0 NRC FY 2000 STRATEGIC PLAN
VOUE2 AT2NCERWSESFT

MAJOR EXTERNAL FACTORS 

Listed below are assumptions about major 

external factors and how they might affect 

achieving the goals of the Nuclear Waste 

Safety arena: 

" The strategic goal of promoting the 

common defense and security in the 

Nuclear Waste Safety arena assumes no 

change in the threat of terrorism. With 

that assumption, the current security and 

safeguard requirements are adequate to 

maintain the strategic goal. 

" Permanent disposal of high-level waste 

will continue to be a goal of the national 

program, and the NWPA and the Energy 

Policy Act of 1992 (EnPA) statutory 

requirements will remain in effect. 

Furthermore, DOE will continue its plan 

to submit a site recommendation to the 

President in FY 2001 and a license 

application to the NRC in FY 2002 for a 

geologic repository at the Yucca Mountain 

site. However, uncertainty exists about 

whether and how Congress might change 

the national program in future legislation. 

Uncertainty also exists about DOE's 

schedule given recent congressional 

budgeting actions affecting DOE's 

program. 

Future legislation could define a high-level 

waste disposal standard and/or specify new 

agency responsibilities for standard 

development. Such changes would affect 

our regulation and Yucca Mountain 

Review Plan. Changes in DOE's schedule 

would affect the NRC's schedules for 

conducting its pre-licensing reviews, 

commenting on site characterization

_____________________ i

sufficiency, and making a licensing 

decision for the proposed geologic 

repository. Other significant legislative 

changes could affect our spent fuel storage 

and transportation activities as well, such 

as: initiating an integrated spent fuel 

storage and transportation strategy that 

includes a national centralized interim 

spent fuel storage facility, mandating that 

DOE "take title" to the spent nuclear fuel 

at the commercial reactor sites, or 

designating spent nuclear fuel as a 

resource for use rather than as a waste 

product for disposal. 

Regardless of the actions that Congress 

may take, spent fuel at commercial 

reactor sites continues to mount, which 

will almost certainly require an increase 

in the use of dry cask storage technology 

and the licensing of independent spent 

fuel storage installations. However, 

uncertainties exist about specific actions 

and schedules. 

Commercial reactor licensees will need to 

increase spent fuel storage capacity over 

the next several years. Storage of spent 

fuel will continue at commercial 

independent spent fuel storage installations 

(either under a general license or a 

site-specific license), and a commercially 

sponsored away-from-reactor central 

storage facility is under review (i.e., 

Private Fuel Storage, L.L.C.). While 

progress has been made in the review of 

spent fuel storage facilities and dual

purpose (spent fuel storage and 

transportation) cask systems, anticipated 

licensing actions are expected to increase. 

Moreover, the NRC may receive an 

application for a second away-from

reactor central independent spent fuel

NRC FY 2000 STRATEGIC PLAN
NUCLAR WSTE AFET

storage installation to store commercial 

reactor spent fuel. Also, licensees will 

need to prepare to transport spent fuel. 

Furthermore, depending upon the 

legislative action taken by Congress 

regarding DOE taking title to the spent 

fuel at each commercial reactor site, 

licensees may decide to begin storing fuel 

in dry cask storage at their site on an 

accelerated schedule. Moreover, DOE 

itself (or its contractor) may submit a 

license application for the storage of spent 

fuel at a DOE facility. The above 

uncertainties could cause changes to or 

conflict with work priorities and schedules 

that, in turn, would reduce staff efficiency 

and possibly delay licensee schedules. 

Finally, if new spent fuel storage and 

transportation technologies are introduced, 

the NRC will need to become 

knowledgeable in the new areas in order to 

review, approve and inspect the new 

designs. Additionally, as DOE delays 

taking spent fuel from the licensees, dry 

cask storage certificates and independent 

spent fuel storage installation licenses will 

have to be renewed. This may present 

technical challenges that have not been 

considered and need to be addressed by 

revising the regulatory framework. 

Differences will continue among Federal 

agencies regarding an acceptable level of 

risk and groundwater protection. These 

differences contribute to uncertainty about 

completing the regulation and review plan 

for the high-level waste repository 

program and the finality of our license 

termination decisions for 

decommissioning. 

EPA's proposed standard for the Yucca 

Mountain high-level waste repository

includes a separate groundwater protection 

requirement and details for implementing 

the standard, which the NRC has opposed 

in formal comments to EPA. If a final EPA 

standard retains some of these proposed 

requirements, particularly the separate 

groundwater protection requirement, 

additional NRC work may be needed that 

could impact schedules and costs. 

Additional work could include developing 

new requirements with supporting tech

nical bases and associated review plans. 

Lack of finality for decommissioning 

decisions could cause additional work to 

be done by the licensee or impact the 

licensee's future plans for the use of a site. 

Agency differences will also unnecessarily 

complicate the public's understanding of 

the acceptable level of protection for the 

public. Furthermore, continued lack of 

resolution will diminish public confidence 

in the credibility of both NRC and EPA 

and would also give the appearance to the 

public that the NRC is less protective than 

EPA. 

There will continue to be substantial 

public interest and involvement in all 

nuclear waste arena activities. Opposition 

may require specific attention to program 

or licensee-specific factors. 

With respect to the performance goal of 

increasing public confidence, interactions 

with the public are important for 

generating understanding of and 

confidence in NRC decisions. This 

confidence is generally based on the 

public's perceptions regarding the 

regulator and the industry. Some of these 

perceptions are based on: (1) actual 

experience with the NRC and its 

performance, (2) external factors (e.g., 

media reports, political commentaries,

0 NRC FY 2000 STRATEGIC PLAN
I VOUM 2,PR .ULARWSESFT

special interest group efforts, and industry 

group statements) that may or may not be 

closely linked to our actual performance, 

and (3) operational events such as 

accidents at Three Mile Island and 

Chernobyl even though the impact on 

health and safety of the first accident was 

minimal and the facility involved in the 

second accident was outside the NRC's 

regulatory control. To many, confidence 

(or lack of confidence) in the regulator and 

in the regulated community cannot be 

clearly separated. Therefore, we recognize 

the potential that our activities, licensee's 

activities, and international events jointly 

contribute to, or erode, the public's 

confidence and may cause us to take 

additional measures to assure the public. 

Responding to public interest and 

improving public involvement will result 

in additional resource costs to both the 

NRC and licensees. However, if additional 

resources are invested early in a project to 

obtain input from the public, a better 

quality product should result and costs 

could be reduced later in the project to 

address more entrenched opposition or to 

resolve conflicts. Recent experience with 

our public workshops for the control of 

solid materials illustrates another 

challenge. In some cases, public interest 

groups have boycotted our workshops 

because of their opposition, thereby 

precluding our initiatives to inform these 

stakeholders and obtain their input about 

this important issue. Such resistance will 

result in additional costs for our future 

efforts to inform and involve important 

stakeholders. In any case, our efforts may 

not be successful and could negatively 

affect our overall goal of improving public 

confidence in the NRC as a regulator.

i

The cleanup and long-term institutional 

control of permanently shutdown nuclear 

materials facilities will be a challenge 

where responsible parties lack adequate 

resources. 

For some decommissioning sites, clean-up 

costs are projected to be very high (well 

over $100 million in some sites) and 

beyond the financial capability of licensees 

and responsible parties. In some cases, 

corporate pressure is strong to minimize 

remediation costs, especially when 

operations have ceased and the facility is 

no longer a source of corporate income. In 

other cases, the costs may bankrupt 

corporations, then be passed along to the 

public. We recognize the desire of 

responsible parties to minimize costs, and 

we will assure that unnecessary costs will 

not occur. However, we must take the 

necessary regulatory actions, including 

financial assurance, so that remediation 

can be completed consistent with our 

regulations to assure meeting the 

performance goal of maintaining safety 

and protection of the environment. 

Agreement States will continue to assume 

responsibility for decommissioning Site 

Decommissioning Management Plan 

(SDMP) sites. In FY 2002, 10 sites will 

be transferred to Pennsylvania and one 

will be transferred to Minnesota unless 

these States make a request similar to 

Oklahoma's request not to transfer the 

SDMP sites in their State. 

The 11 sites in Pennsylvania and 

Minnesota make-up nearly half of the 26 

SDMP sites which NRC is currently 

responsible for. Therefore, final decisions 

regarding site transfer could result in

NRC FY 2000 STRATEGIC PLAN <0
NULA WAT0AEYVOUEAT

major changes to our plans and schedules 

for the decommissioning program. Such 

changes could impede expeditious cleanup, 

raise public concern, and affect the 

efficiency of our work. 

The continued availability of low-level 

waste disposal capacity is uncertain and 

will be determined largely by external 

factors. For example, the Barnwell 

low-level waste disposal facility in South 

Carolina will close to all out-of-compact 

generators in 2008 and will be limited 

each year, from 2001, to decreasing 

amounts for disposal. Only the states of 

Connecticut, South Carolina, and New 

Jersey are in the Atlantic Compact. 

Another uncertainty is whether the 

Envirocare facility in Utah will be granted 

a license amendment to accept all classes 

of low-level waste, not just Class A waste, 

which it currently accepts. The company

submitted an amendment request to the 

State in 1999. 

Closure of or access restrictions on 

operating low-level waste disposal 

facilities could force dispersed storage of 

waste. Should this occur, we would need 

to complete the guidance for low- level 

waste storage that was begun in 1994, but 

suspended because of the reopening of the 

Barnwell facility in 1995. Other potential 

impacts include delays in decommission

ing of large facilities and an increased 

interest by licensees in alternatives to 

conventional disposal, such as increased 

use of the Resource Conservation and 

Recovery Act of 1976 cells for slightly 

radioactive materials. There could also be 

license applications for new facilities from 

private companies, or for a new low-level 

waste management technique, assured 

isolation, both of which could require 

NRC resources to address.

I

0 NRC FY 2000 STRATEGIC PLAN
VOL I P 2

INTERNATIONAL NUCLEAR 

SAFETY SUPPORT 

STRATEGIC GOAL: Support US. interests in the safe and secure use of nuclear 

materials and in nuclear nonproliferation.

The International Nuclear Safety Support 

strategic arena28 encompasses international 

nuclear policy formulation, export-import 

licensing for nuclear materials and equipment, 

treaty implementation, nuclear proliferation 

deterrence, international safety assistance, and 

safeguards support and assistance. The NRC 

also participates in international safety 

cooperation, information exchange, and 

cooperative safety research. These activities 

are addressed in the individual Nuclear 

Reactor Safety, Nuclear Materials Safety, and 

Nuclear Waste Safety strategic arenas because 

that is where most of the results of these 

international efforts are used, where their 

major resource support is located, and 

consequently where their benefits and costs 

can most effectively be measured. NRC 

international activities maintain support of the 

NRC's domestic mission, as well as of broad 

U.S. domestic and international interests. In 

this way, we help influence the incorporation 

of effective policies and practices into the 

nuclear programs of other countries and 

international organizations to improve safety 

and security and to reduce the potential for 

proliferation while gaining valuable 

knowledge, experience, and resources for our 

domestic regulatory and research programs. 

With every major problem in the international 

nuclear arena having repercussions for the

NRC or the domestic program, and with our 

commitment to protect the global commons, it 

is in the direct interest of both the NRC and 

the United States to enhance the safe and 

secure operation of nuclear facilities 

worldwide. 

The absence of the domestic 

implementation and impact from full 

discussion within this chapter is not meant to 

diminish their value. The focus of this chapter 

is on international activities that are not 

otherwise captured-those of an external, 

outward-looking nature, where our national 

interests are the primary motivator and the 

NRC operates within the foreign policy 

framework of the U.S. as defined by the 

President (through the National Security 

Council and the Department of State) and 

Congress. This chapter will concentrate on the 

NRC's international activities in support of 

nonproliferation, safety and safeguards 

assistance, Executive Branch initiatives, and 

influence and partnership in the international 

nuclear community. We use "assistance" to 

denote outward-focused or humanitarian 

activities where the U.S. interests are the 

primary motivator and where the benefits are 

largely intangible. Cooperation activities, in 

contrast, provide direct benefits to the NRC 

domestic program.

m

NRC FY 2000 STRATEGIC PLAN
INENTOA NULER SAET SO PPR VOLUM 2,PR

As regulator of the largest and one of the 

oldest nuclear programs, and with a safety 

research program and policies of openness and 

international engagement to support us, the 

NRC has been a leader and retains a position 

of influence in the international nuclear 

community. We regulate about 25 percent of 

the world's operating power reactors. In 

addition, the U.S. is the world's largest 

exporter of nuclear fuel, equipment, and 

technology. When the Kahl Nuclear Power 

Station in Germany achieved criticality in 

1961, it became the first civilian power reactor 

of U.S. design to be commissioned outside the 

U.S. Today, more than 40 percent of reactors 

operated outside the U.S. are of U.S. design, 

and new technologies developed in other 

countries are being used in our domestic 

program. 

The NRC has carried out a program of 

international activities since its inception in 

January 1975, continuing the exchange of 

information and cooperation in nuclear safety 

and safety research matters as well as efforts 

to upgrade safeguards and encourage 

nonproliferation begun by its predecessor 

agency, the Atomic Energy Commission. The 

primary purposes of our international safety 

activities have been and remain: 

"To gain access to non-U.S. safety 

information that can alert us to potential 

safety problems, help us identify possible 

accident precursors, and provide accident/ 

incident analyses, including lessons 

learned, that could be directly applicable 

to the safety of U.S. nuclear power plants 

and other facilities; 

" To assist other countries in their attempts 

to prevent accidents and to develop or 

improve their regulatory capabilities and 

nuclear safety cultures;

"* To influence international nuclear 

regulatory standards, policies, and 

practices; and 

"* To leverage research dollars, exchange 

research results, share research facilities, 

coordinate analyses of important issues, 

and avoid duplication of efforts. 

The primary purposes of our international 

safeguards and nonproliferation activities have 

been and remain: 

* To implement or help meet U.S. statutory, 

treaty, and international agreement 

obligations; 

* To strengthen domestic safeguards 

systems in other countries; and 

* To support and strengthen the 

nonproliferation regime. 

The U.S. policy is to pursue (a) assurances 

that any nuclear materials or equipment 

supplied will be used for peaceful purposes 

only, and (b) the establishment of more 

effective domestic and international controls 

over the transfer and use of nuclear materials, 

equipment, and technology for peaceful 

purposes, with the goal of helping to prevent 

or deter proliferation. Nuclear nonproliferation 

is implemented through a combination of 

treaties, agreements, procedures, under

standings, and principles that support the 

established international system of 

proliferation control and deterrence. This 

system includes the Treaty on the Non

Proliferation of Nuclear Weapons (NPT); 

regional nuclear weapons-free zone treaties; 

bilateral and multilateral cooperation 

agreements; international and domestic 

safeguards; nuclear export controls; 

verification activities to monitor NPT and 

safeguards agreement compliance; diplomatic 

interventions; and international sanctions, 

when diplomacy has failed.

* NRC FY 2000 STRATEGIC PLAN
VOUM 2,PR .NENTOA ULA S AFT SUPOR

Although much progress has been made in 

the areas of international safety, safeguards, 

and nonproliferation, there is still much to be 

done, both bilaterally and with the two 

international organizations with which we 

work most closely, the International Atomic 

Energy Agency (IAEA) and the Nuclear 

Energy Agency (NEA) of the Organization for 

Economic Cooperation and Development. By 

judiciously strengthening nuclear safety, 

safeguards, and nonproliferation cooperation 

internationally, as needs are identified, 

evaluated, and ranked, the NRC can better 

support the efforts of countries and 

international organizations to develop and 

implement more effective measures to reduce 

the potential for nuclear accidents, loss of 

control of nuclear materials, and spread of 

nuclear weapon technology. The NRC 

leadership/partnership role enables us to foster 

the development of consistent and defensible 

international nuclear policies and practices, as 

well as research activities, which enhance 

nuclear safety, safeguards, and 

nonproliferation interests. 

The primary foundation for the NRC's 

international activities is the Atomic Energy 

Act of 1954, as amended; the Energy 

Reorganization Act of 1974, as amended; the 

Nuclear Non-Proliferation Act of 1978; other 

statutes; executive orders and directives; 

treaties and conventions; other international 

agreements; and Commission directives. 

Strategies 

The NRC will employ the following 

strategies to support U.S. interests in the safe 

and secure use of nuclear materials and in 

nuclear nonproliferation:

We will continue to take a proactive role 

in strengthening safety, safeguards, and 

nonproliferation worldwide. 

