ML20209D521
| ML20209D521 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20209D524 | List:
|
| References | |
| FOIA-85-409, TASK-PINV, TASK-SE SECY-83-378, NUDOCS 8411160238 | |
| Download: ML20209D521 (23) | |
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% a l September 14, 1983
/ SECY-83-378 t
POL.lCY QSSUE (Notation Vote)
For: The Comissioners From: William J. Dircks Executive Director for Operations
Subject:
NRC ROLE IN THE CONTINUITY OF GOVERN!1ENT PROGRAM
Purpose:
To provide the Commission with the staff's review of the functions of the NRC during a national emergency, and recommend modifications to NRC's plans and programs to assure continuity of essential functions under conditions including a massive nuclear attack on the United States.
Backaround: Shortly after the NRC was established in 1975, the Commission approved a functional statement for the NRC for national level emergency preparedness to be included in a revision to Executive Order 11490 (SECY 75-669). In early 1976, the Commission approved a program to begin to implement NRC national level emergency planning and preparedness responsibilities, including the designation of NRC as a " Category A" agency (SECY 76-133).
(Enclosure 1 provides a definition of the categories of emergency responsibilities.)
As initial s'teps in that program, the staff developed (1) a list of NRC. essential uninterruptible functions and (2) a list detailing succession to office, both of which were approved by the Comission in the first half of CY 1977 (SECY 77-189 and SECY 77-316). Scie progress has been made in develo;;ing and
- maintaining three executive teams and ensuring the line of 9;. s successien is clearly defined. In addition, an. alternate s!.
- .i . :.3 '.- location for the Charlie Team is being maintained. However,
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the regions have-been involved pnly in a lim.i.ted way in
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- . 5 planning functions, and at the present time, no.r.esources.are f . ,. budgeted for national level prsparedness planning either at
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headquarters or at the regional' offices.
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' ';. ' . . -( 0'iscussion: 'NRCROL5ANDFUNCTICd5
, ', ' . The NRC regulatory program and its role in emergencies has .
changed significan,tly in the last seven ycars. As a result, IE established a Work Gro;p with repr.esentatives from IE, NRR, NMSS, ELD, ADM, RES, IP, and OPE in 1982 to-consider-the
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- e The Commissioners various asphets of national emergency preparedness planning and make appropriate recommendations to senior management as to future policy and direction of this program.
The Work Group was most concerned about defining what NRC's role would be in the immediate pre-attack period and while the attack was in progress. Representatives of both FEMA and DOE briefed the Work Group on their agencies' activities in this area and described what information and r.upport 00E and FEMA would expect from NRC during a national emergency.
As a result of these briefings, discussions, and a review of historical documents, the Work Group believes that the appli-cability of the current Federal Continuity of Government program to the NRC program should be critically examined. The current regulatory program provides licensees with detailed criteria and parameters within which they can conduct authorized activities and operate nuclear facilities in a safe manner without continuous NRC oversight. Certainly, the basic regulatory structure must be saved and reconstituted after an attack. However, given a sound underpinning, the regulatory program could be suspended for a short period of time (i.e.,
at least several days) in a national crisis. Even in non-emergency situations, the NRC audits only a small portion of licensee actions. There are two other resources recognized as important for the reconstitution of Government (and therefore to be saved) after an attack: (1) its technical expertise, and (2) its methods of public interaction. Neither of these resources, however, fs-an uninterruptible NRC function.
SAFETY FUNCTIONS IN A NATIONAL EMERGENCY In an emergency, it is the licensee who has the immediate and-primary continuing responsibility for limiting the consequences of an incident at his facility. Resident inspectors may be available to consult directly with the nuclear power reactor operating staffs. Although it would not be appropriate to delegate licensing and inspection authority to resident inspectors, those individuals could provide a vital function in consulting with licensees regarding operational concerns and could provide basic intelligence to designated alternate Federal locations, if possible. The resident inspectors could also assist licensees in obtaining necessary support in maintaining operations at the level desired. The resident inspector may be able to obtain support from the regional offices and headquarters, but should be prepared to function
~ independently, if necessary.
