ML20210A170
| ML20210A170 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1994 |
| From: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Russell W NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20210A097 | List: |
| References | |
| FOIA-99-268, REF-GTECI-*****, REF-GTECI-NI NUDOCS 9907220037 | |
| Download: ML20210A170 (15) | |
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UNITED STATES j "'
NUCLEAR REGULATORY COMMISSION dhhd L
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MAY 0 5 1994 l
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MEMORANDUM FOR:-
William Russell, Director Office of Nuclear Reactor Regulation j
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'L FROM:-
Eric S. Beckjord, Director-Office of Nuclear Regulatory Research
SUBJECT:
LICENSE RENEWAL IMPLICATIONS OF GENERIC SAFETY ISSUES (GSIs)
PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994-RES'has completed its review of generic issue actions related to license i
renewal, as committed in my memorandum to you on March 23, 1994. Our c comprehensive review of all GSIs prioritized and/or resolved up to October 1990 showed that consideration of a license renewal pcriod of twenty years did not change thn staff's resolutica of these issues; this review was documented
-in NUREG/CR-5382. With the issuance of the Rule on Nuclear. Power Plant License Renewal (56 FR 64943, December 13,1991), GSI resolution efforts started or in progress after October 1990 were to "... examine renewal-term effects as part.of the original issue resolution process."
RES has reviewed the 84 generic issues that Lwere prioritized and/or resolved
.between October 1990 and March 1994 and found that the conclusions reached on the 80 GSIs will not change with the consideration of a license renewal period
.of twenty years. The remaining 4 issues were classified as non-safety issues with no impact on license renewal:'three Licensing Issues (A-19,- 147,148) and
.one Regulatory Impact-Issue (155.2). With respect to the prioritization of the issues, the reevaluation considered the additional 20-year license renewal term (an approximate factor of two increase in the potential risk reduction) and the revised prioritization guidelines proposed in SECY-93-108 and approved by-the Commission.- These guidelines raised the threshold for HIGH and MEDIUM priority GSIs. A summary of the RES findings on the 80 GSIs is listed in to.this memorandum. provides a list of the 21 GSIs that have been through the resolution process.
It:should be~ noted that the-license renewal period was considered in the l
impact /value analyses for 6 of the 80 GSIs listed in Enclosure 1; an additional 6 GSIs are undergoing resolution and will have to address license
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renewai'in.accordance with RES Office Letter No. 3.
However, in order to facilitate the NRR identification of GSIs for consideration in plant license renewal applications, RES will revise the Introduction of NUREG-0933 to
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reflect: (1) the findings of NUREG/CR-5382; and (2) the RES findings for those GSIs completed between October 1990 and March 1994.
RES Office Letters No.
9907220037 990720 7'
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RALEIGH99-268 PDR
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(I Will am Russell -
e l'and 3 have been revised to include a line item on license renewal and future prioritization evaluations and resolution regulatory analyses will more c'learly state the impacts on license renewal.
l l
Origir.at Signed By:
i C.J. Heltemes,Jr.
Eric S. Beckjord, Director j
Nuclear Regulatory Research L
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Enclosures:
- l. 80 GSis Prioritized and/or Resolved Between October 1990 and March 1994
- 2. 21 GSIs Resolved Between October 1990 and March 1994 cc:
D. Crutchfield i
S. Newberry S. Reynolds M. Malsch-
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J. Milhoan i
J. Moulton i
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A-
m, ENCLOSURE 1 o
80 GSIs PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 l
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Failure of Protective Devices on Essential Eauipment L
License renewal wa not considered in the prioritization of this issue which was p; aced in the DROP. category. because of its negligible risk reduction potential.
Consideration of license renewal did not change the priority of the issue.
24 Automatic ECCS Switchover to' Recirculation License renewal was not considered in the MEDIUM priority ranking of L
this' issue but, in accordance with RES office Letter No.,3, will be addressed during resolution..
29:
Boltina Dearadation or Failure in Nuclear Power Plants License renewal was not considered in the HIGH priority ranking of this issue which was resolved with no backfit based on the actions taken by licensees to address the safety concern. Consideration of license renewal did not affect this resolution.
38 Potential Recirculation System Failure as a Consecuence of Inaestion of Containment Paint Flakes or Other Fine Debris License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on a finding of insignificant risk in the plant analyses of Comanche Peak Units 1 and 2. Consideration of license renewal did not change the priority of the issue.
