L-18-209, Response to Request for Additional Information Regarding Steam Generator Technical Specification License Amendment Request

Response to Request for Additional Information Regarding Steam Generator Technical Specification License Amendment Request

ML18302A244
Person / Time
Site:	Beaver Valley
Issue date:	10/28/2018
From:	Bologna R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18302A242	List: L-18-209, Response to Request for Additional Information Regarding Steam Generator Technical Specification License Amendment Request
References
EPID L-2018-LLA-0075, L-18-209
Download: ML18302A244 (31)

Text

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390.

UPON REMOVAL OF ATIACHMENT 2, THIS LETIER CAN BE PUBLICLY DISCLOSED.

FENOC Beaver Valley Power Station P.O. Box4 FirstEnergy Nuclear Operating Company Shippingport, PA 15077 Richard D. Bologna 724-682-5234 Site Vice President Fax: 724-643-8069 October 28, 2018 L-18-209 10 CFR 50.90 ATIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit No. 2 BV-2 Docket No. 50-412, License No. NPF-73 Response to Request for Additional Information Regarding Steam Generator Technical Specification License Amendment Request (EPID L-2018-LLA-0075)

By letter dated March 28, 2018 (Accession No. ML18087A293), FirstEnergy Nuclear Operating Company proposed changes to the Beaver Valiey Power Station, Unit No. 2 Technical Specifications. The proposed Technical Specification changes would allow the use of Westinghouse Electric Company LLC leak-limiting Alloy 800 sleeves for an additional three fuel cycles of operation, bringing the total usage time from five to eight fuel cycles of operation. The proposed Technical Specification changes also clarify wording in two sections of the Technical Specifications related to use of the leak-limiting Alloy 800 sleeves.

By e-mail dated August 29, 2018, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete their review of the proposed changes.

A nonproprietary and proprietary response to the NRC staff request for additional information is provided in Attachments 1 and 2, respectively. The responses provided with this letter have no impact on the no significant hazards consideration transmitted by the March 28, 2018 letter.

An application for withholding proprietary information from public disclosure, accompanying affidavit, proprietary information notice, and copyright notice are provided in the enclosure.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager Nuclear Licensing and Regulatory Affairs, at 330-315-6808.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October .el.8. 2018.

Richard D. Bologna Attachments:

1. Response to August 29, 2018 Request for Additional Information (Non-proprietary)

2. Response to August 29, 2018 Request for Additional Information (Proprietary)

Enclosure:

Application for Withholding Proprietary Information From Public Disclosure cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Attachment 1 L-18-209 Response to August 29, 2018 Request for Additional Information (Non-proprietary)

Page 1 of 21 The NRC staff's request for additional information is provided below in bold type followed by the FENOC response.

1. Inspection of previously installed hybrid expansion joint and laser welded sleeves that "likely" included +POINT' inspection is discussed on pages 9 and 10 of Enclosure C, to the letter dated March 28, 2018 (ADAMS Accession No. ML18087A293). The table summarizing the installations shows the number of sleeves installed and effective full power years (EFPY) to replacement.

a. To the extent possible, please provide the EFPY to final sleeve inspection since the sleeves were presumably not inspected after the last operating cycle.

Response

Individual sleeve inspection records are not readily available in most cases due to the age of the steam generators (SGs) and replacements having been performed 12 to 21 years ago for the plants on this list. Therefore, a semi-quantitative approach can be taken to estimate the number and frequency of sleeve inspections prior to SG replacement. These estimates are based on general requirements such as standard Technical Specification (TS) requirements, Electric Power Research Institute (EPRI) guidelines and general industry best practices regarding SG tubesheet sleeve inspections.

Table 1-1 includes the effective full power years (EFPY) from sleeve installation to the final sleeve inspection for each plant. Sleeve installation, replacement steam generator (RSG) installation dates and associated EFPY have been included. The majority of the data provided in the table that follows is from the EPRI Steam Generator Degradation Database (SGDD). The level of information in the database varies by utility and by plant, but in most cases it provides ample information on the date and scope of historic SG sleeve inspections to allow estimation of EFPY of the sleeves at their final inspection before SG replacement.

It should be noted that the EFPY from sleeve installation to final sleeve inspection is not necessarily the same for all sleeves installed during a particular outage due to inspection sampling strategies. The standard TS requirement in place at the time was to inspect a random sample of greater than or equal to 20 percent of all sleeved tubes at each outage. Some licensees, including Beaver Valley Power Station, Unit No. 1, elected to inspect in-service sleeves more frequently than the minimum TS requirement.

