ML20206T963
| ML20206T963 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1977 |
| From: | Case E, Casey Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| SECY-77-141A, SECY-77-141A-R, NUDOCS 9902120108 | |
| Download: ML20206T963 (22) | |
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April 21, 1977 SECV-77-141A UaflTED STATEh NUCLEAR REGULATORY COMMISSION CONSENT CALENDAR ITEM 1
i RELEASED TO THE PDR e
E _ cS)(bbY hk, E l
l dats ini%s FOR:
The Commissioners FROM:
Clifford V. Smith Acting Director Office of Nuclear Material Safety and Safeguards Edson G. Case Deputy Director Office of Nuclear Reactor Regulation THRU:
Executive Director for Operations
SUBJECT:
SAFEGUARDS CONTINGENCY PLANS (SECY-77-141)
Enclosed for your approval is the proposed rule on licensee safeguards contingency planning as contained in Enclosure "A" of SECY-77-141 and as. briefed to the Commission on April 11,.1977.
The items in the_
memorandum from S. J. Chilk to Lee V. Gossick dated April 12, 1977, on the above subject have been resolved as follows:
1.
It is the Commission's understanding that licensee contingency plans will be considered-an~ element of the licensing package for physical security.
There-fore, the classification and proprietary nature of information pertaining to contingency plans will be consistent with that for physical security plans.
The Commission understanding is correct.
2.
The Statement of Considerations states that licensee contingency plans would be complementary to radio-logical emergency plans.
Moreover, the proposed I
CONTACT:
T. F. Carter, Jr., NMSS T)
I 427-4191 C,
'2 - 10 9902120108 770421 N-14![R
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.m Memorandum for the Commission ;
rule (Development and Maintenance of the Plan) ensures that any person assigned a responsibility in a safeguards contingency is not prevented from carrying out that responsibility by any other assignment, e.g., for emergency preparedness.
NMSS and OSP have signed a Memorandum of Understanding concerning the relationship between safeguards con-tingency planning and emergency preparedness.
A similar memorandum should be developed by NRR and OSP.
NRR and SP have been tasked by ED0 with preparing a Memorandum of Understanding for their respective Offices concerning the relationship between reactor safeguards contingency planning and emergency prepared-ness.
The suspense date for completion of this Memorandum is May 16, 1977.
3.
The staff should integrate requirements and pertinent guides for licensee contingency plans with the develop-ment of an appropriate national plan.
We consider the Commission request to be direction and are so proceeding.
The development of the national-level safeguards contingency plan is being done within NMSS, as reflected in the Agency-wide Objectives sent to Chairman Rowden on April 11, 1977.
The experience gained from developing the model licensee plans for fuel-cycle plants, nuclear power plants, and transportation should ensure a sensitivity to the necessity of integrating the licensee and national plans.
4.
The Commission notes that much of the implementation of the rule will depend on the development of appro-priate guides.
The Commission wishes an opportunity to comment on all such guides prior to their issuance.
The Commissioners will be given an opportunity to review and comment on the Regulatory Guides before the guides are published.
These I guides are scheduled to be completed and sent to the Commission at i
the same time as the rule is sent for consideration in its effective form.
5.
The NRC should develop an appropriate policy for handling hostage situations within its jurisdiction, including options on how to convey such a policy to l
licensees and the public.
This policy should be i
consistent with that established government-wide.
It is the Commission's understanding that the staff
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,,,w, Memorandum for the Commission l is developing a draft policy statement, which will be forwarded to the Comission for approval in the i
near future.
A draft Commission paper addressing the " hostage situation" was circulated for staff cortrrent on April 12, 1977.
The paper, which is being prepared jointly by NMSS and NRR, is due to EDO on May 16, 1977.
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Cli f rd V. Smith Acting Director Office of Nuclear Material Safety l
ind Safeguards q l
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/, Edson G. Case,
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Deputy Director Office of Nuclear Reactor Regulation
Enclosure:
Proposed rule Note: Commissioner comments or consents should be provided directly to the Office of the Secretary by close of business Friday, April 29, 1977.
Sunshine Act:
Recommended for affirmation at an open meeting.
0GC and OPE concur.
Anticipated Scheduling:
Week of May 2, 1977.