By working proactively to strengthen 

safety, safeguards, and nonproliferation, 

the NRC strives to prevent or minimize the 

occurrence and mitigate the severity of 

safety and safeguards events and 

proliferation incidents and to ensure that 

those that may occur do not result from a 

failure of the NRC to meet its obligations. 

We will continue to proactively support 

U.S. interests to help ensure that 

international outcomes are consistent with 

U.S. goals. The NRC not only works 

collaboratively with other U.S. 

Government agencies to identify and 

frame the U.S. interests, but it also works 

in cooperation with entities from other 

countries addressing the same interests. On 

some issues, the NRC provides the 

international leadership to advance the 

issue; on others, we provide support to 

countries that have taken leadership in 

advancing the issue. In cases where we 

play a less proactive role, we will work to 

reduce the likelihood of adverse impacts to 

U.S. interests. 

The NRC will continue to represent the 

U.S. in international meetings, provide 

policy guidance and technical assistance to 

other countries and international 

organizations, exchange technical 

information, participate in bilateral and 

multilateral research programs, and 

comply with international obligations. We 

will continue to hold positions of influence 

and/or chair and participate on interagency 

and international committees and to detail 

personnel to other key domestic and

NRC FY 2000 STRATEGIC PLAN
INENTOA . ULASFT SdPR VOUM 2, PAR 2.

international organizations. We will do this 

because such activities help us guide the 

direction and scope of important 

international safety, safeguards, and 

nonproliferation initiatives; share our 

expertise; and acquire new insights useful 

to the U.S. program. 

We will focus appropriate agency 

activities and resources on significant 

international obligations and U.S. and the 

NRC international priorities. 

By focusing agency activities and 

resources on significant international 

obligations and U.S. international 

priorities, the NRC seeks to ensure that we 

continue to meet our significant 

international commitments, while also 

demonstrating our full support of nuclear 

safety, safeguards, and nonproliferation 

worldwide. By significant obligations, we 

mean major NRC commitments under U.S. 

nuclear statutes, treaties, conventions, and 

Agreements for Cooperation.29 

We will carry out and track our significant 

obligations under this strategy. For 

example, we will conduct thorough and 

timely licensing reviews of proposed 

nuclear exports and imports, as required by 

statute. In this role, and in the 

Commission's related consultations with 

Executive Branch agencies, the NRC will 

take actions to confirm the reliability of 

the U.S. to meet its commitments to 

supply special nuclear material and/or fuel 

cycle equipment to nations that adhere to 

effective nonproliferation policies. We will 

consult with the Department of Energy on

U

0

Part 810 technology transfers, develop 

independent recommendations on 

proposed Agreements for Cooperation, 

implement IAEA safeguards at licensee 

facilities, and submit international 

safeguards data to the IAEA. To fulfill 

these obligations, we will conduct 

rulemaking proceedings, as necessary. 

In addition to these significant obligations, 

the NRC will continue to engage in other 

activities that are required by agency-to

agency bilateral technical information 

"exchange and cooperative research 

agreements (see other arenas), or directly 

support U.S. and NRC international 

policies. Examples of these activities are 

information exchange with our regulatory 

cooperation partners and their support 

organizations, safety and safeguards 

assistance to the countries of the Former 

Soviet Union (FSU), support and 

strengthening of the nonproliferation 

regime, and participation in important 

policy and technical activities of the IAEA 

and NEA. 

We will identify significant obligations 

and other international related activities, 

set priorities for these obligations and 

activities, track required actions, and 

effectively manage the entire process. 

When issues emerge, we will adjust our 

plans, schedules, and resource allocations, 

as necessary, to ensure that attention is 

focused on the highest priority activities 

and that they are conducted efficiently. 

We will enhance integration of 

international activities in the NRC.

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2, PAR 2 NENTOA ULERSFT UPR

The NRC will develop a more focused 

international program supported by all 

involved offices to promote a common 

approach to, and provide more timely 

information and guidance on, international 

issues and activities. We have established 

an International Council to improve 

agency-wide coordination of international 

activities. Under this Council, senior 

managers meet regularly to exchange 

information; address questions and resolve 

problems; identify and discuss 

international priorities (including changed 

emphases or new initiatives that should be 

brought to the Commission's attention); 

and secure participating offices' support, 

in principle, of planned activities. The 

Council meetings are followed up by 

summary reports, which are prepared and 

circulated to senior managers, who are 

responsible for conveying the results of 

these meetings to their staff. This ongoing 

dialogue is expected to keep both 

managers and staff better informed thereby 

maximizing benefits to the agency, 

enhancing efficiency, and avoiding 

duplication of efforts. The International 

Council also provides a forum for ensuring 

that the NRC's international activities 

result in a consistent program focused on 

the agency's strategic goals. 

We will make more extensive use of 

information technology and the Internet to 

assure that the staff have access to the 

information they need (including trip 

reports by previous trayelers) to participate 

most effectively in the international arena. 

We will look at steps to more effectively 

call to the technical staff's attention 

significant information gleaned from 

foreign interactions. Finally, we will

I

clarify the NRC management's 

expectations for staff working on 

international arena activities to understand 

their role and responsibilities while 

representing the NRC and larger U.S. 

interests. 

The NRC's international activities span the 

agency and are the province of no single 

office. Because of this, a critical element 

of our success is how well we are able to 

integrate or harmonize our international 

activities within the NRC. This integration 

strategy, because it is directed at the 

NRC's international activities overall, 

results in impacts to both our international 

and our domestic nuclear programs. 

Although the impact of international 

activities on the U.S. nuclear program is 

addressed in the individual program 

mission chapters, the primary function of 

much of our international effort is to 

facilitate the achievement of the other 

three arenas' strategic and performance 

goals and, ultimately, of the NRC's 

mission. 

The U.S. is only one of many countries 

forming the international nuclear community 

and the NRC is one of several Federal 

agencies and multiple national regulatory 

authorities involved in international nuclear 

activities. We can try to influence international 

nuclear safety, safeguards, and nonprolifer

ation decisions and activities, when it is in our 

interest and identified as an agency priority to 

do so, but we do not and cannot control them. 

In addition, because of the diversity of this 

arena and the nature of diplomacy, the pace of 

progress is often incremental. Many of our 

international initiatives represent multi-year 

rather than annual efforts. It is steps toward 

their achievement that will be measured.

NRC FY 2000 STRATEGIC PLAN
INENTOA NULA SAFETY .S SUPOTVLM ,PR

Measures 

The NRC will use the following measures 

to assess the results of our efforts to support 

U.S. interests in the safe and secure use of 

nuclear materials and in nuclear 

nonproliferation: 

"Fulfill 100 percent of the significant 

obligations over which the NRC has 

regulatory authority arising from statutes, 

treaties, conventions, and Agreements for 

Cooperation.29 

" No significant proliferation incidents 

attributable to some failure of the NRC. 

" No significant safety or safeguards events 

that result from the NRC's failure to 

implement its international commitments. 

"* Outcomes in international forums are 

consistent with U.S. Government 

objectives identified as pertinent to and 

actively supported by the NRC at least 60 

percent of the time. 

The measures reflect the diversity of the 

NRC's international activities. Both the 

measures and metrics demonstrate our 

commitment to comply with significant 

international obligations, to exchange 

information with and provide assistance to 

other countries and international organizations 

to minimize safety and safeguards events and 

proliferation incidents, and to help accomplish 

U.S. Government objectives in the 

international nuclear community. Failure to 

achieve these targets would trigger a self

assessment. 

The first measure addresses only the 

significant U.S. obligations for which the

NRC has responsibility. These obligations are 

derived from nuclear statutes, treaties, 

conventions, and Agreements for Cooperation 

and must be of identified importance. Failure 

to meet these obligations can significantly 

impair the U.S. Government's ability to pursue 

its international interests as a trustworthy 

participant. These obligations will be tracked 

to ensure that they are met. Compliance with 

lesser NRC commitments, although not 

identified in the measure, remains an 

important component of our strategies. 

The second measure addresses the 

importance the NRC places on nuclear 

nonproliferation. We will continue to exercise 

our responsibilities such as export control and 

safeguards assistance to help prevent 

significant proliferation incidents. Significant 

proliferation incidents are defined as actions 

initiated by a country that threaten the 

fundamental objectives/stability of the nuclear 

nonproliferation system and/or violate NPT 

and Safeguards Agreement commitments. In 

practical terms, this could include a non

nuclear weapon state's detonation of a nuclear 

device, its decision to no longer accept 

international safeguards on all of its peaceful 

nuclear activities or to give specific assurances 

that it will not manufacture or otherwise 

acquire any nuclear explosive device, and/or 

its engagement in activities involving source 

or special nuclear material or equipment 

having a direct connection to the manufacture 

or acquisition of nuclear explosive devices. 

The third measure addresses the 

importance the NRC places on the safe and 

secure use of nuclear materials. We will 

continue to exercise our responsibilities 

through information exchange, technical 

assistance, and research cooperation to help

# NRC FY 2000 STRATEGIC PLAN
I VOUM 2,~ PAT2ITRAINLNCERSFT UPR

prevent significant safety or safeguards events. 

Significant safety events will be identified 

through use of the International Nuclear Event 

Scale (INES).30 Events are classified on a 

scale of seven levels, with the lower three 

termed "incidents" and the upper four 

"accidents." The NRC will focus its evaluation 

on events that are categorized at INES Level 3 

or above. Level 3 is the appropriate threshold 

because it captures the upper limit of facility 

"incidents" as well as significant radiation 

exposures that exceed regulatory limits. A 

significant safeguards event is considered to 

be the theft or diversion of a formula quantity 

of strategic special nuclear material. This is of 

concern because of the possibility that terrorist 

groups or rogue nations could use the material 

to construct a nuclear explosive device. 

Additionally, the sabotage of nuclear material 

or components containing nuclear material 

could represent a significant threat to public 

health and safety through the release of 

radiation into the environment. 

The NRC plays a leading or influential 

role in international forums that can best 

further U.S. Government nuclear safety, 

safeguards, and nonproliferation objectives. 

This role includes activities to improve the 

efficiency and effectiveness of international 

organizations and to raise the levels of safety 

consciousness and technical expertise of 

international regulatory authorities, as 

appropriate. The NRC chairs or has 

representatives on key international nuclear 

committees and working groups, and provides 

direction and recommendations on 

international initiatives either directly or 

through U.S. interagency coordination. The 

fourth measure addresses the NRC's success in 

using its leadership and other positions of 

influence in international nuclear forums to 

bring about outcomes that are consistent with

U.S. Government objectives that have been 

identified and are actively being supported as 

significant to the NRC. 

STATUTORYA UTHORIT 

- Atomic Energy Act as amended 

- Energy Reorganization Act as amended 

- Nuclear Non-Proliferation Act 

- Convention on the Physical Protection of 

Nuclear Material 

- Convention on Nuclear Safety-Agreement 

Between the United States of America and 

the International Atomic Energy Agency for 

the Application of Safeguards in the United 

States of America 

MAJOR EXTERNAL FACTORS 

Listed below are assumptions about major 

external factors and how they might affect 

achieving the goals of the International 

Nuclear Safety Support arena: 

High-level U.S. Government international 

nuclear safety, safeguards, and 

nonproliferation policy initiatives will 

continue to require our participation and 

assistance. 

Although it is recognized that, because of 

the changing world picture, the focus or 

intensity of individual efforts may be 

altered at any time, the total NRC support 

of U.S. Government safety, safeguards, 

and nonproliferation initiatives is expected 

to remain at or near the current level. We 

will continue to meet the critical elements 

of our significant international obligations 

as well as other important international

NRC FY 2000 STRATEGIC PLAN
INENTOA NULAS'FTSUPR VOUM 2, PATS

activities. These premises constitute the 

foundation of the NRC's International 

Nuclear Safety Support arena. The 

strategic goal and associated strategies and 

measures are driven by these factors. 

Advanced countries and international 

organizations (e.g., IAEA, NEA, and the 

International Nuclear Regulators 

Association) will continue to seek our 

cooperation in safety, safeguards, and 

nonproliferation. 

Through cooperation with key advanced 

country and international organization 

partners, the NRC will enhance regulatory 

and research information exchange, help 

develop needed safety guidelines, 

coordinate approaches on international 

nuclear safety issues, and strengthen the 

nonproliferation regime. The number of 

critical research facilities and the levels of 

research funding and technical capabilities 

will continue to decline worldwide, so the 

NRC will leverage its available resources 

and undertake collaborative research 

projects to optimize expenditures and 

investigative results. These factors will 

continue to drive international activities 

addressed in the first two strategies. 

Continuing safety and safeguards needs in 

a number of countries will lead to 

continued requests for NRC assistance 

from foreign regulatory bodies, 

particularly in the Former Soviet Union, 

Central and Eastern Europe, and Pacific

Rim countries as they focus on 

developing or enhancing their regulatory 

programs. 

The NRC will not be able to accommodate 

all incoming requests for assistance, since 

its total support of assistance activities is 

expected to remain near the current level 

or experience very modest growth at best. 

We will have to establish assistance 

priorities and adhere to them as closely as 

possible, acknowledging that the focus or 

intensity of individual efforts may be 

altered by changing circumstances at any 

time. Factors considered in setting 

priorities for these assistance requests 

include the severity of the identified 

problem or need, the origin of the involved 

technology, the state of U.S. relations with 

the country, and whether the assistance to 

be rendered is part of a larger U.S. or other 

international initiative. Our assistance 

activities are an integral part of the first 

two strategies. 

One of the U.S. interests encompassed in 

the International Nuclear Safety strategic 

goal is to maintain adequate protection, 

control and accounting over nuclear 

materials outside the U.S. This strategic 

goal assumes no change in the threat of 

terrorism. With that assumption, current 

export licensing, international physical 

security, safeguards, and transportation 

requirements and information exchange 

and technical assistance activities are 

adequate to maintain the strategic goal.

0 NRC FY 2000 STRATEGIC PLAN
I] VOLUME 2 PART* 2•

C ORPORATE MANAGEMENT 

STRATEGIES

To help accomplish our strategic and 

performance goals, we have established the 

following corporate management strategies: 

"* Employ innovative and sound business 

practices. 

" Sustain a high-performing, diverse 

workforce. 

" Provide proactive information 

management and information technology 

services. 

* Communicate strategic change. 

These corporate management strategies 

help us work together more effectively, both 

within and across strategic arenas. These 

strategies also help the support offices better 

serve their customers within the agency to 

help them achieve the agency's goals. Our 

corporate management strategies describe the 

means by which we will conduct business to 

successfully implement the Strategic Plan and 

accomplish the agency's mission. For the next 

update/revision cycle for the Strategic Plan, 

the NRC will develop measures for Corporate 

Management Strategies. 

Employ Innovative and Sound 

Business Practices 

We are ultimately accountable to the 

taxpayer for our performance. Implicit in this

Y

responsibility is the obligation to foster 

innovative and sound business practices, 

ensure integrity, and accomplish our mission 

in an effective and efficient manner. 

Improving processes and exercising good 

business judgment is critical for improving 

effectiveness and efficiency throughout the 

agency. 

The NRC will employ the following 

supporting strategies to foster innovative and 

sound business practices: 

We will strengthen collaborative processes 

for conducting business among support 

offices and between support and program 

offices. 

As part of the planning process, support 

offices will collaborate with each other and 

with program offices to identify the 

strategies and activities that will contribute 

the most to achieving success. For 

example, collaboration is essential for 

integrating information technology 

initiatives with programmatic initiatives 

and for integrating training and 

development with programmatic initiatives 

to improve performance. 

a We will improve customer service, 

balancing internal customer needs with 

overall agency priorities and available 

resources.

IM

NRC FY 2000 STRATEGIC PLAN
CORPORAT AEMN STAEISVOUEA ..

We will increase understanding of NRC 

business areas to improve the customer 

service provided, and we will involve 

internal customers in establishing goals, 

strategies, and performance measures for 

support programs and services. We will 

identify and work with internal customers 

to agree on service levels that are 

measurable and reflect an appropriate cost

value trade-off. When considering ways of 

improving customer service, we will 

evaluate whether the cost of proposed 

changes is merited by the benefit in terms 

of improved efficiency or effectiveness. 

We will develop service performance 

measures, such as standard response times, 

processing times, and customer satisfaction 

indices. 

We will find new and better ways of doing 

business to increase effectiveness and 

efficiency of operations. 

