ML083290343

License Amendment Request Updating Leak-Before-Break Evaluation

ML083290343
Person / Time
Site:	Catawba
Issue date:	11/20/2008
From:	Morris J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML083290343 (20)

Text

Duke JAMES R. MORRIS, VICE PRESIDENT rEnergy Duke Energy Carolinas, LLC Carolinas Catawba Nuclear Station 4800 Concord Road / CN01 VP York, SC 29745 803-701-4251 803-701-3221 fax November 20, 2008 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke)

Catawba Nuclear Station Unit 2, Docket Number 50-414 License Amendment Request Updating Leak-Before-Break Evaluation In accordance with the provisions of 10 CFR 50.90, Duke is submitting a License Amendment Request (LAR) to update the Leak-Before-Break (LBB) evaluation for Catawba Nuclear Station Unit

2.

This LAR is being submitted in conjunction with Duke's proposal to apply Full Structural Weld Overlays (FSWOLs) to the reactor vessel hot leg nozzle-to-safe end welds in the upcoming Spring 2009 refueling outage.

MRP-139 related Request for Relief 08-CN-002 governing the FSWOLs was submitted under separate cover on November 6, 2008.

The Catawba Unit 2 LBB evaluation was originally approved by the NRC in a letter dated April 23, 1985.

At the time of original

approval, it was not known that these welds may be susceptible to Primary Water Stress Corrosion Cracking (PWSCC). provides Duke's evaluation which contains a description of the proposed changes, the technical evaluation, the determination that this LAR contains No Significant Hazards Consideration, and the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement. contains the vendor report describing details of the LBB evaluation.

This report contains information that is proprietary to Westinghouse.

In accordance with.10 CFR 2.390, Duke requests that this information be withheld from public disclosure. to this letter contains proprietary information Withhold From Public Disclosure Under 10 CFR 2.390 Upon removal of the attachment, this letter is uncontrei.&e

-energy.com

U.S. Nuclear Regulatory Commission Page 2 November 20, 2008 An affidavit from Westinghouse attesting to the proprietary nature of the information is provided as Enclosure 1.

A non-proprietary version of this report will be submitted by a separate cover letter following NRC approval of this LAR.

The Catawba Updated Final Safety Analysis Report (UFSAR) will be updated as necessary as required by 10 CFR 50.71(e).

Duke requests approval of this LAR to support FSWOL application during the Catawba Unit 2 Spring 2009 refueling outage.

Approval is requested by March 1, 2009.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, this LAR has been previously reviewed and approved by the Catawba Plant Operations Review Committee and by the Duke Nuclear Safety Review Board.

Pursuant to 10 CFR 50.91, a copy of this LAR has been forwarded to the appropriate State of South Carolina official.

There are no regulatory commitments contained in this LAR.

If you have any questions or need additional information on this matter, please contact L.J. Rudy at (803) 701-3084.

Very truly yours, Ja esR orris Attachments:

1. Licensee Evaluation

2.

Leak-Before-Break Evaluation

Enclosure:

1. Notarized Affidavit from Westinghouse to this letter contains proprietary information Withhold From Public Disclosure Under 10 CFR 2.390 Upon removal, of the attachment, this letter is uncontrolled

U.S. Nuclear Regulatory Commission

• Page 3 November 20, 2008 James R.

Morris affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Jamet.

Morris, Vice President Subscribed and sworn to me: YoOe 2ce)zve Date o'tary Public dAAMKX/

My commission expires:

doll

/

2/I

..,AiAa./

Date SEAL to this letter contains proprietary information Withhold From Public Disclosure Under 10 CFR 2.390 Upon removal of the attachment, this letter is uncontrolled

U.S. Nuclear Regulatory Commission Page 4 November 20, 2008 xc (with attachments and enclosure)

L.A.

Reyes U.S.

Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85

Atlanta, GA 30303 A.T. Sabisch Senior Resident Inspector (CNS)

U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.F. Stang, Jr. (addressee only)

NRC Senior Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A 11555 Rockville Pike Rockville, MD 20852-2738 S.E. Jenkins Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 to this letter contains proprietary information Withhold From Public Disclosure Under 10 CFR 2.390 Upon removal of the attachment, this letter is uncontrolled Licensee Evaluation

U.S.

Nuclear Regulatory Commission Page 1 of 7 November 20, 2008 LICENSEE EVALUATION

Subject:

License Amendment Request Updating Leak-Before-Break Evaluation for Catawba Unit 2 Reactor Vessel Hot Leg Nozzle-to-Safe End Weld 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

U.S. Nuclear Regulatory Commission Page 2 of 7 November 20, 2008 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Catawba Unit 2 LBB evaluation which was originally approved by the NRC for the first two operating cycles by letter dated April 23, 1985.

The original approval was granted pending the completion of rulemaking on this subject.

The original evaluation was determined to be adequate to show compliance with 10 CFR 50, Appendix A,- General Design Criterion (GDC) 4, "Environmental and Dynamic Effects Design Bases".

The amended LBB evaluation submitted herein applies to the reactor vessel hot leg nozzles to support the application of FSWOLs to the Alloy 82/182 welds connecting the reactor vessel hot leg nozzle-to-safe end.

2.0 DETAILED DESCRIPTION The application of LBB evaluation as a method for meeting the requirements of GDC 4 was approved by NRC letter dated April 23, 1985 which granted an exemption request for Catawba Unit 2 (Ref.

1).

The original approval was for the first two operating cycles pending the completion of rulemaking on this subject.

On April 7,

1987, the NRC informed Duke that rulemaking had been completed and that an exemption was no longer necessary (Ref.

2).

At the 'time of approval, it was not recognized that these welds were susceptible to PWSCC.

Requirements in NUREG/CR-1061, Vol.

3, "Report to the U.S. Nuclear Regulatory Commission Piping Review Committee",

and. Standard Review Plan (SRP) 3.6.3, Rev.

0, "Leak-Before-Break Evaluation Procedures", would not allow application of LBB evaluation to a PWSCC susceptible material.

However, SRP 3.6.3, Rev.

1 indicates that piping systems that are susceptible to PWSCC may qualify for application of LBB evaluation if treated with two mitigation methods and the piping contains no flaws larger than those permitted by ASME Section XI without repair (Ref.

3)..

Duke intends to mitigate the reactor vessel hot leg nozzle welds using FSWOLs during the Catawba Unit 2 Spring 2009 refueling outage.

The FSWOLs will utilize a non-PWSCC susceptible material (Alloy 52).

U.S. Nuclear Regulatory Commission Page 3 of 7 November 20, 2008 Due to the application of FSWOLs to the welds, the LBB evaluation needs to be updated to reflect the new configuration.

The application of FSWOLs with Alloy 52/52M weld metal provides a PWSCC resistant barrier and also results in compressive stresses on the inner portion of the welds, thereby providing further protection against PWSCC.

Thus, the application of FSWOLs provides two mitigation

methods, in addition to providing a smooth surface that can enhance future non-destructive examination of the welds.

The following is a summary of the LBB evaluation approach:

1.

Review the methodology and margins in the currently approved LBB evaluation.

2.

Address the effectiveness of PWSCC mitigation by application of the weld overlays and demonstrate that the post-weld overlay crack growth (both PWSCC and fatigue) is within acceptable limits for the balance of plant life.

The post-weld overlay inspections that will be performed to maintain the integrity of the repair are also addressed.

3.

Determine critical through-wall flaw sizes with the application of the weld overlays at the dissimilar metal welds and the adjacent safe end-to-pipe welds.

Consider the composite materials consisting of the original material and the weld overlay material.

4.

Determine leakage through half the critical flaw size and show that it is greater than the detectable leakage (1 gpm) with a factor of 10.

Address the PWSCC morphology in thedetermination of leakage.

5.

Provide the conclusions of the evaluations.

