Safety Evaluation of "Emergency Response Guidelines" (Generic Letter 83-23)
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
July 29, 1983
TO ALL OPERATING REACTOR LICENSEES, APPLICANTS FOR AN OPERATING LICENSE AND
HOLDERS OF CONSTRUCTION PERMITS FOR COMBUSTION ENGINEERING PRESSURIZED WATER
REACTORS
Gentlemen:
SUBJECT: SAFETY EVALUATION OF "EMERGENCY PROCEDURE GUIDELINES"
(GENERIC LETTER 83-23)
The NRC staff has reviewed the proposed Combustion Engineering Emergency
Procedure Guideline (EPG) Program as described in Combustion Engineering
Owners Group (CEOG) letters of November 22, 1982 and March 29, 1983, and in
the material accompanying those letters. We have concluded that the
guidelines are acceptable for implementation and will provide improved
guidance for emergency operating procedure development as discussed in
Generic Letter 83-09. We suggest that implementation of the guidelines
proceed in three steps:
(1) Preparation of plant specific procedures which, in general, conform
to the Emergency Procedure Guidelines referenced above and implemen-
tation of these procedures as required by Generic Letter 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 the procedures; and
(3) Completion and improvement of the guidelines to meet our long term
requirements, followed by incorporation of improvements into plant
specific procedures.
The prompt implementation of Step 1 will allow the benefits of the
significant improvements you have achieved to be realized soon. We note
however, 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. Step 2 refers to a
program for guideline or procedure updates which will b 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 in your emergency procedure program.
8306270422
.
- 2 - July 29, 1983
We have identified in the Safety Evaluation Report (SER) a number of items
associated with the guidelines which need further work by the Combustion
Engineering Owners. We require that these items be addressed by either
incorporating them into a future guideline revision or otherwise justifying
the disposition of the item. Additionally, 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 Combustion Engineering 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 Combustion Engineering
Owners' Group provide a near term revision to address reactor vessel level
instrumentation and a plan for addressing the other SER items.
Additionally, by letter dated February 4, 1983, we requested a description
of the program for steps 2 and 3 above.
As discussed in the enclosed SER, the staff finds that the EPGs represent a
significant improvement over the guidance provided in current emergency
operating procedures. The approach of dividing the EPGs into a treatment of
recognized "simple" conditions using Optimum Recovery Guidelines (ORGs) and
coverage of all other conditions using Functional Recovery Guidelines (FRGs)
meets the requirements for a symptom oriented emergency response. The
guidelines provide sufficient guidance such that they can be translated into
acceptable emergency operating procedures using the process identified in
NUREG-0899, "Guidelines for the Preparation of Emergency Operating
Procedures." The staff therefore concludes that although efforts to improve
the EPGs should continue, the EPGs identified in CEN-152 Revision 1 will
provide a greater assurance of operational safety and are acceptable for
implementation.
Sincerely,
Darrell G. Eisenhut, Director
Division of Licensing
Enclosures:
1. Letter to Mr. Wells, dated July 29, 1983
2. SER on Guidelines
Page Last Reviewed/Updated Thursday, March 25, 2021