.39 Potential for-Unacceptable Interaction Between the CRD System and Non-Essential Control Air System License renewal was not considered in the prioritization of this i
issue _ wbNh' was placed in the DROP category based on the backfit
~that-r.
made Yo._ address the safety concern.
prior to -
4 priorititation. Consideration of license renewal did not change the priority of the issue.
73' Detached Thermal Sleeves i
'icense renewal was not considered in~ the prioritization of this
.issue which' was placed in the NEARLY-RESOLVED category and then resolved with..backfiti to the' affected Westinghouse pl ants.
Consideration of license renewal did not affect this resolution.
- 76.
Instrumentation and Control-Power Interactions License renewal was considered in the prioritization of this issue which was placed_in the DROP category.
78:
Monitorino of Fatique-Transient limits for Reactor Coolant System License renewal was not considered in the MEDIUM priority ranking of this-issue.
This issue:will provide technical information to the
- overall resolution of the safety concern under Issue 166, for which
Resolution of Issue 166 will consider license renewal.-
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ENCLOSURE 1
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80 GSis PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 l -( k 79 Unanalyzed Reactor Vessel Thermal Stress Durina Natural Convection Cooldown License renewal was not considered in the MEDIUM priority ranking of this issue which was resolved with no backfit.
Consideration of license renewal did not affect this resolution.
l 81 Impact of Locked Doors and Barriers on Plant and Personnel Safety License renewal was considered in the prioritization of this issue which was given a LOW priority ranking.
87 Failure of HPCI Steam Line Without Isolation License. renewal was not considered in the HIGH priority ranking of this issue which was resolved with backfit.
Consideration of license renewal did not affect this resolution.
89 Stiff Pioe Clamos 1
License renewal was not considered in-the LOW priority ranking of i
l this issue for operating plants based on the potential risk reduction (2,500 man-rem) and the high cost of resolution ($95.5M).
Consideration of license renewal did not change the priority of the issue.
100 Once-Throuah Steam Geherator Level '
((
License renewal was considered in the prioritization of this issue 1
which was placed in the DROP category.
105' Interfacina Systems LOCA at'lWRs License renewal was not considered in the HIGH priority ranking of this issue but was considered in the resolution which resulted in no backfit.
Consideration of license renewal did not affect this resolution.
110 Eauioment Protective Devices on Enaineered Safety Features License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the potential risk reduction (negligible). Consideration of license renewal did not change the priority of the issue.
l
'113 Dynamic Oualification Testina of larae Bore Hydraulic Snubbers License ranewal was not considered in the HIGH priority ranking of this issue which was resolved with no backfit.
Consideration of license renewal did not affect this resolution.
118 Tendon Anchoraae Failure i
License renewal was not considered in the prioritization of this i
issue which was placed in the RESOLVED category based on the voluntary actions taken by licensees to address the safety concern.
Consideration of license renewal did not change the priority of the issue.
2
r---O o e, ENCLOSURE 1 80 GSis PRIORITIZED AND/0R' RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994
)
120 ~
On-Line Testability of Protection Systems License renewal was not considered in the MEDIUM priority ranking of this issue which was. resolved with no' backfitv Consideration of
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license renewal did not affect this resolution.
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121' Hydrocen Control for Larae. Dry PWR Containments License renewal was not considered in HIGH priority ranking of this issue which was resolved with no backfit. Consideration of license renewal'(id not affect this resolution.
123 Deficiencies ~ in the Reaulations Governina DBA and Sinale-Failure Criteria Succested by the Davis-Besse Event of June 9.1985
. License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the findng-that the safety concerns either had been or were being addressed in f
other GSIs or NRC programs.
Consideration of license renewal did
.not change the' priority of the issue.
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-128 Electrical Power Reliability License. renewal was not considered in the HIGH priority ranking of this issue which -was resolved with backfit.
Consideration of l
i license renewal did not affect this, resolution.
130 Essential Service Water Pumo Failures at Multiolant Sites License renewal was not considered in the HIGH priority ranking of this issue which was resolved with backfit.
Consideration of license renewal did not affect this resolution.
132 RHR System inside Containment License renewal was _not considered in the prioritization of this issue which was placed in the DROP category based on the conclusion that' the potential reduction in core damage frequency was not substantial enough to meet the Backfit Rule (10 CFR. 50.109).
Consideration of. license renewal.did not change the priority of the
' issue.
Steam Generator and Steam line Overfill'e MEDIUM priority ranking of 135-License renewal was not considered in th this issue ~.which was resolved with no backfit based on the low public risk associated with steam generator tube rupture and steam
.line overfill events.