DISTRIBUTION Commissioners Commission Staff Offices l
Exec Dir for Opers Secretariat
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION l
[10 CFR PARTS 50, 70, and 73]
1 LICENSING OF PRODUCTION AND TIILIZATION FACILITIES; SPECIAL NUCLEAR MATERIAL; PHYSICAL PROTECTION OF PLANTS AND MATERIALS Licensee Safeguards Contingency Plans Agenc'h:
Nuclear Regulatory Commission Ac't ion :
Proposed Rule Summary:
Under the proposed rule, licensees authorized to operate a nuclear reactor (other than cer-tain research and test reactors) and those authorized to possess strategic quantities of s
plutonium or uranium-235 would be required to develop and implement acceptable plans for re-sponding to threats, thefts, and sabotage of
' licensed nuclear materials and f acilities.
Dates:
Comments must be received on or before (sixty days after date of publication).
Address:
Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D. C.
20555 j
Attention:
Docketing and Service Section i
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l For further information, contact:
Thomas F -Carter, Jr., 301-427-4191 Chief, Contingency Planning Branch U. S. Nuclear Regulatory Commission,
1 Washington, D.C.
20555 Supplementary information:
The Of fice of Nuclear Material Safety and Safe-guards within the Nuclear Regulatory Commission was charged by Congress, in the Energy Reorgani-l zation Act of 1974, with the development of f
safeguards contingency plans for dealing with threats, thefts, and sabotage relating to licen-sed special nuclear material and nuclear facili-ties.
In many safeguards contingencies, responses will be expected from more than one person or organization.
Fulfillment of the Congressional mandate requires that the response continuum be c ompl e t ed.
The Office of Nuclear Material Safety, l
and Safeguards is already adressing contingency plans at the Federal level.
The Commission is now
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proposing to complete the continuum by requiring safeguards contingency plans of those licensees having materials and f acilities of greatest safe-guards importance.
See discussion below.
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oy The Nuclear Regulatory Commission has under consideration amendments to its regulations in 10 CFR Part 50, " Licensing of Production and Utiliza-tion Facilities," 10 CFR Part 70, "Special Nuclear Material," and 10 CFR Part 73,
" Physical Protection of Plants and Materials," which, in the interest of the common defense and security and public health and safety, l
would require certain licensees to develop and follow lice'nsee safeguards
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contingency plans for dealing with threats, thefts, and sabotage relating l
to special nuclear material and nuclear facilities licensed under the j
Atomic Energy Act of 1954, as amended.
The proposed amendments would apply to those licensees subject to the physical protection requirements for transportation and fixed sites contained in 10 CFR 55 73.30(a), 73.50, 73.55, and/or 73.60.
For the purposes of this rule making proceeding, " sabotage" as used in il 50.34(d) and 70.22 means " industrial sabotage" as defined in 5 73.2(p) of 10 CFR Part 73.
A contingency is a situation, regarded as remotely possible in the future, that develops unexpectedly and requires prompt attention.
In a practical sense, a safeguards contingency may be regarded as an extraordinary situation that requires the execution of security plans and procedure, not normally performed on a day-to-day basis.
Such situations may or may not occur; they are planned for under assumed conditions of occurrence in order to deal with them effectively if they should occur.
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In many safeguards contingencies, responses will be expected from more than one person or organization.
At the Federal, level, responses may l
involve not only the NRC but also, among others, the Federal Bureau of Investigation, the Energy Res'earch and Development Administration, and various organizations within the Department of Defense.
An important element of safeguards contingency planning by the Commission is the coordination of these various responses.
The responsibilities assigned, to the Of fice of Nuclear Material Safety and Safeguards by the Congressional mandate of Section 204(b)(2)(B) of
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I the Energy Reorganization Act of 1974 are being addressed by developing j
safeguards contingency plans at the Federal level.
At the same time, the Commission recognizes the importance of safeguards actions by those persons who possess special nuclear material and operate certain facilities.
Indeed, licensees would have the primary role in many safeguards contin-gencies because of their intimate connection with the materials and facilities at risk.
The Commission further recognizes the necessity for j
assuring coordinated responses to all safeguards contingencies, including responses by licensees.
To provide and maintain adequate safeguards, therefore, the Commission must ensure that each licensee having important safeguards responsibility develops and follows a " licensee safeguards contin-gency plan" that is compatible with the Federal level plans for responding to safeguards contingencies.