Proposed Update of LBB Evaluation The proposed update of the Catawba Unit 2 LBB evaluation is provided as Attachment 2, "Leak-Before-Break Evaluation, Hot Leg Nozzle Weld Overlays for Catawba Unit 2".

Proposed Update of UFSAR The Catawba UFSAR will be updated as necessary as required by 10 CFR 50.71(e).

U.S.

Nuclear Regulatory Commission Page 4 of 7 November 20, 2008

3.0 TECHNICAL EVALUATION

The proposed update of the Catawba Unit 2 LBB evaluation is provided as Attachment 2, "Leak-Before-Break Evaluation, Hot Leg Nozzle Weld Overlays for Catawba Unit 2".

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The applicable regulatory requirement for submitting the LBB evaluation to exclude dynamic effects associated with postulated pipe ruptures from the design basis is specified in 10 CFR 50, Appendix A, GDC 4.

This LAR is submitted in accordance with 10 CFR 50.90.

4.2 Precedent On September 17,

2008, Duke submitted a similar leak-before-break LAR for McGuire Unit 1 as a contingency to support weld inspections during the Fall 2008 refueling outage.

Following successful inspection of the welds, Duke subsequently withdrew the LAR.

4.3 Significant Hazards Consideration The proposed amendment would update the Catawba Unit 2 LBB evaluation to include mitigation of the reactor vessel hot leg nozzle-to-safe end welds by application of FSWOLs.

Duke has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendmect",

as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response

No.

U.S. Nuclear Regulatory Commission Page 5 of 7 November 20, 2008 The applicable accident is a Large Break Loss of Coolant Accident (LBLOCA).

Since the application of FSWOLs will enhance the integrity of the reactor coolant system, the probability of a previously evaluated accident is not increased..

The consequences of a LBLOCA have been previously evaluated and found to be acceptable.

Application of FSWOLs to the welds will cause no change to the dose analysis associated with a LBLOCA, and therefore, does not affect the consequences.

For the above reasons, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

No.

The proposed amendment will allow application of FSWOLs to mitigate potential PWSCC of the welds.

These welds provide a primary pressure boundary function.

This amendment request does not change the function of the welds, or the way the plant is operated; it allows the application of FSWOLs that will enhance the ability of the welds to perform the pressure boundary function.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response

No.

Margin of safety is related to the ability of the fission product barriers to perform their design functions during and following accident conditions.

These barriers include the fuel cladding, the reactor coolant system, and the containment.

This amendment request does not involve a change to the fuel cladding or the containment.

This amendment request updates

U.S. Nuclear Regulatory Commission Page 6 of 7 November 20, 2008 the LBB evaluation to account for the application of FSWOLs to the reactor vessel hot leg nozzle-to-safe end welds for Catawba Unit 2.

The effect of applying a weld overlay repair has been evaluated with respect to the LBB evaluation at this location.

This evaluation addresses mitigation of PWSCC in these welds.

This evaluation allows the application of a PWSCC resistant overlay that has the added benefit of producing compressive stresses on the inner portion of the welds.

Crack growth evaluations performed as part of the evaluation indicate that no PWSCC is expected after the application of the overlay and fatigue crack growth is minimal.

The effect of the adverse morphology due to PWSCC cracking was also eva'luated.

When. considering the combined effects of flaw size, increased thickness, and adverse morphology, the leakage was shown to be largely unaffected due to the offsetting effects of these factors.

The evaluation described above shows that these welds will perform as originally intended and that the adverse effects of PWSCC will be mitigated.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the preceding discussion, Duke concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed

above, (1) there is reasonable assurance that the, health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

U.S.

Nuclear Regulatory Commission Page 7 of 7 November 20, 2008

5.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.22(b),

an evaluation of this license amendment request has been performed to determine whether or not it meets the criteria for categorical exclusion,set forth in 10 CFR 51.22(c) (9) of the regulations.

Implementation of this amendment will have no adverse impact upon Catawba Unit 2; neither will it contribute to any additional quantity or type of effluent being available for adverse environmental impact or personnel exposure.