We will search out best practices and 

innovative approaches applicable to 

agency functions; review existing practices 

and procedures for the purpose of 

eliminating, modifying, or simplifying 

requirements; and evaluate proposed new 

initiatives by determining the potential 

value or benefit to be gained compared to 

the cost of investment. Where possible, we 

will benchmark our processes and compare 

our practices and costs to similar 

organizations. 

We will improve decision-making 

processes in implementing programs. 

Cognizant offices will develop processes 

to determine the appropriate level of 

decision-making for specific types of 

decisions consistent with our statutory and 

regulatory authority. Staff will be 

authorized to take appropriate and

necessary actions and make decisions that 

are within the scope of their assigned 

responsibilities and will be held 

accountable. 

We will create and maintain a planning, 

budgeting, and performance management 

process that is focused on outcomes and 

provides an effective tool for setting goals, 

allocating resources, tracking progress, 

measuring results, and identifying areas 

for improvement. 

We will ensure that goals, measures, 

strategies, and the work to be 

accomplished for the agency are aligned 

and logically linked, and that expectations 

are clearly understood. We will obtain, 

allocate, and distribute resources consistent 

with strategic goals and priorities. We will 

ensure that employees understand their 

roles and responsibilities under the NRC's 

planning, budgeting, and performance 

management (PBPM) process. 

We will prioritize our work, then plan and 

schedule activities accordingly to achieve 

desired outcomes. We will fully implement 

a disciplined, integrated planning 

framework-the PBPM process-and will 

transition to a more outcome-focused 

organization. Through this process, agency 

programs and activities will be chosen and 

prioritized based on the significance of the 

work to the achievement of our 

performance goals. The chosen programs 

will be planned, scheduled, managed, 

monitored, and assessed through this 

process. When issues emerge, we will 

adjust our plans, schedules, and resource 

allocations, if necessary, to ensure 

attention is focused on the highest priority 

activities.

I

0 NRC FY 2000 STRATEGIC PLAN
VOUE2,PR C~ORPOAT MAAEENTATGE

" We will strengthen our financial systems 

and processes to ensure that our financial 

assets are adequately protected consistent 

with risk and that our financial 

information is better integrated with 

decision-making. 

We will continue to implement new and 

existing financial accounting standards to 

maintain an unqualified financial opinion 

and to improve the effectiveness of our 

internal controls. We will provide reliable, 

timely financial information to managers 

for use in decision-making. We will 

increase managers' accountability/ 

responsibility for their decisions by 

placing more agency funds under their 

controls. We will increase awareness of 

using financial information through 

training. We will use information 

technology to streamline our financial 

management processes. 

" We will acquire goods and services in an 

efficient manner that helps to accomplish 

our mission, ensures fair and equitable 

treatment for all parties wishing to do 

business with the NRC, and results in the 

best value to the NRC. 

We will make acquisition decisions that 

will result in maintaining essential 

in-house resources and employing outside 

resources where necessary and 

cost-effective. We will employ innovative 

methods to streamline and simplify the 

acquisition process, reducing the 

administrative burden for internal clients 

and those wishing to do business with the 

NRC. We will develop acquisition 

strategies that are consistent with agency 

goals for reducing our exposure to contract 

fraud and awarding contracts to small, 

disadvantaged, and woman-owned

i

businesses. Procedures for full and open 

competition will ensure fair and equitable 

treatment for all parties. We will employ 

sound acquisition planning to obtain the 

goods and services needed to achieve our 

goals. 

We will use past performance as a key 

criterion for contractor selections to ensure 

the greatest likelihood that contract 

performance will be high quality and 

cost-effective. We will use performance 

based contracts to the fullest extent 

possible and employ performance 

monitoring techniques to ensure that 

contracts are fulfilled. 

We will maintain an acquisition culture 

that rewards innovation and responsible 

risk-taking. 

We will modify our management and 

organizational structure, as appropriate, 

to meet the changing demands of internal 

and external factors, such as the 

economic deregulation of the electric 

utility industry and any resulting 

consolidation of the nuclear industry. 

We will continue to make certain that the 

agency's management and organizational 

structure permits us to effectively and 

efficiently accomplish our mission and 

achieve our performance goals. Where 

appropriate, we will consolidate activities 

performed by overlapping organizations 

and better define their purpose and 

intended outcome. As regulatory reforms 

are implemented, the NRC will examine 

the need for management and 

organizational structure changes. We will 

monitor changes in the electric utility 

industry that could affect our ability to 

provide effective and efficient oversight 

and prepare our organization for change.

NRC FY 2000 STRATEGIC PLAN
C P AI.. EII V

Sustain a high-performing, diverse 

workforce 

A high-performance organization demands 

a dynamic, results-oriented workforce with the 

knowledge, skills, abilities, and competencies 

to achieve its mission and goals. Because 

mission requirements, stakeholder demands, 

technologies, and other environmental 

influences are constantly changing, the NRC, 

as a performance-based organization, must 

continually assess its capacity to achieve its 

strategic and performance goals. At the NRC, 

workforce planning, deployment, and 

development strategies will produce the right 

mix of skills and abilities in the appropriate 

organizations to contribute to maintaining 

safety and protecting the environment; 

increasing public confidence; working 

effectively and efficiently; and improving 

programs and processes that reduce 

unnecessary regulatory burden. 

We will employ the following supporting 

strategies to sustain a high-performing, 

diverse workforce: 

We will recrui, hire, and retain a high

quality, diverse workforce with the skills 

needed to achieve our mission and goals. 

Working with program and support offices, 

we will use a human resources planning 

process to identify current and future 

human capital needs. We will identify 

specific skills and competencies with the 

assistance of program and support 

partners. Based on information gathered in 

this process, we will develop recruiting 

and hiring strategies to fill identified gaps. 

We will seek active involvement of line 

managers in our recruitment program and 

will solicit feedback from managers about 

the quality of our applicants and the 

timeliness of our hiring process.

We will use effective human resource 

management tools to retain outstanding 

achievers. We will recognize and reward 

them. We will provide interesting and 

challenging work assignments. All 

employees will benefit from the family

friendly policies and programs that 

enhance the quality of work life. We will 

continue to provide training and 

professional growth opportunities in 

support of our strategic and performance 

goals. 

We will monitor recruiting and hiring 

programs to ensure fair and unbiased 

hiring. We will continually assess 

demographic statistics on the agency's 

diversity profile to check our progress 

against comparable labor market 

demographics. 

We will foster a work environment that is 

free of discrimination and provides 

opportunities for all employees to 

optimally use their diverse talents in 

support of our mission and goals. 

We will maintain a healthy, safe, secure, 

and accessible physical work environment. 

We will provide the equipment, facilities, 

and administrative support services that 

employees need to work better, deliver 

products and services on time, and 

accomplish the agency's mission more 

efficiently. 

We will provide policies and programs that 

enhance the quality of work life and help 

employees meet the competing demands of 

work and family. These activities will 

support healthier, more productive 

employees who can focus their talents and 

energies on accomplishing the mission of 

the agency.

I ______________________________________________________________________

4 NRC FY 2000 STRATEGIC PLAN
VOLUE 2, P*A*RT 2CPORATMA cGEENTSTTEGIES

We will support the goals and objectives of 

labor-management partnerships and help 

resolve labor and employee relations issues 

so that staff can focus its efforts on 

accomplishing the agency's strategic and 

performance goals. 

We will provide equal employment 

opportunity and strive to eliminate 

artificial barriers to advancement, such as 

discrimination and sexual harassment, so 

that all employees may realize their 

potential and contribute optimally to 

mission accomplishment. 

We will base our human resource 

decisions on sound workforce planning 

and analysis. 

We will align workforce planning, 

deployment, and development strategies 

with our strategic, program, and 

performance plans. Working with program 

and support offices, we will use a human 

resources planning process to identify 

current and future human capital needs. 

Based on information gained through this 

process, we will be better able to 

determine the appropriate knowledge, 

skills, and abilities needed by our program 

and support partners. With input from 

program and support partners, we will 

develop an agency skills inventory to assist 

in identifying current and future skills 

needs and gaps. Information gained from 

the human resources planning process will 

also help determine whether the workforce 

is deployed appropriately-both 

geographically and organizationally-to 

support efficient and effective 

accomplishment of strategic and 

performance goals.

I

Through development and implementation 

of a human resources information system, 

we will provide accurate, timely, and 

useful human resources information to 

managers so they can make informed 

decisions about hiring, utilizing, training, 

promoting, appraising, and rewarding 

staff. We will provide accurate, timely, and 

useful human resource information to 

employees so they can make informed 

employment and benefits decisions. 

We will improve the capability of our 

workforce through training, development, 

and continuous learning. 

We will provide training and development 

to improve individual and organizational 

performance in those areas necessary to 

support the agency's mission, goals, and 

strategies. We will provide reactor and 

materials technical training to improve the 

capability of NRC technical staff to 

achieve Nuclear Reactor Safety, Nuclear 

Materials Safety, Nuclear Waste Safety, 

and International Nuclear Safety Support 

goals and strategies. We will provide 

professional development opportunities in 

management, communication, business 

processes, and computer skills to increase 

the efficiency and effectiveness of agency 

staff in implementing our programs and 

processes. We will provide organizational 

development services, including team 

building, change management, and 

facilitation services, to help our staff adapt 

to the dynamic environment demanded by 

an outcome-oriented learning organization. 

We will select and develop strong 

managers who can provide vision and 

strategic leadership.

NRC FY 2000 STRATEGIC PLAN 0
COPRT MAAEE-.RAEIE OUM ,PR

We will use executive succession planning 

and executive development to select and 

develop agency leaders committed to 

achieving the agency's mission, goals, and 

strategies. We will identify the 

professional/technical and managerial 

competencies needed for success in Senior 

Executive Service (SES) positions. We 

will also identify high-potential leaders 

from among the SES for succession to 

these positions. After assessing these 

high-potential leaders against the 

competencies identified for these 

positions, we will plan appropriate 

learning and developmental activities for 

them. In addition, we will offer the SES 

Candidate Development Program, as 

needed, to develop and maintain a pool of 

high-potential candidates who are ready 

for selection to SES positions. 

We will focus on results by linking 

rewards and recognition to outcomes and 

organizational effectiveness. 

We will provide compensation, 

performance management, and rewards 

and recognition policies and programs that 

link to program outcomes, organizational 

effectiveness, and accomplishment of the 

agency's strategic and performance goals. 

Working with program and support office 

line managers, we will assist in developing 

performance plans that link individual 

performance with agency strategic and 

performance plans. With this approach, 

performance expectations for employees 

will be aligned with the agency's strategic 

and performance plans, and personal 

accountability for performance will be 

reinforced by both rewards and 

consequences. This will provide incentives 

for employees to focus their efforts and

energies on producing the outcomes and 

results we have outlined in our strategic 

and performance plans. 

Provide proactive information 

management and information 

technology services 

The ability of the NRC staff and 

stakeholders to prepare, access, communicate, 

disseminate, and apply information is essential 

to achieving the NRC's efficiency goal. By 

focusing the agency's information 

management and information technology 

services on enabling staff and stakeholders to 

better access and use needed information, 

significant efficiency gains are possible for all 

participants in the regulatory process. 

Information technology is a key enabler 

for effective access to and use of information 

through the NRC agency networks, the World 

Wide Web, desktop technology, the Agency 

Documents Access and Management System 

(ADAMS), and other business applications. In 

addition, information technology is an 

important tool for the process improvements 

needed to achieve the NRC's effectiveness and 

efficiency goal. Outside the agency, licensees 

and other stakeholders who recognize the 

opportunities for efficiency gains through use 

of Web-based processes are coming to expect 

the capability to do business with the NRC 

electronically. 

In addition to supporting the effectiveness 

and efficiency goal, information management 

and information technology services directly 

support the agency's goals to maintain safety, 

reduce unnecessary regulatory burden, and

I

0 NRC FY 2000 STRATEGIC PLAN
I VOLLo]EZPA:I2 C-POAE AAGMNTSRAE -E]

increase public confidence. The NRC staff 

need information and corporate knowledge 

concerning our regulatory framework and 

licensee performance to ensure the continued 

safety of nuclear power and the safe use of 

nuclear materials and disposal of nuclear 

waste. Unnecessary burden on licensees can be 

reduced by providing information technology 

tools for electronic submittal of licensing 

information. The public and other stakeholders 

need NRC information to participate in the 

regulatory process, and effective access to 

information about the NRC's activities and 

performance through such tools as the Web 

and ADAMS is critical for increasing public 

confidence. 

The NRC's information management and 

information technology services can be 

optimally planned and delivered only though a 

partnership between service providers and 

customers so that information management 

and information technology resources can be 

applied in a manner that achieves the greatest 

overall gains in agency effectiveness and 

efficiency. The NRC's information 

management and information technology staff 

must take a proactive, leadership role to 

understand the NRC's business goals and work 

in partnership with customers to more 

effectively use information management and 

information technology resources to achieve 

them. At the same time, our stakeholders must 

take a proactive and leadership role in 

pursuing the effectiveness and efficiency gains 

that can be achieved through information 

management and information technology 

initiatives. 

In partnership with our customers, the 

information management and information 

technology staff will employ the supporting 

strategies set forth below to use information

I

and information technology to achieve the 

NRC's effectiveness and efficiency goal: 

We will work jointly with program and 

support offices to integrate information 

technology and business planning as a 

means of achieving agency goals and 

strategies. 

We will use the strategic planning process 

as a first step in working with our program 

and support partners to develop 3-5 year 

plans to address program goals through 

information technology applications and to 

plan for the infrastructure needed to 

support those applications. We will work 

with customers to assess the effectiveness 

and efficiency of their current applications 

portfolio, assess best practices used by 

others with similar or analogous business 

processes, and assess IT opportunities 

from current and emerging technology 

with the potential to improve agency 

performance. We will continue to improve 

our Capital Planning and Investment 

Control Process to ensure that future IT 

investments contribute to agency outcome 

goals, provide a demonstrable return on 

investment, and are evaluated in the 

context of long-range plans for the broader 

arena and agency-level applications 

portfolio. We will focus on being business 

solution providers-providing leadership 

to assist our customers in identifying and 

applying technology to support business 

goals. 

We will make it easier for the staff to 

acquire, access, and use the information 

they need to perform their work 

The effective use of both information and 

corporate knowledge is critical in nearly 

all NRC processes and will be essential in

NRC FY 2000 STRATEGIC PLAN 0
C~ORPOAT MAAEMN STAE.E VOUM 2,PR

becoming more efficient over the next 3 to 

5 years. The NRC will pursue programs to 

improve staff access to both knowledge 

and information to increase productivity 

and enhance informed decision-making. 

We will partner with customers to optimize 

the use of existing information access tools 

such as ADAMS and the NRC Intranet for 

information and knowledge transfer. We 

will help the staff acquire the information 

they need from external sources. As part of 

applications and infrastructure planning, 

we will develop strategies for providing 

easier access to data in NRC business 

applications, promote data architecture and 

data sharing, and provide the staff with 

effective information analysis and 

reporting capabilities. We will work with 

customers to investigate and pilot 

knowledge management approaches to 

improve analysis and support informed 

decision-making, particularly in 

programmatic arenas. We will focus on 

making the NRC's desktop interface and 

applications more coherent and 

user-friendly so that finding and using 

needed information becomes easier. 

We will assume a leadership role in 

improving the agency staff s capability to 

use current and planned information 

technology to enhance performance. 

The NRC's staff will play a leadership role 

in evaluating and upgrading the staff's 

capabilities to apply information 

technology to their jobs. We will partner 

with customers and the agency's human 

resources staff to define needed 

information technology skills and develop 

strategies to develop those skills, promote 

fuller and more effective use of existing 

applications, and encourage creative 

application of information technology

knowledge and skills to enhance 

performance and improve business 

processes. We will continue to work on 

improving the staff's ability to 

successfully sponsor and manage 

information technology projects. We will 

promote and place emphasis on change 

management techniques to ready staff to 

receive new technologies and applications. 

We will provide and maintain a robust, 

reliable, cost-effective, and "user

friendly" information technology 

infrastructure that is driven by the agency 

business needs. 

