NG-96-2322, Application for Amend to License DPR-49,converting Std TS Re NUREG-1433.Detailed Description & Justification for Proposed TS Amend Consists of 20 Vols & Summarized in Attachment 1

Application for Amend to License DPR-49,converting Std TS Re NUREG-1433.Detailed Description & Justification for Proposed TS Amend Consists of 20 Vols & Summarized in Attachment 1

ML20129J799
Person / Time
Site:	Duane Arnold
Issue date:	10/30/1996
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Miraglia F NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20129J801	List: NG-96-2322, Application for Amend to License DPR-49,converting Std TS Re NUREG-1433.Detailed Description & Justification for Proposed TS Amend Consists of 20 Vols & Summarized in Attachment 1
References
RTR-NUREG-1433 AL-94-04, AL-94-4, NG-96-2322, NUDOCS 9611080092
Download: ML20129J799 (14)

Text

IES Utaht:es Inc.

', s 200 Forst Street S E.

PO. Box 351 m Cedar Rapids. IA 52406-0351 Telephone 319 398 8162 Fax 319 398 8192 d

UTILITIES sann v. r,a,,z, sc.

We President, Nuclear NG-96-2322 October 30,1996 Mr. Frank J. Miraglia, Jr.

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-37 Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center (DAEC)

Docket No.: 50-331 Op. Lice < a.: DPR-49 Submittal s License Amendment Request to Convert the DAEC Technical Specifications to the Improved Technical Specifications (NUREG-1433), (RTS-291)

References:

1) J. Franz (IES) to W. Russell (NRC), " Revision to Schedule for Submittal of DAEC Conversion to the Standard Technical Specifications (NUREG-1433),"

NG-96-1840, August 30,1996.

2) Nuclear Energy Institute (NEI), " Improved Technical Specifications Conversion

)

Guidance," NEI 96-06, August,1996. l

3) NRC Administrative Letter 96-04:" Efficient Adoption ofImproved Standard  !

Technical Specifications," October 9,1996.

File: A-117

Dear Mr. Miraglia:

The purpose of this letter is to request a license amendment pursuant to 10 CFR Part 50.90 to convert the DAEC Technical Specifications (TS) to the Improved Technical Specifications (ITS) l (NUREG 1433, Rev.1), as committed in Reference 1. The detailed description and justification for the prog <ed TS amendment consists of 20 volumes and is summarized in Attachment 1. The organization of the volumes is consistent with Reference 2 to facilitate the review of the submittal by the NRC Staff. However, as Reference 2 was only recently made available, and as

! the development of our application began in May of 1995, our application has been prepared, to the extent practicable, in accordance with the guidelines contained in Reference 2, but does not conform in all respects. For example, our ' Removed Details,' which are categorized as a subgroup of'Less Restrictive' items in NEl 96-06, are categorized as ' Relocated Items' in our application.

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. NG-96-2322 October 30,1996

, Page 2 of 5 in addition to the conversion of our Current TS (CTS) to the ITS, several changes to the CTS are included in this application and are described in Attachment 2. For example, changes to extend the DAEC operating cycle from 18 to 24 months. These items are considered to be within the scope of the conversion, as described in Reference 2. Attachment 3 contains a listing of those changes to the CTS which may be considered to be 'beyond scope' as defined in References 2 and 3. For overall conservatism, we have characterized several items as beyond scope because they are not current licensing basis, even though they would not change any CTS requirements. I We have kept the number of such beyond scope items to a minimum and included only items that I are consistent with the intent of the NUREG-1433 and therefore, should be reviewed as part of l our ITS submittal. Consequently, we have not prepared individual submittals for these items, nor prepared a version of our ITS which does not include them. Several of these items have been identified as potential generic changes to the NUREG and ' travelers' have been submitted to our Owners' Group for consideration in accordance with Reference 2.

1 As the CTS for the DAEC is of a ' custom' nature, some deviations from the NUREG have been i taken in order to maintain consistency with our current licensing basis. We have summarized the more significant deviations in Attachment 4. Again, several of these items are potentially generic l

in nature and travelers for these items have been submitted to our Owners' Group for consideration. Because it will be important for the reviewers to understand the rationale for these deviations, we would like to meet with the Staff at your earliest convenience to discuss these items, prior to beginning the technical review of the individual chapters and sections.

