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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20211D3981999-08-24024 August 1999 Safety Evaluation Supporting Requested Actions to Licenses DPR-42 & DPR-60,respectively ML20207B5931999-05-26026 May 1999 SER Accepting Licensee Proposed Alternative to ASME Code for Surface Exam (PT) of Seal Welds on Threaded Caps for Unit 1 Reactor Vessel Head Penetrations for part-length CRDMs ML20202J1731999-01-22022 January 1999 Safety Evaluation Concluding That NSP Proposed Alternative to Surface Exam Requirements of ASME BPV Code for CRD Mechanism Canopy Seal Welds Will Provide Acceptable Level of Quality & Safety ML20237A8171998-08-0505 August 1998 SER Related to USI A-46 Program GL 87-02 Implementation for Prairie Island Nuclear Generating Plant,Units 1 & 2 ML20217M6901998-04-29029 April 1998 Safety Evaluation Accepting Methodology for Relocation of Reactor Coolant Sys P/T Limit Curves & LTOP Sys Limits Proposed by NSP for Pingp,Units 1 & 2 ML20203H8331998-02-20020 February 1998 SE Accepting Proposed Alternative to ASME Code for Surface Exam of Nonstructural Seal Welds for Prairie Island Nuclear Generating Plant,Unit 2 ML20148D5441997-05-16016 May 1997 Safety Evaluation of Prairie Island Nuclear Generating Plant Individual Plant Exam ML20138J9961997-05-0606 May 1997 Safety Evaluation Accepting Proposed Alternative to ASME Code for Surface Exam of CRD Mechanism Canopy Seal Welds ML20058N8021993-12-0808 December 1993 Safety Evaluation Approving Third 10-yr IST Program Requests for Pumps & Valves,Per 10CFR50.55a(f)(6)(i) & 10CFR50.55a(a)(3)(i) ML20127C0071993-01-0404 January 1993 Supplemental SE Accepting Changes & Additions Described in Rev 1 to Design Rept for Station Blackout/Electrical Safeguards Upgrade Project ML20127C0291993-01-0404 January 1993 Safety Evaluation Accepting pressure-retaining Components of safety-related Auxiliary Fluid Sys Associated W/Edgs ML20127C0241993-01-0404 January 1993 Safety Evaluation Re Audit of Load Sequencer Implementation. Four of Five Items Reviewed Acceptable & Closed.One Open Item Remained Re Electromagnetic Environ Qualification for Lower Frequency Range of 30 Hz to 10 Khz ML20127C0151993-01-0404 January 1993 Safety Evaluation Accepting Instrumentation & Control Sys Aspects of Unit 2 Load Sequencer Sys in Station Blackout/ Electrical Safeguards Upgrade Project ML20128A7301992-11-30030 November 1992 Safety Evaluation Accepting Licensee 920921 120-day Response to Suppl 1 to GL 87-02 Re in-structure Response Spectra ML20128A7171992-11-30030 November 1992 Safety Evaluation Accepting Licensee 920921 120-day Response to Suppl 1 to GL 87-02 as Commitment to Entire GIP-2, Including Both SQUG Commitments & Implementation Guidance. In-structure Response Spectra Addressed in Separate SE ML20151U1181988-08-17017 August 1988 Safety Evaluation Re Compliance W/Atws Rule (10CFR50.62). Design Acceptable Contingent Upon Successful Completion of Human Factors Engineering Studies & Qualification of Isolation Devices ML20235Y4791987-07-13013 July 1987 Supplemental Safety Evaluation Accepting Util 870120 Requests for Relief from ASME Code Requirements Re Inservice Insp & Testing Program for Second 10-yr Interval ML20205Q8071987-03-30030 March 1987 SER Accepting Util 861104 & 840706 Responses to Generic Ltr 83-28,Item 4.5.2 Re ATWS Requirements for on-line Testing of Reactor Trip Sys ML20205M5261987-03-27027 March 1987 Safety Evaluation Denying Util 860819 Proposal to Reproduce Radiographs on Microfilm ML20211Q2971987-02-18018 February 1987 Safety Evaluation Re Auxiliary Feedwater Sys Reliability (Generic Issue 124) for Prairie Island Units 1 & 2 ML20209C2151987-01-21021 January 1987 Safety Evaluation Re Auxiliary Feedwater Sys