ML091310173

Unit, Additional Information in Support of Proposed Emergency License Amendment Request Regarding Modified Interim Alternate Repair Criteria for Steam Generator B

ML091310173
Person / Time
Site:	Surry
Issue date:	05/06/2009
From:	Price J Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-295A
Download: ML091310173 (18)

Text

PROPRIETARY-Withhold under 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 6, 2009 10 CFR 50.90 U.S. Nuclear Regulatory Commission Serial No.

09-295A Attention: Document Control Desk NLOS/GDM RO Washington, D.C. 20555 Docket No.

50-280 License No. DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNIT I ADDITIONAL INFORMATION IN SUPPORT OF PROPOSED EMERGENCY LICENSE AMENDMENT REQUEST REGARDING MODIFIED INTERIM ALTERNATE REPAIR CRITERIA FOR STEAM GENERATOR B By letter dated May 5, 2009 (Serial No.09-295), Dominion requested an emergency license amendment request (LAR) for Surry Power Station Unit 1. The proposed LAR modifies the Unit 1 interim alternate repair criteria (IARC) contained in TS 6.4.Q, "Steam Generator (SG) Program," and the reporting requirements contained in TS 6.6.3, "Steam Generator Tube Inspection Report" for the Unit 1 B SG during the Unit 1 Refueling Outage 22 and the subsequent operating cycle. The proposed change also revises the allowable primary-to-secondary leakage rate in TS 3.1.C and 4.13.B for the Unit 1 B SG from 150 gallons/day (gpd) to 20 gpd for the same operating period.

During a conference call with the NRC staff to discuss the subject LAR, the NRC requested certain information be provided to facilitate their review.

Specifically, the NRC requested the following two items:

1. An estimate of the mean value of H* and the value of H* at 95% probability at 50%

confidence, and

2. An evaluation of the maximum potential tube slippage under a set of bounding assumptions.

This information has been prepared by Westinghouse and is provided in Attachment 1. contains information proprietary to Westinghouse Electric Company, LLC.

Therefore, this information is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit 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 (b)(4) of 10 CFR 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations.

The affidavit is included in Westinghouse authorization letter LTR-CAW-09-2573, "Application for Withholding Attachment I contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation this page is decontrolled.

Serial No. 09-295A Docket No. 50-280 Page 2 of 3 Proprietary Information from Public Disclosure," which also includes a Proprietary Information Notice and a Copyright Notice. The Westinghouse authorization letter is provided in Attachment 3. Correspondence with respect to the copyright or proprietary aspects of the Westinghouse information noted above or the supporting Westinghouse affidavit should reference the authorization letter 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.

A redacted, non-proprietary version of the Westinghouse supporting documentation is provided in Attachment 2.

The additional information provided herein does not affect the significant hazards consideration determination or the environmental consideration that was previously provided in support of the proposed emergency LAR.

If you have any further questions or require additional information, please contact Mr.

Gary D. Miller at (804) 273-2771.

Sincerely, ZJA n Price ice President - Nuclear Engineering Commitments made in this letter: None COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this (04 day of kJ1ok.

,2009.

My Commission Expires:

13 N(otaS-APublic (SEAL)

Serial No. 09-295A Docket No. 50-280 Page 3 of 3 Attachments:

1. Westinghouse Electric Company LLC Letter (PROPRIETARY), LTR-SGMP-09-64 Rev. 2 P Attachment, "Surry Unit 1: Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends," dated May 6, 2009

2. Westinghouse Electric Company LLC Letter (Non-Proprietary), LTR-SGMP-09-64 Rev. 2 NP Attachment, "Surry Unit 1: Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends," dated May 6, 2009

3. Westinghouse Electric Company LLC Authorization Letter LTR-CAW-09-2573, "Application for Withholding Proprietary Information from Public Disclosure," dated May 6, 2009.

cc:

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 NRC Senior Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building -

7 th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. J. F. Stang, Jr.

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8G9A 11555 Rockville Pike Rockville, Maryland 20852 Ms. D. N. Wright NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8H4A 11555 Rockville Pike Rockville, Maryland 20852

Serial No. 09-295A Docket No. 50-280 Westinghouse Electric Company LLC Letter (Non-Proprietary)

LTR-SGMP-09-64 Rev. 2 NP Attachment, "Surry Unit 1: Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends," dated May 6, 2009 Surry Power Station Unit 1 Virginia Electric and Power Company (Dominion)

Westinghouse Non-Proprietary Class 3 LTR-SGMP-09-64 Rev. 2 NP-Attachment SWestinqhouse Electric Company Surry Unit 1:

Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends May 6, 2009 Westinghouse Electric Company LLC P.O. Box 158 Madison, PA 15663

© 2009 Westinghouse Electric Company LLC All Rights Reserved

-I

LTR-SGMP-09-64 Rev. 2 NP-Attachment References

1. LTR-CDME-08-11, "Interim Alternate Repair Criterion (ARC) for Cracks in the Lower Region of the Tubesheet Expansion Zone", Westinghouse Electric Company, LLC, January 31, 2008.

