**NRC INSPECTION MANUAL** NSIR/DPR/EPD

MANUAL CHAPTER 1601

COMMUNICATION AND COORDINATION PROTOCOL FOR DETERMINING THE STATUS OF
OFFSITE EMERGENCY PREPAREDNESS FOLLOWING A NATURAL DISASTER, MALEVOLENT
ACT, OR EXTENDED PLANT SHUTDOWN

1601-01 PURPOSE

To provide procedures and guidelines for determining the status of
offsite emergency preparedness (EP), and its impact on restart
activities, following an extended plant shutdown (or shutdown caused by
electric grid blackouts), malevolent act, or natural disaster (e.g.,
hurricane, tornado, flood, storm, earthquake) in the vicinity of power
reactors.

1601-02 OBJECTIVES

02.01 Identify Nuclear Regulatory Commission (NRC) groups or individuals
responsible for monitoring licensee restart activities.

02.02 Identify Department of Homeland Security - Federal Emergency
Management Agency (DHS-FEMA) contacts who can provide information on
offsite conditions.

02.03 Establish communication links for coordinating information between
the various organizations involved in plant restart, offsite recovery,
or both.

02.04 Provide a checklist to facilitate tracking of restart assessment
activities.

1601-03 APPLICABILITY

03.01 This manual chapter is used when a natural disaster or malevolent
act has occurred at or in the vicinity of a power reactor and is of such
severity that plant damage is minimal, but damage or changes to the
offsite emergency response infrastructure may be substantial or are in
question. Changes to the emergency response infrastructure may include
physical changes as well as artificial changes (such as the erection of
a "tent city"). In instances where substantial damage to the plant has
occurred, the plant restart activities should be coordinated using NRC
Inspection Manual Chapter 0350, \"Oversight of Operating Reactor
Facilities in an Extended Shutdown as a Result of Significant
Performance Problems.\"

03.02 This manual chapter should be implemented consistent with the
agreements of the Memorandum of Understanding between the NRC and
DHS-FEMA. In this regard, if a disaster damages or changes the area
around a licensed operating nuclear power plant to an extent that raises
serious questions about the continued adequacy of offsite emergency
preparedness, the identifying agency (DHS-FEMA/NRC) will inform the
other promptly. When evaluating implementation of this manual chapter,
among other things, consider whether alternative means can adequately
compensate for the offsite function(s) impacted. If the status of
offsite emergency preparedness is inadequate, it is incumbent on the
State and applicable local governments to develop appropriate
compensatory measures to ensure public health and safety.

03.03 During an extended plant shutdown, or a shutdown due to an
electric grid blackout, the NRC may need to petition DHS-FEMA to issue a
statement of Reasonable Assurance, certifying that the applicable State
and local government emergency plans can and will be implemented in a
manner to protect public health and safety in the event of a
radiological incident at the specific plant emerging from an extended
shutdown.

03.04 This manual chapter only applies when a reactor plant is shutdown
and an offsite review of emergency preparedness is required. If the
reactor plant is operating and there is damage to the offsite emergency
preparedness infrastructure or any portion of offsite emergency
preparedness is degraded, DHS-FEMA management, in consultation with
State and applicable local governments and the NRC, will decide on the
necessary actions to ensure adequate protection of public health and
safety. This manual chapter may be used as a guide to support decision
making regarding offsite preparedness under these conditions.

03.05 This manual chapter applies only to fixed nuclear power reactors.
It does not apply to fuel cycle facilities.

1601-04 BACKGROUND

The NRC has primary responsibility for ensuring the adequacy of
emergency preparedness for commercial nuclear power plants. NRC defers
to DHS-FEMA to assess the status of offsite emergency preparedness, via
its Disaster Initiated Review, and to issue a Statement of Reasonable
Assurance that the State(s) and local governments emergency plans can
and will be implemented in a manner to ensure public health and safety
in the event of an accident at an NRC licensed reactor facility. The
Memorandum of Understanding between DHS-FEMA and the NRC describes the
responsibilities and the authorities of the two agencies. All agency
decisions involving DHS-FEMA and NRC must take place between
Headquarters offices. It is important to note that DHS-FEMA Headquarters
management is the [sole]{.underline} authority for generating a
Statement of Reasonable Assurance. For this reason, direct communication
and coordination between the two agencies is essential when events with
the potential to impact the onsite or offsite emergency response
infrastructure occur. These events include, but are not limited to,
hurricanes, tornadoes, floods, storms, fires, earthquakes, malevolent
acts, and extended plant shutdowns (electric grid issues).