Enclosure 2 lists the broad functional areas now considered uninterruptible during a national emergency, particularly a nuclear attack. These functions of (1) damage assessment, (2)
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The Commissioners :
4 threat assessment, (3) minimizing hazards to health and safety consistent with the national interest, and (4) determining whether it is safe to operate, must be maintained during a national emergency. It is not evident, however, that the NRC, as an organization, is in the best position to carry out these
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functions or whether it is necessary that the NRC oversee and monitor these functions. For example, when considering the j operation of. nuclear facilities, the licensee is in the best position for making the necessary critical decisions in a 4
timely manner. It is not reasonable to even infer that the NRC would have to approve or concur in these vital operating ,
decisions, particularly in a situation in which communications may range from poor to nonexistent. Prior to an attack, the NRC may be able to provide general guidance to licensees in' determining a plan of action in a potential national emergency, but in a large scale emergency, the NRC would not be able to review and approve, in a timely manner, operational changes that may need to be made. As.in 10 CFR 50.54(x), the licensee-4 should be able to take reasonable actions that depart from
> license conditions or technical specifications in a national-i emergency situation, subject to NRC review at a later date.
With respect to damage and threat assessment, it is also individual licensees who arc in the best position to carry out' this function. From a national perspective,' 00E has the overall responsibility for determining national energy.needs and available capacity to meet those needs. Utilities will i have to balance;the concerns of providing energy in the national interest with continued operation under adverse conditions. Although the NR.C may be able to provide DOE with some specific information about individual plant operations, it is doubtful that our information and communications '
capability would be superior to those of the electric utility industry or maintained during a national emergency. 'The same is true for sabotage threats. Other Federal agencies would 4
have the lead and NRC's information is likely to be of little-use.
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In summary, a realistic look at NRC capabilities, functions, L and policies indicate that NRC operations could be deferred ,
for some time (i.e. , at least several days) and. then recon-stituted when conditions permit without creating undue risks i to public health and safety. Under those conditions, NRC '
should change its category of emergency responsibilities for national emergencies.
, FEMA has developed only general guidance as to how an agency determines its category of emergency responsibilities. The limited guidance provided indicates that Category 8 agencies would reconstitute as soon as conditions permit, e.g., imme-
- diately after a nuclear attack. In addition, a Category B f'
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The Commissioners agency would be expected to establish two executive complements at the national level composed of the minimum number of personnel necessary to form the nucleus for agency reconstitution to carry out national defense emergency assignments. Category C agencies are to be prepared to reactivate their regular agency structures when required. FEMA guidance makes no distinction for regional agency components between the responsibilities of Category B and C agencies.
It appears that the National Emergency Program for each Federal agency is almost exclusively dependent on that agency's perceptions of its role in a national emergency. In a postattack environment, no national defense emergency assignments for NRC have been identified. Rather, under Category C, the NRC would have the' flexibility to develop an NRC program for responding to the offnormal events at licensed facilities in a manner that is consistent with the existing NRC emergency response role and organization. NRC would resume its routine licensing activities as soon as feasible. This perception fits best with Category C emergency functions ~ If special requirements are identified in developing a Category C program for NRC, FEMA would be receptive to accommodating any particular NRC needs in their programs.
Consequently, it is concluded that NRC has national emergency functions that are most consistent with Category C of FEMA guidance.
4 NRC NATIONAL EMERGENCY CONCEPTUAL PLAN A more pragmatic approach for the NRC to meet its responsibilities is to suspend, temporarily, the active portions of its routine licensing and inspection programs and provide direct assistance, as needs arise, at selected facilities. Where possible, headquarters and the regions will support NRC individuals at the sites, but these site representatives will be prepared to function independently.
It will be necessary to inform licensees prior to an attack that, during and immediately after an attack, the NRC normal regulatory role may be suspended. Licensees will be reminded that they have the responsibility for deciding whether to continue to operate in light of safety considerations and the national interest. In certain instances they may decide that it is safe and in the national interest to continue to operate in violation of the regulations, technical specifications, and license conditions. NRC site representatives may be available for con'sultation, but they will not have authority to modify licenses or assume operational control of the facility.
At the national and regional levels, it will be useful to
! pre-designate technical representatives to appropriate government j relocation sites to provide expertise on NRC responsibilities, l
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- The Commissioners -
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.J organization, functions, procedures, etc. However, the number of these. individuals will- be severely limited, i.e. , one or two per relocation site, and will not be considered an executive complement to carry _out agency functions.