Therefore, the EFPY to final sleeve inspection is only accurate for sleeves inspected during the outage prior to SG replacement since not necessarily all sleeves were inspected during that outage. The detailed industry inspection records are not readily available for every plant in the table, but it can be assumed that the minimum inspection scope was 20 percent based on the standard TS requirements.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 2 of 21 T abl e 1- 1 Domesf1c Pl ant SWI'th SG T ube SI eeves - Inst a II af10n andi nspec1on f Deta1s

• 1 EFPY No. of Sleeve From Sleeve Batch Number Typical SG Inspections Installation Plant Installation of Sleeves Inspection Replacement Prior to SG to Final Date Installed Scope Date Replacement Sleeve Inspection Beaver Valley 1 3/2000 380 3 100% 4.1 2/2006 (380)

Braidwood 1 10/1996 897 0 N/A<3l N/A<3l 1/1999 Braidwood 1 4/1997 270 0 N/A<3l N/A<3l 1/1999 Byron 1 10/1995 2046 1 100% 0.3 11/1997 (2046)

Byron 1<2) 3/1996 3527 0 N/A<3l N/A<3l 11/1997 Farley 1 9/1992 44 4 20%(1) 5.2 3/2000

(-9)

Farley 1 3/1994 77 3 20%(1) 4.0 3/2000

(-15)

Farley 1 3/1997 919 1 20%(1) 1.3 3/2000

(-184)

Farley 1 12/1998 243 0 N/A<3l N/A<3l 3/2000 Farley 2 3/1992 21 5 20%(1) 6.1 2/2001

(-4)

Farley 2 9/1993 216 4 20%(1) 4.8 2/2001

(-43)

Farley 2 10/1996 826 2 20%<1) 2.3 2/2001

(-165)

Farley 2 4/1998 108 1 25% 1.0 2/2001

(-22)

Notes:

1) Inspection scope range for Farley was conservatively assumed to be 20 percent(%) based on the standard TS requirement of 20 percent. Based on Farley, Unit 2, 1998 inspection data that was available, it is possible the scope of prior inspections was higher.

2) Alloy 690 tungsten inert gas (TIG) welded sleeves. The remainder of the sleeves in this table are Alloy 690 laser welded sleeves (LWS).

3) Sleeve batch was installed at last outage prior to SG replacement.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 3 of 21 From the data above it can be seen that the longest time period from sleeve installation to the final inspection before SG replacement was 6.1 EFPY for a batch of sleeves installed during the spring 1992 outage at Farley Unit 2. The second longest tube sleeve in-service duration is 5.2 EFPY for a batch of sleeves installed during the fall 1992 outage at Farley, Unit 1.

b. Since no sleeve parent tube flaws were detected in Farley, Unit 2 prior to steam generator (SG) replacement, it is stated that residual stresses at the parent tube inside diameter (ID) surface do not support stress corrosion cracking (SCC) initiation and/or installation of the sleeves results in a reduced tube temperature resulting in a reduced SCC initiation function. Please discuss if another possibility could include that sec cracking initiated but had not yet reached a size that was detected by inspection.

Response

Flaw detection capability of any eddy current technique is defined or impacted by a number of factors that can be both internal and external to the testing system. The result of these factors produces a minimum flaw size that the eddy current testing system can reliably detect. This minimum flaw size that can be detected is referred to as the threshold of detection. Eddy current inspection of any steam generator tubing, including sleeves, is subject to a threshold of flaw detection. Flaws that are sufficiently small would not be expected to be detected by any type of eddy current technique, regardless of the degradation mechanism. The eddy current threshold of detection phenomenon is acknowledged and addressed in many industry guidance documents including the EPRI Steam Generator Integrity Assessment Guidelines and the EPRI Examination Technique Specification Sheets. Based on the nature of eddy current inspections, it is possible that flaws smaller than the threshold of detection may be present but not detected during +POINT probe inspection of the parent tube within the lower mechanical roll joint of Alloy 800 sleeves.

The Farley Unit 2 sleeve inspection reports of no sleeve joint parent tube flaw indications in any inspection campaign could be a result of the threshold of detection phenomenon but is not likely the sole reason. With the large number of sleeves installed at Farley Unit 2 and a sleeve inspection program governed by the plant Technical Specifications and industry guidelines, the possibility that every postulated flaw is less than the threshold of detection is extremely remote. This is further exhibited by the larger worldwide operating experience of over 14,000 Alloy 800 tubesheet sleeves where no occurrence of SCC has been reported in the parent tube at the lower sleeve joint. It is more probable that having no flaws being reported during in-service sleeve inspections is a result of reduced susceptibility of SCC of the parent tube at the location of the lower sleeve joint.

The postulated mode of degradation for the parent tube at the lower mechanically rolled sleeve joint is primary water stress corrosion cracking (PWSCC). The expansion process of installing a tube into the tubesheet during initial vessel fabrication imparts a

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 4 of 21 compressive residual stress at the tube inner diameter (ID) surface. The compressive residual stresses are maintained after rolling the sleeve into the parent tube as shown through finite element modeling . Compressive stresses tend to mitigate PWSCC.

Inducing compressive residual stresses at the tube ID surface is the basis for performing tubesheet shot peening as a PWSCC prevention measure.

Industry experience of mill annealed Alloy 600 (A600MA) tubing in mechanically roll expanded tubesheets (similar to the original Farley Unit 2 steam generators) have shown a marked decrease in the occurrence of PWSCC at depths further into the tubesheet from the secondary face (Figure 5 of Reference 1). Figure 5 of Reference 1 shows that there has been a low occurrence of reported PWSCC indications below about seven inches from the top of the tubesheet. These PWSCC indications deeper in the tubesheet have been associated with bulges, over expansions, skipped expansions and other anomalous conditions. The Alloy aoo* mechanical sleeve lower roll joint is located below this depth at a distance of approximately [ Ja,c,e below the top of the tubesheet. This experience further supports the conclusion of low PWSCC susceptibility of the parent tubing at the elevation of the lower sleeve joint.

