ML20148C111
| ML20148C111 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1980 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20148C069 | List: |
| References | |
| REF-10CFR9.7, TASK-CA, TASK-SE SECY-80-006, SECY-80-6, NUDOCS 8001250099 | |
| Download: ML20148C111 (22) | |
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l January 4, 1980 SECY-80-6 For: Commissioners .
cxecu:1ve tONEFL A .1ons From:
COMMISg1 rector Tor voeraCTION
Subject:
COCRDINATION OF NRC AND FEMA EFFORTS FOR IMPROVING EMERGENCY PREPAREDNESS AROUNO POWER REACTORS
- Purcose: To request approval of the " Memorandum of Understanding Between NRC and FEMA to Accomplish a Promet Improvement in Radiological Emergency Planning and Preparedness."
Discussion: Backcround - On December 7, 1979, the President, in response :: the recommendations of the Kemeny Commission on the accident at Three Mile Island, directed that FEMA assume lead responsibility for all off-site nuclear
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emergency planning and response. Memoranda of understanding are being developed between the NRC and FEMA to define the agency roles in the emergency preparedness area. A copy of the memorandum covering emergency planning activities, which has been agreed to by NRC and FEMA technical and legal staffs, is attached as Enclosure 1.
To assure that the area of emergency preparedness continues to receive high priority attention, the NRC is detailing 13 ceople, primarily from the Office of State Programs, to FEMA through June 1980. The detailed individuals and their duties while at FEMA are given in Enclosure 2.
NRC ano FEMA agree that an integrated assessment of emergency preparedness is necessary and will continue the efforts described in SECY-79-450 to obtain a promet improvement in emergency preparedness. These NRC efforts have been coordinated by an inter-office Steering Committee.
Escause of the new responsibilities of FEMA and the desire for a close working relationship between the agencies, an NRC/ FEMA S eering Committee will replace the existing NRC committee. A list of members and a charter for tnis co=i: tee are given in Enclosure 3. The Steering Commi tee .
wil' :::r: ins e effcrts :c : rom:tly upgrade emergen:y .
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- arecness a nuclear reactors inclucing the ceveio: ment cf f:in- GRC/:EMA criteria f:r a::ectability of emergency
- s:arseness plans anc :ne ca:a:ility to imoiement :nese
- lans. Res: rce in:a::s are ciscussed in Encicsure 4
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Ea,. 3. $ri n, 4-27351 NOTE: This paper is identical to advance copies which were hand-carr Commissioners or their offices on January 4,1980. It is c scheduled for discussion at a Commission meeting on Tuesgerm. #,-f=n@r
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Recommendation: That the Commission approve the substance of the attached !
" Memorandum of Understanding Between the NRC and FEMA to l Accomplish a Prompt Improvement in Radiological Emergency l Planning and Preparedness," for signature by Lee V. Gossick :
for dRC and Frank Camm for FEMA. j l
Coordi_ nation: The attached Memorandum of Understanding has been l coordinated with the Offices of State Programs, Nuclear ;
Reactor Regulation, Inspection and Enforcement, and Nuclear Materials Safety and Safeguards. ELD has no legal objection.
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Executive Director :
for Operations Enclosures
- 1. Memorandum of Understanding
- 2. Individuals Detailed and Outies
- 3. Steering Committee Charter 4 Resource Impacts Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, January 11, 1980.*
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT January 9,1980, 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 r.omments may be expected.
- SECY NOTE: ED0 has requested that this paper be given priority attention and would appreciate a decision on this paper at the Commission meeting on January 8.
DISTRIBUTION ,
Commissioners ~
Commission Staff Offices Exec Dir for Operations t ACRS l Secretariat 1
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ENCLOSURE 1 MEMORANDUM 0F UNDERSTANDING BETWEEN NRC AND FEMA TO ACCOMPLISH A PROMPT IMPROVEMENT IN RADIOLOGICAL EMERGENCY PLANNING AND PREPAREDNESS I. BACKGROUND AND PURPOSE This memorandum of understanding establishes a framework of cooperation between the Federal Emergency Management Agency (FEMA) anu the Nuclear Regulatory Commission (NRC) in radiological emergency response planning matters, so that their mutual efforts will be directed toward more effective plans and related preparedness measures at and in the vicinity of nuclear reactors, fuel cycle facilities wnich are subject to 10 CFR Part 50 Appendix E, and certain other fuel cycle and materials licensees which have potential for significant accidental off-site radiological releases. The memorandum is responsive to the President's decision of December 7,1979, that FEMA will take the lead in off-site planning and response, his request that NRC assist FEMA in carrying out this role and the NRC's continuing statutory responsibility for the I radiological health and safety of the public.