NRC staff will continue to work on the identification of those records vital for reconstitution of NRC functions. It is not evident that the records required for future agency operations s are dependent on which category of emergency functions NRC -
assumes. However, it would be prudent to identify, store,
, - and maintain some additional technically oriented records at the various relocation sites throughout the United States
- where the limited NRC staff would be assigned. .
IMPLEMENTATION CONCERNS -
i-There are no known legal or national policy obstacles to.
implementing this change. The basis for the program results '
from Executive Order ~(E.O.) 11490 and the subsequent update of that document, E.O. Order 11953. These emergency fuactions and the functions designated essential uninterruptible functions were developed by the staff for Commission approval. There is no statutory requirement that NRC specifically maintain a ,
1- distinct program for assuring uninterruptible operation of the 1:
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NRC functions. Development of executive teams ~, relocation sites, and other aspects of a national level emergency pre-5 paredness program were initiated as the result of earlier guidance issued by the Federal Preparedness Agency and its successor, the Federal Emergency Management Agency.
I However, FEMA is now actively considering changes to its
- Continuity of Government program.- Both the current and proposed programs appear to depend heavily on how each agency '
identifies and perceives its own responsibilities. ' It could
- - be argued that the.NRC should await new directions from FEMA before the NRC modifies its current program. However, since i FEMA's concepts and approaches will be developed around
,~. individual programs rather than vice versa, by taking the initiative to identify and describe the agency's responsi-bilities now, the NRC can better assure that those government-wide programs now being developed by FEMA will be meaningful and appropriate to the NRC.
Any basic changes to the overall Continuity of Government program should not change NRC's perceived responsibilities, but rather change the structure,and tactics for reconstituting our government. ;
RELATION WITH NRC INCIDENT RESPONSE PROGRAM f It'should also be pointed out that any changes to the national 1evel emergency preparedness program will have little effect
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on the operations and purpose of the NRC's incident response program. We see no policy changes in the latter. Rather, it is suggested that for those national emergencies not involving a massive nuclear attack, the NRC response should be more closely aligned with that of the NRC's incident response program. The support requested by other agencies and the questions received in national level preparedness exercises strongly indicate that the more technically oriented organization defined in MC 0502 and NUREG-0845 would b'e more effective than the current executive teams which, by definition, are managerially oriented. The incident response teams have been receiving enhanced training and are performing with increased efficiency.
We see several drawbacks to initiating a separate program for national level preparedness-
- 1. Competition for team membership time and resources.
- 2. Developing staff understanding of the national emergency planning function which appears more remote and undefined than a nuclear facility accident.
- 3. Unnecessary redundancy.
Modification can be made to the incident response program to accommodate unique features necessary in a national emergency.
t However, this modification would generally be achieved by calling on special personnel as needed.
Recommendation: a. Approve the staff's recommendation to have the NRC change its agency classification for emergency functions, as defined in E.O. 11490, from " Category A" to " Category C."
- b. Approve the enclosed letter (Enclosure 3) to FEMA which requests that they note our change in agency designation from " Category A" to " Category C" and alter space require-ments at the FEMA Special Facility and regional relocation sites to reflect this change.
- c. Direct the staff to implement a program that will follow the concepts provided in this paper.
Willi . Dircks Executive Director for Operations
Enclosures:
- 1. Categories of Emergency Responsibilities
- 2. List of NRC Essential Uninterruptible Functions
- 3. Letter to FEMA t 1
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Commissioners' comments--.or consent should be provided directly to the Office of the Secretary by c.o.b. Thursday, September 29, 1983.
, Commission Staff Office comments, if 'any , should be submitted to the Commissioners NLT Thursday, September 22, 1983, with an information' copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OPE OIA OCA OPA OI REGIONAL OFFICES EDO ELD i
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CATEGORIES OF EMERGENCY RESPONSIBILITIES
- Catecorv A. Organizations with a requirement for postattack reconstitution as soon as conditions permit, unlass othemise directed by appropriate ~ authority.
Federal departments, designated components of the Executive Office- of the President and independent agenices in Category A are to be prepared to carry out national-level essential functions from any one of three geographic location.,
vith the regular office as primary headquarters and the others as alternate headquarters.
Catecorv B. Organizations with a requirement for postattack reconstitution as soon as conditions permit, unless otherwise directed by appropriate authority.
