Safety Evaluation of "Emergency Procedure Guidelines, Revision 2," NEDO-24934, June 1982 (Generic Letter No. 83-05)

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                           WASHINGTON, D.C. 20555 

                              February 8, 1983

TO:       All Boiling Water Reactor Licensees of Operating Reactors (Except 
          LaCrosse), Applicants for an Operating License and Holders of 
          Construction Permits (Generic Letter 83-05) 

SUBJECT:  SAFETY EVALUATION OF "EMERGENCY PROCEDURE GUIDELINES, REVISION 2,"
          NEDO-24934, JUNE 1982 

Gentlemen: 

The NRC staff has reviewed the General Electric Topical Report NEDO-24934, 
"Emergency Procedure Guidelines, Revision 2," June 1982, including the 
errata dated September, 28, 1982 and has found the Emergency Procedure 
Guidelines to be acceptable for implementation. We believe that the BWR 
Emergency Procedure Guidelines provide a basis for a significant improvement 
over current emergency operating procedures. Although the guidelines are not
complete (combustible gas control and secondary containment control 
guidelines are not yet included) and the enclosed Safety Evaluation Report 
requires a few changes to the guidelines, we find the guidelines with the 
NRC proposed charges to be acceptable. We suggest that implementation of the
guidelines proceed in two steps: 

(1)  Preparation of plant specific procedures which in general conform to 
     the Emergency Procedure Guidelines referenced above and implementation 
     of these procedures as outlined in Supplement 1 to NUREG-0737, 
     transmitted by Generic Letter No. 82-33 dated December 17, 1982. 

(2)  Preparation of supplements to the Guidelines which cover changes, new 
     equipment, or new knowledge and incorporation of these supplements into
     plant specific procedures. 

Step (1) refers to the Guidelines referenced above and discussed in the 
enclosed SER. Step (2) refers to Guideline updates which will be generated 
as a matter of routine after the plant specific procedures have been put in 
place. Although Step (2) includes combustible gas control and secondary 
containment control guidelines which are yet to be developed, it is 
essentially a maintenance function. 

During our review, we identified several steps in the guidelines which 
require minor changes. These are identified in the enclosed SER. We ask that
you address these items during the implementation of Step (1). We also note 
that the guidelines are written for the procedure writers, not control room 
operators, and therefore preparation and implementation of procedures will 
require additional Human Factors input. 




8302080301 
.

                                     -2- 

Because the Emergency Procedure Guidelines must be dynamic in that changes 
must be made to reflect changes in equipment or next knowledge, we expect 
the BWR Owners Group or a similar coalition of utilities and vendors to 
accept responsibility for continued maintenance of the guidelines. 
Therefore, we have requested in the enclosed letter that the BWR Owners 
Group provide a description of the program for future changes or supplements 
to the guidelines. 

As discussed in the enclosed SER, we find the actions specified in the 
Emergency Procedure Guidelines to be generally correct and appropriate and 
within the operator's capability. The combination of all emergency actions 
into two guidelines and seven contingencies greatly simplifies the emergency
instructions. In addition, the use of symptoms rather than events as bases 
for actions, eliminates errors resulting from incorrect diagnosis of events,
and addresses mutilple failures and operator errors. We therefore find the 
guidelines acceptable for implementation. 

                              Sincerely, 


                              Darrell G. Eisenhut 
                              Division of Licensing 

Enclosure:     SER on Guidelines 
               Letter to Mr. Dente, dated 
                    February 4, 1983