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
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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
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