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. 




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                                    - 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