Reliability (Generic Issue 124) at Prairie Island Units 1 & 2.Util Actively Pursuing Improvements in Sys Reliability & Reducing Sys Challenges ML20214S4131986-11-26026 November 1986 Safety Evaluation Finding Auxiliary Feedwater Sys Adequately Designed,Maintained & Operated.Licensee Actively Pursuing Improvements in Auxiliary Feedwater Sys Reliability & in Reducing Challenges to Sys ML20214C9231986-11-14014 November 1986 Safety Evaluation Supporting Amends 80 & 73 to Licenses DPR-42 & DPR-60,respectively ML20212K8801986-08-15015 August 1986 Corrected Safety Evaluation Accepting Util 860110 Projected Values of Matl Properties for Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events ML20203B1551986-07-11011 July 1986 SER Re Util 831104 Response to Generic Ltr 83-28,Item 2.1 (Part 1), Equipment Classification. Program Acceptable. Exemption of Turbine Trip Component from Listing Also Acceptable ML20202A7531986-06-23023 June 1986 Safety Evaluation Supporting Projected Values of Matl Properties for Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events ML20199L4491986-06-23023 June 1986 Safety Evaluation Re Util 860110 Projected Values of Matl Properties for Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events.Response Acceptable ML20211A3791986-05-30030 May 1986 Safety Evaluation Re Use of VIPRE-01 Subchannel Thermal Hydraulic Code & WRB-1 Critical Heat Flux Correlation W/Min DNBR Limit of 1.17.Code & Correlation Acceptable ML20211A2111986-05-27027 May 1986 SER Supporting Util Response to Generic Ltr 83-28,Item 1.2, Post-Trip Review (Data & Info Capability) ML20141N0961986-02-25025 February 1986 Safety Evaluation Accepting K(Z) Curve & Current Tech Spec Fq Value of 2.32 ML20138H1951985-10-18018 October 1985 Safety Evaluation Re Util 850422 & 0830 Ltrs Concerning Removal of Rod Cluster Control Guide Tube Thimble Plugs. Plan Acceptable ML20133N2021985-10-18018 October 1985 Safety Evaluation Accepting Util 830415,0915,850118 & 0606 Responses to Generic Ltr 82-33 Re Conformance of post- Accident Monitoring Instrumentation W/Rev 2 to Reg Guide 1.97 ML20138P6301985-10-17017 October 1985 Safety Evaluation Re Util 831104 Response to Generic Ltr 83-28,Items 4.2.1 & 4.2.2 Concerning Reactor Trip Breaker Automatic Shunt Trip.Licensee Position on Items Acceptable ML20138E1661985-10-11011 October 1985 Safety Evaluation Re 850809 Inservice Insp of Components Relief Requests 29 & 66.Alternative Acceptable & Relief Should Be Granted ML20133P0521985-08-0505 August 1985 Safety Evaluation Accepting Util post-trip Review Program & Procedures.Nrc Action on Item 1.1 of Generic Ltr 83-28 Completed ML20128M9091985-05-13013 May 1985 Safety Evaluation Supporting Util 831104 Response to Generic Ltr 83-28,Items 3.1.1,3.1.2,3.2.1,3.2.2,4.1 & 4.5.1 ML20062B6451982-07-0909 July 1982 Safety Evaluation Supporting Thermal Hydraulic Margins for Exxon Toprod for Cycle 7 ML20062B6361981-10-20020 October 1981 Safety Evaluation Supporting Thermal Hydraulic Margins for Exxon Toprod for Cycle 7 1999-08-24
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20217G4461999-09-30030 September 1999 Monthly Operating Repts for Sept 1999 for Pingp.With ML20217A9931999-09-30030 September 1999 NRC Regulatory Assessment & Oversight Pilot Program, Performance Indicator Data ML20217A1691999-09-22022 September 1999 Part 21 Rept Re Engine Sys,Inc Controllers,Manufactured Between Dec 1997 & May 1999,that May Have Questionable Soldering Workmanship.Caused by Inadequate Personnel Training.Sent Rept to All Nuclear Customers ML20216E7151999-08-31031 August 1999 Monthly Operating Repts for Aug 1999 for Pingp,Units 1 & 2. with ML20211D3981999-08-24024 August 1999 Safety Evaluation Supporting Requested Actions to Licenses DPR-42 & DPR-60,respectively