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Separate memoranda will be negotiated covering NRC/ FEMA cooperation and responsibilities in response to an actual emergency and Public Information activities. In addition, an agreement has already been reached between ,
the NRC and FEMA on September 11, 1979, that chairmanship of the Federal l Interagency Central Coordinating Committee should be transferred from l NRC to FEMA. This agreement was transmitted to other Federal agencies by a joint letter from the Chairman of NRC and the Director of FEMA.
The NRC and FEMA also agreed in principle on September 11,1979 to the l idea of joint participation in the review, assessment and concurrence with regard to State and local emergency response plans. That agreement will be implemented by FEMA coordinating all Federal planning and by FEMA's taking the lead for developing a program for assessing State and local emergency response plans in all elements of offsite radiological emergency planning, and for reviewing and making findings as to the adequacy and caoability of imolementing State and local plans, and to make those findings available to NRC. The NRC shall retain responsibility for concurrence in State and local plans for ourpose of making determinations on the overall state of emergency preparedness for issuance of -
licenses or shutdown of coerating reactors. The NRC oroposal to -
require concurrence in State and local emergency resoonse olans is described in the orocosed emergency olanning rule (M FR 75157, December 19, 1979). This arrangement will make the FEMA staff rescorsible for evaluating tne acetuacy of State and local plans anc for assuring that tne plans are ace:uately imolemented on a continuing basis, and will
- nerefore suostantially avoid duolicative effor:s by NRC s:aff.
ENCLDSURE 1 i
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II. AUTHORITIES AND RESPONS!BILITIES )
FEMA - Executive Order 12148 charges the Director, FEMA, with establishing ;
policy for and coordinating all civil emergency planning and assistanc.
functions for Executive agencies (Section 2-101). It also provides i that "The Director shall represent the President in working with State and local governments and private sector to stimulate vigorous partici-pation in civil emergency preparedness mitigation, response, and recovery programs." (Section 2-104).
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On December 7,1979, the president, in response to the recommendations of the Kemeny Commission on the accident at Three Mile Island, directed ,
that FEMA assume lead responsibility for all off-site nuclear emergency !
planning and response.
Specifically, the FEMA responsibilities with respect to emergency preparedness as they relate to NRC are:
- 1. Take the lead in off-site emergency planning and review and assess State and local emergency plans for adequacy.
- 2. To complete by June 1980 the review of State and local emergency plans in those States with operating reactors.
- 3. To complete, as soon as possible, the review of State and local emergency plans in those States with plants scheduled for operation in the near future.
4 To make findings as to whether State and local emergency plans are adequate and capable of implementation (e.g. , adequacy and maintenance of procedures, training, resources, staffing levels and qualifications and equipment adequacy).
- 5. Assume responsibility for emergency preparedness training of State and local officials.
6.. Develop and issue an updated series of interagency assignments which would delineate respective agency capabilities and responsi-
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bilities and define procedures for coordination and direction '
for emergency planning and response.
NRC - The Atomic Energy Act of 1954, as amended, recuires that the NRC ,
grant licenses only if the health and safety of the puolic is adecuately protected. While the Atcmic Energy Act does not specifically require emergency clans and related preparedness measures the NRC has recuired consideratien of overall emergency creoaredness as a cart of the licensing process.
10 CFR 50.3ac .nc ;cpendix E to 10 CFR Part 50 include recuirements for the licensee emergency olans. In a :ederal Register Notice datec December 2d,1975, entitled "Radiclecical Inciden: Emergency Resconse Planning: Fixed Facilities and Trans:Orta-ion" (40 FR 59494), the Federal precaredness Agency, a predecessor cf FEMA, outlined responsibilities
3 of various Federal agencies in providing assistance to State and local governments in their radiological emergency response planning. Both FEMA and NRC recognize that these responsibilities are undergoing reevaluation and that this memorandum of understanding will reouire reissuance of that Federal Register Notice.