1601-05 RESPONSIBILITIES AND AUTHORITIES

The following individuals shall perform the listed actions. It is not
necessary for communications to be restricted to those NRC personnel
listed in this manual chapter. Reporting information to other NRC
personnel should not delay the expected reporting in this manual
chapter.

05.01 [Chief, Inspection and Communications Section (EPD-A Section
Chief), Office of]{.underline} [Nuclear Security and Incident Response
(NSIR), Division of Preparedness and]{.underline} [Response (DPR),
Emergency Preparedness Directorate (EPD)]{.underline}

a\. Act as the lead technical point of contact for the activities of
this manual chapter and ensure completion of all activities using the
checklist in Appendix 1.

[]{.mark}

b\. Participate as the lead technical contact during the restart
counterpart conference call (RCCC, as defined in section 06.02)

c\. Ensure that the Office of Nuclear Reactor Regulation (NRR) Project
Manager is informed of any new developments.

d\. Communicate important developments in the restart process or
continued plant operation, and the Disaster Initiated Review to the
following individuals (who do not participate in the RCCC):

1\. Director of NSIR/DPR;

> 2\. Chief of DHS-FEMA\'s Radiological Emergency Preparedness (REP)
> Section;

3\. Director of NSIR/DPR/EPD;

> 4\. Director of the Incident Response Directorate (IRD), NSIR/DPR.

[]{.mark}

e\. Inform the Chief of DHS-FEMA's REP Section of the licensee\'s
estimated restart date and time, including heatup if the reactor is in
cold shutdown.

[]{.mark}

f\. Obtain from the Chief of DHS-FEMA\'s REP Section, as soon as it is
available, the results of DHS-FEMA\'s Disaster Initiated Review
regarding the status of offsite emergency preparedness and whether it is
adequate to support plant restart. As soon as this information is
received, provide it to the NRR Reactor Projects Directors, the NRR
Project Managers, regional DRS EP Branch Chiefs, and Director of EPD,
NSIR.

[]{.mark}

g\. If it appears that DHS-FEMA's Disaster Initiated Review will not be
complete before the time of the licensee\'s restart schedule, or if the
information received from DHS-FEMA is that the state of offsite
emergency preparedness is [not]{.underline} adequate to support plant
restart on the schedule proposed by the licensee, do the following:

[]{.mark}

1\. Obtain a thorough understanding of the significance of the EP issues
in question.

\(a\) State and local governments, in coordination with DHS-FEMA, will
decide what compensatory measures, if any, are (or could be) available
to offset the EP program elements that are not fully functional; and

\(b\) Obtain the projected date on which the emergency planning zone
(EPZ) infrastructure will be fully functional or when adequate
compensatory measures will be in place.

2\. Discuss these issues with the NRR Executive Team, NSIR senior
management, and senior regional management to determine follow-up
actions with the licensee, DHS-FEMA, and others, as appropriate.

h\. If it appears that communications problems between the various
offsite response organizations are preventing the completion of a timely
assessment regarding the status of offsite emergency preparedness, offer
the services of NRC telecommunications resources to the parties so that
an effective conference call to exchange information can be held.
Examples of resources to consider in accomplishing this conference
include the following:

1\. NRC Operations Center bridge network

2\. Regional Office bridge network

3\. Resident inspector and regional satellite telephone equipment

05.02 [NRR Project Directors for the Affected Sites]{.underline}

[]{.mark}

a\. Participate in the RCCC.