A robust, reliable infrastructure, including 

effective support services, is the 

foundation of all business applications. By 

robust, we mean an infrastructure that is 

adaptable, scalable, and secure and one 

that can meet current and future business 

application needs, that supports productive 

use of information, and that promotes 

effective internal and external 

communication. To improve the staff's 

efficiency, we will strive for an 

infrastructure that is more intuitive and 

simpler to use. We will provide a customer 

support staff that have technical expertise 

and working knowledge of the agency's 

information technology infrastructure to 

provide prompt, accurate, and reliable 

responses to employees' requests for 

service. To ensure cost-effectiveness, we 

will partner with customers to reach 

consensus on levels of infrastructure 

technology and support services that 

effectively balance internal stakeholder 

needs with overall agency priorities and 

available resources. We will use our 

information technology Capital Planning 

process to ensure that infrastructure 

upgrades provide a good return on 

investment.

I

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2,6* PAR 2 OPRT AAGMN T E1

" We will work jointly with stakeholders to 

optimize the delivery of information 

technology and management service. 

We will involve customers in establishing 

goals, strategies and performance measures 

for information management and 

information technology programs and 

services. We will work with customers to 

agree on service levels that are both 

measurable and reflect an appropriate cost

value tradeoff. We will improve our staff's 

understanding of NRC business processes 

and grow their customer service 

orientation. 

" We will improve the ability of the NRC 

and external entities to conduct our 

mutual business electronically. 

The NRC can improve its efficiency and 

effectiveness in conducting business with 

external entities to the benefit of both the 

NRC and stakeholders. Whether they are 

learning about potential employment and 

applying for a position, competing for an 

agency contract, or applying for a license, 

stakeholders will increasingly expect to be 

able to conduct business with the NRC 

electronically. The NRC's information 

management and information technology 

staff will be proactive in championing and 

enabling effective public access to the 

information that is needed to do business 

with the NRC efficiently and effectively 

and we will continue to be aggressive in 

promoting and supporting electronic 

information exchange and electronic 

commerce initiatives. 

We will provide external stakeholders the 

ability to easily access desired publicly

available information to aid in their 

participation in the NRC's regulatory 

processes, and to enhance understanding 

of the Agency's mission, goals, and 

performance. 

The general public needs information to 

understand the NRC's mission and goals, 

and to evaluate the NRC's performance in 

achieving those goals. Interested and 

involved stakeholders need information to 

participate effectively in the regulatory 

process. Public confidence will be directly 

influenced by stakeholders' experiences in 

obtaining information and by the quality of 

that information. The NRC's information 

management and information technology 

programs, including the external Web site, 

the Freedom of Information Act (FOIA) 

program, ADAMS, and the Public 

Document Program, play a key role in 

delivering NRC information to the public. 

As part of these programs, we will be 

proactive in working with the NRC staff 

and seeking input from external 

stakeholders to ensure that the NRC's 

publicly available information is easily 

accessible, meets high standards of 

timeliness and quality, and that sensitive 

and classified information is adequately 

protected from disclosure. We will take a 

leadership role in exploring and making 

the Commission aware of new 

technologies that have potential for 

broadening the public's ability to learn 

about and participate in our regulatory 

processes. Recognizing that not all of the 

public stakeholders have access to 

computer technology, we will ensure that 

reasonable means are available for their 

continued participation.

a

NRC FY 2000 STRATEGIC PLAN 0
CORPORAT MAAEM STAEBSVL . E2 AT2

Communicate Strategic Change 

Communicating strategic change is 

essential to developing and implementing 

activities to improve public confidence in the 

NRC and to fulfilling our responsibilities in an 

effective and efficient manner. 

Communication among employees and with 

external stakeholders is a fundamental and 

necessary aspect of conducting agency 

business. Effective communications are 

instrumental in building and maintaining an 

environment within the NRC in which safety, 

technical excellence, effective and efficient 

decision- making, teamwork, innovation and 

creativity, and improved performance are 

paramount. Fostering such an environment 

will help the agency build public confidence 

and successfully respond to the changing 

environment by implementing timely changes 

to regulatory programs and procedures. 

Because of this environment of change, both 

internal and external, the NRC will have to 

continue to manage change. The success of 

change management will be determined by our 

ability to effectively communicate with all of 

our stakeholders. 

One aspect of communication has been 

changed significantly during the past several 

years. This change was, perhaps, most 

noticeable during the stakeholder meetings 

conducted as part of the NRC's Strategic 

Assessment and Rebaselining Initiative in 

1996. One of the broad issues included in this 

assessment specifically examined public 

communications initiatives. The results of that 

effort included discussing approaches that the 

NRC should take to improve its 

communication with the public. Effective 

communication with external stakeholders is 

essential to inspiring public confidence by 

providing the public, those we regulate, and 

other stakeholders in the national and

international community with clear, accurate, 

and timely information about our regulatory 

activities. 

The legislation that created the NRC states 

that the agency is to be independent of the 

regulated industry and is not to promote the 

use of nuclear technology. This presents 

communications challenges for both the NRC 

and the public, including the regulated 

industry. These challenges are compounded by 

changing expectations of the public and the 

regulated industry. To inspire public 

confidence in the NRC's activities, we must 

understand the expectations of the public and 

provide opportunities for public interactions 

that are meaningful and effective, but that do 

not promote the use of nuclear technology. 

The supporting strategies listed below 

describe how we will establish, evaluate, and 

sustain effective methods of communication 

with our stakeholders: 

Internal Stakeholders 

" We will review and assess the effectiveness 

of communication channels and methods 

within the NRC to ensure that they 

support the needs of a changing 

environment. 

" On the basis of this assessment, we will 

develop and implement communication 

plans that support strategic change and 

foster the desired work environment. 

We will conduct a review of internal 

communications methods or channels to assess 

the effectiveness of internal communications 

actions. This will include activities such as 

developing an inventory of communications 

channels used to transmit information,

i ____________________________________

SNRC FY 2000 STRATEGIC PLAN
VOLU.M.E PART 2 CORPORATEMNAGM ENT STRAE

identifying the staff's information needs and 

expectations at various organizational levels 

within the NRC, identifying the information 

transmitted on a channel, assessing the 

effectiveness of transmitting information on 

individual channels, reviewing the 

communications activities of external 

organizations, identifying best-in-class 

communications activities, and preparing a 

listing of specific changes that can be made to 

improve the effectiveness and efficiency of 

internal NRC communications. 

The results of this review may include 

specific recommendations such as revised or 

new (1) communications procedures, 

(2) communications training for the NRC 

staff, and (3) communications channels or 

methods for different types of information. 

External Stakeholders 

" We will assess the effectiveness of 

communications by evaluating the 

effectiveness of communications channels 

or methods used to provide information to 

the public. 

" We will improve communication with the 

public by using strategies that recognize 

the ongoing changes in the environment 

external to the agency. 

We will assess the effectiveness of 

communications with members of the 

public. Additionally, stakeholder opinions 

on whether their needs and expectations 

are being met will be included to the 

extent possible, based upon the methods 

used. The results of this step will be used 

to review current communications

I

channels and the information provided to 

external stakeholders on individual 

channels. This will allow us to assess the 

effectiveness of communications with 

external stakeholders. The results will be 

recommendations for specific changes to 

the channels used to provide information 

to external stakeholders. Noting that 

different segments or groups of external 

stakeholders may have different needs and 

expectations, the methods used to assess 

communications as well as recommended 

changes may be segment or group specific. 

" We will respond to requests and inquiries 

from stakeholders in a timely, courteous, 

and professional manner. 

We will ensure that inquiries are assigned 

to the appropriate office and that accurate 

and complete responses are prepared 

promptly. 

" We will identify regulatory decisions or 

issues that are most likely to generate 

substantial public interest at an early 

stage of development and initiate actions 

to inform and involve the public. 

We will utilize the information learned 

from assessing communications with 

internal and external stakeholders to 

identify changes to existing procedures or 

the need for new procedures and process 

controls. We will use these procedures and 

process controls to provide information to 

internal and external stakeholders as part 

of regulatory decision-making and issue 

evaluation. The responsibility for this 

aspect of regulatory decision-making and 

issue resolution will be clearly defined.

NRC FY 2000 STRATEGIC PLAN
I 0OUE2 AT2=

LINKS To OTHER PLANNING 

DOCUMENTS, PROGRAM 

EVALUATIONS, AND 

MANAGEMENT CHALLENGES

I.

LINKS TO OTHER PLANNING 

DOCUMENTS 

Key documents that are linked to and 

complement this Strategic Plan are: 

"* NRC's Planning, Budgeting, and 

Performance Management Process 

"* Annual Performance Plan 

"* Annual Performance Report 

"* Annual Budget Requests to the Office of 

Management and Budget (OMB) and 

Congress 

"* Risk-Informed Regulation 

Implementation Plan 

"* Corporate Management Plans 

"* Planned Program Evaluations 

NRC's Planning, Budgeting, and 

Performance Management Process 

In applying businesslike principles to its 

regulatory processes, the Commission's goal is 

to ensure that the NRC is both effective and 

efficient in implementing its mission. 

Beginning with the FY 2000 budget cycle, the 

agency implemented a disciplined, integrated 

process to improve for planning, budgeting, 

and performance management. The integrated 

process will enable the agency to meet the

i

demands of the new results-driven Federal 

environment. The four major components of 

the new process are: 

1. Setting the strategic direction. 

2. Determining resources and planned 

accomplishments. 

3. Measuring and monitoring perfor

mance. 

4. Assessing performance. 

The first step of the process is to establish 

the goals and objectives for the agency and to 

decide how it will meet them. The products of 

this step are the agency's Strategic Plan and 

Performance Plan. The Strategic Plan sets the 

strategic direction of the agency and the 

Performance Plan establishes how those goals 

and objectives are met. Using the direction 

established by the Strategic Plan and the 

Performance Plan, the second step is to 

determine the resources and planned 

accomplishments required to achieve the 

objectives. The result of this step is the agency 

budget which reflects the priority of activities 

and the level of resources based on the goals 

and objectives established in step one. This 

step also includes the development of internal 

agency program-level operating plans, which 

include performance measures and targets. 

This enables the agency to track the degree to

NRC FY 2000 STRATEGIC PLAN # 14
O , 3OD |! . OL N .GE IV M , P

which it is achieving its objectives (the third 

step), as reflected in the planned 

accomplishments (found in the budget), the 

NRC performance goals (found in the 

Performance Plan), and the program-level 

operating plans used by each office. The final 

step in the process is the assessment phase, 

which determines the effectiveness of our 

performance and compares performance 

against established objectives. These 

assessments include annual program reviews, 

program evaluations, self-assessments, and 

internal and external audits. The results of the 

assessment phase form the basis for the 

reevaluation of the agency's strategic 

direction, and the net cycle of the planning, 

budgeting, and performance management 

process. 

Annual Performance Plan 

The strategic goals established in the 

Strategic Plan set the framework for 

developing the NRC annual Performance Plan. 

The Performance Plan delineates objective, 

quantifiable, and measurable performance 

goals to be achieved in a given fiscal year that 

support that the strategic goals contained in 

the Strategic Plan. Each annual Performance 

Plan also includes performance indicators to 

be used in measuring or assessing the relevant 

outputs, service levels, and outcomes related 

to the performance goals. We expect to 

measure our progress by using a combination 

of output and outcome measures. 

Annual Performance Report 

Beginning in FY 2000, and within six 

months after the close of each fiscal year, the 

NRC will submit to the President and 

Congress a report on program performance for 

the fiscal year that has just closed. This 

performance report will review the success of

the agency in achieving the performance goals 

established for the fiscal year being reported 

upon. Where those goals have been achieved, 

the underlying assumptions and strategies will 

be examined to ensure that continued 

application is warranted in the future. If 

performance goals are not met, the agency will 

conduct a thorough analysis of why it did not 

meet the goal and the actions necessary to 

meet the goal in the future. One result of this 

analysis will be the documentation of plans 

and schedules for achieving the established 

performance goal. If the analysis should 

indicate that the performance goal is 

impractical or infeasible, the performance 

report will document why that is the case and 

what action is recommended. 

Annual Budget Request to OMB and 

Congress 

Each year, the NRC submits a budget 

request to OMB, which is part of the 

President's budget to Congress. The budget 

specifies the programs, activities, milestones, 

and resources necessary to implement the 

Strategic Plan and the Performance Plan. 

Risk-Informed Regulation 

Implementation Plan 

The Risk-Informed Regulation 

Implementation Plan is a comprehensive 

description of the various activities being 

conducted by the NRC to implement the 

Commission's PRA Policy Statement. This 

report was issued previously under the title of 

"PRA Implementation Plan." This report is 

prepared semi- annually to provide the 

Commission with the status of risk-informing 

activities and identifies specific tasks being 

carried out to incorporate risk considerations 

into the Commission's rules, regulations, and 

practices. Project milestones are included.

I

0 NRC FY 2000 STRATEGIC PLAN
VOUM 2,* PAR 2 OTE DOUENS EVLATOS AN HLLNE

Corporate Management Plans 

1. Human Resources Plan 

In conjunction with program and support 

offices, the Offices of Human Resources will 

use a planning process to determine future 

recruitment, staffing, and training and 

development needs agencywide. We will look 

at near-term recruitment and staffing needs 

and longer term training and development 

needs. Based on information gained through 

this process, we will be better able to 

determine the appropriate knowledge, skills, 

and abilities needed and how to address any 

identified skills gaps. Information gained from 

this process will also help determine whether 

the workforce is deployed appropriately

both geographically and organizationally-to 

support efficient and effective accomplishment 

of strategic and performance goals. 

2. Strategic Information Resources Manage

ment Plan 

The NRC is required by the Paperwork 

Reduction Act to maintain a Strategic 

Information Resources Management (IRM) 

Plan. The Strategic IRM Plan documents how 

information technology and information 

management will contribute to the Agency's 

strategic and performance goals. The Strategic 

IRM Plan describes the programs and 

initiatives that will be used to implement the 

information technology and information 

management strategies that support those 

goals. It will also include initiatives required 

by legislative mandates and external 

technology drivers. 

3. Communication Plans 

Working with program offices, we will 

conduct a review of communications with

I

stakeholders. Activities that are anticipated to 

be included in this review relate to both 

internal and external stakeholders. Reviews of 

existing communications channels and 

methods and an assessment of the 

effectiveness of these channels is expected to 

result in specific recommendations for change. 

This will include mapping communication 

activities to provide an inventory of current 

communication methods. Based upon the 

results of these reviews and the information 

gained, specific changes to activities will be 

identified and summarized in communication 

plans. Significant regulatory activities should 

have communication plans that identify 

needed public outreaches. 

Planned Program Evaluations 

The Government Performance and Results 

Act requires a description of the program 

evaluations used in establishing and revising 

Strategic Plan goals and a schedule for future 

evaluations. In the past, NRC program 

evaluations typically focused on the efficiency 

and effectiveness of our programs and 

processes. In the future, program evaluations 

will increasingly focus on responding to 

management questions about the performance 

of programs or activities. The program 

evaluations will assess the extent to which the 

expected results in the Strategic Plan goals, 

measures, and strategies have been achieved 

and provide insight into whether the strategic 

direction of the agency should be changed. 

The findings and recommendations of 

completed program evaluations, including 

their effect on the Strategic Plan goals, 

measures, and strategies, will be reported in 

the annual Performance Report.

NRC FY 2000 STRATEGIC PLAN @
OTE DOCMNS EVLATOS CHLENE VOUM 2, PAR 2

Process for Identifying Future Program 

Evaluations 

The NRC will normally conduct 4-5 

program evaluations (one from each Strategic 

Arena and one from the Corporate 

Management Strategies) over a 3-year period 

to coincide with the triennial update of the 

Strategic Plan. Each year a systematic 

agency-wide approach will be used to select 

future program evaluations and to reaffirm the 

priorities and schedules of previously planned 

program evaluations. The following criteria 

will be used to identify program evaluations: 

(1) significant deviations in actual 

performance from performance goals, 

(2) significant changes to the environment 

(e.g., regulated community, resources, 

technology, workload, processes) or 

management expectations which dictate a 

major rethinking of the program, and (3) 

program successes, the understanding of 

which may prove beneficial to other NRC 

programs. 