Specifically, the NRC responsibilities for emergency preparedness are:
- 1. To assess licensee emergency plans for adequacy.
- 2. To verify that licensee emergency plans are adequately implemented (e.g., adequacy and maintenance of procedures, training, resources, staffing levels and qualifications and equipment adequacy).
- 3. To review the FEMA findings on the adequacy and capability of implementation of State and local plans and to concur in those plans where appropriate.
4 To make decisions with regard to overall state of emergency preparedness (i.e. , integration of on-site and off-site emergency preoaredness) and issuance of an operating license or shut down of operating reactors.
III. AREAS OF COOPERATION :
A. NRC Licensino Reviews
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1 FEMA will provide support for NRC reactor, fuel facility and material '
licensing reviews, as requested, with regard to the assessment of the adequacy of State and local respense plans for accidental radiological releases. This will include timely submittal of a letter evaluation suitable for inclusion in NRC safety evaluation reports.
FEMA will provide an independent assessment of evacuation times around all nuclear power plant sites with ooerating reactors. l FEMA will also provide an independent assessment of evacuation times i as part of its support of Operating License reviews. Preliminary estimates, identifying key planning problems will be supplied as cart of FEMA's support of Construction Permit reviews. Evacuation time estimates for plants under construction will be supplied by FEMA as resources permit with criority given to high population density sites.
- Substantially pricr to the time that a FEMA evaluation is recuired, with regard to fuel facility and material license review, NRC will sucoly FEMA wi:n a listing of all fuel and material licensees, identify : nose with octential for significant accidental of'-site aciolcgical releases and for these NRC will submit to FE"A :ne emergency plans as they are c0moleted.
- EMA routine succor: will include oroviding assessments of State anc local plans related to reac:cr Construction :ermi anc 00erating
_icense reviews and centinuing assessrent c# State and local clans
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4 l during the facility lifetime. To succort its findings and I assessments, FEMA will make expert witnesses available before the l' NRC Advisory Committee on Reactor Safeguards, NRC hearing boards and adPinistrative law judges, any court actions, and curing any related discovery proceedings. Nothing in this document shall be !
construed in any way to diminish NRC's responsibility for protectinc
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the radiological health and safety of the oublic.
1 B. FEMA Review of State and Local Plans .
NRC will assist in the development and review of State and local i plans through its membership on the Regional Advisory Committees.
FEMA will chair the Regional Advisory Committees, j C. Evaluation of Exercises FEMA and NRC will cooperate in determining exercise requirements for j joint licensee, State, local and Federal exercises and will jointly '
observe and evaluate such exercises. NRC and FEMA will also jointly agree uoon the exercise scenarios to be used in such exercises.
D. Emercency Precaredness Guidance NRC has lead responsibility for the development of emergency preparedness guidance for licensees. FEMA has lead resconsibility for the development of emergency preparedness guidance for State and local agencies.
NRC and FEMA recognize the need for an integrated assessment of the degree of emergency preparedness guidance for State and local agencies.
NRC and FEMA recognize the need for an integrated assessment of the degree of emergency preoaredness by NRC licensees and State and local governments. NRC and FEMA will, therefore, provide coportunity for the other agency to review and comment on emergency preparedness guidance prior to adoption as formal agency guidance.
E. Training of State and Local Officials FEMA will assume lead resconsibility for emergency crecaredness
! training of State anc local officials. "RC will cocperate in l assuring existing NRC scenscred training crograms are i cacted to the minimum ex:ent during -he ceriod January to June,1950. NRC will in':rm CMB 4 writing of its intention to pass res:onsibili*y to FEW # r - en: training program for State and $0 cal c#ficials duri; IV aC will su:Cor: IE?AA ditn recarO to ths *rans#er of
- Fainir; bd?d'. :o FE?sA in years af*ar IV $3EC.