Other components of the Executive Office of the President and independent agencias in Category 8 are to be prepared to reconstitute their organizations and to carry out emergency assignments at regular headquarters or a designatec alternate location as soon as conditions permit, unless othemise ordered by appropriate- authority.
Catacerv C. Organizations that a$ e to defer reconstitution until directed by appropriate authority. ~The remaining independent agencies in . Category C do not have emergency assignments requiring advance arrangements for alternate locations.
but are to be prepared to resume activities in the reconstitution period when ordered by appropriate authority.
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- Federal Preparedness Circular 11, FEVA i
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- I 3 1E77 NUCLEAR REGULATORY COMMISSION
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ESSENTIAL UNINTERRUPTISLE FUNCTIONS .
5 During a national emergency staming frem a nuclear attack, or threat of an iminent attack,' the. Nuclear Regulatory Comission will be pre-pared to perform or administer the following essential uninterruodble functions. These functions are limitad to the praattack, attack, and imediate postattack pericds, and will be carried out only as authorized by statutory or constitutional authority.
- 1. Maintain increased surveillance of the operations of if censed nuclear reactors and fuel cycle facilities to assure minimum hazard tc health and safety consistant with Natic'nal secuHty needs, and as. necessary and apprcpriate:
- a. Order sh'utdcwn or curtailment of operations.
- b. Order continued coeration.
- c. Order entry to assume operational centrol of essential facilities.
- d. Stoo or curtail the use-or transportadon of special nuclear material, or order recall of such material.
- 2. Assess the damage to if censed nuclear facilities to:
- a. Identify useable facilities.
- b. Esdmate the time required for restarting inoperative-1
[ facili ties. '
- c. Deter.nine all hazardous conditions at. these facilities and any hazardous releases frem the facilities.
- d. A~s sure that accropriate actions are taken to correct the hazardous canditions and inform and instruct the public to minimize injury and damage to prcperty.
- 3. Assess the threats to scecial nuclear materials, high-level radioactivity wastes, and nuclear facilities, and increase security measures as recuired to counter threats, thefts and
] sabotage.
4 Order the recacture or order entry into a facility to recacture i
saecial nuclear materia'1.
- 5. Authorize revised safety criteria for licansed nuclear-facilides and special nuclear material handling acclicable tc the caanged operating and environmental conditions. brougnt on by the emergency.
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. 6. Provide suppori: to and maintain liaison with:
.' a. Tne office designate'd by the President to receive recorts on functions listed above, advice on _ the content of puolic instructions and information, and reccmendations concerning the NRC role in achieving national objectives.
- b. Other Federal agencies which ,have related functicns.
- c. State agencies cancerning emergency conditions and actions -
related to licensed nuclear facilities and materials. .
To aid in carrying out the NRC mission functions, the NRC staff will also be prepared to perform essential administrative and succor. tasks.
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- THE WHITE HOUSE WASHINGTON k -
( February 1, 1984 s dA
Dear Mr. Chairman:
have As you requested in your letter of January 23, Irtise might need considered the role that NRC resources and expe play in a national emergency. lly -
Restoration of essential services will beation criticaThis facilities, will require t important in any post-attack environment.
ability to assess damage to nuclear power genering i facilities can and to determine conditions under which surv vThe NRC shoul be operated.
determinations, and NRC personnel However, and expertis'e this function d willw have to rters to help make the judgments.
be carried 'out by people *on the scene, not i by a hea bequasing func organization. Moreover, the rule-making and lcertainly cen the Commission's normal regulatory program can suspended during a national emergency. tions could
( I therefore agree with your staff thar NRC opera ted when i
be deferred during a national emergency and reconst tu .
conditions permit.
Sincerely, t .s-
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The Honorable Nunzio J. PalladinoChairman, Nuclear R Washington, D.C. 20555 e
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- ( honora61Gik M N Palladino Chairman, United States Nuclear Aegulatory Comt:sion Washington, D.C. 20S55
Dear Mr. Chairman:
s Thank y6u for your letter of January F3,1*S4, requesting the irlevs of this Acency on the tasks that the huclear Regulatory C movie need to accomplish durine. a national emergency, ommission (RRC) lie have reviewed the materials developed by your staff to. determine '
whether it would be appropriate to change the destenation of the ARC from its current classification as a Category A agency.
