Issue Date: 11/08/11 - 1 - 82002.06

ATTACHMENT 82002.06

EMERGENCY RESPONSE ORGANIZATION, DOSE ASSESSMENT DRILLS

82002.06-01 INSPECTION OBJECTIVES

To verify, prior to fuel load of the plant, the adequacy of the licensee’s Emergency

Response Organization (ERO) Dose Assessment Program; to ensure its ability to 

transition to monitoring under the reactor oversight process.

82002.06-02 INSPECTION REQUIREMENTS

02.01 Review specific elements for the drill scenario. If appropriate, the drill scenarios 

developed by the licensee for this attachment may be combined with IP 82002.05

(Attachment 5).

02.02 Review the listing of licensee participants expected to fill emergency response 

organization (ERO) positions for this drill.

02.03 Determine through evaluation of ERO dose assessment in the drill whether ERO 

members can implement the Emergency Plan as appropriate for the scenario 

presented. 

02.04 Determine the effectiveness of licensee corrective actions in addressing ERO 

dose assessment issues.

02.05 Provide inspection information based on the results of the ERO dose 

assessment drill evaluation to support the determination of whether the EP program is 

operationally ready.

82002.06-03 INSPECTION GUIDANCE 

General Guidance 

The inspector(s) shall become familiar with the scenario(s) upon arrival on site to 

understand how to evaluate ERO dose assessment. Review any changes made to the 

scenarios and tour the location(s) to be used for the drills to become familiar with 

equipment, displays, procedures and supplies to be used to perform the evaluated 

tasks.

Specific Guidance

03.01 For all sites, the licensee shall develop several dose assessment scenarios with 

the understanding that the different ones would be used with different participants. The 

licensee must keep the scenarios confidential. If confidentiality is not maintained, the 

inspection may be postponed until a later date when confidential scenarios are available 

for use. 
Issue Date: 11/08/11 - 2 - 82002.06

Scenarios must be designed to address dose assessment and may be combined with 

the elements of IP 82002, Attachment 5. However, it should be recognized that 

increasing the number of functions and elements involved will increase the resources 

and time needed to conduct the drill. 

Items that the licensee shall consider for incorporation into scenarios include:

a. Various levels of fission product barrier degradation. 

b. Events escalating core damage (coolant only, to clad damage to core damage).

c. Releases resulting in exceeding radiological emergency action levels, including 

the General Emergency.

d. Events resulting in releases of radioactive material offsite.

e. Diverse meteorological conditions.

f. Unmonitored releases.

g. Releases from monitored release points.

h. Conflicting field monitoring team data.

i. Effluent sample data.

j. Post-accident sampling system (PASS), or the licensee’s equivalent capability,

sample data.

03.02 No inspection guidance.

03.03 The licensee must take reasonable steps to make the drills closely simulate the 

actual emergency response task(s). This is accomplished through the use of the 

emergency response facilities and computer equipment. If the site is co-located with 

operating power reactor(s), drills should be conducted so as not to interfere with plant 

operations and activities. The inspector should not interrupt drills, but await the end of 

performance to ask questions or to determine the causes of problems. Interruptions 

and numerous probing questions may create an atmosphere in which participants can 

not respond in a manner that simulates an emergency. In addition, questioning 

mistakes may eliminate an opportunity for the responding team to self correct. The 

scope of each drill may include the unit of personnel expected to respond, e.g., the duty 

roster dose projection staff. Although individual response proficiency may be assessed 

through this procedure, the performance may not be representative of an actual 

emergency where a team response is expected.

To determine whether key dose assessment ERO members perform dose 

assessments, the licensee shall evaluate drill performance. In addition, the inspector 

will perform an independent evaluation of the drill participant’s performance, to confirm 

the licensee’s results. Performance standards for assessment include:
Issue Date: 11/08/11 - 3 - 82002.06

a. Responsible personnel must be able to correctly perform the calculation in a 

timely manner.

b. The results of dose calculations should be incorporated into classification efforts. 

Crossing an emergency action level (EAL) threshold should be recognized by 

licensee personnel.

c. The results of dose calculations should be incorporated into protective action 

recommendation (PAR) decision making and, if in accordance with the site 

Emergency Plan, the PAR should be developed.

d. There are persons on every shift performing dose assessment. 

e. Dose values should include total effective dose equivalent and thyroid 

committed dose equivalent.

f. Doses should be calculated for the applicable distances where PAR 

considerations are made (e.g., site boundary, 2 miles radius, 5 mile radius and 

10 mile radius.)

g. The assumed release duration should be reasonable for the release pathway 

and projected plant conditions. When technically appropriate, release duration 

should be modified based on plant conditions. 

h. Dose assessment personnel should demonstrate ability to incorporate field team 

survey data in the refinement of dose assessments.

i. Dose assessment personnel should demonstrate ability to recognize data that is 

outside the credible range of parameters.

j. The objective is to develop scenarios that are realistic and sufficiently complex 

to evaluate performance ability. 

k. Licensee performance in the following areas shall be observed and may provide 

valuable inspection information: 

1. procedure usability

2. familiarity with procedures 

3. familiarity with equipment, displays, indications and calculational tools

l. Licensee prompting of drill participants is not a finding under the assessment 

process because it represents no risk significance in itself. However, prompting 

could negate the validity of the drill and may create the need for another drill 

evaluation for the involved ERO members.
Issue Date: 11/08/11 - 4 - 82002.06

03.04 Based on early results from the ERO performance drills, the licensee may 

determine if additional drills need to be conducted or if the scope of the remaining drills 

needs to be modified.

03.05 No inspection guidance.

82002.06-04 RESOURCE ESTIMATE

It is estimated that conduct of this attachment will take 40 hours.

END
Issue Date: 11/08/11 E1-1 82002.06

Exhibit 1

Revision History for IP 82002.06

Commitment 

Tracking Number

Issue Date Description of 

Change

Training Needed Training 

Completion Date

Comment 

Resolution 

Accession Number

N/A 11/08/11

CN 11-030

ML111040314

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