The following program evaluations are 

planned for FY 2000 through FY 2003: 

NUCLEAR REACTOR SAFETY 

New Reactor Oversight Process 

Expected Completion Date: FY 2001 

Objective: The NRC will perform a 

comprehensive evaluation of the effectiveness 

and implementation of the NRC's new reactor 

oversight process. The program evaluation 

will assess whether the revised oversight 

process (1) ensures that plants continue to be 

operated safely, (2) enhances public 

confidence by increasing predictability, 

consistency, and objectivity of the oversight

process, (3) improves the efficiency and 

effectiveness of regulatory oversight by 

focusing agency resources on aspects of 

performance that have the greatest impact on 

safe plant operations, and (4) reduces 

unnecessary regulatory burden on licensees as 

the process becomes more efficient and 

effective. The program evaluation will be used 

to determine how effective the program has 

been in achieving all four of our performance 

goals and implementing strategies. The 

findings will be used to make any changes 

needed to the current goals, measures, metrics, 

and/or strategies. 

Scope: In FY 2000, the NRC is 

transitioning from the current inspection, 

assessment, and enforcement processes to the 

revised reactor oversight process. The NRC 

developed changes to its current processes to 

improve their objectivity, make them more 

understandable and predictable, and provide 

increased focus on aspects of performance that 

have the greatest impact on safe plant 

operation. The improved processes include the 

risk-informed baseline inspection program, 

use of license-reported performance indicator 

information, and revised assessment and 

enforcement activities. 

A pilot program of the revised reactor 

oversight process was conducted at nine 

reactor sites over a six-month period that 

began in June 1999. The results of the pilot 

program were reported to the Commission in 

SECY-00-0049, "Results of the Revised 

Reactor Oversight Process Pilot Program", 

dated February 24, 2000. Initial 

implementation at all operating reactor sites 

began during April 2000. In FY 2001, the 

NRC will evaluate the implementation and 

effectiveness of the first year of 

implementation of the NRC's new reactor

I

1 NRC FY 2000 STRATEGIC PLAN
VOUE2 PART 2 OTHE DOUENS EAUTOS, AN CHLENE

oversight process and the results generated by 

the performance indicator reporting, baseline 

inspections, assessment, and enforcement 

activities. The evaluation will determine the 

effectiveness of the revised oversight process 

in meeting its objectives of (1) improving the 

objectivity of the oversight so the subjective 

decisions and judgments are not central 

features, (2) improving the scrutability of the 

oversight so NRC actions have a clear tie to 

licensee performance, and (3) risk-informing 

the oversight process to focus NRC and 

licensee resources on performance having the 

greatest impact on plant safety. Findings from 

the program evaluation will be used to make 

any necessary adjustments to the reactor 

oversight process, and to make any changes 

needed to the current goals, measures, metrics 

and/or strategies in the Strategic Plan. 

NUCLEAR MATERIALS SAFETY 

National Materials Program 

Expected Completion Date: FY 2001 

Objective: The NRC currently shares its 

regulatory authority for materials regulation 

with 31 Agreement States throughout the 

country. Given the anticipated increase in the 

number of Agreement States, this program 

evaluation will consider the effectiveness of 

the current structure and provide the 

Commission with options for maintaining an 

infrastructure of supporting regulations, 

guidance and other program elements needed 

for the nationwide materials program. A 

working group of State government and NRC 

representatives has been established to conduct 

this program evaluation. The program 

evaluation will consider (1) the changing 

external environment, (2) accommodation of 

Federal and State strategic performance goals 

and outcomes under a national materials

m

program, and (3) a process that could be used 

to measure the performance. 

Scope: Presently, the NRC exercises 

regulatory responsibility over about 5,310 

material licensees. The 31 Agreement States 

regulate about 16,550 material licensees. The 

NRC staff expect four additional States will 

become Agreement States by Fiscal Year 2003 

and estimates that the number of NRC 

licensees will drop to approximately 4,000. At 

that time, the Agreement States will be 

regulating about 17,860 licenses. This shift in 

responsibility has significant implications for 

both the NRC's materials program and the 

Agreement States. The process that the NRC 

will use in the future to develop and maintain 

the infrastructure of regulations and 

supporting guidance applied by the NRC and 

the Agreement States in their respective 

licensing and inspection programs should 

reflect this shift. 

The working group will formulate a 

number of options for the Commission's 

consideration. In broad terms, the selected 

option, when implemented, will accomplish 

the Commission's goal of creating an 

integrated materials program of national scope 

in cooperation with the States, professional 

organizations, licensees, and the public. The 

working group will develop a list of elements 

needed for a national materials program, such 

as licensing and inspection guidance, 

reciprocity, general licensing, regulations, 

training, and databases, using the Conference 

of Radiation Control Program Directors, Inc. 

(CRCPD) and the Integrated Materials 

Performance Evaluation Program (IMPEP) 

elements as a basis. The working group will 

consider issues such as: 

The continuing trend for States to assume 

authority for the regulation of radioactive 

materials;

NRC FY 2000 STRATEGIC PLAN
OTE DOCMETS EV *ATOS 0 N CHLENE VOUM 2,PR

" The potential impact of this trend on 

maintaining the infrastructure of the 

existing State and Federal regulatory 

programs in the current fiscal 

environment and the increased fee burden 

on a decreasing number of NRC licensees 

to support generic activities; 

" The roles and legal responsibilities of the 

NRC, the Agreement States, the 

Organization of Agreement States (OAS), 

the CRCPD, and other organizations; 

" The need for statutory changes in Federal 

and State programs for a national 

materials program; 

" The required elements and scope of 

activities in a materials regulatory 

program; 

" The assessment process and performance 

indicators that could be used to measure 

the performance of a national materials 

program considering the current IMPEP 

process; 

" Mechanisms for program coordination 

and program evolution; and, 

" The resource needs required for a national 

materials program and options for 

meeting those resource needs at both State 

and Federal levels. 

NUCLEAR WASTE SAFETY 

Changes to the Decommissioning 

Process 

Expected Completion Date: FY 2003 

Objective: The decommissioning of 

reactor and other sites which used nuclear

materials has been undergoing significant 

change with the introduction of new rules, 

industry restructuring and increased activity 

and interest in decommissioning sites. This 

program evaluation will assess the various 

NRC decommissioning initiatives, deviations, 

if any, from performance goals, changes in 

external factors, and program successes 

regarding the implementation of the license 

termination rule. We will determine how 

effective the program has been in achieving all 

four of our performance goals and 

implementing strategies. The findings will be 

used to make any changes needed to the 

current goals, measures, metrics and/or 

strategies. 

Scope: This program evaluation will focus 

on evaluating ongoing and planned changes to 

the decommissioning program. These changes 

are the result of implementing the license 

termination rule, the Strategic Plan, and 

changes in external factors such as transfers of 

sites to Pennsylvania and licensee plans 

regarding the restricted release. Reactor 

decommissioning is also within the scope of 

this program evaluation. The following 

changes will be evaluated: 

"* Pilot for streamlining decommissioning 

for simple sites 

" Phased approach for reviewing 

decommissioning plans and preparing 

environmental impact statements for 

restricted release sites 

"* Resolution of institutional control, 

financial assurance, and funding issues 

• Additional contaminated sites identified 

from completing the Terminated License 

Review Project

I

SNRC FY 2000 STRATEGIC PLAN
VOUE2,PR OTE DOCMNS EVLATOS AN CHALEGE

• Transfer of sites to Pennsylvania when it 

becomes an Agreement State 

* Lessons learned from stakeholder 

feedback regarding use of the 

decommissioning standard review plan 

• Review of guidance and licenses for 

appropriate risk informed approach 

"* Improvements in public outreach and 

prelicensing interactions with licensees 

"* More realistic dose modeling 

"* Reactor license termination plan review 

process 

"* Lessons learned from stakeholders 

regarding reactor license termination plan 

public meeting 

CORPORATE MANAGEMENT 

STRATEGIES 

Agencywide Documents Access and 

Management System (ADAMS) 

Expected Completion Date: FY 2001 

Objective: The ADAMS document 

management system has substantially changed 

the way the NRC staff and external 

stakeholders manage and retrieve documents. 

The implementation of ADAMS impacts 

essentially all of the corporate management 

strategies aimed at helping the NRC 

accomplish its strategic and performance 

goals. Of particular note, one of the NRC's 

corporate management strategies is to provide 

proactive information management and 

information technology services, including 

(1) making it easier for the staff to acquire, 

access, and use the information needed to 

perform its work, (2) improving the ability of 

the NRC and external entities to conduct our

_________________________________________ I

mutual business electronically, and 

(3) providing external stakeholders the ability 

to easily access desired publicly available 

information to aid in their participation in the 

NRC's regulatory processes, and to enhance 

understanding of the Agency's mission, goals, 

and performance. 

Scope: This evaluation will be conducted 

in FY 2001 and will help us assess the extent 

to which we successfully implemented these 

strategies. The ADAMS document 

management system has seven objectives 

which identify how it will support the 

Corporate Management Strategies: 

" Discontinue the need for individual 

organizational units to invest their 

full-time equivalent (FTE) resources and 

dollars in local document management 

applications with limited functionality by 

implementing an enterprise-wide 

document management capability that 

meets all of the NRC's functional 

requirements. 

" Ensure the integrity of the NRC's 

document repository for record keeping, 

legal uses, and staff retrieval by capturing 

documents once, at their source, as they 

are electronically created or received by 

the agency. 

" Reduce the time and effort that the staff 

spend searching for and retrieving 

distributed hardcopy and electronic 

versions of documents of every 

description by providing staff with 

immediate access to the full text images 

of documents through a comprehensive, 

single, electronic repository at their 

desktops. 

" Reduce staff time spent creating 

documents by storing them electronically, 

allowing the staff to easily retrieve 

electronic text for reuse.

NRC FY 2000 STRATEGIC PLAN *
O TH ER D S A*ND L.ES V.UM ,ZPAT,

"* Reduce the administrative costs of 

reproducing and distributing documents, 

and speed their delivery to the NRC staff 

and their availability to the public by 

producing and disseminating documents 

electronically, rather than as paper copy. 

" Eventually, eliminate the time, effort, and 

space now spent filing, maintaining, 

destroying, or retiring hardcopy in 

centralized and local document collections 

by implementing a complete, easy-to

access, electronic document repository 

that is accepted by the National Archives 

and Records Administration (NARA) as 

the NRC's official record keeping system. 

" Manage document workflow processes 

more efficiently by creating an automated 

agencywide workflow infrastructure that 

allows individuals to collaborate on 

document preparation by routing them for 

parallel reviews, concurrence, and 

signature. 

As part of the Capital Planning and 

Investment Control (CPIC) process, OCIO 

will work with its ADAMS partners to prepare 

a 'lessons learned' study which will evaluate 

whether ADAMS has met these objectives. 

Although not part of ADAMS original 

objectives, we will evaluate whether ADAMS 

is effectively supporting the Public 

Confidence goal. Where goals and objectives 

have not been fully met, we will examine 

alternative options for fully achieving them. 

Additional alternatives will be explored which 

may accelerate the benefits and reduce the 

costs of ADAMS implementation. OCIO plans 

a unified approach to produce a single 

document which will satisfy the Capital 

Planning and Investment Control 'lessons 

learned' evaluation and this program 

evaluation.

MANAGEMENT CHALLENGES 

The NRC has no high risk areas designated 

by the General Accounting Office (GAO) 

(High Risk Series: An Update GAD/HR

99-01) as being particularly vulnerable to 

fraud, waste, abuse, and mismanagement. 

Additionally, the NRC does not have any 

mission-critical management problems that 

pose a realistic and prospective impediment to 

carrying out the agency's mission or achieving 

its goals. However, in response to a 

Congressional request, in December 1998, 

NRC OIG identified what it believed to be the 

10 most serious management challenges facing 

the agency and reaffirmed this list in 

December 1999. GAO also identified three 

additional management challenges in a 

January 1999 report, Performance and 

Accountability Series: Major Management 

Challenges and Program Risks: Nuclear 

Regulatory Commission (GAO/OCG-99-19). 

The NRC has several goals, associated 

measures, and strategies in this Plan that 

substantially cover the management challenges 

identified by GAO and the NRC OIG. For 

"example, this Plan includes a number of 

strategies focused on making our regulatory 

process more risk-informed and on improving 

how we communicate change. The strategies 

will help correct previously identified 

problems and findings in GAO's reports on 

"Strategy Needed to Regulate Safety Using 

Information on Risk and NRC staff have not 

Fully Accepted Planned Changes". 

Additionally, one of the challenges identified 

by the OIG was effectively communicating 

with the public and industry. The Plan's 

Performance Goal to "Increase Public 

Confidence" addresses the agency's plans to 

strengthen communications, including (1) 

assessing the effectiveness of communication 

channels and methods for providing

&

0 NRC FY 2000 STRATEGIC PLAN
VOUEAT OTHE DOUENS EVLATOS AN CHLENE

information to the public and (2) improving 

communication with the public by using 

strategies that recognize the ongoing changes 

in the environment external to the agency. 

The following is a list of the management

challenges identified by GAO and the OIG. 

For each challenge, the goals, their associated 

strategies, and/or corporate management 

strategies that relate to them in the NRC 

Strategic Plan are referenced.

NRC FY 2000 STRATEGIC PLAN
0OUEAT

MANAGEMENT CHALLENGES

The following is a list of the management 

challenges identified by GAO and the NRC 

OIG. The NRC OIG identified ten 

management challenges in a December 1998 

letter to the Honorable Dick Armey, House 

Majority Leader, and the Honorable Dan 

Burton, Chairman, of what was then the House 

Committee on Government Reform and 

Oversight. GAO also identified three 

additional management challenges in a 

January 1999 report, Performance and 

Accountability Series: Major Management 

Challenges and Program Risks: Nuclear 

Regulatory Commission (GAO/OCG-99-19). 

For each challenge, the goals, their associated 

strategies, and/or corporate management 

strategies that relate to them in the NRC 

Strategic Plan are provided. 

1. Challenge (GAO): 

NRC lacks assurance of nuclear plants' 

safety. NRC assumes that plants are safe if 

they operate as designed and follow the 

Commission's regulations. However, the 

regulations and other guidance do not 

defme the conditions necessary for a 

plant's safety; therefore, determining 

safety is subjective. 

Strategic Plan References: 

Performance goal, "Maintain safety, 

protection of the environment, and the

common defense and security" and the 

associated strategies to: (1) sharpen our 

focus on safety to include a transition to a 

revised NRC reactor oversight program for 

our inspection, assessment, and 

enforcement activities; (2) evaluate 

operating experience and the results of risk 

assessments for safety implications; and 

(3) continue to develop and incrementally 

use risk-informed and, where appropriate, 

less prescriptive performance-based 

regulatory approaches to maintain safety 

address this challenge in the Nuclear 

Reactor Safety Arena. (See Part 1, pages 

2-3 and Part 2 pages 2-5) 

2. Challenge (GAO): 

NRC is slow to require corrective action. 

Although NRC's indicators show that 

conditions throughout the nuclear energy 

industry have generally improved, they 

also show that several plants are 

chronically poor performers. At three 

nuclear plants with long-standing 

problems, NRC did not take aggressive 

action to ensure that the utilities corrected 

the problem. 

Strategic Plan References: 

Performance goal, "Maintain safety, 

protection of the environment, and the

I

NRC FY 2000 STRATEGIC PLAN
MANAEMET CHLLEGESVOLUE2,AR0

common defense and security" and the 

associated strategy to sharpen our focus on 

safety to include a transition to a revised 

NRC reactor oversight program for our 

inspection, assessment, and enforcement 

activities address this challenge in the 

Nuclear Reactor Safety Arena. (See Part 1, 

page 3 and Part 2 pages 2-3) 

3. Challenge (GAO): 

NRC's culture and organizational structure 

impede effective actions. Since 1979, 

various reviews have concluded that 

NRC's organizational structure, inadequate 

management control, and inability to 

oversee itself have impeded its 

effectiveness. 

Strategic Plan References: 

The NRC has identified several 

overarching corporate management 

strategies that relate to this challenge. In 

order to employ innovative and sound 

business practices, we will find new and. 

better ways of doing business to increase 

effectiveness and efficiency of operations. 

We will modify our management and 

organizational structure, as appropriate, to 

meet the changing demands of internal and 

external factors. (See Part 1, pages 38-39 

and Part 2, pages 68-69). We will also 

select and develop strong managers who 

can provide vision and strategic leadership 

and we will focus on results by linking 

rewards and recognition to outcomes and 

organizational effectiveness. (See Part 1, 

page 39 and Part 2, pages 71-72). 

As a part of this management challenge, 

GAO recommended that the NRC develop 

a comprehensive strategy to transition to 

risk-informed regulation. NRC goals and 

strategies that pertain to this

recommendation are provided in the 

strategic plan references for a related 

management challenge-Management 

Challenge 4, "Developing and imple

menting a risk-informed, performance

based approach to regulatory oversight." 