2. LTR-CDME-08-43, Revision 3, "Response to NRC Request for Additional Information Relating to LTR-CDME-08-11, Revision 3 P-Attachment", Westinghouse Electric Company, LLC, June 3, 2008.

3. LTR-SGMP-09-63," Assessment of Tube-end Indications at Surry Unit 1", Westinghouse Electric Company, LLC, May 4, 2009.

4. WCAP-17071 (proprietary), "H*: Alternate Repair Criteria for the Tubesheet Expansion Region in Steam Generators with Hydraulically Expanded Tubes (Model F)", April 2009.

A. Introduction During the spring 2009 inspection at Surry Unit 1, under the inspection program required to implement the Interim Alternate Repair Criteria (Reference 1 and Reference 2) for the tubesheet expansion region, multiple permeability variation signals were reported at the tube-ends in SG-B. Permeability variations are not degradation of the tube material but, if they cannot be resolved by eddy current techniques, they may mask signals of real degradation. Therefore, if unresolved, these indications must be treated as if they are indications of actual degradation. The permeability variations were reported at approximately 0.2 inches above the tube ends, consistent with the location of axial and circumferential tube end indications reported at other plants that have applied the IARC (Reference 1 and 2). Because the permeability variations may mask signals that would require plugging many of the tubes with these signals, it is necessary to perform an engineering evaluation of this condition.

Reference 3 provided an independent justification for leaving the tubes with tube-end permeability variations in service. The information in Reference 3 was transmitted to Dominion and forwarded in part to the USNRC staff. In a telephone conference on May 4, 2009, the NRC staff requested additional information including the following:

1. An estimate of the mean value of H* and the value of H* at 95% probability at 50% confidence. The justification of H* is a current work in progress whose completion was scheduled for mid-June 2009. Because of the request from Dominion, it was agreed to provide an early estimate of the mean and probabilistic values of H*. The values of H* must be considered a preliminary estimate because the normal rigor of the internal review process could not been completed in the time available.

2.

An evaluation of the maximum potential tube slippage under a set of bounding assumptions that are specified in this letter.

3

LTR-SGMP-09-64 Rev. 2 NP-Attachment The following provides the requested information:

A. Preliminary Values of H*

H* is the length of undegraded tubing required to retain the tube in the tubesheet under limiting loading conditions as required by NEI 97-06, Revision 2. The technical justification of H* for the Model 51F SGs at Surry is a current work in progress, scheduled to be completed in mid-June 2009. The final report for H* for the Model F steam generator is complete (Reference 4). The estimates of the values of H* for the Surry Model 51F SGs utilize the same methods presented in Reference 4.

Based on the same assumption used in Reference 4, but considering the geometry specific to the Model 51F SGs, the mean value of H* was calculated. The structural difference between the Model 51F SGs and the Model F SGs discussed in Reference 4 are principally the tube diameter ([

] a,c,e inch for the Model 51F SGs vs. [

a,c,e inch for the Model F SGs) and tube pitch ([

a,c,e inches for the Model 51F SGs vs. [

] a"' inch for the Model F SGs). Further, the operating conditions specific to the Surry Units were considered instead of the bounding Model F plant conditions.

The predicted mean value of H* for Surry Units 1 and 2 is [

] ac,e inches from the top of the tubesheet, including a [

]a,ce inch allowance for the location of the bottom of the expansion transition and an allowance for thermal distribution in the tubesheet at normal operating conditions.

In reference 4, the whole bundle 95% probability, 50% confidence value of H* was principally determined by a square root sum of the squares (SRSS) approach based on the principal variables that affect the value of H* when it is assumed that residual contact pressure is zero. The Model 51F SGs include a complement of. [

a~c~

e tubes. From standard binomial distribution calculations, the required deviation from mean is [

] a,ce standard deviations (sigma) to achieve 95% probability at 50% confidence for a population of [

] a without any failures.

Based on the SRSS approach at [

a,c,e sigma, the 95/50 value of H* for the Surry SGs is estimated to be 12.5 inches. This value includes the adjustment of [

j a,c,e inch for the uncertainty in location of the bottom of the expansion transition and the correction for the normal operating condition tubesheet thermal distribution. Normal operating conditions are limiting for the value of H*. The value of H*

does not include the adjustment for referencing the crevice pressure distribution to the predicted value of H*. An estimate of this adjustment is obtained from Reference 4. For the Model F SG, a predicted value of H* of [

] a,c,e inches would require an additional crevice pressure adjustment of approximately [

a,c,e inches. However, the Surry Unit 1 inspection results have confirmed that nearly the full length of the tube, minus the tube end portion in the 0.20 inch above the primary face of the tubesheet, exists and is free of defects. Therefore, no crevice pressure adjustment is necessary for the Surry Unit 1 preliminary value of H*.

B. Assessment of Slippage Based on a review of the tubesheet maps from Surry (Figures 2 and 3) which identifies all of the locations of the permeability variation (PVN) signals for SG B of Surry Unit 1, the bounding hypothetical vertical displacement of a single tube end is calculated to be 8.7 inches at column number 71. The 4

LTR-SGMP-09-64 Rev. 2 NP-Attachment thickness of the Surry 1 Model 51 F tubesheet is [

a,c,e inches. This calculation conservatively assumes the following as initial conditions:

1. Each permeability variation signal is masking a completely severed tube,

2.

