Issue Date: 03/23/05 - 1 - 82201

NRC INSPECTION MANUAL PEPB

INSPECTION PROCEDURE 82201

EMERGENCY DETECTION AND CLASSIFICATION

PROGRAM APPLICABILITY: 2515

SALP FUNCTIONAL AREA: EMERGENCY PREPAREDNESS (SOEP)

82201-01 INSPECTION OBJECTIVE

To determine that the licensee has a standard emergency

classification and action level scheme, the bases of which include

facility systems, effluent parameters, and projected offsite doses.

82201-02 INSPECTION REQUIREMENTS

02.01 Verify that the emergency plan implementing procedures

(EPIPs) contain measurable and observable emergency action levels

(EALs) based on in-plant conditions, onsite and offsite

radiological monitoring results, and offsite dose projections.

02.02 Determine whether the licensee has reviewed the EALs with

State and local authorities as required.

02.03 Determine whether the emergency event classifications in

the EPIPs are consistent with those in the emergency plan, meet

regulatory requirements, and that the classification procedure(s)

has provisions for prompt and correct classifications by the

licensee.

02.04 Verify that there is an individual on site at all times

who has the authority and responsibility to immediately and

unilaterally classify events and initiate any emergency actions,

including recommending protective measures to offsite officials.

02.05 Determine whether the licensee has adequate procedures to

direct the user to classify emergencies. 

02.06 Verify that the licensee's EALs are consistent in range,

units, and conversion factors with appropriate control room

instrumentation and that the decisional aids used for event

classification in the control room, the Technical Support Center

(TSC), and the Emergency Operations Facility (EOF) are readily

available and consistent with the EALs.
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82201-03 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

should be obtained from FEMA.

Guidance for interviews and walkthroughs with licensee staff

covering the understanding and performance of emergency detection

and classification responsibilities is included in Inspection

Procedure 82206.

Specific Guidance

03.01 Requirements for EALs may be found in 10 CFR 50.47(b)(4)

and 10 CFR Part 50, Appendix E, Section IV.B. Some licensees will

have event-based EALs. Some licensees will have symptom-based EALs

that often are based on the status of fission product barriers.

Some licensees will have EALs based on the status of critical

safety functions and their relationship to the status of fission

product barriers. In all cases it should be possible to compare

EAL schemes to the example initiating conditions in Appendix 1 of

NUREG-0654 or NUMARC/NESP-007, Revision 2, and this comparison

should result in equivalent classifications. The licensee should

indicate which methodology has been utilized.

03.02 State and local officials responsible for offsite

notification and protective action decisionmaking should be given

an opportunity, on an annual basis, to review the EALs used for

event classification and for making protective action

recommendations. Documentation to verify this could be a letter

from the offsite authorities (see 10 CFR Part 50, Appendix E,

Section IV.B).

03.03 The inspector should should review the classification

procedures and focus on potential impediments or errors that could

lead to incorrect or untimely event classification. It is

important that emergencies not be misclassified. Misclassification

can be minimized if the classification procedures are written so

that a user does not have to search through a lengthy list of

similar events, several of which may relate to different

classification levels. Requirements for classification may be

found in 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E, Section

IV.B.

03.04 The emergency plan, the EPIPs, or other relevant

documentation should provide a list of individuals who are on site

at all times and who have been given the authority and

responsibility to initiate emergency actions.

03.05 A small sample of these procedures should be reviewed and
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discussed with appropriate personnel to determine whether

classification information is included. While not required, it is

good practice for the Emergency Operating, Alarm, and Abnormal

Occurrence Procedures to clearly direct the user to classify an

emergency in a timely manner.

03.06 Several EALs should be examined for consistency with

range, units, and conversion factors used in the control room.

Decisional aids (such as nomograms) used for event classification

in the control room, the TSC, and the EOF should be readily

available and should be consistent with the EALS.

82201-04 INSPECTION RESOURCES

For planning purposes, the estimated time to complete this

procedure is 15 hours.

82201-05 REFERENCES

Regulatory Guide 1.101, "Emergency Planning and Preparedness for

Nuclear Power Reactors," Revision 3, August 1992. 

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)." 

Information Notice 83-28, "Criteria for Protective Action

Recommendations for General Emergencies" (Microfiche Address:

18441/001-119).

NUMARC/NESP-007, Revision 2, "Methodology for Development of

Emergency Action Levels," January 1992. 

END