Catescry 8 agency.la accordance with current criteria. the MRC should be
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have been revised and lacorporated into the new Pperational the ExecutiveReadiness Branch." to Provios for Continuity of Essential Functions of as they appear in the dra f t FPC.Enclosee for your information are the new criteria
- Sincerely, i
. . -u Louis 0. Giuffrica Cirector i
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- E wAsMNGToN,0.C. 20585
,. April 3,1984 .
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S Honorable Nunzio J. Palladino Chairman, U.S. Nuclear Regulatory .
Commission Washington, D.C. 20555
Dear Mr. Chairman:
Thank you for your January 23, 1984, letter providing the Department of Energy (00E) with an opportunity to review the Nuclear Regulatory Commission (NRC) staff proposal for reclassifying the NRC from a Category A to a Category C Federal ~ organization in the Federal Continuity of Government Program. In its anlaysis of that proposal, 00E took into consideration the nature of emergency preparedness functions.which are expected to be assigned to the NRC when Execu-tive Order 11490 is revised. Some of these functions include the regulation of licensed nuclear materials and facilities; the conduct of health and safety activities pertaining to NRC-licensed nuclear facilities; the assurance of continued security and safeguards at licensed facilities; and the administra-tion of any priorities and allocation authorities delegated to the NRC.
00E believes that the NRC emergency preparedness functions are sufficiently
..T vital that NRC should reestablish them as expeditiously as possible following
- ( an attack on the United States. Undar the Federal Continuity of Government Program, Category B agencies are required to resume performance of essential functions as soon as conditions permit, rather than to await direction from other. authorities. Accordingly, it is DOE's recommendation that NRC be classified a Category B agency.
If the Com:nission decides to seek a classification lower than Category B, 00E would recommend that the emergency functions discussed above be assigned to other agencies, so that the expeditious performance of those functions in an emergency can be ensured.
Should the NRC staff desire a more detailed explanation of DOE's views in this matter, they may contact Mr. Richard E. Weiner at 252-1311.
incere .
/M1 DONALD PAUL H00EL
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.- , , THE SECRETARY OF STATE WAS HINGTON February 16, 1984
Dear Mr. Chairman:
This is in reply to your letter of January 23 in which you sought the Department of State's views on tasks which might require NRC resources and expertise during a time of national emergency.
A careful reading of the background material you provided on the NRC role in the cont'inuity of government leads us to conclude that it is unlikely that the Department of State would seek NRC action during a national emergency. We assume NRC functions with regard ,
to import and export of nuclear materials and facilities would be suspended. .
I hope this information helps you in reaching a decision on the proper classification of the NRC.
incerely yours, George P. Shult:
The Honorable Nunzio J. Palladino, Chairman, Nuclear Regulatory Commission.
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- . . p I* THE SECRETARY OF DEFENSE ,
Ch airman Nuclear Regulatory Commission Washington, DC 20555 ce ar Dr. P alladino,
- Your letter of January 23, 1984 ano its enclosed proposal to reclassify the Nuclear Regulatory Commission as a Category C
- Agency have been ' reviewed. The Department of Defense inter-poses no objection tc the reclassification action. As presently envisioned, there are no specific DoD taits in a national emergency situation that would require support from or augmenta-tion by NRC,resodrces or expertise.
Sincer'ely, I. ' . '
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.k MEMORANDUM FOR: Chairman Palladino Commissioner Gilinsky Commissioner Roberts Commissioner Astelstine Commissioner Bernthal FROM: William J. Dircks Executive Director for Operations
SUBJECT:
SECY-83-378: NRC ROLE IN THE CONTINUITY OF GOVERNMENT PROGRAM ^
This is in response to Commissioner Asselstine's April 26, 1984 request for an evaluation of the resource implications of NRC determining that it has Category C functions versus Category B.
Since SECY-83-378 was transmitted to the Commission for consideration (September 14, 1983), FEMA has reissued its guidance to Federal agencies for their participa -
tion in the Continuity of Government program. There has been little additional
, guidance provided to assist an agency in determining a specific program for carrying out its functions. However, the staff has met with FEMA officials responsible for this progra.i and has been able to discuss approaches which
- would be most compatible with NRC's incident response program and . manner of operations.
As stated in SECY-83-378, the most realistic approach for NRC would be to align the NRC's incident response program with that needed for national emergencies.
