Issue Date: 11/08/11 - 1 - 82002.02

ATTACHMENT 82002.02

PROCEDURE QUALITY

82002.02-01 INSPECTION OBJECTIVES

To verify, during plant construction (and prior to fuel load of the plant), the adequacy of 

the facility Emergency Preparedness (EP) procedures and to ensure the licensee’s 

ability to transition to monitoring under the reactor oversight process.

82002.02-02 INSPECTION REQUIREMENTS

02.01 Review the emergency action level (EAL) procedures for adequacy. 

02.02 Review notification procedures for adequacy.

02.03 Review Protective Action Recommendation (PAR) development procedures for 

adequacy.

02.04 Review Emergency Plan Implementing Procedures (EPIPs) for adequacy in 

implementing the Emergency Plan.

02.05 Determine the effectiveness of licensee corrective actions in addressing 

procedure quality issues.

02.06 Provide inspection information on the results of the procedure review to support 

the determination of whether the EP program is in a state of operational readiness.

82002.02-03 INSPECTION 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/FEMA REP 1, Rev. 1, “Criteria for Preparation and 

Evaluation of Radiological Emergency Response Plans and Preparedness in Support of 

Nuclear Power Plants;” NUMARC/NESP-007, Revision 2, “Methodology for 

Development of Emergency Action Levels;” NEI 99-01 Revision 5, “Methodology for 

Development of Emergency Action Levels;” or NEI 07-01 Revision 0, “Methodology for 

Development of Emergency Action Levels Advanced Passive Light Water Reactors,”

and this comparison should result in equivalent classifications. The licensee shall 

indicate which methodology has been utilized. The inspector must verify that the 

licensee's EAL procedure(s) ensure that the EALs are consistent in range, units, and 

conversion factors with appropriate control room instrumentation and that the decisional 
Issue Date: 11/08/11 - 2 - 82002.02

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. The inspector must be alert for any management directives that would delay 

classification until management notifications or other actions are performed that are not 

immediately necessary for public health and safety.

03.02 The inspector will determine whether the licensee has adequate procedures to 

direct the user to notify offsite authorities accurately and promptly of emergency 

conditions. The content of initial and follow-up emergency messages to offsite 

authorities shall be verified as adequate with regard to data and information 

requirements. The inspector must review the licensee's notification procedures for 

consistency with the emergency classification and action level scheme. One important 

aspect of the notification procedures is the existence in the procedures of the 

expectation to promptly (within 15 minutes) initiate notifications after declaring an 

emergency (see 10 CFR Part 50, Appendix E, Section IV.D.3). Verify that usable and 

current procedures exist in the control room and in the licensee's emergency response 

facilities. Verify that procedures contain provisions for message verification.

Initial and follow-up emergency messages will be consistent with the guidance of Part II, 

Sections E.3 and E.4, of NUREG-0654. At a minimum, messages must contain the 

following data:

a. classification of the emergency

b. emergency action level upon which the emergency declaration is based

c. a brief description of the plant conditions supporting the classification

d. the status of any offsite releases of radioactive material

e. meteorological conditions at the release point

f. offsite protective action recommendations or whether no such recommendations 

are required

03.03 The organizational elements, responsibilities, and authorities in the EPIPs for 

protective action recommendations must be compared with those in the Emergency 

Plan. The EPIPs shall 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 NUREG-0654, Supplement 3, EPA-400-R-92-001, 

“Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,”

Regulatory Information Summary (RIS) 2005-08, “Endorsement of Nuclear Energy 

Institute (NEI) Guidance for Range of Protective Actions for Nuclear Power Plant 

Incidents,” and IE Information Notice 83-28, “Criteria for Protective Action 

Recommendations for General Emergencies (GE).”

a. Verify the licensee=s procedures for making offsite protective action 

recommendations are able to be used by the on-shift crew with the information 

available to them in the control room. 
Issue Date: 11/08/11 3 82002.02

b. Verify that the licensee=s procedures provide for the generation of protective 

action recommendations on an ad-hoc basis for distances beyond the ten-mile 

plume exposure emergency planning zone. PARs will not deviate substantially 

from those contained in Federal guidance (NUREG-0654, Supplement 3 and 

EPA-400) unless the licensee=s agreement with the offsite agencies specifies 

such a deviation. In such cases, review the licensee=s basis for its PAR policy.

03.04 Verify that the Emergency Plan contains a listing, by title, of procedures required 

to implement the Plan. Procedures should be available, but not necessarily limited to, 

information needed to demonstrate compliance with Plan elements such as: the 

organization for coping with radiation emergencies, assessment action, activation of 

emergency organization, notification procedures, emergency facilities and equipment, 

training, maintaining emergency preparedness and recovery. Licensees should have 

procedures necessary to implement the standards of 10 CFR 50.47(b), against which 

the Emergency Plan is evaluated for compliance.

03.05 No inspection guidance.

03.06 No inspection guidance.

82002.02-04 RESOURCE ESTIMATE

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

END
Issue Date: 11/08/11 E1-1 82002.02

Exhibit 1

Revision History for IP 82002.02

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

ML111040279

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.

N/A N/A N/A