**NRC INSPECTION MANUAL** PEPB

INSPECTION PROCEDURE 82202

PROTECTIVE ACTION DECISION MAKING

PROGRAM APPLICABILITY: 2515

SALP FUNCTIONAL AREA: EMERGENCY PREPAREDNESS (SOEP)

82202‑01 INSPECTION OBJECTIVES

To determine whether the licensee maintains a 24‑hour‑a‑day capability
to assess and analyze emergency conditions and to make recommendations
to protect the public and on-site workers.

82202‑02 INSPECTION REQUIREMENTS

02.01 Verify that the authorities and responsibilities assigned by the
licensee to assess the accident and to make recommendations for
protective actions are clearly reflected in the emergency plan
implementing procedures (EPIPs) and are consistent with the emergency
plan.

02.02 Determine that the criteria and methodology for making offsite
protective action decisions are clearly reflected in the implementing
procedures.

02.03 Verify that the implementing procedures contain criteria
concerning protective actions for nonessential onsite personnel.

02.04 Determine that the licensee has the capability to deliver timely
protective action recommendations to the appropriate offsite
authorities.

82202‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}. NRC inspectors should limit their
evaluations conducted in accordance with this procedure to the staff,
activities, records, and facilities of the licensee. Where necessary to
verify licensee performance, concerning interactions with organizations
and persons involved in [offsite]{.underline} emergency preparedness,
inspectors should limit their activities to reviews of pertinent records
available through the licensee. If additional information is needed
about [offsite]{.underline} emergency preparedness, it should be
obtained from FEMA.

Guidance for interviews and walkthroughs with licensee staff covering
the understanding and performance of protective action decision making
responsibili­ties is included in Inspection Procedure 82206.

[Specific Guidance]{.underline}

03.01 The organizational elements, responsibilities, and authorities in
the EPIPs for accident assessment and protective action recommendations
should be compared with those in the emergency plan. Particular
attention should be given to organizational structure, reporting chains,
personnel interactions, and staffing. Requirements for the emergency
organization may be found in 10 CFR 50.47(b)(1) and (2) and 10 CFR Part
50, Appendix E, Section IV.A.

03.02 The emergency plan implementing procedures should clearly specify
a methodology that enables the licensee to make protective action
recommendations appropriate for the particular plant conditions (see
NUREG‑0654, Appendix 1, and IE Information Notice 83‑28, dated May 4,
1983).

03.03 The procedures should specify protective actions for onsite
nonessential personnel, including evacuation for Site Area Emergencies
and General Emergen­cies. This information is also normally included in
the licensee\'s General Employee Training Program.

03.04 Requirements for protective actions may be found in 10 CFR
50.47(b)(10). General Guidance is provided in NUREG‑0654, Part II,
Sections I and J. The key items to discuss with the licensee are listed
below:

a.  The licensee has provisions for reaching offsite officials with the
    authority and responsibility for protective action decision making
    on a 24‑hour basis.

b.  There is a procedure(s) to allow offsite protective action
    recommen­dations to be made at all times by the licensee within 15
    minutes of the determination that an emergency exists.

c.  The licensee has predetermined criteria for making protective action
    recommendations on the basis of plant conditions (even if no
    radioactive release is under way) or on projected doses.

d.  The licensee has taken steps to understand how offsite officials use
    the licensee\'s protective action recommendations to make protective
    action decisions. If the decision-making criteria of the offsite
    officials are not consistent with the licensee\'s criteria, confirm
    that the licensee understands the differences and has informed the
    offsite officials and the NRC Regional Response Staff of the
    differences.

82202‑04 INSPECTION RESOURCES

For planning purposes, the estimated on-site time to complete this
procedure is 10 hours.

82202‑05 REFERENCES

Regulatory Guide 1.101, \"Emergency Planning and Preparedness for
Nuclear Power Reactors,\" Revision 3, August 1992.

NUREG/CR‑2925, \"In‑Plant Considerations for Optimal Offsite Response to
Reactor Accidents,\" March 1983 (Microfiche Address: 17738/096-245).

Information Notice 83‑28, \"Criteria for Protective Action
Recommendations for General Emergencies\" (Microfiche Address:
18441/001-119).

NUREG‑0396, \"Planning Basis for the Development of State and Local
Government Radiological Emergency Response Plans in Support of Light
Water Nuclear Power Plants,\" December 1978 (Microfiche Address:
00567/260 - 00568/40).

NUREG‑0654/FEMA‑REP‑1, Rev. 1, \"Criteria for Preparation and Evaluation
of Radiological Emergency Response Plans and Preparedness in Support of
Nuclear Power Plants,\" November 1980 (Microfiche Address: 01997/314 -
01998/71).

Inspection Procedure 82206, \"Knowledge and Performance of Duties
(Training).\"

EPA‑520/1‑75‑001-A, \"Manual of Protective Actions for Nuclear
Incidents,\" January 1990.

END