[]{.mark}

b\. Communicate important developments in the restart process and the
Disaster Initiated Review with the NRR Executive Team.

05.03 [NRR Project Managers for the Affected Sites]{.underline}

[]{.mark}

a\. Organize and facilitate the RCCC (as defined in section 06.02).

b\. Keep the EPD-A Section Chief informed of any new developments.

c\. Obtain from the EPD-A Section Chief, as soon as it is available, the
results of DHS-FEMA\'s Disaster Initiated Review and whether it is
adequate to support plant restart or continued operation. As soon as
this information is received, provide it to the NRR Executive Team and
regional DRP Branch Chief for the affected site.

[]{.mark}

05.04 [Regional State Liaison Officers (RSLOs) and/or NRC Regional
Assistance]{.underline} [Committee (RAC) Representatives]{.underline}

a\. Participate in the DHS-FEMA-led Disaster Initiated Review, as
necessary and appropriate to the representative's skills.

Note: Consider obtaining a portable satellite telephone unit from the
Regional Emergency Response Coordinator to facilitate the communication
responsibilities of this paragraph in the event of degraded
communication infrastructure in the affected area.

b\. Obtain information regarding important developments in the onsite
recovery and restart process to support the DHS-FEMA-led Disaster
Initiated Review.

05.05 [Regional Division of Reactor Projects (DRP) Branch
Chiefs]{.underline}

[]{.mark}

a\. Participate in the RCCC, as necessary.

[]{.mark}

b\. Communicate important developments in the restart process to senior
regional management.

[]{.mark}

c\. Establish a dialogue with licensee management to determine their
schedule for reactor restart, or the status of continued operations and
assessments of risks involved. Inform them whether any offsite EP
assessments are scheduled, or ongoing, so that licensee management may
factor these into their plans.

[]{.mark}

05.06 [Regional Division of Reactor Safety (DRS) EP Branch
Chiefs]{.underline}

[]{.mark}

a\. Participate in the RCCC.

b\. Communicate status of emergency preparedness assessment activities
with senior regional management and the EPD-A Section Chief.

c\. Establish a dialogue with licensee EP management to determine the
status of ongoing actions to restore EP infrastructure.

d\. Once informed by the EPD-A Section Chief of DHS-FEMA's Disaster
Initiated Review results, provide this information to senior regional
management. Note that this Statement of Reasonable Assurance can
[only]{.underline} originate from DHS-FEMA Headquarters.

05.07 [Senior Resident Inspectors]{.underline}

a\. Participate in the RCCC, as necessary.

b\. Communicate important developments in the restart process and the
assessment of onsite EP elements that link to offsite preparedness and
emergency sirens (if maintained by the licensee) with the regional DRP
Branch Chief.

c\. The following information should be relayed as soon as it is known:

1\. Licensee\'s expected commencement of heatup and/or rod withdrawal,
if the reactor is shut down;

2\. General condition of the EP infrastructure (see communications
protocol identified in the caution statement that follows).

\(a\) The general condition may be determined from discussions with
licensee personnel. (Obtaining this information does not require an
independent inspection to verify the status.)

CAUTION: It is [not]{.underline} appropriate to contact offsite agencies
to determine this information. That responsibility rests with the
appropriate DHS-FEMA regional office. The Regional State Liaison Officer
is the primary NRC staff member who is responsible for interface with
DHS-FEMA at the regional/local level. All [decisions]{.underline}
concerning the adequacy of offsite EP will be based on DHS-FEMA's
Disaster Initiated Review.

> \(b\) Particular effort should be made to determine the status of the
> following (gathered from the licensee and the inspector's insights):
>
> \(1\) Communication circuits between the licensee and the offsite
> authorities;
>
> \(2\) Licensee\'s emergency response facilities;
>
> \(3\) Licensee\'s ability to staff the required emergency response
> organization positions and critical plant personnel;

\(4\) Environmental monitoring;

\(5\) Meteorological towers;

\(6\) Evacuation routes to and from the plant site;

\(7\) Emergency sirens, if maintained by the licensee; and

\(8\) Structures, systems, and components needed for Emergency Action
Level classifications.