There are currently no outstanding TS amendment requests on the DAEC docket that affect this submittal and to date, we have not identified any changes to the CTS that will be submitted during the review of our ITS conversion. While Amendment # 219 (Appendix J, Option B) to the CTS has been recently approved, the enclosed CTS mark-up pages have not been updated to reflect the new typed pages for those changes. The enclosed CTS mark-up pages are the " pen &

ink" pages from that submittal. We will include new CTS mark-up pages based upon the typed Amendment pages in the first revision to our ITS submittal.

Conversion to the ITS will require changes to the DAEC Quality Assurance Program Description (QAPD). A revision to the QAPD will be prepared, pursuant to 10 CFR Part 50.54(a) and submitted to the Staff for review after the Staff's review ofITS Chapter 5.0 (Administrative Controls)is completed. Changes to the Updated Final Safety Analysis Report (UFSAR) necessitated by conversion to the ITS, will be submitted pursuant to 10 CFR Part 50.71(e), after issuance of the final Safety Evaluation for the ITS conversion.

A number of CTS requirements are being proposed for relocation to a licensee-controlled document because they either do not meet the screening criteria of 10 CFR Paa 50.34(c)(2)(ii) for the DAEC or are at a level of detail not required by NUREG-1433 for inclusion in the ITS (iz, a " Relocated Detail" as defined in Reference 2.) The proposed desti iation of these relocated items is identified in our Discussion of Changes (eg, UFSAR, QAPD, TS BASES, etc.), except

l NG-96-2322 October 30,1996 Page 3 of 5 where a destination has not yet been selected. Where a final destination is not identified, the Discussion of Change indicates that they are being relocated to a " licensee-controlled document" where " changes to the requirements will be evaluated in accordance with the DAEC 10 CFR 50.59 program." We will determine the f' mal destination of these relocated items during implementation of the ITS, acknowledging the guidance contained in Reference 3.

Attachment 5 contains the list of those Generic Travelers (by TSTF No.) that have been l incorporated into our submittal. The freeze date for consideration of Generic Travelers was July 31,1996, with TSTF-114 being the last traveler considered. No travelers, or revisions to

! previously-issued travelers, issued after this date have been included in our ITS.

The DAEC ITS includes a number of new Surveillance Requirements (SRs). We intend to treat these new SRs as being ' met' at the time ofimplementation of the ITS, with the first performance scheduled within the required Frequency starting from the final implementation i l

date. The ITS also will extend the Frequency of many current SRs, for example from 18 to 24 months. Upon implementation of the ITS, the due date for these SRs will be changed to reflect the new Frequency based upon their last performance date. In adelon, the new SRs for i Secondary Containment Isolation Valve / Damper stroke time te<!ing (ITS SR 3.6.4.2.1) and for l Turbine Bypass Valve functional and response time testing ( n r, 3Rs 3.7.7.2 and 3, l respectively), require a trial run to verify that they can be done with the DAEC design. A trial run l of these SRs is planned for the current refuel outage. Based upor. the results of these trial runs, we may need to revise our submittal to modify or delete these SRs. Consequently, we consider these issues to be Open Items in our submittal. We expect to close these Open Items by the end of this year.

i Implementation of the DAEC ITS is currently planned for the Fourth Quarter of 1997. This date l is based upon a requalification examination for licensed operators in December,1997 and to allow time for sufficient planning to support the Spring 1998 refuel outage. To meet this schedule, and acknowledging that additional review time will be needed by the Staff to support review of those items listed in Attachments 3 and 4, we request that the NRC issue the draft l l Safety Evaluation for our TS conversion by July 31,1997, with final approval no later than October 31,1997.

In accordance with Reference 2, in addition to the three copies required by 10 CFR Part 50.4, our application includes six additional copies for the Staff's use. By prior arrangement with our l l Licensing Project Manager (LPM), one of these six copies is being forwarded directly to the l NRC's contractor for their use. Also, by prior arrangement, we will be forwarding the electronic l version of our application to our LPM, via Internet transmission. The DAEC ITS LCOs and l

BASES have been prepared in Word Perfect 5.2 for Windows and the Discussion of Changes (DOCS) and No Significant Ilazards Considerations (NSIIC) evaluations have been prepared in MS Word 6.0 format.

i

s

. NG-96-2322

] October 30,1996 j Page 4 of 5 l The enclosed application has been approved by the DAEC Operations Committee and Safety Committee. This application and evaluation of No Significant Hazards Considerations has been forwarded to our appointed state official, pursuant to 10 CFR Part 50.91.

The following commitment is closed by this letter

I Submit the conversion of the DAEC TS to the Standard TS (NUREG-1433) by October i 31,1996.

j Please contact this ollice if you have any questions regarding this submittal.

i This applica90n, consisting of the foregoing letter, attachments and enclosure, is true and

. accurate to the best of my knowledge and belief.

l I IES UTILITIES INC.