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> The proposed rule would define a licensee safeguards contingency plan as a documented plan to give guidance to licensee personnel in order to accomplish specific, defined objectives in the event of threats, thefts, or sabotage relating to special nuclear material or nuclear facilities licensed under the Atomic Energy Act of 1954, as amended.
The plan would contain (1) a predetermined set of decisions and actions to satisfy the stated objectives, (2) an identification of the data, criteria, procedures, and mechanisms necessary to effect efficiently the decisions and actions, i
and (3) a specification of the individual, group, or organizational entity i
l responsible for each decision and action; The plan is not intended to include actions under any emergency plans that deal with the hazards to public health and safety that are the consequence of nuclear accidents or releases of nuclear materials--even though those accidents or releases might result from acts of threats, thefts, or sabotage--other than steps to initiate the implementation of such emergency plans.
Accordingly, the licensee contingency plans that would be required by the proposed amendments would be complementary to radiological emergency plans including those developed for all nuclear power reactors pursuant to Appendix E of 10 CFR
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Part 50 and for fuel-cycle facilities developed pursuant to Section 70.22(i) of 10 CFR Part 70.
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The goals of licensee safeguards contingency plans for dealing with threats, thefts, and sabotage are (i) to organize the response effort at the licensee level, (ii) to provide predetermined structured responses by licensees to safeguards contingencies, (iii) to integrate the licensee response with the
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+e responses by other entities, and (iv) to achieve a measurable performance in response capability.
Licensee safeguards contingency planning would result in organizing the licensee's responding resources in such a way that the parti-cipants would be identified, their several responsibilities specified, and the responses coordinated.
Because they would be predetermined, the responses are more likely to be structured and orderly rather than executed impulsively.
It is anticipated that the responses would~ thus be effected in a timely manner and would be consistent among themselves and with Federal responses.
To the.e, tent that requisite data and criteria were predetermined, the response capability of the participants could be predicted and assessed.
A methodology for developing licensee safeguards contingency plans has been devised and evaluated, and typical plans have been drawn up for fuel-cycle. plants, nuclear reactors, and road transportation of special nuclear material.
Licensees will receive the benefit of this experience by means of Regulatory Guides to be issued by the time the rule is issued in ef fective fo rm.
In accordance with the provisions of National Security Decision Memorandum 347, certain portions of the Safeguards Contingency Plans for fuel-cycle licensees will be classified.
These licensees and their agents,will be re-quired to hold appropriate security clearances in order to use these plans.
Certain information in safeguards contingency plans may be withheld from public disclosure in accordance with the provisions of paragraph 2.790(d) of 10 CFR Part 2.
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s sh If the Com=ission adopts the proposed amendments to 10 CFR Parts 50, 70, l
and 73, each affected licensee would be given a' period of 120 days following l
l publication in the FEDERAL REGISTER of the rule in effective form to submit a licensee safeguards contingency plan.
In addition, each licensee would be given until 300 days after publication in the FEDERAL REGISTER or 30 days after the submitted plan is approved, whichever is later, to be in a position to follow his plan.
The Commission has determined under Council of Environmental Quality guide-lines and the criteria in 10 CFR Part 51 not to prepare an environmental impact statement for the proposed amendments to 10 CFR Parts 50, 70, and 73 Concurrently with the publication of this notice of proposed rule making the Commission is making available in its Public Document Room at 1717 H Street, N.W., Washington, D.C., an " Environmental Impact Appraisal of Amendments to 10 CFR Parts 50, 70, and 73, Licensee safeguards Contingency Plans," intended to support a negative declaration.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorgani-sation Act of 1974, as amended, and section 553 of Title 5 of the United States Code, notice is hereby given that adoption of the following amendments
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to Title 10, Chapter 1, Code of Federal Regulations, Parts 50, 70, and 73 is contemplated.
All interested persons who wish to submit written comments or suggestions for consideration in connection with the. proposed amendments should send them to the Secretary of the Commission, U.S. Nuclear Regulatory Com:.ission, Washington, D.C. 20555, Attention:
Docketing and i
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.,,, Service Section by [60 days af ter publication].
Copies of comments on the proposed anendments may be examined at the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C.
l 1.
Section 50.34 of 10 CFR Part 50 is amended by adding a new paragraph (d) to read as follows:
5 50.34 contents of applications:
Technical information.