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F. Oncoina NRC Procrams Ongoing NRC programs that are related to State and local emergency planning and preparedness that are suoported by FY S0 funds, will continue without interruotion unless modifications are recommended to the NRC by the FEMA /NRC Steering Committee. (See IV.a below).
i G. Public Information Proarams I l
FEMA will take the lead in developing public information programs.
NRC will- assist FEMA by reviewing for accuracy educational materials concerning radiation and its hazards and information regarding i appropriate actions to be taken by the general public in the event j of an accident involving radioactive materials. A separate i memorandum of understanding will be negotiated for Public Information ;
activities. '
1 IV. NEAR-TERM COOPERATIVE MEASURES In order to achieve a prompt improvement in the state of emergency preparedness at and around nuclear power facilities, and because of the need for an integrated assessment of the degree of preparedness, FEMA and NRC recognize the need for especially close working relationship over the next six months. To this end, FEMA and NRC agree to the following mode of operation through June of 1980.
- 1. NRC staff will proceed with the evaluation team review of emergency preparedness at each power reactor and will publish Safety Evaluations on each plant.
- 2. FEMA will provide members to participate with NRC staff on the evaluation teams. The FEMA team members will participate in the preparation of assessments of the plans supplied to NRC. Team members will perform as described in NRC Steering Committee Memorandum dated November 23, 1979, subject: Guidance on Team Reviews.
- 3. FEMA will provide an interim evaluation of the adecuacy of State and local preparedness associated with each power reactor suitable for attachment to the NRC Safety Evaluation. FEMA will report to NRC on the schedules of State and local governments to upgrade their plans and will prepare a final evaluation when the uegraded -plans are completed. .
- a. The NRC interoffice Steering Committee on Emergency 3recaredness will be ex:anded to an NRC/ FEMA Steering Cormittee consisting of soual numoer of members to represent each agency with one vote Der agency. Where the Steering Committee cannot agree en the resoluti:n of an issue, the issue will :e referred to NRC and FEMA management. The NRC members will have lead resconsibility
, for licenses cretaredness and the fey.A mem:ers will nave lead
- responsibility for State and local pre
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Committee will oversee the evaluation team review activities and develop upgraded acceptance criteria for licensee, State and i local emergency preparedness. NRC and FEMA will then consider and adopt criteria, as appropriate, in their respective jurisdictions.
- 5. To permit the orderly transfer from NRC to FEMA of the lead responsibility for evaluating State and local plans and preparedness, the NRC staff who had been performing this function will be assigned through June 1980 to work directly with FEMA. Those incidental activities, such as responding to correspondence that would l normally be handled by the NRC's State Progrcms Emergency Preparedness :
Staff, will continue to be handled by these personnel while assigned to FEMA. See Enclosure 2 for listing of detailed personnel and their functions. ,
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- 6. NRC will ensure continuation of NRC computer and automatic data ;
processing support (including TERRA record keeping system support) to the NRC staff personnel detailed to FEMA.
- 7. NRC Program Support funds specifically identified in the FY 80 budget (including supplemental), for the emergency preparedness function of NRC's Office of State Programs, and NRC FY 80 travel funds in the amount of $25,000 will be maintained as is, and continue to be managed by the NRC staff detailed to FEMA, to ensure that ongoing programs affecting State and local government emergency preparedness are not interrupted.
V. WORKING ARRANGEMENTS A. The normal point of contact for implementation of the points in this agreement will be the NRC/ FEMA Steering Committee.
S. The Steering Committee will establish the day to day procedures for carrying out the arrangements of this memorandum.
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VI. TERM OF AGREEMENT A. This agreement shall be effective as of and, except for the near-term cooperative measures wnien continue in effect through June, 1980, this agreement shall continue in effect unless terminated by either party upon 120 days' notice in writing.
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B. Amendments or modifications to this Agreement may be made upon written agreement by both parties to the Agreement. .