The installation of an Alloy 800 mechanical sleeve reduces the temperature at the ID surface of the parent tube at the lower tubesheet sleeve joint by approximately

[ ) a,c,e. This was determined through three-dimensional finite element thermal modeling of the lower SG complex consisting of the channel head, divider plate, tubesheet and lower shell, as well as the sleeve and parent tube component. The industry accepted methodology for comparing SCC initiation rates at two different temperatures is through the use of an adjustment factor using the Arrhenius equation, in the form of:

Adjustment Factor = exp [-QR (- 1

- - ~)]

TRef. Tz where Q =activation energy, R =gas constant, and TRef. and T2 are the temperatures evaluated .

The [ Ja,c,e temperature drop at the parent tu*be inside diameter produces a nominal 1.127 improvement factor on the tubing PWSCC initiation rate for a nominal primary fluid temperature of 609 degrees Fahrenheit (°F), further reducing the sec potential of the parent tube at the lower sleeve roll joint.

2. Figure 2, "Alloy 800 Sleeve Worldwide Installations" of Enclosure C provides a cumulative plot of Alloy 800 tubesheet sleeves installed worldwide and a plot of those sleeves still in-service after accounting for SG replacements. Please discuss these installations in terms of the EFPY of the sleeves that remain in-service (or EFPY at the time of SG replacement), how sleeve inspections are performed, and benchmark these to the projected age in*EFPY of the Beaver Valley Power Station sleeves after eight cycles of operation.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 5 of 21

Response

A large amount of international plant data was collected to produce the referenced figure. Two of the source data plants are the Han bit Unit 3 and Unit 4 plants in Korea, which still have sleeved tubes in service. The SGs have been replaced for the remaining plants. Table 2-1 shows the installation date and EFPY for tubesheet PLUSS (PLUg replacing Sleeve which also Stabilizes) sleeves installed at both Hanbit Unit 3 and Unit 4 in addition to the dates for each in-service inspection. The inspection scope at the Korean plants for the PLUSS sleeves is based on the EPRI Steam Generator Management Program Pressurized Water Reactor (PWR) SG Examination Guidelines as follows: 100 percent first in-service inspection and 100 percent sleeved tube inspection over sequential periods of 120, 90 and 60 effective full power months (EFPM). It is also required that 50 percent of installed sleeves are inspected prior to the midpoint of the sequential period.

Inspection records were obtained from the EPRI SGDD. However, inspection records are incomplete after 2012 for the Korean plants and, for outages that have occurred after 2016, records are not yet included in the database. Both plants have recently completed the second sequential inspection period of 90 EFPM. The EFPY to final inspection only applies to a portion of the sleeves installed in each batch since the minimum requirement for the second inspection period is 100 percent sleeve inspection over 7.5 EFPY (or five operating cycles). Based on this, it can be conservatively assumed that a minimum of 20 percent of the sleeved tubes were inspected during the most recent outage for each unit. Inspections of the sleeved tubes at Hanbit Unit 3 and Unit 4 were performed using a Motorized Rotating Pancake Coil (MRPC) probe that included +POINT probe coils.

A large number of tubesheet PLUSS sleeves were installed at Ringhals Unit 4 and Angra Unit 1; however, these sleeved tubes are no longer in service due to steam generators having been replaced at both units. The sleeve inspection strategy for Angra Unit 1 was to inspect 100 percent of the sleeves every refueling outage. The sleeve inspection strategy for Ring ha ls Unit 4 was to inspect 100 percent of the sleeves every refueling outage from 2000 through 2008. In 2009, Ringhals received regulatory approval to eliminate future sleeve inspections with SG replacement in 2011. Table 2-1 shows the installation date and EFPY for sleeves installed at these two plants in addition to the dates for each in-service inspection. Inspections of the sleeved tubes at both Ringhals Unit 4 and Angra Unit 1 were performed using a MRPC probe that included +POINT probe coils.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 6 of 21 Table 2-1. International Plants with SG Tube Sleeves - Installation and Inspection Details Sleeve Number Estimated EFPY Plant Installation of Sleeves to Latest Sleeve Year Installed lnspection(1l (Plant EFPY)

Hanbit 4 2001 (4.9) 35 14.1 (2)

Hanbit 4 2002 (6.2) 151 12.8 Hanbit 3 2003 (7.3) 136 12.7(3)

Hanbit 4 2004 (7.5) 170 11.5 Hanbit 3 2004 (8.6) 144 11.4 Hanbit 4 2005 (8.8) 156 10.2 Hanbit 3 2006 (9.9) 360 10.1 Hanbit 3 2007 (11.0) 180 9 Hanbit 4 2007 (10.1) 267 8.9 Hanbit 4 2008 (11 .3) 1 7.7 Hanbit 3 2008 (12.3) 112 7.7 Ringhals 4 2000 (13.6) 71 5_5(4)

Hanbit 3 2010 (13.5) 100 6.5 Hanbit 4 2009 (12.6) 2 6.4 Ringhals 4 2001 (14.2) 92 5_9(4)

Hanbit 3 2011 (14.7) 268 5.3 Angra 1 2001 (6.5) 79 5.2

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 7 of 21 Sleeve Number Estimated EFPY Plant Installation of Sleeves to Latest Sleeve Year Ins pection(1l Installed (Plant EFPY)

