Issue Date: 11/08/11 - 1 - 82002.07

ATTACHMENT 82002.07

OPERATIONAL STATUS OF THE EMERGENCY PREPAREDNESS PROGRAM

82002.07-01 INSPECTION OBJECTIVES

To verify, during the final phase of new plant construction (and prior to fuel load of the 

plant), the operational readiness of the licensee’s Emergency Preparedness (EP) 

Program; to ensure its ability to transition to monitoring by the reactor oversight process.

82002.07-02 INSPECTION REQUIREMENTS

02.01 Organization and Management Control. Verify that the licensee has developed 

appropriate organization and management controls within the Emergency Plan and 

emergency plan implementing procedures (EPIPs).

02.02 Training. Verify that individuals that are assigned key roles for emergency 

response have been trained as required and understand their emergency assignments, 

responsibilities, authorities, and changes to the EPIPs.

02.03 Independent and Internal Reviews and Audits. Examine independent and 

internal review and audit reports of the licensee's EP programs.

02.04 Effectiveness of Licensee Controls. Evaluate the effectiveness of the licensee’s 

controls in identifying, resolving and preventing problems by reviewing such areas as 

corrective action systems, root cause analyses, safety committees, and self assessment 

in the area of EP.

82002.07-03 INSPECTION GUIDANCE

General Guidance

Evaluations conducted in accordance with this procedure are limited to the staff, 

activities, records, and facilities of the licensee.

Specific Guidance

03.01 Organization and Management Control. Based on discussions with licensee 

management and the review of relevant documentation, determine whether the 

licensee’s organization and management control systems are appropriate and have 

been incorporated into the Emergency Plan and EPIPs. Reviewing relevant portions of 

the Emergency Plan and EPIPs is a way to verify that all organization and management 

controls are included. The inspectors shall look for documentation on organizational 

structure; responsibilities, authorities and staffing of key emergency response 

personnel; interfaces and coordination between onsite, offsite, and corporate 

organizations; and shift staffing. Such details include, but are not limited to, the 

following:

a. The inspector shall review the duties assigned to the Emergency Planning 

Coordinator (EPC). The inspector shall ensure that there is a description of the 

reporting chain or the EPC is not assigned additional responsibilities outside the 

EP area. The inspector should examine the organizational or administrative 
Issue Date: 11/08/11 - 2 - 82002.07

procedures and interview licensee personnel.

b. The inspector shall review the corporate and plant staff organization to 

determine the personnel who have emergency planning responsibilities.

c. The inspector shall review the assignment and qualifications of individuals to the 

emergency organization. A review of the training and qualification records of 

individuals assigned functional responsibilities in the emergency organization 

will indicate whether the individual(s) completed all training requirements before 

the assignment and are qualified to fulfill the assigned responsibilities.

d. The inspector shall review the key offsite response personnel and methods of 

coordination with them. This information is normally obtained from the licensee 

or from the FEMA Radiological Emergency Preparedness (REP) Regional 

Assistance Committee (RAC) Chairman.

e. The inspector shall review personnel availability that may affect augmentation of 

the emergency organization (e.g. proximity of personnel to the plant).

f. The inspector shall review agreements with offsite response organizations.

03.02 Training

a. Requirements for training are found in 10 CFR 50.47(b)(15) and 10 CFR Part 

50, Appendix E, Item IV.F. The inspector will interview the Emergency 

Coordinator, Emergency Directors in the emergency response facilities (ERFs), 

the Shift Supervisor, and selected individuals involved in the notification 

process. As part of the interview process, a walk-through with the shift crew, 

including the Shift Supervisor and Shift Technical Advisor, on one or more shifts 

(as necessary to assess training effectiveness rather than individual 

performance) is required. During the walk-through, responsible licensee 

emergency response staff and management, as appropriate, will be able to (1) 

evaluate hypothetical conditions or data, (2) identify respective emergency 

action levels, (3) evaluate or, where appropriate, perform dose calculations (4) 

classify the emergency using the latest procedures, and (5) recommend 

appropriate protective actions. 