Consideration of license renewal did not affect this resolution.-
138' Deinertino of BWR MARK I and 11 Containments Durina Power Operations
~
Voon Discovery of RCS Leakace or a Train of a Safety System Inocerable License renewai was considered in the LOW priority ranking of this issue.
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n, ENCLOSURE 1 80 GSis PRIORITIZED AND/0R RESOLVED BETWEFN OCTOBER 1990 AND MARCH 1994 142 -
Leakaae Throuah' Electrical Isolators in Instrumentation Circuits License renewal was not considered in the MEDIUM priority ranking of this issue which was resolved with no backfit.
Consideration of license renewal did not affect this resolution.
143 Availability of Chilled Water Systems and Room Coolina License renewal was not considered in the HIGH priority ranking of this issue which was resolved with no backfit.
Consideration of license renewal did not affect this resolution.
144 Scram Without a Turbine / Generator Trio License renewal was not considered in the LOW priority ranking of this issue based. on the potential risk reduction (52 man-rem).
Consideration of license renewal did not change the priority of the issue.
145 Actions to Reduce Connon Cause Failures License renewal was considered in the prioritization of this issue which was placed in the NEARLY-RESOLVED category.
In accordance with RES Office Letter No. 3, license renewal will have to be addressed again in the resolution of the issue.
146 Sucoort Flexibility of Eouioment an'd Components
((.
License renewal was not considered in LOW priority ranking of this
' issue for operating plants based on the findings that the safety concern had been addressed in another GSI and an ongoing NRC I
program.
Consideration of licese renewal did not change the priority of the issue.
i 149-Adeouacy-of Fire Barriers License renewal was not considered in the LOW priority ranking of this issue based on the potential risk reduction (500 man-rem).
Consideration of license renewal did not change the priority of the issue.
150 Overoressurization of Containment Penetrations License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the potential risk reduction (40 man-rem). Consideration of license renewal did not change the priority of the issue.
~
151 Reliability of Anticipated Transient Without SCRAM Recirculation Pumo Trio in BWRs License. renewal was not cons'idered in the MEDIUM priority ranking of this issue which was resolved ith no backfit; a more detailed analysis showed very little risk reduction potential. Consideration of license renewal did not affect this resolution.
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ENCLOSURE 1 80 GSIs PRIORITIZE0 AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994
('k 152 -
Desian Basis for Valves That Micht Be Subiected to Sionificant Blowdown loads License renewal was not considered in the LOW priority ranking of this issue based on the potential risk reduction (110 man-rem).
Consideration of license renewal did not change the priority of the issue.
153 Loss of Essential Service Water in LWR 1 License renewal was not considered in the HIGH priority ranking of this issue.
However, license renewal was considered in the resolution of this issue which was resolved with no backfit.
i 154_
Adeouacy of Emeroency and Essential Liahtino License renewal was not considered in the LOW priority ranking of this issue based on the potential risk reduction (1,854 man-rem) and the high cost of resolution ($18.75M).
Consideration of license renewal did not change the priority of the issue.
i 155.1 More Realistic Source Term Assumptions This issue involves deve.l_oping a new licensing basis source term to replace TID-14844.
This new source term is being based on recent severe accident research findings.
Accordingly, consideration of license renewal will not impact the' resolution of this issue.
155.3 Imorove Desian Reouirements for Nuclear Facilities License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the findings that the safety concerns either had negligible risk reduction potential or were addressed or being addressed in other NRC programs.
Consideration of license renewal did not change the priority of the issue.
155.4 Imorove Criticality Calculations License renewal was not considered in the prioritization of this issue which was placed
+tN ORnP category based on the finding that the safety concer ng addressed in an ongoing NRC program.
Considerni-
.t ose renewal did. not change the priority of the is 155.5 More Realistic Severeleactor Accident Scenario License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed by an ongoing NRC program.
Consideration of license renewal did not change the priority of the issue.
155.6 Imorove Decontamination Reaulations License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the - safety concern was being addressed in an ongoing NRC lt -
program.
Consideration of license renewal did not. change the priority of the issue.
l.
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n ENCLOSURE 1
'80'GSIs PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 155.7" Imorove'Decommissionina Reaulations License' renewal was not. considered in the prioritization of this issue which was placed in the DROP category based on the finding b
that the safety concern was being addressed in an. ongoing NRC program.
Consideration of license renewal did not <hange the priority of.the issue.