Angra 1 2002 (7.5) 258 4.2(5)

Hanbit 4 2012 (15.0) 10 4 Hanbit 3 2012 (16.0) 3 4 Angra 1 2003 (8.3) 351 3.4(5)

Angra 1 2004 (8.8) 251 2.9(5)

Hanbit 4 2013 (16.4) 2 2.6 Angra 1 2005 (9.3) 104 2.4(5)

Angra 1 2006 (10.0) 124 1 _7(5)

Angra 1 2007 (10.5) 78 1.2(5)

Ringhals 4 2007 (19.3) 242 0.8(4)

Angra 1 2008 (11.2) 89 0(5)

Notes:

1) Sleeve inspections were performed at each of the plants using a MRPC probe. The MRPC probe includes +POINT probe coils.

2) The most recent outage documented in the EPRI SGDD for Hanbit Unit 4 is August 2015 (SG EFPY of 17.7). The estimated SG EFPY at the following outage (May 2017) is 19, which results in the sleeve EFPY of the most aged sleeves being 14.1 as of May 2017.

3) The most recent outage documented in the EPRI SGDD for Hanbit Unit 3 is October 2016 (SG EFPY of 18.7). The estimated SG EFPY at the following outage (May 2018) is 20, which results in the sleeve EFPY for the most aged sleeves being 12.7 as of May 2018.

4) The last inspection of tubed sleeves at Ringhals Unit 4 was performed in 2008 (SG EFPY of 20.1) because the steam generators were replaced in 2011 .

5) The last inspection of tubes sleeves at Angra Unit 1 was performed in 2008 (SG EFPY of 11.2) because the steam generators were replaced at the next refueling outage.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 8 of 21 Table 2-2 provides the installation and inspection details, as well as EFPY at the end of eight cycles, for the Beaver Valley Power Station (BVPS), Unit No. 2, SG tube sleeves.

When comparing the BVPS Unit No. 2 sleeves to the international data, there are several batches of sleeves at Hanbit Unit 3 and Unit 4 that either are comparable, or exceed, the EFPY of the earliest installed BVPS Unit No. 2 sleeves at the end of the eight cycle service life.

r Det a1*1s Ta bl e 2 -2 B eaver V a II ey Unt*t 2 SG T ube SI eeves - Ins ta IIa r,on an di nspec1on Sleeve Sleeve Life at Number of Number of Last Sleeve Installation Inspection Proposed End of Sleeves Sleeves in Inspection Date Date Scope 8-Cycle Service Installed Service (EFPY)

(EFPY) Life EFPY 2012 97 94< 1> 2017 (25.08) 100% 11 (20 .9) 2017 171 171 2017(25.08)<1) 100%<2> 6.8 (25.08)

Notes:

1) Three tubes were plugged for non-sleeve related reasons.

2) Sleeve installation baseline inspection.

3. Page 14 of Enclosure C indicates that the degradation assessment for Beaver Valley Power Station, Unit 2, for the fall 2018 and subsequent outages, will identify that sec of the parent tube behind the nickel band is not a potential degradation mechanism. Page 15 indicates that the licensee intends to continue

+POINT' probe inspection of the sleeve each outage to monitor the condition of the tube-to-sleeve roll joint, upper joint, and sleeve length in between. Please confirm that detection of crack like indications in either the sleeve or parent tube at any location, including adjacent to the nickel band, will result in tube plugging.

Response

FE NOC intends to continue the use of the +POINT' probe to inspect the sleeves each outage to monitor the condition of the tube-to-sleeve roll joint, upper joint, and the sleeve length in between. Detection of crack like indications in the sleeve, including adjacent to the nickel band, will result in the tube being removed from service via plugging. Indications in the parent tube at any location between the tube-to-sleeve upper and lower joints are not part of the pressure boundary and will remain in-service.

Indications in the parent tube between the upper and lower joints are the reason why the sleeve was installed. Crack like indications located anywhere else along the length of the parent tube, other than between the sleeve upper and lower joints, will be plugged upon detection.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 9 of 21

4. Page 37 of Enclosure C states: "For PWSCC [primary water stress corrosion cracking], 100% TW [through-wall] flaw penetration has 300 kHz +POINT' coil amplitude of approximately 4 volts." It is unclear to the staff if a specific measurement was used for the 4 volt amplitude referenced above. More specifically, is the 4 volt estimate from one particular indication, the average response of the four laboratory grown indications, or is it from some other reference document. The staff notes that laboratory tests generally suggest that probe response from 100% TW sec can vary significantly, depending on crack morphology, tightness, etc. Please clarify the basis for the statement regarding the 4 volt sizing of the 100% TW PWSCC flaw.

Response

The basis for correlating a 100 percent through-wall (TW) flaw penetration to approximately 4 volts in +POINT probe amplitude is supported by three separate evaluations. The first being WCAP-15128, Revision 3 (Reference 2), the second being a Westinghouse re-evaluation of the WCAP-15128, Revision 3 data, and the third being a Westinghouse re-analysis of the EPRI examination technique specification sheet (ETSS) 20511.1 data set.

WCAP-15128, Revision 3, served as the technical basis for the depth based alternate repair criteria for axial PWSCC at dented tube support plate intersections. This WCAP was submitted to the NRC in support of a plant-specific license amendment implementing the alternate repair criteria (ADAMS Ascension Number ML003733054).

