Safety Evaluation of "Emergency Response Guidelines" (Generic Letter 83-22)

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

                                June 3, 1983

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

Gentlemen: 

SUBJECT:  SAFETY EVALUATION OF "EMERGENCY RESPONSE GUIDELINES" (GENERIC 
          LETTER 83-22) 

The NRC staff has reviewed the proposed Westinghouse Emergency Response 
Guideline (ERG) Program as described in Westinghouse Owners Group (WOG) 
letters of November 30, 1981, July 21, 1982 and January 4, 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. We suggest that implementation of
the guidelines proceed in three steps: 

(1)  Preparation of plant specific procedures which, in general, conform to 
     the Emergency Response Guidelines referenced above and implementation 
     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 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 as part of abnormal 
procedure updates. 



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                                    - 2 -                       June 3, 1983 

We have identified in the Safety Evaluation Report (SER) a number of items 
associated with the guidelines which need further work by the Westinghouse 
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 Westinghouse 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 Westinghouse Owners' Group provide a plan for 
addressing the SER items and a description of the program for steps 2 and 3 
above. 

As discussed in the enclosed SER, the staff reviewed each step of individual
guidelines to determine if the expected results would be obtained, if 
sufficient alternatives were provided for equipment failure, and if the set 
of instructions would bring the plant to a safe shutdown condition. The 
staff also compared the ERGs with the Item I.C.1 requirements of NUREG-0737. 
The staff concluded that (1) a sufficient portion of the final ERG package 
has been completed so that implementation of the ERGs into plant procedures 
can begin, (2) the ERGs meet the most significant requirements of 
NUREG-0737, and (3) overall plant safety will be improved by prompt 
implementation since the ERGs provide a significant improvement over 
existing plant procedures. The staff has also concluded that the guidelines 
can be translated into emergency operating procedures, that they are 
sufficiently function-oriented, and that acceptable procedures can be 
developed based on the guidelines using the guidance of NUREG-0899, 
"Guidelines for the Preparation of Emergency Operating Procedures." We 
therefore find the guidelines acceptable for implementation. 

                              Sincerely, 


                              Darrell G. Eisenhut, Director 
                              Division of Licensing 

Enclosures: 
1.   Letter to Mr. Sheppard, dated June 1, 1983 
2.   SER on Guidelines