1. The inspector shall verify that the licensee uses the correct procedures 

and demonstrates proficiency during each step in the classification and 

notification processes. Classifications must be correct. Notifications will be 

made as required. Both classifications and notifications shall be done in a 

timely manner.

2. For each emergency classification, the inspector shall verify that the 

licensee demonstrates proficiency for initiating protective actions onsite 

and recommending those to be taken offsite. Requirements for protective 

actions are found in 10 CFR 50.47(b)(10).

b. Significant changes to the licensee's procedures and equipment must be

examined and discussed with responsible personnel to determine whether the 

personnel are aware of the changes, understand them, and have received 

training appropriate for their use.

03.03 Independent and Internal Reviews and Audits. Independent and internal 

reviews or audits of the licensee's EP program are generally done on a 12-month cycle. 

Requirements may be found in 10 CFR 50.54(t). The qualifications of the respective 
Issue Date: 11/08/11 - 3 - 82002.07

audit personnel are normally found in the licensee's Quality Assurance (QA) Manual. 

Criteria for auditors normally include training and experience commensurate with the 

scope, complexity, and special nature of the activities being audited. Audit personnel 

are required to have no direct responsibility for the development or implementation of 

the EP program. Inspectors must determine whether the licensee’s Emergency Plan 

and/or EPIPs require audits that meet these requirements. 

03.04 Effectiveness of Licensee Controls. The inspector shall review the effectiveness 

of licensee controls. The inspector will determine whether the licensee has 

implementing procedures to ensure the following with regard to safety issues, events or 

problems:

a. Initial identification of the problem.

b. Elevation of problems to the proper level of management for resolution (internal 

communications and procedures).

c. Root cause analysis.

d. Disposition of operability issues.

e. Implementation of corrective actions.

f. Expansion of the scope of corrective actions to include applicable related 

systems, equipment, procedures and personnel actions.

82002.07-04 RESOURCES

The estimated time to complete this procedure is 35 hours of direct onsite inspection 

effort (when conducting public meetings, add an additional 10 hours).

82002.07-05 REFERENCES

Regulatory Guide 1.101, “Emergency Planning and Preparedness for Nuclear Power 

Reactors,” Revision 5.

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).

NUREG-0696, “Functional Criteria for Emergency Response Facilities,” February 1981 

(Microfiche Address: 08158/270-313).

NUREG-0731, “Guidelines for Utility Management Structure and Technical Resources,”

September 1980 (Microfiche Address: 06910/234-265).

NUREG-0737, “Clarification of TMI Action Plan Requirements,” November 1980 

(Microfiche Address: 07003/27-284) and Supplement 1, January 1983 (Microfiche 

Address: 17301/342-363).
Issue Date: 11/08/11 - 4 - 82002.07

EPA-520/1-75-001-A, “Manual of Protective Actions for Nuclear Incidents,” January 

1990.

ANSI/ANS 3.1-1981, “Selection, Qualification and Training of Personnel for Nuclear 

Power Plants,” (Supersedes ANSI N18.1-1971-77) (Microfiche Address: 65959/199-

225).

END
Issue Date: 11/08/11 E1-1 82002.07

Exhibit 1

Revision History for IP 82002.07

Commitment 

Tracking Number

Issue Date Description of 

Change

Training Needed Training 

Completion Date

Comment 

Resolution 

Accession Number

N/A 11/08/2011

CN 11-030

ML111040328

Initial issue to 

support inspections

of construction 

programs described 

in IMC 2504, 

Construction 

Inspection 

Program: 

Inspection of 

Construction and 

Operational 

Programs.

Completed 4 year 

search of historical 

CNs and found no 

commitments 

related to this 

Inspection 

Procedure.

None N/A N/A