]
I (d)
Each application for a license to operate a production or utilization facility that shall be subject to 55 73.50, 73.55, or 73.60 shall include a licensee safeguards contingency plan for dealing with threats, thef ts, and industrial sabotage, as defined in Part 73 of this chapter, relating to the special nuclear material and nuclear facilities licensed under this chapter and in the applicant's possession and control.
Appendix C to Part 73 of this chapter sets forth the criteria to be followed in developing such plans.
2.
Paragraph 50.54(p) of 10 CFR"Part 50 is amended to read as follows:*
5 50.54 Conditions of licenses.
Whether stated therein or not, the following shall be deemed conditions in every license issued:
- Comparative text.
Additions are underlined and deletions are lined j
through.
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(p) The licensee shall make no change,which would decrease the effectiveness of a security plan prepared pursuant to 5 50.34(c) or Part 73 of this chapter, paragraph fq} ef this seeeien or a licensee safeguards contingency plan prepared pursuant to S 50.34(d) or Part 73, as applicable, without the prior approval of the Commission.
A licensee desiring to make such a change shall submit an application for a change in the techniest specifications ineerperseed' in his tieense er for an amendment to his license pursuant to Section 50.90.
as approprisee-The licensee shall' maintain records of changes to the plans made without prior Commission approval for a period of two years from the date of the change, and shall furnish to the Director of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission, Washington, D.
C.
20555, with a copy to the appropriate NRC Regional Of fice specified in Appendix D of Part 20 of this chapter, a report containing a description of each change within two months after the change is made.
3.
In 5 70.22 of 10 CFR Part 70, paragraph (g) is amended and a new paragraph (j) is added to read as follows:
5 70.22 Contents of applications.1 (g) Each application for a license that would authorize the trans-port or delivery to a carrier for transport of special nuclear material in an amount specified in 5 73.1(b)(2) of this chapter shall include (1) a description of the plan for physical protection of special nuclear l
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I material in transit in accordance with 55 73.30 through 73.36 and 73.70(g) of this chapter, including a plan for the selection, qualification and training of armed escorts, or the specification and desygn of a specially designed truck or trailer as appropriate and (2) a, licensee safeguards 3
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contingency plan for dealing with threats, thef ts, and sabotage -- relating to the special nuclear material in transit. Appendix C to Part 73 of this chapter sets forth the criteria to be foi-lowed in developing licensee safeguards contingency plans.
(j) Each application for a license to possess or use at any site or contiguous sites subject to control by the licensee uranium-235 (contained in uranium enrict to 20 percent or more in the uranium-235 I
isotope), uranium-233, or plut. onium alone or in any combination in a quantity of 5,000 grams or more computed by the formula, grams = (grams contained U-235) + 2.5 (grams U-233 + grams plutonium) other than a license for possession or use of such material in the operation of a nuclear' reactor licensed pursuant to Part 50 ot this chapter, shall include a licensee safeguar's contingency plan for dealing with threats, d
thefts, and industrial sabotage, as defined in Part 73, relating to the special nuclear material-and nuclear facilities licensed under Parts 3/ Sabotage as used in this section has the same meaning as in t 73.2(p)
H this chapter except that the deliberate acts are postuTatE to occur E ring transportation rather than a_t a, fixed site.
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- c. w 59t 50 or 70 of this chapter and in his possession and control.
Appendix C to Part 73 of this chapter sets forth the criteria to be followed in developing such plans.
4.
Section 70.32 of 10 CFR Part 70 is amended by adding a new paragraph (g) to read as follows:
5 70.32 Conditions of licenses.
(g) The licensee shall make no change that would decrease the sa'feguards effectiveness of any licensee safeguards contingency plan prepared pursuant to 55 70.22(g), 70.22(j), 73.30(g), or 73.40 of this chapter without the prior approval of the Commission.
A licensee desiring to make such a change shall submit an application for an amend-ment to his license pursuant to gg 50.90 or 70.34 of this chapter, as appropriate.
The licensee may make changes to the licensee safeguards contingency plan without prior Commission approval if the changes do not ' decrease the safeguards ef fectiveness of the plan.
The licensee shall maintain records of changes to any such plan made without prior approval for a period of two years from the date of the change and shall furnish to the Director of Nuclear Material Safety and Safeguards, U. S.
Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the appropriate NRC Regional Office specified in Appendix A of Part 73 of this chapt'er, a report containing a description of each change'within two months after the change is made.