156.1.1
' Settlement of Foundations and Buried Eauinment
. License renewal was not considered in the prioritization of this issue ~ which was. placed in' the DROP category based on the finding that - the safety ~ concern was being addressed in an ongoing-NRC program.. Cnnsideration of license renewal did not change the priority of_the issue.
156.1 ^. 2 Dam Intearity and Site Floodina License. renewal. was not considered in the prioritization of this issue which-was placed in the DROP category based on the finding
'that the safety concern was being addressed in an ongoing NRC program..
Consideration of license. renewal did not change the priority of the issue.
s-156.1.3 Site Hydroloov and Ability to Withstand Floods License renewal was not considered:in the prioritization of this
!((.
issue which was placed in _the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC i'
program.
Consideration of license renewal did not change the priority of_the issue..
I 156.1.4 Industrial Hazards
- License renewal was not considered'in the prioritization of this
' issue which was placed in the DROP category based on the finding that. the safety concern was being addressed in an ongoing NRC program.
-Consideration of license renewal did not change the priority of.the issue.
I 156.1.5 Tornado Missiles License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the L
priority of the issue.
l-156.1.6-Turbine Missiles
' License renewal was not co5sidered in the prioritization of this issue which was placed in' the DROP category based on the finding that the safety concern had'been previously addressed in Issue A-37 l-(evaluated in NUREG/CR-5382). Consideration of license renewal did not. change the priority of.the issue.
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ENCLOSURE 1
[.
80 GSis PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 t
156.2cl Severe Weather Effects on Structures License renewal was not' considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety Joncern was being addressed in an ongoing NRC program.
Consideration of license renewal did not _ change the priority of the issue.
156.2.2 Desian Codes. Criteria. and Load Combinations License renewai ho out considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern 'was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the priority of the issue.
156.2.3 Containment Desian and insoection License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was addressed in Issue 118 (evaluated above).
Consideration of license renewal did not change the priority of the issue.
156.2.4 Seismic Desian of Structures. Systems. and Components License renewal was not considered' in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the priority of the issue.
156.3.1.1 Shutdown Systems-License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the priority of the issue.
156.3.1.2 Electrical Instrumentation and Controls License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the priority of the issue.
156.3.2 Service and Coolina Water Systems License renewal was not considered in the prioritization of this l
issue which was placed in the DROP category based on the finding l
that the safety concern was addressed in Issues 51 (evaluated in NUREG/CR-5382),
and
- 130, 143, and 153 (evaluated above).
Consideration of license renewal did not change the priority of the
' issue.
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ENCLOSURE 1 80 GSIs PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 156.3.3 Ventilation Systems License renewal was not considered in the prioritization of this issue.which was placed in the DROP category based on the finding that the safety concern was addressed in Issues 136 (evaluated in NUREG/CR-5382),143 (evaluated above), and 83 and 106_(currently being resolved).
Consideration of license renewal did not change the priority of the issue.
156.3.4
'Isosauon 'of riich and low Prengre Systems i
License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was addressed in Issue 105 (evaluated above).
Consideration of license renewal did not change the priority of the issue.
i i
156.3.5 Automatic ECCS Switchover License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was addressed in Issue 24 (evaluated above).
Consideration of license renewal did not change the priority of the issue.
156.3.6.1 Emeroency AC Poweg q
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License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was addressed in Issues 128 (evaluated above) and B-56 (evaluated below). Consideration of license renewal did not change the priority of the issue.
4 156.3.6.2 Entraency DC Power Li4erse renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was being addressed in an ongoing NRC program.
Consideration of license renewal did not change the
'~
priority of the issue.
156.3.8 Shared Systems License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding i
that the safety concern was addressed in Issues 43 and A-44 (evaluated in NUREG/CR-5382) and 130 (evaluated above).
Consideration of license renewal did not change the priority of the issue.
156.4.1 RPS and ESFS isolation License renewal was not considered in the prioritization of this issue which was incorporated into the resolution of Issue 142 (evaluated above). Consideration of license renewal did not change the priority of the issue.
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L l9 ENCLOSURE 1 r
l1 80 GSis PRIORITIZED AND/OR RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 iL Testino of the RPS and ESFS 156.4.2 License renewal was not considered in the prioritization of this ~
issue which was incorporated into the resolution of Issue 120 (evaluated above). Consideration of license renewal did not change the priority of the issue.
157 Containment Performance License renewal was not considered in the prioritization of this issue which was placed in:the RESOLVED category based on the finouif that the safety concern was addressed in a completed NRC program.
Consideration of license renewal did not change the priority of the
. issue.