By AA j /

/ John' F. Franz )

Vfee President, Nuclear l 1

State ofIowa '

) (County) of Linn Signed and sworn to before me on this AO day of O/~M 0 L

,1996, 9

by0P u Ar. ~ J it t u -

y o l oEBRA ). SCHWENKER

• Jtf '. f _Jf f f1)

Ih* "T"f"TP Notary Publi8m and for the Siate ofIowa i //- /- 91

] Commission Expires 4

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NG-96-2322

, October 30,1996 Page 5 of 5 Attachment 1: Description of the Content and Organization of each Volume of the DAEC i

Improved Technical Specifications (ITS) Submittal.

i Attachment 2: Brief Description of Changes to the Current Technical Specifications (CTS) that are Within Scope of the Improved Technical Specifications (.lTS) Conversion.

j Attachment 3: Brief Description of Changes to the Current Technical Specifications (CTS) that are Beyond Scope of the Improved Technical Specifications (ITS) Conversion.

4 Attachment 4: Significant Changes to the NUhi1i-1433 Requirements which maintain the l DAEC Current Licensing Basis.

Attachment 5: Technical Specification Task Force (TSTF) Generic Changes to NUREG-1433 that have been incorporated into the DAEC ITS.

)

Enclosure:

Volumes 1 through 20 of the DAEC Improved Technical Specifications (ITS) i Submittal (RTS-291)(described in Attachment 1).

1 cc: R. Browning (w/o Enclosure) l L. Liu (w/o Enclosure) 1 P. Baig (State ofIowa) (w/ Evaluation of No Significant Hazards Considerations only)

A. Beach (NRC Region III) (w/ Enclosure)

G. Kelly (NRC NRR)(w/ Enclosure,3 copies) i C. Grimes (NRC NRR) (w/ Enclosure,2 copies)

T. Ryan (Lockheed Idaho Technologies Co.) (w/ Enclosure)

NRC Resident Office (w/ Enclosure)

DOCU (w/ Enclosure) l I

4

2 i

. U. S. Nuclear Regulatory Commission i

Document Control Desk i

To Whom It May Concem

i i This is to inform you that we have made the necessary copies and i distributed them as follows:

Region III Office - I copy Resident Inspector- I copy j Licensing Project Manager - 3 copies l

Technical Specification Coordination Branch - 2 copies Contractor (Lockheed Idaho Technologies Co.) - I copy The enclosed Original is for your file copy.

If you have any questions, please contact Tony Browning, IES Utilities, Duane Arnold Energy Center, at (319) 851-7750.

I

i e Attachment I to NG-96-2322 October 30,1996

. Page 1 of I Description of the Content and Orpanization of each Volume of the DAEC Imoroved Technical Foecifications (ITS) Submittal Volume # 1: Application of 10 CFR 50.36 (c)(2)('i) Selection Criteria (including Relocation Matrix);

Mark-up of Relocated Current Teciinical Specification (CTS) pages.

Volume # 2: CTS mark-up pages (Limiting Conditions for Operations (LCOs) and Surveillance Requirements (SRs) only) in CTS order.

Note: Thefollowing Volumes are organi:ed in thefollowing manner on a Chapter /Section basis:

1) Clean, typed ITS (LCO and BASES); 2) CTS mark-up pages (LCOs andSRs only) in ITS order;

3) Discussion ofChanges (DOCS)for the CTS; 4) NUREG-1433 mark-up pages (LCO and BASES); 5) DOCsfor NUREG-1433; 6) No Sigmficant Ha:ards Consideration (NSHC) i evaluationt Volume # 3: DAEC ITS Chapter 1.0 Use and Application Volume #4: DAEC ITS Chapter 2.0 Safety Limits Volume #5 DAEC ITS Section 3.0 Limiting Cond:tions c .. Operation j Applicability and Surveillance )

Requirements Applicability 4

Volume #6 DAEC ITS Section 3.1 Reactivity Control System Volume #7 DAEC ITS Section 3.2 Power Distribution l

Volumes #8,9 & 10 DAEC ITS Section 3.3 Instrumentation Volume #11 DAEC ITS Section 3.4 Reactor Coolant System l 4

Volume #12 DAEC ITS Section 3.5 Emergency Core Cooling System and Reactor Core Isolation Cooling System j Volumes #13 & 14 DAEC ITS Section 3.6 Containment System Volutae 415 DAEC ITS Section 3.7 Plant Systems 4

