Issue Date: 03/23/05 - 1 - 82202

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. 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 emergency

preparedness, inspectors should limit their activities to reviews

of pertinent records available through the licensee. If additional

information is needed about offsite emergency preparedness, it
82202 - 2 - Issue Date: 03/23/05 

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.
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Specific Guidance

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.
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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