05.08 [NRC Operations Center - Headquarters Operations Officer (HOO)
and]{.underline} [Headquarters Emergency Response Officer
(HERO)]{.underline}

[]{.mark}

a\. Relay any incoming information from any source (i.e., licensee, NRC
employee, other Federal agency employee) that may affect the restart
process, or continued plant operation, to the EPD-A Section Chief.

05.09 [NRR Executive Team]{.underline}

a\. Participate in the restart decision, along with NSIR senior
management and senior regional management.

b\. Evaluate the need for the NRC to issue an order or confirmatory
action letter to the licensee to ensure that the restart does not occur
under degraded offsite conditions, and the plant is maintained in a
condition of minimal risk.

c\. Determine whether the affected plant is subject to the restart
provisions of Inspection Manual Chapter 0350, \"Oversight of Operating
Reactor Facilities in an Extended Shutdown as a Result of Significant
Performance Problems.\"

05.10 [NSIR Senior Management (Office Director, Deputy Director,
Division Directors)]{.underline}

a\. Participate in the restart decision, along with the NRR Executive
Team and senior regional management.

05.11 [Senior Regional Management (Regional Administrator, Deputy
Regional Administrator, Division Directors)]{.underline}

a\. Participate in the restart decision, along with NSIR senior
management and the NRR Executive Team.

b\. Evaluate the need for the NRC to issue an order or confirmatory
action letter to the licensee to ensure that the restart does not occur
under degraded offsite conditions, and the plant is maintained in a
condition of minimal risk.

c\. Determine whether the affected plant is subject to the restart
provisions of Inspection Manual Chapter 0350, \"Oversight of Operating
Reactor Facilities in an Extended Shutdown as a Result of Significant
Performance Problems.\"

d\. The Regional Administrator shall inform the licensee of the restart
decision.

1601-06 GUIDANCE

06.01 The restart decision, if applicable, will be made jointly by the
NRR Executive Team, NSIR senior management, and Regional Administrator.
The Regional Administrator will inform the licensee of the restart
decision.

06.02 The restart counterpart conference call (RCCC) is the primary
means for information sharing during the restart assessment process. The
call should be scheduled once daily, and additionally as necessary,
while the actions of this manual chapter are ongoing. The NRR Project
Manager for the affected site will establish a conference bridge and
notify all stakeholders (identified in this manual chapter) of the
schedule and logistics

for the call. During the call, the EPD-A Section Chief will lead
discussion of new and updated information. This call is NRC-internal;
the EPD-A Section Chief has the responsibility to ensure that DHS-FEMA
HQ is notified of any relevant information.

06.03 The most important activity to be pursued by all NRC parties is
the establishment of informative and timely communications. It is not
necessary to continuously maintain open circuits with other offices or
agencies; important information and developments should be relayed to
designated contacts as quickly as possible. The NRR Executive Team, NSIR
senior management, and the Regional Administrator need to be reliably
informed so that they can communicate with the licensee for a safe
restart.

> Note: Prompt communication of findings and the Statement of Reasonable
> Assurance is of the utmost importance and may necessitate late night
> conference calls. Review activities pertaining to a restart decision
> should not wait for daylight hours.

06.04 If, at any time, NRC staff receives new or updated information, it
should be passed on to the EPD-A Section Chief. The EPD-A Section Chief,
in consultation with the NRR Project Manager for the affected site,
shall pass that information on to the appropriate stakeholders; or, if
applicable, the NRR Project Manager will schedule a RCCC to allow
dissemination of the information.