Additionally, GAO recommended that the 

NRC act more aggressively on safety 

issues when they are discovered. Goals 

and strategies that pertain to this 

recommendation are provided in the 

strategic plan references for a related 

management challenge-Management 

Challenge 2, "NRC is slow to require 

corrective actions." 

4. Challenge (OIG): 

Developing and implementing a risk

informed, performance-based approach to 

regulatory oversight. 

Strategic Plan Reference: 

The NRC will employ strategies in the 

Nuclear Reactor Safety, Nuclear Materials 

Safety, and Nuclear Waste Arenas that 

address this issue. In the Nuclear Reactor 

Safety Arena, NRC will continue to 

develop and incrementally use risk

informed and, where appropriate, less 

prescriptive performance-based regulatory 

approaches to maintain safety. (See Part 1, 

page 3 and Part 2, page 5). In the Nuclear 

Materials Safety Arena, NRC will continue 

to improve the regulatory framework to 

increase our focus on safety and 

safeguards, including incremental use of 

risk-informed and, where appropriate, less 

prescriptive performance-based regulatory 

approaches to maintain safety. (See Part 1, 

page 14 and Part 2, page 22). In the 

Nuclear Waste Safety Arena, NRC will 

continue developing a regulatory 

framework to increase our focus on safety,

I

0 NRC FY 2000 STRATEGIC PLAN
including the incremental use of risk

informed and, where appropriate, less 

prescriptive performance-based regulatory 

approaches to maintain safety. (See Part 1, 

page 25 and Part 2, page 41) 

5. Challenge (OIG): 

Developing information management 

systems and being able to anticipate and 

measure the benefits to be gained. 

Strategic Plan Reference: 

The corporate management strategy 

"provide proactive information 

management and information technology 

services" and the associated supporting 

strategies will address this challenge. (See 

Part 1, pages 39-40 and Part 2, pages 

72-75.) 

6. Challenge (OIG): 

Responding to the impact of industry 

deregulation and license transfers. 

Strategic Plan Reference: 

Performance goal, "Maintain safety, 

protection of the environment, and the 

common defense and security" and the 

associated strategies to: (1) evaluate 

operating experience and the results of risk 

assessments for safety implications; and 

(2) ensure that changes to operating 

licenses and exemptions to regulations 

maintain safety and meet regulatory 

requirements address this challenge in the 

Nuclear Reactor Safety Arena. (See Part 1, 

pages 2-3 and Part 2, pages 3-4.) The 

performance goal, "Make NRC activities 

and decisions more effective, efficient, and 

realistic," and the associated strategy to 

identify, prioritize, and modify processes

i

based on effectiveness reviews to 

maximize opportunities to improve those 

processes address the challenge by stating 

that we will modify our regulatory 

processes to keep pace with the challenges 

associated with economic deregulation of 

the electric power industry. (See Part 1, 

pages 6-7 and Part 2, pages 9-11.) 

In addition, NRC has a corporate 

management strategy to employ innovative 

and sound business practices. Associated 

with this strategy, we will modify our 

management and organizational structure, 

as appropriate, to meet the changing 

demands of internal and external factors, 

such as the economic deregulation of the 

electric utility industry and any resulting 

consolidation of the nuclear industry. (See 

Part 1, page 38 and Part 2, Page 69.) 

Finally, the economic deregulation and 

restructuring of electric power industry 

will continue to be considered as an 

external factor that could affect 

achievement of NRC strategic goals. (See 

Part 2, pages 15-16.) 

7. Challenge (OIG): 

Administering and overseeing agency 

procurement under new government 

contracting rules. 

Strategic Plan Reference: 

NRC has as an overarching corporate 

management strategy to employ innovative 

and sound business practices. As a 

supporting strategy, NRC will acquire 

goods and services in an efficient manner 

that helps to accomplish our mission, 

ensures fair and equitable treatment for all 

parties wishing to do business with the 

NRC, and results in the best value to the

NRC FY 2000 STRATEGIC PLAN

VOUE20 AT2MNAEETCALNE
I MAAGEENTCHALENGS IVOLUE 2* PRT

NRC. These strategies will enable NRC to 

address this challenge. (See Part 1, page 38 

and Part 2, page 69.) 

8. Challenge (OIG) 

Ability to effectively communicate with 

the public and industry. 

Strategic Plan Reference: 

The NRC has established performance 

goals and supporting strategies in the 

Nuclear Reactor Safety, Nuclear Materials 

Safety, and Nuclear Waste Safety arenas to 

increase public confidence. (See Part 1, 

pages 4, 16, and 27, respectively. In 

addition, see Part 2, pages 6-8, 26-29, and 

45-47, respectively.) In addition, the 

Agency has established a corporate 

management strategy to communicate 

strategic change. (See Part 1, pages 40-41 

and Part 2, pages 76-77.) These strategies 

will address this challenge. 

9. Challenge (0IG) 

Maintaining an unqualified financial 

statement opinion in light of new existing 

Chief Financial Officer's requirements. 

Strategic Plan Reference: 

NRC has as an overarching corporate 

management to employ innovative and 

sound business practices and a supporting 

strategy to strengthen our financial 

systems and processes to ensure that our 

financial assets are adequately protected 

consistent with risk and that our financial 

information is better integrated with 

decision-making. (See Part 1, page 38 and 

Part 2, pages 67-69.) These strategies will 

address this challenge.

10. Challenge (OIG): 

Ensuring that the NRC's processes are 

responsive to industry's needs. 

Strategic Plan Reference: 

Performance goals in the Nuclear Reactor 

Safety, Nuclear Materials Safety, and 

Nuclear Waste Safety arenas to make NRC 

activities and decisions more effective, 

efficient, and realistic and to reduce 

unnecessary regulatory burden on 

stakeholders and their supporting strategies 

address this challenge. (See Part 1, pages 

6-9, pages 18-21, and pages 28-31, 

respectively; and Part 2, pages 9-14, pages 

29-35, and pages 48-54, respectively.) 

11. Challenge (OIG): 

Ensuring that NRC's enforcement program 

has an appropriate safety focus and reflects 

improved licensees' performance. 

Strategic Plan References: 

Performance goal, "Maintain safety, 

protection of the environment, and the 

common defense and security" and the 

associated strategy to sharpen our focus on 

safety to include a transition to a revised 

NRC reactor oversight program form our 

inspection, assessment, and enforcement 

activities address this challenge in the 

Nuclear Reactor Safety Arena. (See Part 1, 

pages 2-3 and Part 2 pages 2-3.) 

12. Challenge (OIG) 

Refocusing NRC's research program to 

reflect a mature industry.

i

0 NRC FY 2000 STRATEGIC PLAN
Strategic Plan References: 

Three Performance Goals address this 

challenge in the Nuclear Reactor Safety, 

Nuclear Materials Safety, and Nuclear 

Waste Safety Arenas. They are: (1) 

Maintain safety, protection of the 

environment, and the common defense and 

security; (2) Make NRC activities and 

decisions more effective, efficient, and 

realistic; and (3) Reduce unnecessary 

regulatory burden on stakeholders. (See 

Part 1, pages 2, 6, 8, 13, 18, 20, 24, 28, 

and 30 and Part 2, pages 2, 9, 12, 20, 29, 

33, 40, 48, and 51.) 

The associated strategies in the Nuclear 

Reactor Safety Arena which address this 

challenge are: (1) to evaluate operating 

experience and the results of risk 

assessments for safety implications; (2) to 

identify, evaluate, and resolve safety 

issues, including age-related degradation, 

and ensure that an independent technical 

basis exists to review licensee submittals 

to ensure that safety is maintained; (3) to 

use risk information to improve the 

effectiveness and efficiency of our 

activities and decisions; (4) to make 

agency decisions based on technically 

sound and realistic information; (5) to 

anticipate challenges posed by the 

introduction of new technologies and 

changing regulatory demands; and (6) to 

utilize risk information and 

performance-based approaches to reduce 

unnecessary regulatory burden. 

The associated strategies in the Nuclear 

Materials Safety Arena which address this 

challenge are: (1) to continue to improve 

the regulatory framework to increase our

a

focus on safety and safeguards, including 

incremental use of risk-informed and, 

where appropriate, less prescriptive 

performance-based approaches to maintain 

safety; (2) to continue to improve the 

regulatory framework to increase our 

effectiveness, efficiency, and realism; and 

(3) to continue to improve our regulatory 

framework in order to reduce unnecessary 

regulatory burden. 

The associated strategies in the Nuclear 

Waste Safety Arena which address this 

challenge are: (1) to continue to improve 

the regulatory framework to increase our 

focus on safety and safeguards, including 

incremental use of risk-informed and, 

where appropriate, less prescriptive 

performance-based approaches to maintain 

safety; (2) to evaluate potential new 

information from research, new safety 

issues, changing external factors, 

international programs, and licensee 

operational experience so that 

improvements can be made to maintain an 

adequate regulatory framework; (3) to 

keep pace with the national high-level 

waste management program; (4) to 

continue to improve the regulatory 

framework to increase our effectiveness, 

efficiency, and realism; and (5) to continue 

to improve our regulatory framework in 

order to reduce unnecessary regulatory 

burden. 

13. Challenge (OIG): 

Responding to external influences for 

changing NRC's operations, for example 

its ability to meet the requirements of the 

Results Act following the agency's 

proposed reorganization.

NRC FY 2000 STRATEGIC PLAN 0

I VOLUME2,PART2 MANAGEMENT CHALLENGES ý
MANAEMET CALLEGýS VOUME , PRT

Strategic Plan References: 

The corporate management strategy to 

employ innovative and sound business 

practices and the supporting strategy to 

create and maintain a planning, budgeting, 

and performance management process that

is focused on outcomes and provides an 

effective tool for setting goals, allocating 

resources, tracking progress, measuring 

results, and identifying areas for 

improvement address this challenge. (See 

Part 1, page 38 and Part 2 page 68)

I

0 NRC FY 2000 STRATEGIC PLAN
I 6OUE2,PR

CROSS-CUTTING FUNCTIONS 

WITH OTHER GOVERNMENT 

AGENCIES

Several Government agencies have 

missions that are related to the NRC. The 

NRC identified no inconsistent or duplicative 

areas in this Plan compared to other agencies' 

Strategic Plans, but the Agency continues to 

be alert to potential inconsistencies or 

duplication in its cooperative activities. These 

interaction and coordination efforts are 

important in accomplishing the Agency's 

mission. In most instances, the NRC has, or is 

developing, memoranda of understanding 

(MOU) or other agreements with these 

agencies to ensure that areas of mutual interest 

and cooperation are treated in a consistent, 

coordinated, and complementary way that 

avoids unnecessary duplication or conflict. To 

develop programs in those areas that are 

critical to the NRC's mission, senior agency 

management meet with agency counterparts 

and establish plans and strategies in the areas 

of common programs and goals. Interagency 

committees are established, as necessary, to 

facilitate consensus on programs and promote

consistent approaches in implementation. One 

such example is the Interagency Steering 

Committee on Radiation Standards. 

Commission briefings on the status of 

programs are held as well, such as the periodic 

briefings by DOE on the high-level waste 

program. In other areas of mutual interest, 

agency staff coordinates with other agencies as 

appropriate. The review of cross-cutting 

programs, the coordination of those programs, 

and the identification of any issues are also an 

integral part of the NRC's internal technical 

program review process. In the area of 

intra-agency cross-cutting activities and 

functions within the NRC, there is no 

substantive cross-cutting or overlap between 

the programs within the agency. A table of the 

major cross-cutting functions with other 

agencies and their relationship to NRC 

programs is provided below, followed by 

descriptions of the specific NRC areas of 

mutual interest with other agencies.

I

NRC FY 2000 STRATEGIC PLAN
CRSS-UTN CIOJ WIH0kRAECESVLM -. ,PR

Agency Areas of Mutual Interest NRC Prograni/(Strategic 

_____________________Arena) 

Department of Energy (DOE) High-Level Waste Disposal High-Level Waste/(Nuclear Waste 

Safety) 

Transportation and Storage of Spent Fuel Storage and 

Spent Fuel and Waste Transportation Licensing and 

Inspection 

(Nuclear Waste Safety) 

Uranium Mill Tailings Radiation Uranium Recovery Licensing and 

Control Act Inspection 

(Nuclear Materials Safety) 

Low-Level Waste Regula(Nuclear Waste Safety)tion 

of Low-Level Waste 

Excess Plutonium Disposition Fuel Facilities Licensing and 

Mixed Oxide Fuel Fabrication Inspection 

DOE Tank Waste Remediation (Nuclear Materials Safety) 

System (TWRS) 

Regulatory Oversight at Gaseous 

Diffusion Plants 

Mitigation of Threat from Certain Regulation of Low-Level Waste 

Discrete Radioactive Material (Nuclear Waste Safety) 

Security of Classified National Fuel Facilities Licensing and 

Security Information and Inspection 

Restricted Data (Nuclear Materials Safety) 

Department of Energy (DOE) Threat Assessment Reactor Incident Response 

Federal Bureau of Investigation (Nuclear Reactor Safety) 

(FBI) 

U.S. Customs Service Fuel Facilities Licensing and 

Defense Intelligence Agency Inspection 

(DIA) (Nuclear Materials Safety) 

Central Intelligence Agency 

(CIA) Spent Fuel Storage and 

Department of State (DOS) Transportation 

(Nuclear Waste Safety) 

Environmental Protection Agency Protection of Public Health and (Nuclear Materials Safety) 

(EPA) Safety and the Environment (Nuclear Waste Safety) 

High-level Waste Site-specific High-Level Waste Regulation 

Standards (Nuclear Waste Safety)

NRC FY 2000 STRATEGIC PLAN
VOUE2,PR CRS-CUTN FNTOS WIHOHRAECE

Agency Areas of Mutual Interest NRC Program/(Strategic 

Arena) 

Federal Bureau of Investigation Response to Suspected Terrorist Reactor Incident Response 

(FBI) or Criminal Initiated Threat or (Nuclear Reactor Safety) 

Incident Involving Licensed (Nuclear Materials Safety) 

Reactor, Material or Fuel 

Facilities 

Federal Emergency Management Offsite Nuclear Power Plant Reactor Licensing 

Agency (FEMA) Emergency Planning Reactor Incident Response 

(Nuclear Reactor Safety) 

Offsite Fuel Cycle Facility Fuel Facilities Licensing and 

Emergency Planning Inspection 

(Nuclear Materials Safety) 

National Dam Safety Program Uranium Recovery Licensing & 

Inspection 

(Nuclear Materials Safety) 

Potassium Iodide (DI) Reactor Incident Response 

Supplement Program (Nuclear Reactor Safety) 

Federal Energy Regulatory Utility Economic Deregulation, Reactor Licensing 

Commission (FERC) Antitrust and Market Power (Nuclear Reactor Safety) 

Issues 

Department of Transportation Transportation of Radioactive and Spent Fuel Storage and 

(DOT) Fissile Materials Transportation Licensing and 

Inspection 

Nuclear Waste Safety) 

Food & Drug Administration Approval of Medical Devices Nuclear Materials Users 

(FDA) Incorporating Byproduct Licensing and Inspection 

Materials, Radiopharmacuticals, (Nuclear Materials Safety) 

and Radioactively Labeled 

Biologic Materials 

Occupational Safety & Health Worker Health and Safety Fuel Facilities Licensing & 

Administration (OSHA) Inspection 

I_ I_ ,(Nuclear Materials Safety)

NRC FY 2000 STRATEGIC PLAN
I RS-CUTN CTO 0 WIH0ýRAECE S iVLM ,PR

Agency Areas of Mutual1 Interest NRC Programl(Strat gc _________________Arena) 

Department of Health and Human Public Health and Safety in the Reactor Inspection 

Services, Public Health Service, Release and Transportation of Reactor Incident Response 

Agency for Toxic Substances and Ionizing Radiation (Nuclear Reactor Safety) 

Disease Registry Fuel Facilities Licensing and 

(HHS/PHS/ATSDR) Inspection 

Materials Incident Response State 

Programs 

(Nuclear Materials Safety) 

High-Level Waste Regulation 

(Nuclear Waste Safety) 

Department of Interior (DOI) Protection of the Environment Reactor Licensing 

(Nuclear Reactor Safety) 

Uranium Recovery Licensing and 

Inspection 

(Nuclear Materials Safety) 

Department of Labor (DOL) Enforcement Reactor Enforcement Actions 

Department of Justice (DOJ) (Nuclear Reactor Safety) 

Materials Enforcement Actions 

(Nuclear Materials Safety) 

Investigations Reactor Investigations 

(Nuclear Reactor Safety) 

Materials Investigations (Nuclear Materials Safety) 

Department of State (DOS) Nuclear Safety Assistance to Participation in International 

Department of Defense (DoD) Other Countries Activities 

Agency for International (International Nuclear Safety 

Development (AID) Support) 

Department of Energy (DOE) 

Department of State (DOS) Export of Nuclear and Nuclear Participation in International 

Department of Defense (DoD) Related Materials, Equipment, Activities 

Department of Energy (DOE) and Technology (International Nuclear Safety 

Department of Commerce (DOC) Support) 

National Security Council (NSC) Nuclear Safeguards Assistance to Participation in International 

Department of State (DOS) Other Countries Activities 

Department of Energy (DOE) (International Nuclear Safety Support)

S NRC FY 2000 STRATEGIC PLAN
VOUS 2, T CRSSCTTN FNTOS WIT OTE GECE

Department of Energy (DOE)-The NRC 

and DOE share responsibility for high-level 

waste (HLW) disposal. As specified in the 

Nuclear Waste Policy Act of 1982, as 

amended (NWPA), DOE is responsible for 

characterizing the site and for the design and 

construction of the repository and NRC is 

responsible for regulatory oversight, including 

licensing the construction and operation of the 

facility. Our strategy is to provide regulatory 

guidance to DOE and prepare to license a 

high-level waste repository at a pace 

consistent with the national program. An 

agreement is in place with DOE that outlines 

the procedures for staff consultation and 

exchange of information. This procedural 

agreement was updated in 1999 to incorporate 

changes to the HLW program since 1993. 