Approved for the U. S. Nuclear Approved for the U. S. Federal Regulatory Commission Emergency Management Agency By: By:
Lee V. Gossick Frank Camm, Associate Director Executive Director for Plans and Preparedness for Operations t
ENCLOSURE 2 DUTIES OF NRC PERSONNEL DETAILED TO FEMA THROUGH JUNE 1930 I. List of NRC Personnel Assigned to FEMA through June 1980 R. Ryan H. Collins ,'
S. Schwartz R. Defayette H. Gaut R. Jaske M. Sanders S. Salomon R. Clevenger R. Green R. Van Niel S. Welch (administrative)
P. Weldon (clerical)
II. Descriotion of Duties While Reassigned to FEMA A. Participate in preparing an interim evaluation of the adequacy of _
State and local preparedness associated with each power reactor suitable for attachment to the NRC evaluation team Safety Evaluation. This will include determination on the adequacy of State and local schedules to upgrade State and local plans and in preparing final evaluations on completion of the upgraded emergency planning elements.
B. Participate with FEMA members and with other NRC staff on the evaluation teams so that the assessment will pr ceed on a coordinated basis and, along with FEMA personnel, to fulfill the roles formerly defined for the evaluation team members from the NRC Office of State Programs.
C. Review and assess State and 10 cal plans. This will assure censistency between evaluation team reviews ani Regional Advisory Committee concurrence effor:s.
O, Partici:a s as assigned with ::Mer ~EMA re: essn a-ives on -he NRC/ FEMA .
5:eering C:m.-i::ee. Tne 5:ecr'9: : mmi: se .all :ccrdinate the svaluation team PEV15., a0 i .'i-ies an0 0- er 'iEC/REMA a:~ivi!iss and cevel 0 U graded 3cce::anCE C*i!sris fCr licensts, $! ate in0 local emergency prs:Brecness
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G. Continue to m0nitor ongoing FY-80 NRC funded programs related to State and 1ccal government emergency planning and precarecness.
III. Outy Station While seassigned :
FEMA offices in the GSA Building at 18th and F Streets, N.W.,
Washington, D. C. 20472 IV. Provisions Regarding Detail .
An employee detailed to the U.S. Federal Emergency Management Agency (FEMA) will be returned to his/her cermanent position when the detail is terminated unless the permanent position is impacted by a reorganization or restructure of functions. Should a reorganization or restructure occur, the indivicual will be returned to a position of the same grade and in an occupational series for which he/she is qualified. A letter stating this will be sent to each individual detailed.
An employee detailed to FEMA in excess of 30 calendar days will receive an NRC Form 181 which will documen: the detail. A short description of the duties to wnicn he/she is assigned should be entered on, or appended to, the NRC Form 181 to assure proper evaluation of tne employee's work performance when detailed to FEMA. Such documentation will be filed in the employee's Official Personnel Folder (OPF).
At the conclusion of an employee's detail, and provided that the length of the detail is more than four months, an appropriate FEMA or NRC management official will prepare a Personnel Performance Appraisal (NRC Form 625A). Tne a:craiser will evaluate the empicyee's performance at FEMA and this evaluation will be considered by the employee's permanent supervisor when :na; su;ervisor prepares the annual performance appraisal.
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i ENCLOSURE 3 i
l FEMA /NRC STEERING COMMITTEE l l
1 Pur:ose Coordinate efforts to promptly upgrade emergency preparedness for nuclear l power reactors as described in NRC/SECY-79-450 and the President's statement l of December 7, 1979. Coordinate consistent criteria for licensee, State. !
and local emergency preparedness. -
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Co-Chairmen:
Brian Grimes NRC R. Ryan FEMA Members:
S. Wengravit: FEMA J. Thomas FEMA l H. Collins FEMA (detailed from NRC) l J. Snie:ek IE/NRC l J. Miller NRR/NRC -
K. Perkins OED0/NRC Duration The Steering Committee will provide coordination for these activities until the initial evaluatier. :eam reviews are complete (about June 1980).
Coordination When items involving responsibilities of other NRC or FEMA offices are discussed, the affected office will be contacted as a:orcpriate.
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ENCLOSURE a RESOURCE IMPACTS A. Evaluation of Exercises The MOU specifically commits the NRC to jointly observe and evaluate exercises with FEMA. An exercise is required annually for eacn. site.
The NRC portion of the evaluation will be focused on the licensees' actions during the exercise. To accomplish this function, it is projected tnat fifteen man-years of effort per year will be recuired. During the exercise, NRC personnel will be stationed at locations to evaluate the licensee activities (Control Room, Technical Support Center, Field Monitoring activities, Near-site Emergency Operations Center). In addition, one NRC staff member will be coordinatine the on-site, off-site interface evaluation effort with FEr%.