ML20211C2531999-08-0404 August 1999 Unit 1 ISI Summary Rept Interval 3,Period 2 Refueling Outage Dates 990425-990526 Cycle 19 971212-990526 ML20210Q4891999-07-31031 July 1999 Monthly Operating Repts for July 1999 for Pingp,Units 1 & 2. with ML20211B5971999-07-31031 July 1999 Cycle 20 Voltage-Based Repair Criteria 90-Day Rept ML20209J1131999-07-15015 July 1999 Safety Evaluation of Topical Rept NSPNAD-8102,rev 7 Reload Safety Evaluation Methods for Application to PI Units. Rept Acceptable for Referencing in Prairie Island Licensing Actions ML20196H8621999-06-30030 June 1999 NRC Regulatory Assessment & Oversight Pilot Program, Performance Indicator Data, June 1999 Rept ML20209F9811999-06-30030 June 1999 Monthly Operating Repts for June 1999 for Prairie Island Nuclear Generating Plant,Units 1 & 2.With ML20196F4081999-06-23023 June 1999 Revised Pages 71,72 & 298 to Rev 7 of NSPNAD-8102, Prairie Island Nuclear Power Plant Reload Safety Evaluation Methods for Application to PI Units ML20195G5181999-05-31031 May 1999 Monthly Operating Repts for May 1999 for Prairie Island Nuclear Generating Plant,Units 1 & 2.With . Page 3 in Final Rept of Incoming Submittal Was Not Included ML20207B5931999-05-26026 May 1999 SER Accepting Licensee Proposed Alternative to ASME Code for Surface Exam (PT) of Seal Welds on Threaded Caps for Unit 1 Reactor Vessel Head Penetrations for part-length CRDMs ML20196L2501999-05-13013 May 1999 Rev 0 to PINGP Unit 1 COLR Cycle 20 ML20206L6191999-04-30030 April 1999 Monthly Operating Repts for Apr 1999 for Pingp,Units 1 & 2. with ML20205N1081999-03-31031 March 1999 Monthly Operating Repts for Mar 1999 for Pingp,Units 1 & 2. with ML20205Q5101999-03-15015 March 1999 Inservice Insp Summary Rept Interval 3,Period 1 & 2 Refueling Outage Dates 981109-1229 Cycle 19,970327-981229 ML20207J6951999-02-28028 February 1999 Monthly Operating Repts for Feb 1999 for Prairie Island Nuclear Generating Plant ML20202J7711999-02-0404 February 1999 Simulator Certification Rept for Prairie Island Plant Simulation Facility,1998 Annual Rept ML20202G3761999-01-31031 January 1999 Non-proprietary Rev 7 to NSPNAD-8102-NP, Prairie Island Nuclear Power Plant Reload SE Methods for Application to PI Units ML20207L2811999-01-31031 January 1999 Revised Monthly Operating Repts for Jan 1999 for Pingp,Units 1 & 2 ML20202J1731999-01-22022 January 1999 Safety Evaluation Concluding That NSP Proposed Alternative to Surface Exam Requirements of ASME BPV Code for CRD Mechanism Canopy Seal Welds Will Provide Acceptable Level of Quality & Safety ML20206P7861998-12-31031 December 1998 Monthly Operating Repts for Dec 1998 for Prairie Island Nuclear Generating Plant.With ML20205H0561998-12-31031 December 1998 Northern States Power Co 1998 Annual Rept. with ML20198J6441998-12-17017 December 1998 Rev 0 to PINGP COLR Unit 2-Cycle 19 ML20206N2731998-11-30030 November 1998 Monthly Operating Repts for Nov 1998 for Prairie Island Nuclear Generating Plant,Units 1 & 2.With ML20196D7341998-11-20020 November 1998 Third Quarter 1998 & Oct 1998 Data Rept for Prairie Island Isfsi ML20155K6301998-10-31031 October 1998 Monthly Operating Repts for Oct 1998 for Prairie Island Nuclear Generating Plant,Units 1 & 2.With ML20154H4061998-09-30030 September 1998 Monthly Operating Repts for Sept 1998 for Prairie Island Nuclear Generating Plant.With ML20202J7991998-09-30030 September 1998 Non-proprietary Version of Rev 3 to CEN-629-NP, Repair of W Series 44 & 51 SG Tubes Using Leaktight Sleeves,Final Rept ML20198P0571998-09-0303 September 1998 Rev 1 to 95T047, Back-up Compressed Air Supply for Cooling Water Strainer Backwash Valve Actuator ML20153B0761998-08-31031 August 1998 Monthly Operating Repts for Aug 1998 for Prairie Island Nuclear Generating