The NRC also interacts with DOE on a 

number of activities associated with the 

transportation and storage of spent nuclear 

fuel and high-level radioactive waste. The 

NRC and DOE have a procedural agreement 

regarding spent fuel and HLW transportation 

packaging. Further, DOE is required by law to 

use NRC-certified packaging for certain waste 

and spent fuel shipments. NRC and DOE have 

signed a cost-reimbursable interagency 

agreement whereby NRC provides DOE with 

oversight of physical security arrangements 

for certain foreign research reactor spent fuel 

shipments. NRC and DOE have signed a 

second cost-reimbursable interagency 

agreement whereby NRC provides DOE with 

review of a cask design for shipment of spent 

fuel from the West Valley Demonstration 

Project to the Idaho National Engineering and 

Environmental Laboratory. Lastly, NRC and 

DOE-Naval Reactors have signed a cost

reimbursable interagency agreement whereby 

NRC provides DOE-NR with review of a 

spent fuel dry storage facility for navy fuel.

i

The NRC and DOE have a joint 

responsibility in carrying out the Uranium 

Mill Tailings Radiation Control Act 

(UMTRCA) Title I Program and in the 

long-term care of reclaimed uranium mill 

tailings sites. Although DOE has the 

responsibility for carrying out remedial action, 

the NRC must concur in DOE's selection and 

completion of the remedial action and must 

license the sites for long-term care. The NRC 

and DOE have a memorandum of under

standing (MOU) to minimize or eliminate 

unnecessary duplication of effort between the 

two agencies. 

NRC and DOE are assigned 

responsibilities for the management of 

low-level radioactive waste (LLW) under the 

Low-Level Radioactive Waste Policy Act of 

1980 and its 1985 amendments. These 

responsiibilities are different but comple

mentary; thus, an MOU or other type of 

agreement has not been necessary. NRC and 

DOE interact on LLW policy, regulatory, and 

technical issues. 

DOE and NRC have established a 

cost-reimbursable agreement for NRC to 

provide technical assistance and coordinate 

with DOE on regulatory issues associated with 

DOE's disposition of excess plutonium 

through measures other than mixed-oxide 

(MOX) fuel fabrication/irradiation. Under the 

agreement, NRC advises DOE on regulatory 

issues associated with activities such as pit 

disassembly, conversion and immobilization. 

The FY 1999 Defense Authorization Act 

(P.L. 105-261) gave NRC statutory licensing 

authority over any MOX fuel fabrication 

facility constructed by DOE or its contractors 

to convert excess weapons plutonium into 

MOX reactor fuel. The facility will be located 

at DOE's Savannah River Site. This program

NRC FY 2000, STRATEGIC PLAN
CRSSC. rN 0UCIý WIT OTE GNISVLMS ,PR

depends on a number of factors outside of 

NRC control, including national policy, DOE 

funding, and Russian progress on 

dispositioning excess plutonium. 

The NRC will continue to assist DOE in 

regulating the Tank Waste Remediation 

System (TWRS) at Richland, Washington. 

DOE initiated this effort in 1996 to 

demonstrate technologies for solidifying 

highly radioactive tank waste at the Hanford 

site through the design of a pilot-scale facility. 

NRC and DOE developed an MOU in 1997 

and is updating it to reflect the current status 

and required objectives for the TWRS 

program. 

The NRC and DOE have regulatory 

oversight of different portions of the 

Portsmouth and Paducah Gaseous Diffusion 

Plants. The NRC regulates those portions 

which are leased by the United States 

Enrichment Corporation while DOE has the 

regulatory oversight for the remainder of the 

sites. Regulatory issues occasionally arise 

which concern both DOE and NRC. An MOU 

establishes the protocol between the NRC and 

DOE to address those issues. 

The NRC and DOE currently have an 

agreement that outlines the procedures for 

NRC requests for DOE assistance to mitigate 

threats to the public from certain discrete 

radioactive material, including material that 

exceeds Class C waste (10 CPR 61.55) 

classification. This agreement is being 

formalized in an MOU. 

The NRC and DOE share responsibility 

for the security of classified National Security 

information and Restricted Data at certain 

licensees (principally Naval Nuclear Fuel 

Facilities) and at the U.S. Enrichment

Corporation (USEC). Although DOE has 

principal responsibility at Naval Nuclear Fuel 

Facilities under the auspices of its classified 

contracts with those firms, NRC has 

responsibility for the personnel security 

program for access to or control over strategic 

nuclear material and for information related to 

the physical protection plans for the protection 

of the strategic nuclear material. At USEC, 

NRC has primary responsibility for the 

protection of classified information and DOE 

for the personnel security program. The NRC 

and DOE have several MOUs in place to 

minimize or eliminate duplication of effort 

between the two agencies. 

DOE, FBI, CIA, Customs, DIA, DOS

The NRC, as part of its mission to protect 

public health and safety and ensuring the 

common defense and security, maintains close 

working relationships with other agencies to 

ensure the design basis threat for radiological 

sabotage and theft or diversion are current and 

accurate. For this reason, NRC has established 

Memorandums of Understanding and Letters 

of Agreement for the exchange of relevant 

threat information. These arrangements also 

facilitate the timely receipt by NRC of any 

potential threats to NRC licensed materials or 

facilities. 

Environmental Protection Agency (EPA)

The NRC and EPA share responsibility for 

protection of public health and safety and the 

environment. There are numerous MOUs and 

interrelated activities between the NRC and 

EPA. NRC and EPA have been successful in 

many of these interrelated activities, including 

the development of the Multi-Agency 

Radiation Site Survey and Investigation 

Manual and the Multi-Agency Radiation 

Laboratory Protocols Manual, support for the 

National Research Council Committee on the

I

0 NRC FY 2000 STRATEGIC PLAN
I VOUM 2, PAT2COSCTIGFNTIN 6IHOHRAECE

Biological Effects of Ionizing Radiation, 

development of the Joint NRC/EPA Guidance 

for Testing Requirements for Mixed 

Radioactive and Hazardous Waste, 

development of a Technical Position for 

Disposition of Cesium-137 Contaminated 

Emission Control Dust, development of a 

nationwide survey to analyze for radioactive 

contamination of sewer sludge and ash at 

publicly-owned treatment works, and 

development of modeling scenarios in support 

of potential rulemakings for recycle/reuse of 

radioactively contaminated materials. The 

NRC is currently working with EPA to define 

roles, responsibilities, and jurisdictions 

regarding orphan source issues and to develop 

regulations to facilitate the disposal of mixed 

wastes. 

As specified in the Energy Policy Act of 

1992 (EnPA), EPA is tasked to develop 

site-specific HLW standards consistent with 

the recommendations of the National 

Academy of Sciences report on the Technical 

Bases for Yucca Mountain Standards. NRC 

has one year to develop an implementing rule 

after issuance of final EPA standards. EPA 

proposed a HLW standard in August 1999 for 

public comment. Both Houses of Congress 

have legislation pending that would, among 

other things, prescribe an overall performance 

standard for Yucca mountain, and, depending 

on which bill is enacted, could impact NRC 

and EPA responsibilities. The NRC maintains 

a formal liaison with the EPA staff and has 

implemented a strategy for the conforming 

requirements to ensure that the NRC 

completes the implementing rule within a year 

of issuance of the final EPA standards. 

Differences continue between the EPA and the 

NRC on groundwater protection requirements 

and other matters; they may impact the

i

requirements, complexity, and costs of 

licensing the repository. 

One area in which the NRC and EPA have 

been unsuccessful in their interrelated 

activities is setting standards to establish 

radiological criteria for decommissioning/ 

cleanup of contaminated sites, and high-level 

waste disposal. EPA is responsible for 

developing general radiation standards, which 

are then reflected in NRC regulations and 

other requirements. The NRC continues to 

seek legislation as reflected in the House 

Report 2531, "The Nuclear Regulatory 

Commission Authorization Act for Fiscal Year 

2000, Title II", that would make it clear that, 

with very limited exception, the standard 

issued by NRC and Agreement States governs 

cleanup of Atomic Energy Act material at 

facilities licensed by them. EPA expressed 

concerns with certain provisions of NRC's 

license termination rule and included in their 

guidance, "Establishment of Clean-up Levels 

for Comprehensive Enviromnental Response, 

Compensation, and Liability Act (CERCLA) 

Sites with Radioactive Contamination", a 

statement that the dose limits established in 

the NRC license termination rule would not 

provide a protective basis for establishing 

preliminary remediation goals for cleanup at 

CERCLA sites and that the NRC sites could 

require further remediation. Top-level NRC 

and EPA management will continue to address 

these issues to resolve the question of finality 

for sites that have complied with the NRC 

cleanup standards for license termination 

based on the House Report 2684, "Hazardous 

Substance Superfund (Including Transfers of 

Funds)". It is NRC's current position that 

changes to legislation are needed to resolve 

these issues, however NRC will continue to 

engage EPA in resolution of this matter as 

directed by the House Report 2684. The NRC

NRC FY 2000 STRATEGIC PLAN
0RS-U-N WIHOHRAECE6OUEAT 0UCIý 

has also supported provisions in high-level 

waste legislation in both Houses of Congress 

that would effectively remove EPA from the 

standard-setting role for the Yucca Mountain 

repository and establish a Congressional 

standard for which NRC would issue 

implementing regulations. While the bills 

differ on specifics, either would be preferable 

to the current statutory provisions on standard 

setting. 

Federal Bureau of Investigation 

(FBI)-The NRC and the Federal Bureau of 

Investigation (FBI) share responsibility (along 

with FEMA) for a response to a suspected 

terrorist or criminal initiated threat or incident 

involving NRC licensed facilities or material. 

The FBI has lead responsibility for crisis 

management during a threat or incident and 

the NRC retains the responsibility for 

radiological matters. The NRC and FBI have 

an MOU to minimize or eliminate unnecessary 

duplication of effort between the two agencies. 

Federal Emergency Management Agency 

(FEMA)-FEMA has the lead responsibility 

for offsite nuclear power plant emergency 

planning and for nuclear materials emergency 

planning. FEMA also has the lead in assessing 

offsite emergency plans and preparedness for 

adequacy. NRC is responsible for onsite 

radiological emergency preparedness and for 

review of FEMA findings and determinations 

as to whether offsite plans are adequate and 

can be implemented. NRC also has the 

responsibility to make radiological health and 

safety decisions with regard to the overall state 

of emergency preparedness, such as assurance 

for continued operation and shutdown of 

operating reactors. Should an actual peacetime 

radiological emergency require more than one 

agency to respond, the Federal Radiological 

Emergency Response Plan (FRERP) provides 

for coordination of all Federal response

activities. The FRERP is maintained by the 

Federal Radiological Preparedness 

Coordinating Committee (FRPCC); NRC is an 

active member in several FRPCC 

subcommittees that develop Federal 

procedures and guidance. In the event of an 

emergency involving an NRC-regulated entity, NRC is the lead Federal agency and works 

closely with six agencies: FEMA, DOE, EPA, 

USDA, HIHS, and NOAA. Representatives of 

these agencies train with, and are integrated 

into, the NRC response team. Response 

coordination on a broader scale is provided by 

the Federal Response Plan (FRP) for 

emergencies of all kinds, including responses 

under the National Contingency Plan (NCP) 

for emergencies involving chemical and 

radiological hazards occurring together. NRC 

is a member of the teams that coordinate 

actions under the NCP. The NRC and FEMA 

share responsibility (along with FBI) for a 

response to a suspected terrorist or criminal 

initiated threat or incident involving NRC 

licensed facilities or material. FEMA has lead 

responsibility for consequence management 

during a threat or incident and the NRC retains 

the responsibility for radiological matters. The 

NRC and FEMA have an MOU to minimize 

or eliminate unnecessary duplication of effort 

between the two agencies. 

FEMA and the NRC share involvement in 

the National Dam Safety Program. The 

primary purpose of this program is to bring 

together the expertise and resources of the 

Federal and non-Federal communities to 

achieve national dam hazard reduction. The 

NRC has regulatory authority over only 

uranium mill tailings dams and those dams 

integral to the operation of licensed facilities, 

or the possession and use of licensed material, 

that pose a radiological hazard if these dams 

should fail.

4 NRC FY 2000 STRATEGIC PLAN
VOUE2,PR CROS-UTN FUCIN WIHOHRAECE

Federal Energy Regulatory Commission 

(FERC)-The NRC and the Federal Energy 

Regulatory Commission (FERC) have ongoing 

interaction regarding issues of mutual concern, 

such as: (1) FERC actions with respect to 

economic deregulation of the electric utility 

industry and the potential impact of FERC's 

deregulation activities on the NRC's mandate 

to protect public health and safety, and (2) the 

respective roles of the NRC and FERC in 

evaluating antitrust and market power issues 

arising from NRC power reactor license 

applicants or licensees. NRC supports those 

aspects of the President's electric sector 

restructuring legislation that pertain to it, in 

particular, the elimination of NRC's 

duplicative role in antitrust reviews. 

Department of Transportation (DOT)

Under an MOU, the NRC and the Department 

of Transportation (DOT) share responsibility 

for developing, establishing, implementing, 

and enforcing consistent and comprehensive 

regulations and requirements for the safe 

transportation of radioactive and fissile 

materials, often through interagency 

committees. Generally, the NRC works with 

DOT to develop regulations for transporting 

materials, and the NRC adopts DOT 

requirements into its regulations. 

Food and Drug Administration (FDA)

The NRC and the Food and Drug 

Administration (FDA) have an MOU that 

outlines procedures for sharing information of 

mutual interest relating to the approval of 

medical devices, radioactive drugs, and 

radioactive biologies when these products 

contain NRC-regulated material. The NRC 

routinely relies on prior FDA approval of 

medical devices as an essential component of 

the NRC's sealed source and device safety 

evaluations. The MOU also establishes

procedures for notification, sharing of 

information, and coordination of joint 

inspections of events related to design and 

manufacturing defects and failures of these 

devices or of radioactive drugs or radioactive 

biologies. 

Occupational Safety and Health 

Administration (OSHA)-By an October 1988 

OSHA/NRC MOU, NRC and OSHA share 

responsibility for worker health and safety at 

NRC-regulated facilities. NRC regulates 

worker safety concerning radiation and 

chemical risks resulting from processing 

radioactive material and OSHA regulates 

worker safety concerning non-radiological and 

other industrial hazards. 

Agency for Toxic Substances and Disease 

Registry (ATSDR)-The NRC coordinates 

with ATSDR on issues relevant to the agency's 

mission to prevent exposure and human health 

effects and diminished quality of life 

associated with exposure to hazardous 

substances from waste sites, unplanned 

releases, and other sources of pollution in the 

environment. This coordination includes 

ATSDR's hazardous substances role in public 

health, including the impact of radioactive 

releases from power plants on adjacent 

communities' and Indian reservations' air, 

water, and food chain and impacts resulting 

from transportation of nuclear waste. 