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.-, 5.
Paragraph 73.30(g) of 10 CFR Part 73 is revised to read as follows:
5 73.30 General requirements.
'O (g)
Paragraphs fbtr fety fd}7 and ff) of this section are effective March-67 1974r By [120 days after publication of this rule in effective form], each licensee subject to the requirements of paragraph (a) of this section shall submit to the Commission for approval a licensee safeguards contingency plan for dealing with threats, thefts, and sabotaae relating to the transport of the special nuclear material in his possession and control. The plan <shall be implemented and followed (when appropriate) by the licensee within 30 days af ter approval by the Commission or 300 days after [ effective date of this amendment], whichever is later.
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6.
Section 73.40 of 10 CFR Part 73 is amended to read as follows:
5 73.40 Physical Protection:
General requirements at fixed sites.
Each licensee shall provide physical protection against industrial sabotage and against thef t of special nuclear material at the fixed sites where licensed activities are conducted.
Seearity ptsns submitted to the Atemte Energy 6emmissien.fer approvst shatt be fettewed by the tieensee after March 67 E974r The provisions of a licensee's security plan as 1
approved by the Commisssion shall be followed by the licensee.
By [120 days after publication of this rule in effective forml each licensee i
subject to the requirements of _L 73.50, 73.55, and/or 73.60 shall' submit i
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t2.the Coemission f2E aporoval a licensee safeguards contingency Elaa
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in,accordance with the criteria set forth in Apoendix C t2.this natt for dealine wid1 threats, thefts, and industrial sabotare relating in,the special nuclear raterial and nuclear facilities licensed under Parts l
1Q on lq of this chapter and in his possession and control.
The plan shall he inolenented.and followed (when acoropriate) hr the licensee within 2Q days after acoroval by, the Cone.ission p_t 2QQ gays. after feffective datt. 2[ this amendentl. whichever h later.
9 7.
A new Appendix C is added to 10 CFR Part 73 to read as follows:
APPENDIX C LICENSEE SAGEGUARDS CONTINGENCY PLANS l
INTRODUCTION
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l Certain licensees and license applicants are required to prepare licensee safeguards contingency plans pursuant to 5 5 50 34(d), 70.22(g), 70.22(j),
i 73 30(g), or 73.40 of this chapter.
A licensee safeguards contingency plan is a documented plan to give guidance to licensee personnel in order to accomplish specific, defined objectives in the event of threats, thefts, or
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sabota6e relating to special nuclear material or nuclear facilities licensed under the Atomic Energy Act of 1954, as amended.
The plan shall contain (1) a predetermined set of decisions and actions to satisfy stated objectives, (2) an identification of the data, criteria, procedures, and mechanisms necessary to effect efficiently the decisions and actions, and l
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(2) a specification of the individual, group, or organizational entity responsible for each decision and action.
The safeguards contingency plan include actions under any emergency plans that deal with the shall not hazards to public health and safety that are the consequence of nuclear accidents or releases of nuclear materials--even though those accidents or releases may result from acts of threats, thef ts, or sabotage--other than Accordingly, steps to initiate the implementation of such emergency plans.
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the licensee safeguards contingency plans are complementary to any emergency plans developed pursuant to Appendix E of Part 50 of this chapter and t
4 to 5 70.22(i) of Part 70 of this chapter.
The goals of licensee safeguards contingency plans for dealing,with threats, at the licensee thefts, and sabotage are (1) to organize the response effort level, (2) to provide predetermined, structured responses by licensees to safeguards contingencies, (3) to integrate the licensee response with the responses by other entities, and (4) to achieve a measurable performance in response capability. Licensee safeguards contingency planning should in organizing the licensee's response resources in such a way that result the participants will be identified, their several responsibilities specified, j
and the responses coordinated.
The responses should be timely, internally consistent among themselves, and compatible with Federal responses.
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CONTENTS OF THE PLAN Each licensee safeguards contingency plan shall include five categories of inforr.ation.:
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===1.
Background===
2.
Generic Planning Base 3
Licensee Planning Base 4.
Responsibility Matrix 5.
Procedures 4
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Backcround.
Under the following topics, this category of information shall identify and define the perceived dangers and incidents with which the plan will deal and the general way it will handle these:
a.