FEMA is amenable to this approach if NRC were to be designated as either a Category B or Category C agency. As a Category B agency, the NPC incident response teams would serve as the basis for Alpha and Bravo teams at headquar- l ters and a primary and alternate team in the regions. Upon being notified of
- an impending national emergency, all or portions of selected teams would report to headquarters and/or the regions. At an appropriate time, the Executive Team would designate two individuals each to relocate to the headquarters Bravo site and regional relocation centers with appropriate predesignated authorities and order of succession. A small number of additional NRC personnel could be provided to supplement the personnel at.the Bravo site and regional relocation centers when the NRC Operations Center and regional Incident Response Centers are about 'o be abandoned. Direct communication with nuclear power plants and .
other key '4RC-licensed facilities would be maintained through the Emergency Notification System which would be extended to the Bravo site.
CONTACT: K. E. Perkins, IE
, 492-7361
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The Commission r
( As a Category C agency, the NRC would, in a potential national emergency, also use the NRC headquarters and, regional incident response teams to collect and assimilate available information to understand the situation, particularly with respect to impacts to NRC. This team would then determine a course of action and direction that the agency would take. However, when a nuclear attack is immirent, the headquarters and regional teams would disband after providing any appropriate instructions to licensees and NRC staff. After the attack and cessation of the crisis, the agency will begin reconstitution based on proce-dures developed prior to the attack.
Enclosure 1 provides a comparison of the general FEMA guidance for each of these categories and an estimate of the resources needed to implement and maintain the agency's , capability for both Category 8 and Category C.
Estimates of personnel resources indicate that it would require 1 FTE to implement a Category B program in FY85 and then take about 3 FTEs to provide maintenance, upgrading, exercising, and associated staff. training. For a Category C agency, it is anticipated that staff activities would be less than 0.5 FTE. There will be some significant costs associated with locating the NRC Emergency' Notification System at the Bravo site for Category B. These costs are uncertain but are estimated to be between $100,000 and 5500,000 plus unknown annual recurring costs. .No additional communication costs have been identified ir association with a Category C status. -
As we understand, both FEMA and DOE's suggestion that NRC designate itself as a o
Category B agency rather than Category C, each is concerned about having someone available throughout any national emergency who can act with the authority of the Commission in ordering licensees to cease or continue opera-4 tion in the national interest. If the NRC is to be designated as a Category C agency, it will be necessary to explore with 00E the possibility of providing guidance to the licensees that they should continue operation under their existing guidance unless the Department of Energy directs them otherwise in the national interest. A mechanism would then be developed where NRC could extend certain limited authority to DOE in a national emergency when NRC senior officials would not be available. l William J. Oircks Executive Director for Operations
Enclosure:
Comparison of FEMA Guidance and Estimate of Resources DISTRIBUTION: -
OCS IRB File (EW-359) VStello, DEDROGR DEPER Rdg. (EW-359) WJ0ircks, E00 GCunningham, ELO JRoe, E00 TRehm, EDO JDouglas, IE (2)
BTravers, E00 E00 Rdg. E00-14387 R0eYoung, IE JTaylor, IE SECY-83-378 EJordan, E SSchwartz, IE
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- E :IE c 0:IE E00 eis :kw t. i artz rdan C.JM Alor RCD oung WJ0frcks 05/J/84 Og/84 /84 06/(/84 06/g /84 06/ /84 f/84
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ENCLOSURE ~
l l CONTINUITY OF GOVERNMENT RESOURCES i
CATEGORY 0 CATEGORY C Reconstitute as soon as conditions permit Defer reconstitution until directed by Definition appropriate authority.
to perform essential functions.
Reconstitute their organizations to carry No advance arrangement for alternate l
Responsibilities locations necessary.
out emergency assignments as soon as con-
- ditions permit at regular headquarters or at one or more alternate locations.
l l
Alpha and Bravo Teams at national level. Prepared to activate regular agency Emergency structures when required by appropriate Operating Alpha Team composed of minimum cadre to reactivate national office. Each team authority. Agency personnel to make them-l Capability selves available for other emergency duty capable of forming nucleus for agency l
' reconstitution and composed of minimum and cooperate with local, State, and l
number of personnel for resumption of national authorities until recalled.
l essential agency functions. Supporting l professional, clerical, and service staffs prepared to report to either location.