158 Performance of Power-Operated Valves Under Desion Basis Conditions License renewal was not considered in the MEDIUM priority ranking of this issue but, in accordance with RES Office Letter No. 3, will be addressed during resolution.
159 Oualification of Safety-Related Pumos While Runnino on Minimum Flow License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that. the safety concern had been addressed by Bulletin 88-04.
Consideration of license renewal did not change the priority of the issue.
160 Sourious Actions of Instrumentation Voon Restoration of Power License renewal was not con!,idered in the prioritization of this
' issue which was placed in the DROP category based on the potential risk reduction (4,320 man-rem) and the high cost of resolution
($46M). Consideration of license renewal will only move the issue to a LOW priority ranking.
161-Use of Non-Safety-Related Fower Supolies in Safety-Related Circuits License renewal was not considered in the prioritization of this issue which was placed in the DROP category based on the finding that the safety concern was one of compliance with existing regulations.
Consideration of license renewal did not change the priority of the issue.
l 162 Inadeouate Technical Soecifications for Shared Systems at Multiolant Sites When One Unit is Shutdown l-License renewal was not considered in the prioritization of this issue which was placed in, he DROP category based on the finding t
that _ the safety concern was addressed in other NRC programs.
Consideration of license renewal did not change the priority of the issue.
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ENCLOSURE 1 80 GSIs PRIORITIZED AND/OR RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 k
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~164 Neutron' Fluence in Reactor Vessel by License renewal was not considered in the prioritization -of this issue. which was placed in the DROP category based on. the finding l
l that the. safety concern.was addressed in other NRC programs.
l-Consideration of license renewal did not change the priority of the l
Lissue.
165 Sorina-Actuated Safety and Relief Valve Reliability L:icense renewal was not considered in the HWH priority ranking of this issue but,- in accordance with RES Office Letter No. 3, will be addressed dur'ng resolution.
166 Adecuacy of' Fatiaue Life of Metal Components License renewal was not considered in the prioritization of this issue which was placed in the NEARLY-RESOLVED category. NRR has the lead responsibility for resolving this issue and would be expected to follow the Statement of Consideration in the License Renewal Rule
. (56. FR.64943) in considering license renewal during resolution.
168 Environmental Qualification of Electrical Eauioment.
License renewal was not considered in. the prioritization of this issue which was placed in the NEARLY-RESOLVED category. NRR has the lead responsibility for resolving this issue and would be_ expected
'6 to follow the Statement of Consideration in the License Renewal Rule (56. FR 64943) in considering license renewal during resolution.
B LWR Fuel License renewal was not considered in the prioritization of this
)
' issue which was placed in.the DROP category based on the negligible
. risk reduction potential. Consideration of license renewal did not change _the_ priority of the issue.
B-56 Diesel Reliability License renewal was not considered in the HIGH priority ranking of
-this issue which was resolved with the' issuance of Regulatory Guide
'1.9. Rev. 3 and incorporation of' diesel generator maintenance by.the Maintenance Rule. Consideration of license renewal did not affect
]
this resolution.
HF4.4
. Guidelines'for Vooradina Other Procedures License renewal was not considered in the HIGH priority ranking of l
this issue which was resolved with no' backfit.
Consideration of L
-license renewal did not affect this resolution.
)
HFS.1 Local Control Stations
-License renewal was not considered in the HIGH priority ranking of 1
this issue which was resolved with no backfit.
Consideration of license -renewal did not affect this resolution.
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ENCLOSURE 1 l
80 GSIs PRIORITIZED AND/0R RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 HF5. 5 "
Review Criteria for Human Factors Asoects of Advanced Controls and Instrumentation l
License renewal was not considered in the HIGH priority ranking of l
this issue which was resolved with no backfit.
Consideration of i
license renewal did not affect this resolution.
I.D.3-Safety System Status Monitorina License renewal was not considered in the MEDIUM priority ranking of this issue which was resolved wi.h no backfit.
Consideration of license renewal did not affect this resolution.
II.J.4.1 Revise Deficiency Reportino Reouirements License renewal was not considered in the prioritization of this issue which was placed in the NEARLY-RESOLVED category and resolved with no backfit; procedure changes do not qualify as backfit.
Consideration of license renewal did not affect this resolution.
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ENCLOSURE 2
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21 GSIs-RESOLVED BETWEEN OCTOBER 1990 AND MARCH 1994 (SEE TITLES IN ENCL 0SURE 1) 29 73
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79 87 105 113 120 121 128 130-135 142 143 151 153 B-56 HF4.4 HF5.1 i
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