This document provided the inspection and data analysis protocol required to support the alternate repair criteria. In the development of the alternate repair criteria , it was concluded that axial PWSCC indications having maximum voltages greater than approximately [ ]a,b,c had a high probability of being TW. The data analysis procedure described in the WCAP when implementing the alternate repair criteria is to assign a maximum depth of 100 percent TW for flaws with +POINT probe voltages that are [ ]a,b,c or greater. The data set used in the development of the alternate repair criteria supported by WCAP-15128 consisted of 56 pulled tube and laboratory crack specimens. The entire set of pulled tube and laboratory crack specimens were destructively examined to obtain metallurgical flaw depth and length dimensions.

Subsequent to issuance of WCAP-15128, Westinghouse performed an additional evaluation regarding axial PWSCC at dented tube support plate (TSP) intersections.

The data used for this evaluation consisted of 38 pulled tube and laboratory crack specimens from the WCAP-15128 data set that had [

]a,b,c Using a Ja ,b,c, a 100 percent TW flaw would result in a voltage of approximately Ja,b,c and approximately [

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 10 of 21 The data set for EPRI ETSS 20511 .1 consists of 32 laboratory cracks located within expansion transitions. The ETSS information provides the destructive examination maximum depth of the flaws but does not include the flaw voltage amplitude values. The eddy current data for these flaws were re-analyzed by Westinghouse to obtain the flaw voltage amplitudes. Using a [

]a,b,c , a 100 percent TW flaw would result in a voltage of approximately [ ]a,b,c.

The 100 percent TW voltage amplitude ranges from the three evaluations described above ranged from approximately [ ]a,b,c_ Therefore, the three evaluations described above support the conclusion that a 100 percent TW flaw penetration has a 300 kilohertz (kHz) +POINT probe voltage amplitude response of approximately 4 volts.

5. The same paragraph on page 37 also discusses how the flaw amplitudes were increased following the expansion process [

] Please discuss if tube wall thinning from the expansion process could also affect the flaw amplitudes.

Response

Wall thinning could affect flaw amplitude if it is significant. However, [

1a,c,e and can be demonstrated.

Westinghouse had previously fabricated 11 test samples that simulated the Alloy 800 mechanical sleeve joint configuration that included parent tube expansion into a carbon steel collar to represent the tubesheet. The test samples consist of eleven 7/8 inch x 0.050 inch wall thickness (WT) Alloy 600 parent tube samples. The samples were hard roll expanded into a carbon steel split collar to simulate an actual in-generator condition.

The non-expanded and post-hard roll expansion diameters of the eleven samples were measured at areas of interest. Figure 5-1 illustrates where measurements were performed and Table 5-1 contains the recorded values (in inches) along with results of various calculations. As expected, the observed average change in wall thickness from the average outer diameter (OD) [ ]a,c expansion process was [

Revision 8 of the EPRI PWR Examination Guidelines (Reference 3), specifically, Section H.4.1.2 "Frequency/Material/Wall Thickness," pertains to eddy current testing essential variable tolerances, and states that the relative current density (RCD) at a given depth within the tube wall can be calculated for different combinations of frequency and material. A technique is considered equivalent if the relative current density is within [ ]e of the qualified technique. The tolerance is applied as a calculated value. The relative current density value is calculated at the outside diameter surface of the tube wall. When a mix is the qualified channel, individual

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 11 of 21 frequencies that make up the mix are evaluated independent of each other. Beaver Valley Unit No. 2 uses a two frequency mix for inspecting within the tubesheet region with differential frequencies of 400 and 100 kHz. Table 5-2 contains the calculated RCD for each of these frequencies for the nominal non-expanded wall thickness (0.050 inch) and the average post hard roll expanded wall thickness of the 11 samples [

]a,b.c. Table 5-3 contained the calculated [ ]e range for the qualified 400 and 100 kHz frequencies using the nominal 0.050 inch wall thickness. Table 5-3 also shows that the calculated RCD for the expanded wall thickness falls well within the

[ ]e range for both frequencies, 400 and 100 kHz, with a percentage difference of only [ ]a,b,c and [ ]a,b,c, respectively. Based on this analysis, the [ ]a,c,e change in wall thickness from the expansion process is considered as equivalent with respect to the inspection technique being applied and would have [ ]a,c,e effects on flaw amplitudes.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 12 of 21 a,c,e Figure 5-1 Post-Expansion Pre-Machining Dimension Measurements

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 13 of 21 Table 5-1 Measurements and Wall Thickness Calculations 1lJBE ACl\JAL MEASUREMENT DIMENSION . I Exp#1 I Expt1 I Exp #2 I Exp #2 I Non Exp I Non Exp A I B I C I D I E I F I [Ht .

I WT I Q,A I WT, I F-E

• I ViT a,b,c Sample S/N: S1 .