Department of the Interior (DOI), Fish 

and Wildlife Service-Under the Endangered 

Species Act, the NRC has responsibility to 

assure that its actions are protective of 

endangered species. NRC consults with the 

Fish and Wildlife Service (FWS) in evaluating 

effects on endangered species of proposed 

NRC actions. If a proposed NRC action has 

the potential to affect endangered species, 

NRC prepares a biological assessment of the

NRC FY 2000 STRATEGIC PLAN
CRS-UTN FUCII WIHOHRAECESVLM S ,PR 

1 1

effects, and the FWS then renders a biological 

opinion. This consultation process can be 

extensive, as in the Atlas uranium mill tailings 

remediation case. 

Department of Labor (DOL)/Department 

of Justice (DOJ)-The NRC monitors 

discrimination actions filed with the 

Department of Labor (DOL) under Section 

211 of the Energy Reorganization Act and 

develops enforcement actions where there are 

properly supported findings of discrimination, 

either from NRC's Office of Investigations or 

from DOL adjudications. Suspected criminal 

activities concerning NRC licensees, and 

others within NRC's regulatory jurisdiction, 

are referred to the Department of Justice 

(DOJ). Coordination with DOJ occurs prior to 

initiating any civil enforcement action for 

matters under DOJ consideration for criminal 

prosecution. 

Department of State (DOS), Department of 

Defense (DoD), Agency for International 

Development (AID), Department of Energy 

(DOE), Department of Commerce 

(DOC)-The NRC shares responsibility with 

the DOS, DOE, DoD and the Agency for 

International Development (AID) in providing 

nuclear safety and safeguards assistance to 

other countries. State provides foreign policy 

guidance for U.S. government agencies in 

carrying out such assistance, while NRC 

contributes actively to the formulation of this 

guidance and clears its assistance programs 

with State to ensure they are within U.S. 

Government policy. The NRC also shares 

responsibility with DOE for providing nuclear 

safety and safeguards assistance

internationally. The NRC and DOE coordinate 

their efforts with each other and with other 

countries providing assistance to ensure they 

are complementary and to avoid duplication 

and conflict. The National Security Council 

and the Office of the Vice President provide 

high-level policy guidance on key issues in the 

international assistance area and resolve 

questions that arise in providing such 

assistance. 

The NRC, DOE, DOS, DoD, and the 

Department of Commerce (DOC) have 

interrelated roles in controlling exports of 

nuclear and nuclear-related materials, 

equipment, and technology. The NRC's 

primary role involves issuing export licenses 

for nuclear materials and equipment, including 

reactors. The following issue licenses or 

authorizations in related areas: DOE for 

nuclear technology exports and for retransfers 

or changes in form or content of previously 

exported nuclear materials and equipment; 

DOS for munitions made with depleted 

uranium; and Commerce for nuclear reactor 

balance-of-plant equipment and "dual use" 

commodities. Each agency is obliged to 

consult with the others (including, if 

warranted, DoD) for significant cases. 

DOE and NRC are in the process of 

establishing a cost-reimbursable agreement for 

NRC to provide Material Protection, Control, 

and Accounting Support to the regulatory 

agencies of Russia, Ukraine, and Kazakhstan 

through the development of regulations and 

the development of the licensing, inspection, 

and enforcement programs.

i

0 NRC FY 2000 STRATEGIC PLAN
VOLUME 2, ART 2 STRAEGIC PLANCOPNTSCEAI 

0M

NRC'S PLANNING, BUDGETING, AND PERFORMANCE MANAGEMENT PROCESS 

PRINCIPAL COMPONENTS OF THE PROGRAM CHAPTERS OF THE STRATEGIC PLAN

GOAL STSTRATEGIC 

Strategic goals represent the principal mission of the NRC and reflect the overall wc•he out to be achievingoer a 

perod of time. Achieving these strategic goals requires the collective efforts of the NoR, use Agreement States, 

and licensees. Achievement of the strategic goals while not totally within the control of NFIC ultimately 

determines how well the NRIC Is carrying out Its mission. 

L STRATEGIC GOAL MEASURES 

Strategic measures are outcome-odlented results that Indicate whether the NRC Is achieving Its 

strategic goals. The specific NRIC measures of overall safety In the Nation's use of byproduct, 

source, and special nuclear materials are primarily those reported In the annual Abnormal 

Occurrence Report to Congress 

PERFORMANCE GOAL 

Performance goals are the key contributors to achieving strategic goals and are focused on outcomes. The 

peformance goals establish the basis for the agency to plan, Implement, and monitor work, and to make 

Informed, value-added decisions In planning and In operations. The agency will manage Its activities to these 

goals. Performance goals Include an Indication of whether performance needs to change and In which direction 

(e.g., maintain, Increase, decrease). 

PERFORMANCE GOAL MEASURES 

These outcome or output measures provide Information to determine whether the NRC Is 

achieving its performance goals. NRC tracks the achievement of performance goals to provide 

Information to manage the agency and to report on Its performance. These measures establish 

how far and how fast the agency will move In the direction established by the performance goal. 

STRATEGIES 

Strategies describe how the NRC will achieve Its performance goals. Strategies provide the direct link between 

what the NRC wants to achieve (i.e., performance goals) and the key actvMties the NRC'will conduct to achieve 

those goals. (Strategies link to key activities and all work links to the performance goals.) 

COMMISSION POLICY 

Provides policy guidance on the conduct of NRC programs. 

SiBUDGET ASSUMPTIONS 

Key external factors that signific.antly rimpact the NRC's 

work activities and resource requirements. 

PERFORMANCE-BASED BUDGET 

Performance-based budgets identify resources for programs and activities necessary to achieve performance 

goals and expected performance targets for a given fiscal year. 

I 

OPERATING PLANS 

Operating plans identify detailed output measures that are tied to achieving the agency's outcome goals. The 

operating plan also reports on performance progress. Quarterly updates will contain Information about program 

effectiveness, shifting resource needs, and Internal and external environmental changes so that operational 

changes can be made during the fiscal year.

NRC FY 2000 STRATEGIC PLAN 0

C 

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Cop a) 

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a-.:
VOUE2,PR6

ENDNOTES

1. "Licensees" as used in this Strategic Plan 

include persons required to be licensed (as 

defined in Section l1(s) of the Atomic 

Energy Act, as amended) as well as, 

where appropriate, applicants for NRC 

licenses, certificate of compliance holders 

and applicants for certificates of 

compliance, contractors (including 

subcontractors, suppliers, consultants, and 

vendors), and all persons subject to the 

NRC's regulatory jurisdiction. 

2. Specific values of the metrics were, in 

general, set after consideration of past 

performance. Failure to meet a metric will 

generally prompt a re-evaluation of the 

involved programs and activities. 

However, some failures to meet some 

metrics may be due solely to randomness 

in the timing of events and not due to a 

change in underlying level of safety. In 

such cases, no changes to programs or 

activities would be warranted. 

3. "Nuclear reactor accidents" are defined in 

the NRC Severe Accident Policy 

Statement (50 Federal Register 32138, 

August 8, 1985) as those accidents which 

result in substantial damage to the reactor 

core, whether or not serious offsite 

consequences occur. 

4. "Significant radiation exposures" are 

defined as those that result in unintended

i

permanent functional damage to an organ 

or a physiological system as determined 

by a physician in accordance with 

Abnormal Occurrence Criterion I.A.3. 

5. Releases that have the potential to cause 

"adverse impact" are currently undefined. 

As a surrogate, we will use those that 

exceed the limits for reporting abnormal 

occurrences as given by AO criterion 

I.B.1 {normally 5,000 times Table 2 (air 

and water) of Appendix B, Part 20}. 

6. Regulatory Guide 1.174, "An Approach 

for Using Probabilistic Risk Assessment 

in Risk-Informed Decisions in Plant 

Specific Changes to the Licensing Basis," 

establishes general principles for using 

risk information in NRC review and 

approval of licensing actions. 

7. Stated succinctly, risk-informed, 

performance-based regulation is an 

approach in which risk insights, 

engineering analysis and judgement, and 

performance history are used to (1) focus 

attention on the most important activities, 

(2) establish objective criteria based upon 

risk insights for evaluating performance, 

(3) develop measurable or calculable 

parameters for monitoring system and 

licensee performance, and (4) focus on 

the results as the primary basis of

NRC FY 2000 STRATEGIC PLAN
ENNTSS 

I VOUE2 PR -

regulatory decision-making. This 

definition is from the Commission White 

Paper which can be located at 

www.nrc.gov/NRC/COMMISSION/SRM/ 

1998-144srm.html. 

8. Such events have a 1/1000 (10-3) or 

greater probability of leading to a reactor 

accident. 

9. The agency provides oversight of plant 

safety performance on a plant-specific 

basis as well as on an industry-wide basis. 

As a refinement to the existing process, 

the specific parameters and criteria for 

measuring statistically significant adverse 

trends in industry-wide safety 

performance will be developed by FY 

2001. The parameters to be monitored 

will include NRC-approved performance 

indicators, inspection findings, accident 

sequence precursor results, and other 

risk-related indications or measures of 

industry safety performance that will be 

developed and qualified for use in phases. 

10. Overexposures are those that exceed 

limits as provided by 10 CFR 

20.2203(a)(2), excluding instances of 

overexposures involving a shallow dose 

equivalent from a discrete radioactive 

particle in contact with the skin. 

11. Releases for which a 30 day reporting 

requirement under 10 CFR 20.220)(3) is 

required. 

12. A 10 CFR 2.206 petition is a written 

request filed by any person to institute a 

proceeding to modify, suspend, or revoke 

a license, or for any other enforcement 

action. The petition specifies the action 

requested and sets forth the facts that

constitute the basis for the request. The 

NRC evaluates the technical merits of the 

safety concern or investigates the 

wrongdoing presented by the petition. 

Based on the facts determined by the 

NRC technical evaluation or investigation 

of the merits of the petition, the Director 

will issue a decision to grant the petition, 

in whole or in part, or deny the petition. 

The Director's Decision explains the 

bases upon which the petition has been 

granted and identifies the actions that the 

NRC staff has taken or will take to grant 

the petition in whole or in part. Similarly, 

if the petition is denied, the Director's 

Decision explains the bases for the denial 

and discusses all matters raised by the 

petitioner in support of the request. 

13. The start time of the 120 days is the date 

that the Petition Review Board (PRB) 

determines that the proposed petition 

satisfies the criteria of the NRC 

Management Directive (MD) 8.11, 

"Review Process for 10 CFR 2.206 

Petitions" and acknowledges by letter the 

petitioner's request. MD 8.11 is currently 

being revised to allow the petitioner and 

the licensee various opportunities to 

participate in the petition process. This 

additional stakeholder involvement may 

have an effect on the 120 day 

performance measure. 

14. For fuel cycle activities, this extends to 

other hazardous materials used with, or 

produced from, licensed material, 

consistent with proposed amendments to 

10 CFR Part 70. It also includes 

exposures from uranium recovery 

activities under the Uranium Mill Tailings 

Radiation Control Act.

NRC FY 2000 STRATEGIC PLAN
VOUM 2,PRT2ENDO

15. Under Section 274 of the Atomic Energy 

Act of 1954, as amended, a state may 

assume and the NRC discontinue 

regulatory jurisdiction for certain uses of 

byproduct, source, and limited quantities 

of special nuclear materials within the 

state. The assumption in authority is 

accomplished through an agreement with 

the state upon an NRC finding that the 

State's program is adequate to protect 

public health and safety, and is compatible 

with the NRC regulatory program. 

16. In this context, the regulatory framework 

consists of several interrelated aspects. 

They are: 1) the NRC's mandate from 

Congress in the form of enabling 

legislation; 2) the NRC's rules in Title 10 

of the Code of Federal Regulations; 3) the 

regulatory guides and review plans that 

amplify those iegulations; 4) the body of 

technical information, obtained from 

research performed by the NRC or by 

others and from evaluation of operational 

experience, that supports the positions in 

the rules and guides and review plans; 5) 

the licensing and inspection procedures 

utilized by the staff; and 6) the 

enforcement guidance. 

17. Significant exposures are defined as those 

that result in unintended permanent 

functional damage to an organ or a 

physiological system as determined by a 

physician. Hazardous material exposures 

only apply to fuel cycle and uranium 

recovery activities in the Nuclear 

Materials Safety Arena. 

18. In accordance with Appendix G to 10 

CFR part 73 and 10 CFR 74.11(a). 

19. In accordance with the requirements of 10 

CFR 95.57.

i

20. We recognize that no explicit reporting 

requirements exist for substantiated 

breakdowns of programs. The NRC relies 

on its safeguard inspection findings and 

license notifications. 

21. Material entering the public domain in an 

uncontrolled manner. The Nuclear 

Materials Event Data base contains the list 

of these events as reported by NRC 

licensees and , through the Agreement 

States, and their licensees. 

22. Overexposures are those maximum annual 

exposures that exceed limits as provided 

by 10 CFR 20.2203(a)(2). For fuel cycle 

activities, this extends to other hazardous 

materials used with, or produced from, 

licensed material, consistent with 

proposed amendments to 10 CFR 70. 

Reportable chemical exposures are those 

that exceed license commitments. It 

would also include chemical exposures 

involving uranium recovery activities 

under the Uranium Mill Tailings 

Radiation Control Act. 

23. Medical events as reported under 10 CFR 

35. 

24. Releases for which a 30 day reporting 

requirement under 10 CFR 20.220(3) is 

required. 

25. This measure involves chemical releases 

from the NRC regulated activities under 

the Uranium Mill Tailings Radiation 

Control Act. 

26. Measuring the protection of future 

generations over the planning period of 

the next five years is a unique challenge 

which the Commission is continuing to 

evaluate.

NRC FY 2000 STRATEGIC PLAN
ENNOE 1 S1

27. Prelicensing activities such as these 

constitute informal conferences between a 

prospective applicant and the staff and are 

not part of a potential licensing 

proceeding. 

28. As used in this arena: 

"Nuclear safety means protection of 

the public health and safety and the 

environment. 

"Domestic safeguards are those 

nuclear material control and 

accounting measures and physical 

protection measures implemented by 

and within any country, including the 

U.S., to prevent sabotage of nuclear 

materials or facilities or theft or 

diversion of nuclear materials by an 

individual or a group within that 

country. Secure use of nuclear 

materials is achieved through the 

successful implementation of 

domestic safeguards. 

" International safeguards are the 

independent verifications performed 

by the International Atomic Energy 

Agency (IAEA) of a country's 

"peaceful use" declarations on 

nuclear materials and nuclear 

facilities. 

" Nuclear nonproliferation means 

control over or deterrence of the 

spread of nuclear explosive devices. 

29. Agreements for Cooperation in the 

Civil/Peaceful Use of Nuclear Energy are 

required under section 123 of the Atomic 

Energy Act of 1954, as amended, to 

establish the legal framework for

technical cooperation in the production 

and use of special nuclear material as well 

as for the supply of such material or fuel 

cycle equipment, or related sensitive 

information to another country or 

international organization. These 

Agreements for Cooperation (or Section 

123 Agreements, as they are also known) 

include such nonproliferation conditions 

and controls as safeguards commitments; 

a guarantee of no explosive or military 

use; a guarantee of adequate physical 

protection; and U.S. rights to approve 

retransfers, enrichment, reprocessing, 

other alterations in form or content, and 

storage of U.S.-supplied or derived 

material. They must be in effect before an 

NRC export license can be issued. 

30. The INES is a tool designed by an 

IAEA/NEA-sponsored group of experts to 

communicate promptly and consistently 

to the public the safety relevance of 

reported events at nuclear installations. 

Criteria for INES Level 3 are (a) an 

external release of radioactivity above 

authorized limits, resulting in a dose to 

the most exposed individual off-site on 

the order of 0.1 millisievert. (With such a 

release, off-site protective measures may 

not be needed.); (b) an on-site event 

resulting in a dose to workers sufficient to 

cause acute health effects and/or an event 

resulting in a severe spread of 

contamination; and (c) an incident in 

which a further failure of safety systems 

could lead to accident conditions, or a 

situation in which safety systems would 

be unable to prevent an accident if certain 

initiators were to occur. 

31. As defined in 10 CFR Part 73.2.

I ______________________________________

4 NRC FY 2000 STRATEGIC PLAN
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-000 1

years