06.05 If the reaffirmation of adequate offsite emergency preparedness is
not forthcoming before the licensee plans to heat up the plant or
restart the reactor then inform the NRR Executive Team, NSIR senior
management, and the Regional Administrator of this fact as soon as
possible. These officials will evaluate the need for the NRC to issue an
order, or confirmatory action letter to the licensee. This will ensure
that the restart does not occur under degraded offsite conditions, and
the plant is maintained in a condition of minimal risk. These senior
officials will also determine whether the affected plant is subject to
the restart provisions of Inspection Manual Chapter 0350, \"Oversight of
Operating Reactor Facilities in an Extended Shutdown as a Result of
Significant Performance Problems.\"

06.06 NRC shall strive to ensure that all decisions regarding emergency
preparedness reviews are carried out consistently across regional
boundaries, both during one initiating event and from one event to
another. Additionally, if an emergency preparedness assessment is
necessary for more than one plant site simultaneously, the NRC should
prioritize reviews per this manual chapter on situational information.

1601-07 REFERENCES

NRC Inspection Manual Chapter 0350, "Oversight of Operating Reactor
Facilities in an Extended Shutdown as a Result of Significant
Performance Problems.\"

DHS-FEMA-NRC Memorandum of Understanding (MOU).

END

APPENDIX A

EMERGENCY PREPAREDNESS RESTART STATUS CHECKLIST

***Initiating Action:***

1\. After consulting with DHS-FEMA, if any of the following events
affect the 10-mile emergency planning zone surrounding a power reactor,
this checklist [should be considered]{.underline}: hurricanes, tornados,
flooding, high winds, large fires, blizzards, ice storms, seismic
activity, malevolent acts, or any other events that challenge offsite
emergency preparedness capability. Also, for extended plant shutdowns
(including electric grid blackouts), this checklist [should be
considered]{.underline} (see section 03.03).

2\. If the licensee has made any level of emergency declaration in
regard to any of these events, this checklist [must be
implemented]{.underline}.

3\. Contact from DHS-FEMA regarding the status of offsite preparedness
may also warrant implementation of this checklist.

***This checklist should be initiated immediately following the
resolution of the response to an event or after the determination is
made that the checklist is required.***

***Notes:***

\*\*\*[ALL]{.underline} agency decisions involving DHS-FEMA and the NRC
must take place between Headquarters offices.

\*\*\*Written reports may be necessary per the MOU to document agency
reports and decisions, however, verbal communication is appropriate and
acceptable for all agency interactions.

  ------------------------------------------------------------------------
  ***Required Action***               ***Responsible      ***Date
                                      Party***            Completed***
  ----------------------------------- ------------------- ----------------
  1\. Determine whether this          NSIR EPD            
  checklist shall be implemented for                      
  a given event.                                          

  2\. Refer to IMC 1601 for complete  All NRC             
  list of communications              stakeholders        
  requirements.                                           

  3\. Make contact with the relevant  NSIR EPD            
  NRC Region / DRP to begin the                           
  assessment process. Notify the NRR                      
  Project Manager for the affected                        
  sites.                                                  

  4\. Initiate dialogue with licensee NRC Region / DRP    
  to determine current plant status,  and Resident        
  restart plan (if applicable), and   Inspectors          
  status of licensee communications                       
  with DHS-FEMA regarding offsite EP                      
  (if known). Report results to NSIR                      
  EPD.                                                    

  5\. Initiate dialogue with DHS-FEMA NSIR EPD            
  HQ / REP to inform them of current                      
  status/restart plan for affected                        
  plant (estimated restart date/time,                     
  including heatup if the reactor is                      
  in cold shutdown), and to discuss                       
  offsite EP issues that the NRC and                      
  DHS-FEMA are aware of.                                  
  ------------------------------------------------------------------------