It is expected that a five-man NRC team can perform an evaluation every three weeks, thus, fifteen professional staff members will be required for this effort to observe and evaluate about 50 exercises per year.
At this time the present NRC level of effort for this function is a oroxinately three man-years / year of professional staff effort.
It shouM be noted that the MOU does not drive the NRC resource require-ments upward but rather the need for the NRC to adecuately perform its licensee exercise evaluation function, dictates the resource requirements.
E. FEMA Review of State and Local Plans The MOU notes that the Regional Advisory Committees will be responsible for development and review of State and local plans. At the present time, the NRC is devoting ao:roximately four man-years of effort / year (IE-3, SP-1) o the PAC field effort. It is exce: ed that the increased role of tne Regional Advisory Cc=ittees will re:uire three to four acditional man-years per year of NRC effort.
C. NRC Concurrence Role and Coordination with FEMA We anticipate at least two man-years per year of effor- to be recuired o coordinate the FEtG reviews as tney relate :: the licensing process.
The MOU aisc ass 1;ns the NRC continued responsibili y for concurrinc in 5 a e and local cians indecencent of the licensing crecess. This ar-angemen v.as insis ed on y FE".2, wnich wisnes t: enly review state ar 10 cal Clar.s and Or: Vide i.s #inci".gs t: NRC. he ex en. *.: ani n .
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D. Resource Summary The above rescurces are the staff's estimate of those recuired to adequately perform the functions described. 1 Because staff for these efforts was not allocated in the FY-80 supplement or FY-81 budget, minimal manpower will be allocated to these areas until additional staff becomes available. The FEMA coordination and administrative concurrence workload could be handled by individuals returning frem the FEMA detail assignment.
The coordinat. ion function will be absorbed in tne near-term by .
I the NRC evaluation teams and ne NRC contingent of the NRC/ FEMA Steering Committee. Except for near.-term operating license i reviews, the impact for observing exercises can be deferred until l about the beginning of FY-81. We intend to inform FEMA that we !
cannot augment our Regional Advisory Committee participation until l FY-81. I 1
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i NRC EMERGENCY PREPAREDNESS ORGANIZATIONAL OPTIONS BACKGROUQ e TASK PvRCE ON EFE ~2Y PLANNING (SECY 79-499) e SECf lim (SEPTEMBER 14,1979)
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FETWS ROLE (J2/7/79 MilTE Il00SE FACT SHEET & 1^ 2d^ 79 FBWNRC Iffd) i ENERGEfEY PREPAREDNESS FUNCTI0fl1 e PLAWIfE e llCENSING e IMPLEMENTING #4D IESTING '
e RESPONDING TO AN ACTUAL ENERGENCY l QLGANIZATIONAL OPTIOfLS.