Prepare regional components to accept No direction provided.
Regional Support Interim authority and responsibility for performance of essential national functions.
Communications: Communications:
Necessary Resources Bravo Site only No additional l
! Commitments Emergency Notifications System Estimated: $100,000 to $500,000-Installstion Operating Costs-Unknown l ::
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' CATEGORY B CATEGORY C .
k Personnel Resources (FTE)* Personnel Resources (FTE) -
, FY 85 - 1.0 FY 85 - 0.4
-1 FY 86 - O.4 i FY 86 - 3.0 FY 87 - 3.0 FY 87 - 0.4 !
FY 88 - 3.0 FY 88 - 0.4- j f.
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~'.T Efune .14, 1977 SECY-77-316 _
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For. COMMISSLQNER ACTION .
Robert G. Ryan, Directoi, Office of State Programs From: .
Thru: Lee V. Gossick, Executive Director for Operatio M ~
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Subject:
NRC'S ESSENTIAL UNINTERRUPTIBLE FUNCTIONS DURING A '
EE; NATIONAL EMERGENCY is' Wh isE;
Purpose:
To request the Comission's approval of a proposed ,
list of NRC's uninterruptible functions during a C2=..
national emergency resulting from a nuclear attack -
. M on the United States. . Mas!
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. Issue: .
As a Category "A" Federal agency, NRC 'is required to
- E.WM determine those functions which it must be prepared DEE
- to carry out to contribute to the survival of the -
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nation and the continuity of the government in a time T i
of extreme crisis.
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Discussion: ' A list of essential uninterruptible functions', needed 2MM
.- for the national level emergency planning required by !"=:
Executive Order 11490, has been identified by the . . IME
- NRC major program offices and the Office of the 'Execu- EliEE
- tive Legal Director. When approved, the functions -
y will provide a basis for further development of the aw HRC national level emergency preparedness program.
- Executive Order 11490, amended by Executive Orders [MD+P.7.~
- 11921 and 11953, states that national security is de- EEE pendent upon continuity of government at every level
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and requires identification of functions that would e have to be performed during a national emergency. ?!ai?.
- . Eiecutive Order 11953 specifically requires the Nuclear '!Mf Regulatory Commission to continue or resume controlling .M
. licensed nuclear material and facilities during such 4:3 an emergency. p Ms
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.- The list is also consistent with section 108 of the DE:
Atomic Energy Act of 1954, as amended, titled " War or' 4 .E."Z Q j.
. ; . National Emergency".
x Our proposed essential uninterruptible functions are gym
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also in accordance with guidance from the Federal Pre- .n g g.
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-, paredness Agency for a national emergency arising from an imminent threat of, or :the use of, enemy nuclearf tsai
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weapons against the United States. Emphasis has),een - S g[ .!(('.
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Contact:
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The Comissioners -
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given to those time-sensitive emergency functions - Xfl of the Nuclear Regulatory Comission that might Mi;t
. have to be performed during such a national emergency. mEE We expect that any planning and other preparation =...
to carry out these functions under such severe con- . RG ditions should permit NRC to continue these and other ::fE
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emergency functions under a variety _ of lesser national 5,;.l.3 emergency conditions. '
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It should b.e retcagnized that follow-on actions will be_ , ,,,,, jH necessary._such as assignment of responsibility for the "=
functions among NRC offices and the development of plans %"
and procedures, for carrying out these. functions.
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- Recomendation: That the Commission anorove the functions and direct- r.3
, continued work on thE NRC_ national.lsnLp.riparedness $-
, program to assure that these functions can be performed -
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during.a national emergency. . .gC.... 2 Coordination::
The' Offices of Standards Development, Nuclear Reactor i=s Regulation, . Nuclear Material Safety and Safeguards, mEI
. Nuclear Regulatory Research and Inspection-and Enforce- 7'
. ' ment have concurred with the statement of functions. "
The Office of Executive Legal Director has no legal eli
. .' objection. In addition, staff representatives of the . .
M Federal Preparedness Agency Energy'Research and - #=
Development Administration, Interior Department and - 5W Federal Power Comission have indicated the statement.