+-----------------------------------+------------------+---------------+
| ***Continuous Actions***          |                  |               |
+-----------------------------------+------------------+---------------+
| If immediate agency action is     | All NRC          |               |
| required (i.e., orders,           | stakeholders     |               |
| conference calls, ensuring        |                  |               |
| compensatory measures are taken)  |                  |               |
| before formal review activities   |                  |               |
| can be completed, follow guidance |                  |               |
| in sections 03.04 and 05.01(g).   |                  |               |
+-----------------------------------+------------------+---------------+
| Conduct restart counterpart       | NSIR EPD, NRR    |               |
| conference calls (RCCC), as       | DLPM, and all    |               |
| needed (section 06.02).           | stakeholders     |               |
+-----------------------------------+------------------+---------------+
| Communicate important highlights  | NSIR EPD         |               |
| from the RCCC to DHS-FEMA HQ /    |                  |               |
| REP.                              |                  |               |
+-----------------------------------+------------------+---------------+
| Participate in DHS-FEMA review of | Regional State   |               |
| offsite preparedness, as          | Liaison Officers |               |
| necessary. Maintain awareness of  |                  |               |
| plant situation, including onsite |                  |               |
| and offsite preparedness          |                  |               |
| (dialogue with State/local        |                  |               |
| officials regarding conditions    |                  |               |
| around the plant and evacuation   |                  |               |
| routes) and continuously provide  |                  |               |
| that information to the NRC       |                  |               |
| Region and DHS-FEMA RAC           |                  |               |
| Chairpersons.                     |                  |               |
+-----------------------------------+------------------+---------------+
| ***Required***                    | ***Responsible   | ***Date       |
|                                   | Party***         | Completed***  |
| ***Action***                      |                  |               |
+-----------------------------------+------------------+---------------+
| 6\. DHS-FEMA HQ assesses the need | DHS-FEMA HQ      |               |
| for a review of offsite EP        |                  |               |
| adequacy and informs NRC HQ       |                  |               |
| (including a schedule for the     |                  |               |
| review).                          |                  |               |
+-----------------------------------+------------------+---------------+
| 7\. Conduct an RCCC to inform NRC | NSIR EPD, NRR    |               |
| stakeholders of DHS-FEMA's        | DLPM, and all    |               |
| Disaster Initiated Review         | stakeholders     |               |
| schedule. However, If DHS-FEMA    |                  |               |
| determines no review is           |                  |               |
| necessary, cease checklist        |                  |               |
| activities.                       |                  |               |
+-----------------------------------+------------------+---------------+
| 8\. DHS-FEMA conducts review of   | DHS-FEMA HQ      |               |
| offsite EP. DHS-FEMA provides     |                  |               |
| interim reports of its findings   |                  |               |
| to NSIR EPD. Upon completion of   |                  |               |
| the review, DHS-FEMA HQ transmits |                  |               |
| results to NSIR EPD.              |                  |               |
+-----------------------------------+------------------+---------------+
| 9\. Conduct an RCCC to inform NRC | NSIR EPD, NRR    |               |
| stakeholders of the results of    | DLPM, and all    |               |
| DHS-FEMA's offsite preparedness   | stakeholders     |               |
| review.                           |                  |               |
+-----------------------------------+------------------+---------------+
| 10\. NRC considers DHS-FEMA HQ    | NRR Executive    |               |
| input and review findings, in     | Team / NSIR      |               |
| addition to status of onsite      | senior           |               |
| preparedness, to determine        | management /     |               |
| appropriate action (i.e.,         | Regional         |               |
| restart, order, CAL).             | Administrator    |               |
+-----------------------------------+------------------+---------------+

+-----------------------------------+------------------+---------------+
| 11\. NRC informs DHS-FEMA HQ of   | NSIR EPD         |               |
| the NRC's decision and, if        |                  |               |
| appropriate, licensee schedule    |                  |               |
| for restart of the affected       |                  |               |
| reactor(s). NRC updates DHS-FEMA  |                  |               |
| HQ regarding changes, as          |                  |               |
| necessary.                        |                  |               |
|                                   |                  |               |
| If plant is not permitted to      |                  |               |
| restart due to EP issues, return  |                  |               |
| to step 10. Continue RCCCs and    |                  |               |
| information exchanges until       |                  |               |
| issues are resolved.              |                  |               |
+-----------------------------------+------------------+---------------+
| 12\. NRC Region informs licensee  | Regional         |               |
| of restart decision.              | Administrator    |               |
+-----------------------------------+------------------+---------------+
| ***Plant Restart -- Assessment    |                  |               |
| Complete***                       |                  |               |
+-----------------------------------+------------------+---------------+