e OPTIQ11: (STAluS Quo) Att N LEVEL COORDINATOR e OPTIQ12: CREATE (OR AUGFBid AN M LEVEL STAFF 0FFICE e OPTIQ13: CONSOLIDATEINLICENSING0FFICESANDIE e OPTIU'l4: C0f4SOLIDATE IN A SINGLE PROGRAM OFFICE EVALUATION FACTORS e REMOVAL OF FRATENTATION e UNION OF PLANNING AND RESPONSE FUNCTIONS e USEOFLINEEXPERTISEANDAuT10RITY
2 OPTION 1: (STARS 000) #1 EDO-LE\EL COORDINATOR DESCRIPTI0ff COORDINATOR - MONITORS Al.L NRC ACTIVITIES; REPRESENTS NRC IN INTERAGEfCY ACTIVITIES N O COORDINATESWITHIBM; SP -
REVIEWS IB%'S EVALUATION OF STAWlLOCAL PUNS; PARTICIPATES IN AND EVALUATES,WITHIBM, EXERCISES NRR & itES - REVIEW AND APPROVE LICENSEE PLANS IE - INSPECTS FOR COMPLIANCE WITH LICENSEE PLANS; PROVIDES FIELD RESPONSE TO ACCIDENT; OPERATES INCIDENT RESPONSE CENTER SD - WRITES N O KEEPS CURRENT APPROPRIATE REGULATIONS, GUIDES, AND STANDARDS EMT - MANAGES RESPONSE TO ACTUAL ACCIDENT -
NNNTfKES NG DISNNNMES e PROVIDES COORDINATION OVERLAY NO CENTRALIZES TRACKING e PROVIDES A SINGLE POINT OF CONTACT FOR EXTERNAL ACTIVITIES e PERPETUATES FRAGMENTATION e FAILS TO TIE PLMf4ING WITH RESPONSE e PROVIDES NO SUPERVISION OVER DAY-TO-DAY OPERATIONS 9
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3 OPTIW 2: AN ED0-lEEL STAFF 0FFIE DESCRIPfl0N SP/NEW W OFFICE -
LEADS ALL IEC EMERGENCY PREPAREDESS FUNCTIONS EXCEPT INSPECTION AND RESPONSE ACTIONS; REVIEWS ID W S EVALUATION OF STATE / LOCAL PLANS IE -
INSPECTS FOR COMPLIANCE WI m LICENSEE PLANSJ PARTICIPATES IN AND EVALUATES, WITH;fD%, EXERCISESJ PROVIDES FIELD RESPONSE AND RUNS INCIDENT RESPONSE CENTER ,
SD -
WRITES AND KEEPS CURRENT APPROPRIATE REGULATIONS, GUIDES, AND STANDARDS Ofl' - liANAGES RESPONSE TO ACTUAL ACCIDENT ADVNiTAGES AND DISNNANTAES e REDUCES FRAGE NTATION (SON WHAT) e CREATES OPERATIONAL RESPONSIBILITY WImotJT LINE EXPERTISE, FIELD CAPABILITY, AND AUm0RITY OVER ElmER e ADDS A STAFF OFFICE TO T E LICENSING PROCESS e FAILS TO TIE PLANNING Wim RESPONSE
4 OPTION 3: CONSOLIINE IN UEiEING OFFIES NO IE DESGIPTION NRR & E - 1.EADS ALL LICENSEE Ato IRC RESPONSE PLANNING Ato LICENSING; NRR REVIEWS E EVALUATIONS OF STATE /WCAL PLANS '
- LEADS POST NRC RESPONSE FUNCTIONSJ INSPECTS FOR COMPLIANCE WITH LICENSEE PLANSJ PARTICIPATES IN AND EVALUATES, WITH E, EXERCISES SD
- WRITES AND KEEPS CURRENT APPROPRIATE REGtLATIONS, GUIDES, Af0 STANDARDS
@f - IMGES RESPONSE TO ACTUAL ACCIDENT AINANTAGES NO DISAINNffAES e REDUCES FRAGE NTATION (SOMENIAT) e PLACES PRIE RESPONSIBILITY IN LINE OFFICES HAVING AllDIORITY, EXPERTISE, AND FIELD CAPABILITY e
RECOGNIZES EMERGENCY PREPAREDNESS AS AN OPERATIONAL PROGRAM IN LIFE OFFICES e SEPARATES ASPECTS OF PLAtElltG FROM RESPONSE db b
5 TIIDI 4: CONSOLIIMIE IN A SINGLE PROGR#i 0FFIE ESCRIPTION IE -
PROVIDES LEAD FOR ALL NRC ENERGENCY PREPAREDNESS ACTIVITIES INCLUDING APPROVAL OF LICENSEE PLANS AS INPUT TO ME AND M6S; REVIEWS f8E'S EVALLMTION OF STATE / LOCAL PLANS SD -
WRITES AND KEEPS CURRENT APPROPRIATE REGULATIONS, GUIDES, AND STANDARDS DIf - bMGES RESPONSE TO ACTijAL ACCIDENT HEWTAGES AND DISADVMTAGES e
VIRTUALLY ELIMINATES fRAGiENTATION 3 CenSin3c.00)d alih0U3h become Fragmteted .