Plant.With ML20237A3961998-08-11011 August 1998 Safety Evaluation on Westinghouse Owners Group Proposed Insp Program for part-length CRDM Housing Issue.Insp Program for Type 309 Welds Inadequate from Statistical Point of View ML20237A8171998-08-0505 August 1998 SER Related to USI A-46 Program GL 87-02 Implementation for Prairie Island Nuclear Generating Plant,Units 1 & 2 ML20236X8531998-07-31031 July 1998 Monthly Operating Repts for July 1998 for Prairie Island Nuclear Generating Plant ML20236R6481998-07-15015 July 1998 Metallurgical Investigation & Root Cause Assessment of Part Length CRDM Housing Motor Tube Cracking at PINGP Unit 2 - Preliminary Summary Rept ML20236R0771998-06-30030 June 1998 Monthly Operating Repts for June 1998 for Prairie Island Nuclear Generating Plant ML20249A5751998-05-31031 May 1998 Monthly Operating Repts for May 1998 for Prairie Island Nuclear Generating Plant ML20247G7011998-05-31031 May 1998 Metallurgical Investigation & Root Cause Assessment of Part Length CRDM Housing Motor Tube Cracking at Prairie Island Nuclear Generating Plant,Unit 2 ML20248M0561998-05-31031 May 1998 Rev 5 to CEN-620-NP, Series 44 & 51 Design SG Tube Repair Using Tube Rerolling Technique ML20247E2671998-05-0505 May 1998 Rev 0 to Pingp,Units 1 & 2,Pressure & Temp Limits Rept (Effective Until 35 Efpy) ML20247G2921998-04-30030 April 1998 Monthly Operating Repts for Apr 1998 for Prairie Island Nuclear Generating Plant ML20217M6901998-04-29029 April 1998 Safety Evaluation Accepting Methodology for Relocation of Reactor Coolant Sys P/T Limit Curves & LTOP Sys Limits Proposed by NSP for Pingp,Units 1 & 2 ML20216C6361998-03-31031 March 1998 Monthly Operating Repts for Mar 1998 for Prairie Nuclear Generating Plant Units 1 & 2 ML20216H0341998-03-31031 March 1998 Cycle-19 Voltage Based TSP Alternate Repair Criteria 90-Day Rept ML20217D2041998-03-13013 March 1998 Rev 1 to 28723-A, Intake Canal Liquefaction Analysis Rept for Pingp,Welch,Mn ML20236P9801998-03-12012 March 1998 Rev 0 to 97FP02-DOC-01, Compliance Review of 10CFR50,App R, Section Iii.O RCP Lube Oil Collection Sys ML20248L3931998-03-10010 March 1998 ISI Summary Rept Interval 3,Period 1 & 2 Refueling Outage Dates 971018-971212 Cycle 18,960303-971212 ML20216D0911998-03-0606 March 1998 Rev 0 to Prairie Island Generating Plant,Units 1 & 2, Pressure & Temp Limits Rept 1999-09-30
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- C - UNITED STATES . I l' - IgnL NUCLEAR REGULATORY COMMISSION j
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. ENCLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR-REACTOR REGUL61LQN-EVALUATION OF THE NORTHERN STATES POWER COMPANY'S i
PRAIRIE ISLAND NUCLEAR GENERAlfNG PLANT, UNITS'l'AND 2-I 120-DAY RESPONSE TO SUPPLEMENT NO 1 IQ_AfNERIC LETTER 87-02 ,
DOCKET NOS. 50-282 AND 50-306. a BACKGROUND By its letter of September 21', 1992 to NRC, the licensee, Northern States ,
Fower (NSP), has committed to use the Seismic Qualification Utility Group-(SQUG) methodology as documented in Generic Implementation Procedure, Revision 2 ' GIP-2) to resolve the A-46 issue at Prairie Island Nuclear Generating Plant-(PINGP) Units 1 & 2. _-
t EVALUATION For the USl A-46 issue resolution of PINGP, NSP has provided the procedures- l and criteria-used-to generate.in-structure response spectra (IRS). The staff reviewed the submittal, and found the following-information:
- 1. The licensing basis ground motica at PINGP-is'specified in terms of Housner spectra on ' soil site tied to a peak ground acceleration (PGA) of 0.129 for the SSE and. 0.069 for the 08E. NSP used the time history. method using"a
~
ground acceleration time history motion 1 developed from the ground response spectra-(GRS) for-development of.the design basis' IRS.