Sample SIN: 52 Sample: SIN: S3 Sami,le SIN: S4 Samllle SIN: S6 Sample S/N: S6 Sample S/N: S7 Sami,le SIN: SB Samole *s/N: S9 Sample SIN: S10 Sample SIN: *s11 ,

Average

- - abc 00 Ovallty of Epanslon: Difference of the average of ExD #1 and the average of Exp #2:

Averaqe OD ExDanslon Dimension Averaae of C & D averaaes:

Average Non-Expanded 00 Average of F:

Average Expansion:

Averaae Wall Thickness of Exi,anded Realon:

Averaae Thickness of Non-Exi,anded Realon:

Difference In Wall Thickness of Expanded Realon and Non Expanded Region:

Percentage Change In Wall Thickness of Non-Expanded to Expanded OD:

Table 5-2 Relative Current Density CONDITION Hz Material Resistivity _WT(t) I SDP I [-t/SDP]_ RCD (% of ID Density)

Un-expanded Norn 0.050 TW 400000 a,D,C 600 101.40 20.47335 Average EXP WT of 11 Samples 400000 600 101.40 20.96294 Un-expanded Norn 0.050 TW 100000 600 101.40 45.2474 9 Average EXP WT o f 11 Samples 100000 600 101.40 4 5.78530 J a,b,c Average Wall Thickness o f Expanded Parent Tube samples[

FORMULAS USED FOR RELATIVE CURRENT DENSITY Standard Depth of Penetration = 8 = 1 .98 ..J (p/f) where:

p Resistivity in microncm 101.4 for Alloy 600

=

f frequency in hertz Relative Current Density = 100 x e *CtioJ where:

=

t tube wall thickness in inches

=

o Standard Depth of Penetration

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 14 of 21 Table 5-3 Relative Current Density Comparison

~

a,b,c Frequency 400 kH z 100 kH z

6. On page 38 of Enclosure C, there is discussion of how Flaw 4 (a non-through-wall flaw) was not detectable at 300 kHz (suggesting that penetration at this frequency was limited) and how Flaws 1, 2, and 3 (two through-wall flaws and one likely through-wall flaw) did have observable signals at 50, 75, and 150 kHz.

Please discuss the signals associated with Flaw 4 at the 50, 75, and 150 kHz frequencies, and what these signals mean with regards to detection of non-through-wall flaws, including cracks originating from the inside diameter of the parent tube.

Response

The 300 kHz frequency has an eddy current depth of penetration targeted for inspecting the sleeve material with minimum penetration into the parent tube. Therefore, little or no response for the four parent tube flaws is expected for this frequency. Figure 6-1 illustrates the response of Flaw 1 at 75 kHz in the Lissajous and the orientation of all four Flaws 1, 2, 3 and 4 in the terrain plot. Figures 6-2, 6-3 and 6-4 provide the Lissajous signal responses for Flaw 4 at 50 kHz, 75 kHz, and 150 kHz frequencies, respectively. Flaw 4 has an 86 percent through-wall (TW) maximum penetration depth from the outside diameter of the parent tube, which is less than 100 percent TW and detectable on all three frequencies. Flaws with similar depths initiating from the inner diameter (ID) of the parent tube would have a higher probability of detection since the flaw opening is closer to the test coil, which has a higher eddy current density and would produce a higher amplitude response.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 15 of 21 scnu !ill* on. 11nt......nn uuun.. ,.~,..* 1111 1n 1*

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Figure 6-1 75 kHz Terrain Plot of Flaws 1, 2, 3 and 4 with Flaw 1 in Lissajous j 5D'llll SEnr iri 1n1_111u s 1s n 1111u11C , * .._~h

• UrJl llt'f ,~ot f"iiio"" l. 1Crct11 jmm2 *~fi4fisfiii"""rnm1S11a1iu J te~ftll( j.5Cllllll115 fmiz fiirltl[MllfrDlf fiiir I Hl',ltl" 111:tflff ut: NCIC'lllt LltE Figure 6-2 50 kHz Response of Flaw 4

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 16 of 21 I 5C.ftU HllD_IINll'nlS , ..-_.. h~ UTJ L "" TUUl fiiii>j lCl"CIAT l I 1£PDRT 2 fRnlTiTfisfiG~I Sllllm I HESSm j SCREIIIJ!I, j SCIII 2 f'1iii"""l *D1 l[PORT (Tat I I¥ I 4 7S ,~~ ll :iat=l.O r!ifr-*1.3i11w-..1.1101 Xltm I tJ'l~I H = - - - - i -- - " - '- ---i---- - - - '-'_.,_, - - ----11F::r~i:: l~~..... 'Tlminl

~ * ~

• c t * " ' 1 " ' 1 t " C o >IDJl1,IDO :i(ffln.'0!111 KUll£JJr rurc:iat1 ~ S.. r-1.1 ~ I~ ta > 11,.'U JK~IU' Figure 6-3 75 kHz Response of Flaw 4

[I SC~ SUl!P w*~ OOTO_RIIRlY515 STBIDl..l>>E ,~--~i.i. . ITIL RPf TD~L

~,I mm I I RD'm 2 ~ ~ f i s f i ' ~ l ,fllm J tcmGE J mmuH& fstiitfiiirl 11D1 mon fiiir I 2 lSIJkh.,,

Cl+PI r-r 1~1' err WJI!: caw P-!lD o. :r.cm W..TI!=l.t!I ~

=--.mo tltsrtP:11 ' t.illll~ . - ll<lt'Ul(Yf ~l'JfCl/11 flU:I.IE;..tlT ru, ~ ~ - h .,_P1.e_ * ~ lOl > [ IIITtlW.XIU' *,.

