Review of Combustion Engineering Owners' Group Emergency Procedures Guideline Program (Generic Letter No. 83-09)

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

                              February 8, 1983

TO ALL OPERATING REACTOR LICENSEES, APPLICANTS FOR AN OPERATING  LICENSE AND 
HOLDERS OF CONSTRUCTION PERMITS FOR COMBUSTION ENGINEERING PRESSURIZED WATER 
REACTORS 

Gentlemen: 

SUBJECT:  REVIEW OF COMBUSTION ENGINEERING OWNERS' GROUP EMERGENCY 
          PROCEDURES GUIDELINE PROGRAM (Generic Letter No. 83- 09) 

This letter provides preliminary acceptance of the CE Owners' Group (CEOG) 
Emergency Procedure Guidelines for implementation in plant specific 
emergency procedures and outlines our requirements for additional work in 
this area. The staff has identified technical and administrative issues 
which require timely resolution. We also require a program to manage future 
changes as the need is identified. 

Our review has progressed to the point where we conclude that implementation
of the guidelines should provide a greater assurance of operational safety 
than presently exists. Therefore, you should proceed with plant-specific 
implementation. We anticipate issuing an SER subsequent to our review of the
CEOG formal submittal of CEN-152, "Combustion Engineering Emergency 
Procedure Guidelines," dated November 22, 1982. We anticipate that our SER 
will find CEN-152 acceptable. Both this conclusion and our conclusion that 
you should begin implementation of Emergency Procedure Guidelines into plant 
specific procedures are based on the judgment that no further major problems 
in the proposed guidelines are expected. Our conclusions are further based 
upon the assumption that the results from the NRC/CE Owners' meetings are 
reflected in the CEOG CEN-152 submittal. We suggest that the implementation 
program contain three elements: 

     (1)  Preparation of plant specific procedures based on 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)  A program for the preparation of supplements to the generic 
          guidelines or plant specific guidelines which cover changes, new 
          equipment, or new knowledge and incorporation of these supplements
          into the procedures. 

     (3)  Completion of and improvements to the Emergency Procedure 
          Guidelines (EPG) or plant specific procedures in the longer term. 



8302080295  
.

                                    - 2 - 

The prompt implementation of Step 1 will allow the benefits of the 
significant improvements you have achieved to be realized soon. 

Step 2 refers to a program for guideline or procedure updates which will be 
generated as a matter of routine after the implementation. This essentially 
is a maintenance function. 

Step 3 refers to a program for addressing those aspects of the guidelines 
and procedures where additional long term work may be needed, either in your
emergency procedure program or a part of abnormal procedure updates. A 
listing and discussion of identified issues will be provided in the staff 
SER. It is anticipated that one or more of these areas will be resolved 
under TMI action item I.C.9.  

Because the Emergency Procedure Guidelines must be dynamic in that changes 
must be made to reflect changes in equipment or new knowledge, we expect the
CE 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 CE Owners' Group provide a 
description of the program for steps (2) and (3) above. 

                              Sincerely, 


                              Darrell G. Eisenhut, Director 
                              Division of Licensing 

Enclosure: 
Letter to Mr. Wells 
  dated  
.
                                                                ENCLOSURE 

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

                            February 4, 1983  

Mr. R. W. Wells 
Chairman, CE Owners Group  
Box 270 
Hartford, CT 06141-0270 

Dear Mr. Wells  

This letter provides preliminary acceptance of the CE-Owners' Group (CEOG) 
Emergency Procedure Guidelines for implementation in plant specific 
emergency procedures and outlines our requirements for additional work in 
this area. The staff has identified technical and administrative issues 
which require timely resolution. We also require a program to manage future 
changes as the need is identified. 

Our review to date has been primarily based on draft submittals of the CEOG 
Emergency procedure Guidelines supplemented with extensive contact between 
the staff and CEOG representatives. The current review relied on the 
following sources of information: 

(1)  The draft report "Combustion Engineering Emergency Procedure 
     Guidelines," CEN-152 Revision 01, August, 1982 

(2)  Response to our questions titled "Resolutions to Procedures and Test 
     Review Branch Questions and Comments on C-E Emergency Procedure 
     Guidelines, June 29, 1982" (no date) 

(3)  Response to our questions titled "Resolutions to Warren C. Lyon's 
     Questions and Comments on C-E Emergency Procedure Guidelines, June 23, 
     24, 29" (no date) 

(4)  Results from Meetings between C-E (and in some cases with C-E Owner's 
     Group representatives) and NRC between 1979 and 1982. 