- 2. A lumped mass stick model with; springs to account for interaction with~the soil was used in generating _the. IRS. The three-dimensional mathematical model was subjected to the ground acceleration time history, n 1 the response time history of- the: horizontal acceleration at.each t .ss point of the mathematical model was generated. _ The totalcresponse was determined by computing the square root of the-sum of squares of the maximum response of '
each mode. Using this response acceleration time history att selected mass ~
points, the IRS for the-desired damping values were calculated.
- 3. NSP states that the model was analyzed for earthquake motion-in both- _
2-horizontal directions acting non-concurrently. However, the submittal did not show how the analysis took into account the effects ~ of-two horizontal components as' well as the vertical component off the earthquake motion.-- ,
- 4. In order tofdetermine the total ~ spectral acceleration at the point of- ..'
-support of the' equipment or piping in the three-dimensional = dynamic.
-analysis, a torsional acceleration was considered by multiplying the
- translational ' acceleration by the factor shown -in the submittal .
9212030436 921130 2-PDR ADOCK 0500 P
. -. _ _ . . __ = _
2 Additional live load (snow load) cf 50 psf on the roof of each structure was also considered in the dynamic analysis.
- 6. The IRS provided in the submittal for the reactor building, the turbine building, and the auxiliary building are for the OBE (0.069) only. -NSP states that the IRS for the SSE (0.129) will be obtained by multiplying the OBL IRS by a factor of 2.0, which is the ratio of the SSE (0.129) to OBE (0.06g) maximum ground acceleration. It also states that a similar procedure has been taken to generate the IRS for the screen house.
- 6. There is no indication in the submittal about consideration of variation of the foundation medium properties in the dynamic analysis.
- 7. Although no mention is made of any peak broadening of the IRS, the spectra curves provided by NSP show some minimal amount of peak broadening to produce the design IRS.
Based on our review of the licensee response and the staff positions delineated in the SSER No. 2, we conclude that the procedure used to generate the IRS is adequate, and the IRS presented in the submittal are accepted as
" conservative, design" IRS according to the pertinent definition in SSER 2.
Furthermore, NSP states in the submittal that the-licensee may generate and use realistic, median-centered IRS as an additional option per the provision of the GIP-2 for resolution of USI A-46 issue. NSP is requested to provide all information related to the " realistic, median-centered". IRS generation for NRC review before implementation, should such an option be taken for resolution of the USl A-46 issue.
l The staff's evaluation is based on an assumptior snat the statements made in
- the submittal, including the procedures used in generation of the floor response spectra, correctly reflect the FSAR and other licensing basis. The staff may audit the process by which the IRS were generated.
004ClVSION l
Based on our review of the licensee response and the staff positions delineated in the SSER No. 2, we conclude that the procedure used to generate
< the IRS is adequate, and the IRS presented in the submittal are accepted as l " conservative, design" IRS according to the pertinant definition in SSER 2.
l l
l
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- . e, ENCLOSURE 3
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- UNITED STATES
[ ' Q ,, g NUCLEAR REGULATORY COMMISSION-WASHING TON, D. C. 20666
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QCT 0 2 R Mr. Neil Smith, Chairman Seismic Qualification Utility Group c/o EPRI 1019 19th Street, N.W.
Washington, DC 20036
SUBJECT:
NRC RESPONSE TO SEISMIC QUALIFICATION UTILITY GROUP (SQUG)
Re: Letter, 8. Smith, EPRI, To J. Partlow, NRR, dated August 21, 1992, concerning USI A-46 Issues.