It has been determined that there is:

1.

No significant hazards consideration,

2.

No significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and

3.

No significant increase in individual or cumulative occupational radiation exposure.

Therefore, this amendment request meets the criteria of 10 CFR 51.22(c) (9) for categorical exclusion from an environmental impact statement.

6.0 REFERENCES

1. Letter from Elinor G. Adensam, NRC to Mr.

H.B. Tucker,

Duke, "Request for Exemption from a Portion of General Design Criterion 4 of Appendix A to 10 CFR Part 50 Regarding the Need to Analyze Large Primary Loop Pipe Ruptures as a Structural Design Basis for Catawba Nuclear Station, Unit 2", dated April 23, 1985.

2. Letter from Kahtan N. Jabbour, NRC to Mr.

H.B. Tucker,

Duke, "Catawba Nuclear Station - Elimination of Large Primary Loop Pipe Ruptures", dated April 7, 1987.

3. "Leak-Before-Break Evaluation, Hot Leg Nozzle Weld Overlays for Catawba Unit 2", Report No.

0800147.406, Structural Integrity Associates, Inc.,

November 14, 2008.

Notarized Affidavit from Westinghouse

fWestinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter ref DPC-08-45 Our ref CAW-08-2470 August 27, 2008 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

1. LTR-MRCDA-08-165, "Duke Energy McGuire Unit 1 Reactor Vessel Inlet and Outlet Nozzle Information" (proprietary)

2. LTR-MRCDA-08-167, "Duke Energy McGuire Unit I Reactor Vessel Inlet and Outlet Nozzle Information" (proprietary)

3. Section 7 of WCAP-10585, "Technical Basis for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for McGuire Units 1 and 2" (proprietary)

4. Section 7 of WCAP-10546, "Technical Basis for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for Catawba Units 1 and 2" (proprietary)

5. LTR-PAFM-08-122, "McGuire Units I and 2 Hot Leg Nozzle to Pipe Weld LBB Information Release" The proprietary information for which withholding is being requested in the above-referenced documents are further identified in Affidavit CAW-08-2470 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (bX4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Duke Energy.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-08-2470 and should be addressed to J. A.

Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very t-u* yours, J A. Gresham, Manager Regulatory Compliance and Plant Licensing cc: George Bacuta (NRC OWFN 12E-1)

Enclosures

CAW-08-2470 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 2 7 th day of August, 2008 Notary Public

_COMMONWEALTH OF~ PENNSYLVANIA Notarial Seal Sharon L Markie, Notary Pubric Monroeville Boro, Allegheny County My Commission Expires Jan. 29,2011 Member, Pennsylvania Association of Notaries

2 CAW-08-2470 (1)

I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.

(3)

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-08-2470 (b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c)

Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f)

It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a)

The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c)

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component

4 CAW-08-2470 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e)

Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f)

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii)

The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-MRCDA-08-165, "Duke Energy McGuire Unit I Reactor Vessel Inlet and Outlet Nozzle Information" (proprietary);

LTR-MRCDA-08-167, "Duke Energy McGuire Unit I Reactor Vessel Inlet and Outlet Nozzle Information" (proprietary);

Section 7 of WCAP-10585, "Technical Basis for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for McGuire Units 1 and 2" (proprietary);

Section 7 of WCAP-10546, "Technical Basis for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for Catawba Units 1 and 2" (proprietary)

LTR-PAFM-08-122, "McGuire Units 1 and 2 Hot Leg Nozzle to Pipe Weld LBB Information Release" for submittal to the Commission, being transmitted by Duke Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk.

This information is part of that which will enable Westinghouse to:

(a) Provide Duke Energy with information needed to support the reactor vessel nozzle alloy 600 weld overlay projects at McGuire Unit I and Catawba Unit 2.

5 CAW-08-2470 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of this information to its customers for purposes of supporting reactor vessel nozzle alloy 600 weld overlay projects (b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculations and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.