Our review has progressed to the point where we conclude that implementation
of the guidelines should provide a greater assurance of operational safety 
than presently exists. The CE owners should proceed with plant-specific 
implementation. We anticipate issuing an SER subsequent to our review of 
your formal submittal of CEN-152, "Combustion Engineering Emergency 
Procedure Guidelines" dated November 22, 1982. We anticipate that our SER 
will find CEN-152 acceptable. Both this conclusion and our conclusion that 
you should begin implementation of Emergency Procedure Guidelines into plant 
specific procedures are based on the judgment that no further major 
.

Mr. R. W. Wells                  - 2 -                   February 4, 1983 

problems in the proposed guidelines are expected. Our conclusions are 
further based upon the assumption that the results from the NRC/CE Owners 
meetings are reflected in your CEN-152 submittal. The enclosure presents our 
thoughts on the implementation phase. 

                              Sincerely, 


                              Darrell G. Eisenhut, Director 
                              Division of Licensing 

Enclosure: 
Implementation Program 

cc:  w/enclosure 
     CE Licensees 
     CE Applicants 
     CE 
     J. Barrow, CE Owners Group 
     G. Bishoff, CE 
     V. Callahan, CE 
     R. Pearce, CE  
.

                           IMPLEMENTATION PROGRAM 

We suggest that the implementation program contain three elements: 

     (1)  Preparation of plant specific procedures based on the Emergency 
          Procedure Guidelines referenced above and implementation of these 
          procedures. 

     (2)  A program for the preparation of supplements to the generic 
          guidelines or plant specific guidelines which cover changes, new 
          equipment, or new knowledge and incorporation of these supplements
          into the procedures. 

     (3)  Completion of and improvements to the Emergency Procedure 
          Guidelines (EPG) or plant specific procedures in the longer term. 

The prompt implementation of Step 1 will allow the benefits of the 
significant improvements you have achieved to be realized soon. 

Step 2 refers to a program for guideline or procedure updates which will be 
generated as a matter of routine after the implementation. This essentially 
is a maintenance function. 

Step 3 refers to a program for addressing those aspects of the guidelines 
and procedures where additional long term work may be needed, either in your
emergency procedure program or a part of abnormal procedure updates. A 
listing and discussion of identified issues will be provided in the staff 
SER. It is anticipated that one or more of these areas will be resolved 
under TMI, action item I.C.9. 

     A.   Generic items, ATWS rulemaking, SPDS designs, RCS vent 
          installations, and ICC instrumentation. Unresolved Safety Issues 
          may also enter this list. 

     B.   Technical items such as the following: 

          a.   EPG coverage extention into electrical power supply 
               availability so that plant behavior under such events as 
               station blackout is covered. 

          b.   Management of accidents such as multiple ruptured steam 
               generator tubes from the viewpoint of radioactivity release 
               and a more complete procedure for SGTR. 

          c.   Containment coverage. 

          d.   Additional consideration for condensate management, such as 
               the coverage of alternate sources of water. 
.

                                    - 2 - 

     C.   Potential behavior under conditions where physical phenomena may 
          differ from those discussed in the EPG needs evaluation and 
          coverage. Typical are the following: 

          a.   Hydraulic-instabilities which may introduce unusual 
               instrument readings which could mislead an operator to take 
               an unwarranted action. 

          b.   Degraded core conditions and guidance for operator response 
               under these conditions. 

     D.   Several items are plant specific; but general guidance is 
          applicable. These include: 

          a.   Differences between plants with and without PORVs and 
               differences in PORV sizing and possible instruction a 
               perturbations. 

          b.   The influence of sensor location, such as positioning of hot 
               leg temperature determination devices, and feedback into 
               operator instructions. 

We request that you describe your program for Items (2) and (3), above, of 
the implementation program.