e PLACES NRC RESPONSIBILITY IN A LINE OFFICE WI m AUT10RITY, EXPERTISE Af0 FIE W CAPABILITY e
RECOGNIZES EERGENCY PREPAREDNESS AS AN OPERATIONAL PROGRAM IN A SINGLE LINE OFFIC e TIES NRC PLANNING WIT 11 RESPONSE e POTS INSPECTION OFFICE IN ' HIE LICENSING PROCESS
6 0FFIE PREFERNCES_
EDO - tbvE TO OPTIm 3 OlRR, tES, AND IE) FOR OfE YEAR, DEN EVALUATE WE ADVANTAGES OF MOVING TD OPTION l ! (IE)
- DESIGNATE ONE LEAD OFFI& BUT LEAVE SOK FWCTIONS IN OTHER OFFICES t.S - EENTRALIZE FUNCTIONS IN ONE OR MORE OFFICES IE - AooeT OPTION it (IE) OVER DE LONG TERM D) - ADOPT OPTION 3 (NRR, PES, AND IE); RETAIN SD SEPARATE FOR STANDARDS WRITING SP
- ASSIGN ENTIRE STATE / LOCAL PROGRAM TO FE?M OR ADOPT OPTION 1 (STATUS 000-ED0 E0mDIfMTDR)
E (0&P) - ADOPT OeTION 2 (NLEVEL STAFF 0FFICE); AS AN ALTERNATIVE, INITIALLY CONINE ALL LICENSING IN NRR AND PUT OWER FUNCTIONS IN IE, DEN ADOPT OPTION l l (IE) fFA - AD0eT OPTION 11 (IE); DECIDE S0ON; ComDINATE MANSFER TO FEIE, SYNCHRONIZE I
TRANSITION TO OPTION l Him COMPETING UPGRADE EFFORTS AND RESOLVE ORGANIZATI0fML AND PEOPLE ISSUES IN 1980
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TABLE 1: Summary of Office Responsibilities for Long-Term Organizational Options for Emergency Preparedness (First of fice shown has lead)
Option 1* Option 2 Option 3 Option 4 PLANNING
- Develop guidance / rules for NRR & NMSS, SD SP/New EDO Office, NRR & NMSS, SD IE, SD licensee plans NRR & NMSS, SD
- Develop guidance for State FEMA, SP, SD FEMA, SP/New EDO FEMA, NRR & NMSS, FEMA, IE, SD and local plans Office, SD SD
- Develop NRC response plan IE, SP SP/New EDO Office, IE NRR & NMSS, IE IE LICENSING
- Review & approve licensee plans NRR & NMSS SP/New EDO Office ** NRR & NHSS IE** i
. - Review & assess State and local FEMA, SP FEMA, SP/New EDO FEMA, NRR & NMSS FEMA, IE plans O f fice '
t IMPLEMENTING & TESTING t
- Inspect licensees against plans IE IE IE IE
- Prepare for, participate in, and SP, IE, FEMA SP/ flew EDO Office, IE, NRR & NHSS, IE, FEMA evaluate exercises IE, FEMA FEMA
- Provide field assistance & training FEMA, Sp FEMA, SP/NEW EDO FEMA, IE FEMA, IE to State and local authorities Office RESPONiUNG TO EMERGENCY
- Prompt field response IE IE IE IE
- Run Incident Response Center (IRC) IE IE IE IE
- Carry out NRC plans and monitor EMT EMT EMT EMT licensee, State and local, and Federal actions (involves information flow, evaluation, assistance and direc-tion where appropriate).
- Role of EDO-Coordinator would be to coordinate and monitor all the above activities.
EMT = Executive Management Team.
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RESPONSIBILITY "Along with Ownership Comes the Need for Acceptance of Full Responsibility for the Work. It is now Common in Government to Deal with Problems in a Collective .
Way. For Example, a Program will be Divided into Component Parts or into Sub-programs, but with no one Responsible for the Entire Effort. Another Approach is to Have a Committee Run the Program in Some Pseudo-Democratic Form, or to Establish More and More Levels of Managers to Theoretically Give Better Control. All of These are but Different Forms of Shared Responsibility, and Shared Responsibility Means that no one is Responsible. Unless the One Person Truly Responsible can be identified when Something Goes Wrong, then no one has been Really Responsible."
- Rickover, Excerpt from " Management in Government," p.17.
Management (OPM Magazine), September 1979 1
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