)

)

Figure 6-4 150 kHz Response of Flaw 4

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 17 of 21

7. Pages 39 and 40 of Enclosure C discuss how the eddy current signal at the edge of the nickel band can have a transitioning noise effect similar to the expansion transition at the top-of-the tubesheet in a steam generator. Page 40 also states the center of the nickel band does not have this noise influence due to the design of the +Point' coil. In the Model Assisted Probability of Detection (MAPOD) simulation that is discussed on page 42, the noise distribution was developed by performing noise measurements at 70 and 130 kHz at the center of the nickel band. Please discuss why the measurements were taken at the center of the band and not at the edge of the nickel band, since the edge of the band would have likely resulted in higher noise and a lower signal-to-noise ratio.

Response

Noise at the center of the nickel band was evaluated to assess the general effect of the nickel band on the probability of detection and not specifically for discrete sections.

Analysis software tools and protocol such as line filters, average filters, and mixes are used to eliminate or reduce the nickel band transition effect response. Figure 7-1 illustrates the effect of the nickel band transition raw (unfiltered) frequencies at 70 and 40 kHz. Figure 7-2 illustrates the same sleeve and same location with an axial average filter applied to eliminate or minimize the nickel band transition noise effect. Figure 7-2 also illustrates that with the filter applied, the dominate noise is observed within the nickel region and, therefore, supports the center of the nickel band being the conservative location for measuring noise.

The 70 kHz terrain plots were provided because the main frequency for detection of defects in the sleeve is 70 KHz. The axial average filter can be applied to the other frequencies. The 40 kHz plots are provided for reference only.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 18 of 21

' *'!:..}I I SCREElf SETCP RI'[ AUTD_RNIILYSIS METWOIIXED 1r-_diak UTIL RPF TDDL fliiofiEPoiirTI mun 2 fiPTTfi+f°isl'6fliTsrl ""'"" I""'"" I sc1m1w, [sciizfiirl HEJi "'"" fliir 12.SZ I l 79 1Chz 1n Rl't1 CJ'l :1ViVH

"' C I +n SE'l.l[RO

< i . Ud' )

CO.tR= l . l!I V flfTORf'C !(1tl'

.~ ...

DCG ...

7.81 I S 41 1 hz 267 C I *Pl Figure 7-1 70 kHz and 40 kHz Raw (Unfiltered) Frequencies Terrain Plot of Sleeve Note: The upper terrain plot is for 70 kHz and the lower terrain plot is for 40 kHz.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 19 of 21 J SCREEN SETUP m; AUTO_IIIBLYUS MElllORIED "--*ok UTIL APF TIDL fiiDo I "'°" 1 I '""" 2 fTri"T fi< [is fi< I TLIST I SlltlARI I NESSm I SCREIHI"' [TciiT" [Rlir I HEIi REPORT fiiii, 12 . !12 I l ,- Khz CI + PT 7 .11 I 5 4f Mh1.

Cl *rt DIG TNB Figure 7-2 70 kHz and 40 kHz Frequencies Terrain Plot of Sleeve with Axial Average Filter Applied Note: The upper terrain plot is for 70 kHz and the lower terrain plot is for 40 kHz.

8. Page 42 of Enclosure D (also from the letter dated March 28, 2018), discusses how the major challenge to performing a MAPOD simulation for the parent tube adjacent to the nickel band of the Alloy 800 sleeve was that the analysis frequencies were 75 kHz (for the sleeved tube) and 300 kHz (for the parent tube) and there was no direct amplitude correlation between the two frequencies. [

] Thus, it was judged that existing A-hat function for axial PWSCC in non-sleeved tubes could be extended to the sleeve tube condition in 70 kHz. [

] Please

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 20 of 21 discuss how this could affect the probability of detection simulations presented in Figure 19 and Table 3.

Response

Eddy current is a volumetric inspection technique where the signal amplitude responses are proportional to the flaw volume. An electrical discharge machined (EDM) notch signal amplitude would be larger than the response from the same depth crack due to the crack having a smaller volume loss. The probability of detection (POD) methodology uses the flaw signal amplitude compared to the tube noise to determine if a flaw can be detected. Therefore, the flaw type used to create the POD curve must be the same flaw type that is being detected.

The EDM notches were used to demonstrate that the eddy current amplitude response of the flaws at [ ]a,c,e are equivalent to the eddy current amplitude response of the [ ]a,c.e_ This equivalency is valid for the same flaw types (notch-notch or crack-crack) . Once it was shown that the amplitude responses of identical flaws of the same type are equivalent at

[

]a,c,e was able to be used to generate the POD curve applicable to PWSCC in the sleeved tube at 70kHz. It would not be appropriate to apply an EDM notch-based POD curve to represent PWSCC as the larger EDM notch voltage amplitudes would unrealistically overestimate the detection capabilities for PWSCC.

The POD curves provided in Figure 19 and Table 3 of Reference 1 are based upon a correlation of flaw amplitude to the metallurgical flaw depth. This flaw voltage to depth correlation is referred to as the Ahat function. A noise distribution is also used as input to produce a POD curve . Figure 18 of Reference 1 provides a voltage amplitude distribution of noise within the nickel band region of the sleeve as measured at 70 kHz.