Perceived Danger - A statement of the perceived danger to the security of special nuclear material, licensee personnel, and licensee property, including covert diversion of special nuclear material, sabotage, and overt attacks.
b.
Purpose of the Plan - A discussion of the general aims and opera-tional concepts underlying implementation of the plar..
c.
Scope of the Plan - A delineation of the types of incidents covered and not covered in the plan.
d.
Definitions - A list of terms and their definitions used in describing operational and technical aspects of the plan.
2.
Generic Planning Base.
Under the following topics, this category cf information shall define the criteria for initiation and termination of responses to safeguards contingencies together with the specific decisions, actions, and supporting information needed to bring about such responses:
a.
Identification of those events that will be used for signaling the beginning or aggravation of a safeguards contingency according to how they are perceived initially by licensee's personnel.
Such events may include alarms or other indications signaling penetration of a protected area, vital area, or material access area; material control or material accounting indications of material missing or unaccounted for; or threat indications--
either verbal, such as talephoned threats, or implied, such as escalating civil disturbances.
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Definition of the specific objective to be accomplished relative to each identified event.
The objective cay be to obtain a_ level of awareness about the nature and severity of the safeguards contingency in order to prepare for further responses; to establ'ish a level of response preparedness; or to successfully nullify or reduce any adverse safeguards consequences arising from the contingency.
3 Licensee Planning Base.
Under the following topics, this category of information shall include' the factors affecting contingency planning that are specific for each facility or means of transportation:
a.
Licensee's Organizational Structure - A delineation of the organi-zation's chain of command and delegation of authority as these apply to i
safeguards contingencies.
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Physical Layout - (1) Fixed Sites - A description of the physical structures and their location on the site, and a description of the site in relation to nearby towns, roads, and other important environmental features.
(11) Transportation - A description of the vehicles, shipping routes, and related features that would affect contingency responses.
c..
Safeguards Systeem Hardware - A description of the physical security
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and accounting system hardware that influences how the licensee will respond to an event.
Examples of systems to be discussed are communications, alares, locks, seals, area access, armaments and surveillance.
d.
Law Enforcement Assistance - A listing of available local law enforce-ment agencies and a description of their response capabilities and their
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f criteria for response; and a discussion of working agreements or arrangements for communicating with these agencies.
e.
Policy Constraints and Assumptions - A discussion of State laws, local ordinances and company policies and practices that govern' licensee response to incidents.. Examples that may be discussed include:
use of deadly force use of employee property use of off-duty employees site security jurisdictional coundaries f.
Administrative and Logistical Considerations - Descriptions of licen-s'ee practices that may have an influence on the response to safeguards contingency events.
The descriptions shall include provisions for ensuring that all equipment needed to effect a successful response to a safeguards contingency will be easily accessible, in good working order, and in sufficient supply to provide redundancy in case of equipment failure.
4.
Fesconsibility Matrix.
This category of information consists of detailed identification of the organizational entities responsible for each decision and action associated with specific responses to safeguards contingencies.
This identification shall be done by means of a matrix composed of an array of cells for each event, each cell correlating a decision or action with a member or unit of the organization and containing a task, i.e.,
a detailed description of how a decision is to be made or an action is to be taken.
5.
Procedures.
In order to aid implementation of the detailed plan as
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developed in the matrix, this category of information shall summarize the actions to be taken and decisions to be made by each member or unit of the organization as planned in the matrix.
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DEVELOPMENT AND MAINTENANCE OF THE PLAN
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When submitting a licensee safeguards contingency plan to the Commission for approval, each license applicant and licensee shall also submit a description of the steps that he has taken or will take to ensure that:
(1) Safeguards contingency responsibilities are assigned in a manner that precludes conflicts in duties or responsibilities that would prevent the execution of the plan in any safeguards contingency; (2) Adequate resources are available at all times for carrying out the plan; (3)
The plan will be reviewed and updated periodically to take due account of changing conditions; and (4)
Periodic drills or tests will be made to ensure that safeguards contingency responses follow those set forth in the plan.
(Sec. 1611, Pub. L.83-703, 68 Stat. 948; secs. 201, 204(b)(1), Pub. L.
93 438, 88 Stat. 1243, 1245 (42 U.S.C. 2201, 5841, 5844))
Dated at this day of 1976.
FOR THE NUCLEAR REGULATORY COMMISSION l
Samuel J. Chilk Secretary of the Com=ission l