- is acceptable from the viewpoint of the emergency @M functions of their agencies. 5
-DISTRIBUTION: - - :.:='.'_'
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Comissioners - - -
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M Comission Staff Offices Exec. Dir. for Operations j [Mg -
rEf gm Robert G. Ryan, [1 rector Secretar9at ,
. ... . m Office of State Programs . -[fij
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Enclosure:
35 Proposed NRC Essential
~ Uniht' a rruptible Functions
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' hiote: Comissioners comments shou'1d be submitted directly to the Office
- iML of the Secretary by close of business Friday, June 24, 1977. jM5 Comission ' staff office coments, if any, sliould be submitted to the Office of @
the'Comissione'rs NLT June 21, with an information copy to the Office of the
- E==
Secretary'. If the paper is of such a natur.e that it requires additional time F~"i
. 'for analytiical review and coment, the Comissioners and the Secretariat should E,.y be apprised of when c5ments may be expected.- :7
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'.'.7 f{. . JUN l's 39y f5f
- 5. I NUCLEAR REGULATORY COMMISSION $5$
ESSENTIAL UNINTERRUPTIBLE FUNCTIONS Wi
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During a national emergency steming from a nuclear attack, or threat Mj;.,
of an imminent attack, the Nuclear Regulatory Commission will be pre- MIE
. pared to perform or administer the following essential uninterruptible 12;J functions . These functions are limited to the preattack, attack, and g!TM Eigi
- imediate postattack periods, and will be carried out only as authorize.d i by statutory or constitutional authority.
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- 1. Maintain increased surveillance of the operations of licensed 55s nuclear reactors and fuel cycle facilities to* assure minimum .alsE hazard to health and safety consistent with Natic,nal security- MQ
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needs, and as necessary and appropriate.
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- a. Order shutdown or curtailment o'f operations. ts=a
- b. Order continued operation.
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- c. Order entry to assume operational control of essential j{j;i;.
im a facilities. '
- d. Stop or curtail the use or transportation of special nuclear f3N material, or order recall of such material. -
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Assess the damage to licensed nuclear facilities to: ess
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- a. Identify useable facilities. -
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- b. Estimate the time required for restarting inopera'tive ,%3 r
facili ties. h!.2
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- c. Determine all hazardous conditions at these facilities . L
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- d. Assure that appropriate actions are taken to correct the ..N
- hazardous conditions and inform and instruct the public TK7 to minimize injury and damage to property. .
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- 3. Assess the threats to special nuclear materials, high-level . Ei5 l~'
radioactivity wastes, and nuclear facil.ities, and increase security measures as required to counter threats, thefts and sabotage. ,
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- 4. Order the recapture or order entry into a facility to recapture *- ,
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special nuclear material. :g M
. 5, Authorize revised safety criteria for licensed nuclear faciliti.es T and special nuclear material handling applicable to the changed M opera, ting and environmental conditions brought on by the emergency. g h
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- 6. Provide support to and maintain liaison with:
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- a. The office designated by the President to receive ieports 9555 on functions listed above, advice on the content of public .Ti:Ts
. instructions and information, and recommendations concerning jlMS the NRC role in achieving national objectives, p#iji#
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- b. Other Federal agencies which have related functions. MEiG m=
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- c. State agencies concerning emergency conditions and actions .
related to licensed nuclear facilities and materials. .
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To aid in ~ carrying out the NRC mI....ssion functions, the NRC staff will
.also be prepared to perfonn essential administrative and support tasks.. -l.i=
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c ,/ June 30,1977
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. MMn orFict oF THE 9,;;;.: 3..
SECRETAMY
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MEMORANDUM FOR: Lee V. Gossick, Executive ,
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- . - . Director.for. Operation P - - . ..
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FROM:
.- - . Samuel J. Chilk Secreta 43 .
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- :=. .=. . . 14 "SECY-77-316 - NRC'S ESSlHT i UNINTERRUPTIBLE E It
SUBJECT:
FUNCTIONS DURING A NATIONAL EMERGENCY l (COMMISSIONERACTIONITEM)
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f.Hi This is to advise you that the Comissioners have accept;ed'your rec-omendations concerning the subject item. - w==
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The Office of the Executive Director for Operations was informed of this
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. . action'by telephone on June.30,1977. . .
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cc: Comis'sioner Gilinsky . . _ E.T
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, Comissioner Kennedy :=~2 Acting General Counsel ;?:?== -
Director, Policy Evaluation
. Director *, State Programs . ==; 5
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