No friction forces existbetween the tube and the tubesheet.

3.

The tubesheet does not bend or deform during any of the plant conditions (bending in the tubesheet will act to restrain vertical motion of the tubes),

The estimate for maximum potential vertical travel of a tube is based on using nominal tube and tubesheet dimensions (i.e., a tube pitch of [

] a,c,e inches and a nominal tube outside diameter of a'c'e inch).

The tubes are installed concentrically in the tube bundle of a Model 51F steam generator; that is, the center of the U-bends for all rows of tubes is located at the same elevation in the bundle. Therefore, the distance of potential motion is calculated by multiplying the number of consecutive tubes in a column with permeability variation indications on either the hot leg and cold leg of the tube bundle times the difference between the tube pitch and outside diameter of a tube. For columns with stayrods, two tube diameters were added to the vertical motion distance. A graph of the maximum travel of a tube end by tube bundle column number in SG B is provided in Figure 1. Figure 1 is based on a study of Figure 2 to determine the maximum number of contiguous tubes with tube end permeability variations in the same column.

All tubes in Surry Unit 1 SG B would be expected to remain well within the thickness of the tubesheet during all plant conditions as each set of "stacked" tubes would be immediately retained by an adjacent outboard tubewithout PVN signals.

There are no peripheral tubes with PVN signals in SG B. The outermost tubes with PVN signals are:

Row 22 Column 7 Row 45 Column 49 Row 45 Column 46 The circumferential extent of the PVN signals for two of the three tubes in question are less than the 94 degree acceptance criteria in the IARC and are acceptable for continued service without the proposed emergency change. The circumferential extent of the PVN signals on R45C49 and R45C 46 are 59.degrees and 38 degrees, respectively. The third tube has a PVN signal with a circumferential extent of 136 degrees.. For each of the three outermost tubes, there are no indications on the hot leg side of the tube.

5

LTR-SGMP-09-64 Rev. 2 NP-Attachment Figure 1 Surry Unit 1 SG B PV Indications Potential Slip Evaluation 10 9

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7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73 76 79 82 85 88 91 94 SG B Column Number I ElSG B Potential Slip Distances 6

LTR-SGMP-09-64 Rev. 2 NP-Attachment Figure 2 Combined Hot/Cold Leg Permeability Variations (SG B)

GROUP IND/TUBES Surry:Unit 1 1 R22 -.04/09 All PVN Indications TOTAL TUBES:' 3342.

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Serial No. 09-295A Docket No. 50-280 Westinghouse Electric Company LLC Authorization Letter LTR-CAW-09-2573, "Application for Withholding Proprietary Information from Public Disclosure,"

dated May 6, 2009.

Surry Power Station Unit 1 Virginia Electric and Power Company (Dominion)

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001.

Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA (412) 374-4643 (412) 374-4011 greshaja@westinghouse.com Direct tel:

Direct fax:

e-mail:

Our ref: CAW-09-2573 May 6, 2009 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGMP-09-64 Rev. 2 P-Attachment, "Surry Unit I Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends," dated May 6, 2009 (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-09-2573 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 (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Dominion VA.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-09-2573, 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 truly yours, J.A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc:

A. Mendoila, NRR G. Cranston, NRR G. Bacuta, NRR

CAW-09-2573 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared R. M. Span, 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:

R.M. Span, Principal Engineer Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 6d day of May, 2009 Notary Public COMMONWEALTH OF PENNSYLVANIA Lorraine M. Pplca, Notary Pubfc oroewe Boro, Alegheq lyCoilty --..-

My Commlsson E.xres Dec. 14,2011 Member, Pennsylvania Association of Notaries

2 CAW-09-2573 (1)

I am Principal Engineer, 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)

I 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 constitute Westinghouse policy and provide 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 3 CAW-09-2573 (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 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4 CAW-09-2573 (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-SGMP-09-64 Rev. 2 P-Attachment, "Surry Unit I Support for Emergency Technical Specification Amendment to Address Permeability Variation Signals at the Tube Ends," dated May 6, 2009 (Proprietary), for submittal to the Commission, being transmitted by Dominion VA Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for Surry Unit 1 is expected to be applicable to other licensee submittals in support of implementing an alternate repair criterion that does not require plugging tubes with potential circumferential cracking at the tube ends in tubes that have been hydraulically expanded in the tubesheet.

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

(a) Provide documentation of the analyses and methods used in support of the implementation of an alternate repair criterion for indications at the tube ends of the Surry Unit I steam generators.

5 CAW-09-2573 (b) Assist the customer in obtaining NRC approval of the Technical Specification changes associated with the alternate repair criterion.

Further this information has substantial commercial value as follows:

(a)

Westinghouse plans to sell the use of similar information to its customers for the purposes of meeting NRC requirements for licensing documentation.

(b)

Westinghouse can sell support and defense of the technology to its customers in the licensing process.

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 calculation, evaluation 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.