Monte Carlo sampling techniques using the Ahat function and the noise distribution are used to produce the POD curve as further described in Section 8-4 of Reference 1.

Since it was demonstrated that the flaw voltage amplitude at [

]a,c.e can be applied to represent PWSCC flaw amplitudes at 70 kHz in a sleeved tube . Therefore, the

[ ]a,c.e Ahat function for non-sleeved tubes was used as the 70 kHz PWSCC Ahat function for sleeved tubes. Using this Ahat function and the noise distribution for the sleeve nickel band produces the POD curves shown in Figure 19 and Table 3 of Reference 1. The curves shown in Figure 19 and Table 3 of Reference 1 are PWSCC-based POD curves applicable to PWSCC at the nickel band of the Alloy 800 sleeve. Therefore, the use of EDM notch data to establish the correlation that flaws of the same type have the same eddy current response in [

]a,c,e does not affect the POD curves as shown in Figure 19 and Table 3 of Reference 1.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-18-209, Attachment 1 Page 21 of 21 References

1. FENOC, Letter L-18-081,

Subject:

"Steam Generator Technical Specification Amendment Request," Enclosures C and D, "Steam Generator Alloy 800 Nickel Band Tubesheet Sleeve Operating Cycle Length Extension License Amendment Request: Technical Bases," Non-proprietary and Proprietary versions, respectively, dated March 28, 2018 (Accession Numbers ML18087A293 and ML18087A294).

2. Westinghouse Report WCAP-15128, Revision 3, "Depth-Based SG Tube Repair Criteria for Axial PWSCC at Dented TSP Intersections," June 2000.

3. EPRI Report 3002007571, "Steam Generator Management Program: Pressurized Water Reactor Steam Generator Examination Guidelines: Revision 8," June 2016.

Enclosure L-18-209 Application for Withholding Proprietary Information From Public Disclosure (7 Pages Follow)

Westinghouse Non-Proprietary Class 3

@Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-3382 Document Control Desk Direct fax: (724) 940-8542 11555 Rockville Pike e-mail: russpa@westinghouse.com Rockville, MD 20852 CAW-18-4823 October 17, 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGMP-18-40 P-Attachment, "Responses to Request for Additional Information Regarding Beaver Valley Power Station Unit No. 2 Amendment Request for Use of Westinghouse Leak-Limiting Alloy 800 Sleeves in Steam Generators" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

'i The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-18-4823 signed by the owner of the proprietary information, Westinghouse. 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 CPR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by FirstEnergy Nuclear Operating Company.

• Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4823, and should be addressed to CamilleZozula, Manager, Facilities and Infrastructure Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Tow'nhi , nnsylv~QZ:__*a1 66.

' ~

'-9-* ..

Paul A. Russ, Director Licensing and Regulatory Affairs

Enclosures:

1. Affidavit CAW-18-4823

2. Proprietary Information Notice and Copyright Notice

3. LTR-SGMP-18-40 P-Attachment, "Responses to Request for Additional Information Regarding Beaver Valley Power Station Unit No. 2 Amendment Request for Use of Westinghouse Leak-Limiting Alloy 800 Sleeves in Steam Generators" (Proprietary)

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-18-4823 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

I, Paul A. Russ, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

Executed on: I e{ {'"1 / t ~

Paul A. Russ, Director Licensing and Regulatory Affairs

3 CAW-18-4823 (1) I am Director, Licensing and Regulatory Affairs, 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 Nuclear Regulatory Commission's ("Commission's") regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure 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

4 CAW-18-4823 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(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 desiratile.

(iii) 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.

5 CAW-18-4823 (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.

(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.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CPR Section 2.390, is to be received in confidence by the Commission.

(v) 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 thethod to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGMP-18-40 P-Attachment, "Responses to Request for Additional Information Regarding Beaver Valley Power Station Unit No. 2 Amendment Request for Use of Westinghouse Leak-Limiting Alloy 800 Sleeves in Steam Generators" (Proprietary), for submittal to the Commission, being transmitted by FirstEnergy Nuclear Operating Company (FENOC) letter. The proprietary information as submitted by Westinghouse for use by FENOC for Beaver Valley Unit 2 is provided in response to a request for additional information from the Nuclear Regulatory Commission staff concerning the use of Alloy 800 sleeves for the repair of degraded steam generator tubes, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to demonstrate the acceptability of extending the life of Alloy 800 sleeves that are already installed or

6 CAW-18-4823 planned to be installed in the Beaver Valley Unit 2 steam generators from five operating cycles to eight operating cycles.

(b) Further, this information has substantial commercial value as follows:

(i) Westinghouse can sell the use of similar information to its customers for the purpose of meeting NRC requirements for licensing documentation supporting the use of Alloy 800 or other types of sleeves.

(ii) Westinghouse can sell support and defense of this information on Alloy 800 sleeves or other types of sleeves to customers in the licensing process.

(iii) 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 technical evaluation justifications and licensing &efense 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 non-proprietary versions of a document, furnished to the NRC in support of response to a request for additional information from the NRC staff concerning a license amendment to extend the life from five operating cycles to eight operating cycles of Alloy 800 sleeves used to repair degraded steam generator tubes in the Beaver Valley Unit 2 steam generators, and may be used only for that purpose.

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)(l).

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.