Dear Mr. Smith:
This is to acknowledge the receipt of the SQUG response to Supplement No. 1-to Generic Letter (GL) 87-02, and Supplemental Safety Evaluation (SSER) No. 2 on o the SQUG Generic Implementation Procedure-fcr Geismic Verification of Nuclear Plant Equipment, Revision 2, as corrected February 14, 1992 (GIP-2). -The NRC staff believes that successful implementation of the entire GIP-2, supple -
mented by the staff's SSER No. 2, by each SQUG licensee will result in cost-effective plant safety' enhancement for their USI A-46-plants.
The staff also believes that the positions delineated in Supplement No.n1 to GL 87-02 and SSER No. 2 are clear and correct, and should not be misinterpret-ed. The staff's comments on SQUG's August 21, 1992, letter and attachment are provided in the enclosure to this letter. If you need further clarification concerning our response, please contact Mr. James Norberg at'SO4-3288.
Sincerely, r
0 James G. Partlow
. Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated 3M 3 ' f . N
- y. m3 ,nz -,S- g gww e n hy v ** '
~
ENCLO$URE I. NRC's Comments on the SOUG Letter of Auaust 21. 1992:
- 1. In regard to the hsue of seismic qualification, the staff reiterates the position stated in the SSER No. 2, in that the GIP-2 methodology is not considered to be a seismic qualification method, rather, it is an acceptable evaluation method, for USl A-46 plants only, to verify the seismic adequacy of the safe-shutdown equipment and to ensure that the pertinent equipment seismic requirements of General Design Crit 3rion 2 and the purpose of the NRC regulctions relevant to equipment seismic adequacy including 10 CFR Part 100 are satisfied.
- 2. The second paragraph on page-2 of your letter addressed the issue of timing of staff response to additional information requested from a licensee. Although you are correct in your statement regarding the sixty-day period for response to initial submittal of in-structure response spectra (ISRS) Information, we do not agree that the same concept applies to a licensee's submittal of additional information received following a rejection or a question from the staff. To elimirate any potential misunder-standing in this regard, the staff has determined that it will respond to any submittal of additional information received from a licensee within 60 days. However, in this response, the staff will either state its approval (or rejection) of the information provided, or indicate the time duration needed for the review of such information, prior to transmitting a follow-up response of acceptance (or rejection) to the licensee. This time duration will vary depending on the complexity of the submittal.
- 3. Regarding the EBAC and ANCHOR computer. codes, the staff's evaluations and concerns stated in the SSER No. 2 are correct and valid. The ANCHOR code does not consider the effects of base plate flexibility on the anchorage capacity.
- 4. With respect to transfer of knowledge regarding major problems identified, and lessons learned, in the USI A-46 plant walkdowns and third-party reviews, we request that you include the NRC in the distribution of written comunications to all member utilities in this regard, and inform the NRC staff of any planned workshops on A-46 implementation for possible staff participation.
II. RC's Comgatj on th' e Procedure for Reviewino the GIP
- 1. The staff supports SQUG's establishment of a Peer Review Panel composed of seismic experts since it should serve to enhance the review process of substantive changes to the technical requirements in the GIP, prior to its submittal to NRC for approval. However, since the NRC no longer intends to help finance a Peer Review Panel, the staff does not believe it
- y.; , . . . . . . .
2-is appropriate to-participate in the selection of the Peer Review '
members, who will be financed by SQUG/EPRI. We would like to emphasize that staff's review of a p.oposed GIP change will receive thorough independent NRC evaluation and will be assessed on its merits.
- 2. With respect to the NRC review and approval of the changes to-the GIP (Item 5, page 3 of the procedure), the staff's position on the issue of its response timing is identical to that delineated in the response to a licensee submittal of additional information (refer to item P. of NRC's Coreents on the SQUG 1etter in this enclosure). This comment also applies to the section " LICENSING CONSIDERATIONS" on page 5 of the Attachment to the SQUG letter.
- 3. With respect to item 4, " Additional Restrictions," the text should be expanded to reflect that new information which indicates that existing GIP criteria and guidelines may be unconservative should be evaluated for potential 10 CFR Part 21 implications.
.