Volume #16 DAEC ITS Section 3.8 Electrical Systems Volume #17 DAEC iTS Section 3.9 Refueling Operations Volume #18 DAEC ITS Section 3.10 Special Operations Volume #19 DAEC ITS CI: apter 4.0 Design Features Volume #20 DAEC ITS Chapter 5.0 Administrative Controls

_ __.~ __. _ ___ . _ _ . _ . - . . _ _ _ _ . . _ . _ _ . - _ _ . . _ . _ . _ . _ _ . _ . _ _ . . _ ._

e  :

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, Attachment 2 to NG-96-2322 October 30,1996 Page1ofI I j  !

Brief Description of Changes to the Current Technical Specifications (CTS) i {

that are Within Scone of the Imnroved Technical Soecifications (ITS) Conversion

! 1. Extension of Surveillance Requirements to support the extension of the operating cycle from i 18 months to 24 months, as described in NRC Generic Letter 91-04. In addition, the i

Frequency of other Surveillance Requirements has been extended, using the methodology of Generic Letter 91-04, but are less than 24 months.

t 4

I 2. Implementation of additional Allowed Outage Time (AOT) and extensions to Surveillance

! Test Intervals (STIs), per NRC-approved Topical Report GENE-770-06-1, " Bases for

! Changes ta Surveillance Test Intervals and Allowed Out of Service Times for Selected j Instrumentation Technical Specifications," February,1991.

I l 3. Conversion of CTS instrument setpoints fres current values to Allowable Values, in j accordance with the NRC-approved methodology of NEDC-31336," General Electric j Instrument Setpoint Methodology," October,1986.

i l 4. Relocation ofinstrument response time values from TS to Updated Final Safety Analysis j Report, in accordance with NRC Generic Letter 93-08.

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Attachment 3 to NG-96-2322 l October 30,1996  !

Page1of1 Brief Description of Changes to the Current Technical Specifications (CTS) that are Beyond Scone of the Imnroved Technical Specifications (ITS) Conversion 4

1. DAEC ITS 3.5.1 modifies NUREG-1433 LCO 3.5.1 by revising Conditions C, D, G and I to allow certain combinations of Emergency Core Cooling Systems / subsystems out of service j that are supported by the DAEC Loss-of-Coolant Accident (LOCA) analysis. (Note: this I change has been determined to be potentially generic and a proposed Traveler has been j

submitted to the BWR Owners' Group.) '

l

2. DAEC ITS SRs 3.5.1.4,3.5.1.5, and 3.5.1.6 modify NUREG-1433 SRs 3.5.1.7,3.5.1.8, and 3.5.1.9 to relax the required flowrates per the DAEC LOCA analysis, using the NRC-approved SAFER /GESTR-LOCA model.

3. DAEC ITS SR 3.8.4.1 modifies the frequency for NUREG-1433 SR 3.8.4.1 for performing pilot cell inspections from weekly to monthly, in accordance with industry (IEEE-450) and l vendor recommendations. l

4. The DAEC ITS relocates the requirements for Suppression Pool Spray (NUREG-1433 LCO 3.6.2.4) to licensee-controlled documents, as it does not meet the 10 CFR 50.36(c)(2)(ii) screening criteria.

Thefollowing changes represent requirements that are not in the CTS, but may not be current licensing basis, which represent significant deviationsfrom the NUREG-1433.

They have been characteri:ed as "beyond scope " changesfor overall conservatism.

5. DAEC ITS 3.0.3 modifies NUREG-1433 LCO 3.0.3 to allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> versus 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach Mode 2. In addition, all other Required Actions that require reaching Mode 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> have been extended to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for consistency (eg, NUREG-1433 LCO 3.3.4.2)(Note: this change has been determined to be potentially generic and a proposed Traveler has been submitted to the BW'R Owners' Group.)

6. DAEC ITS 3.4.8 and 3.9.7 modify NUREG-1433 LCO 3.4.7 and 3.9.8 to not require forced l circulation when reactor coolant temperature is less than 150 F. (Note: this change has been determined to be potentially generic and a proposed Traveler has been submitted to the BWR Owners' Group.)

7. DAEC 11S SR 3.8.1.C combines NUREG SRs 3.8.1.11,3.8.1.12 and 3.8.1.19 to eliminate unnecessary multiple Emergency Diesel Generator starts.

8. DAEC ITS 3.4.7 modifies the Applicability of NUREG 3.4.8 to use the Reactor Core Isolation Cooling (RCIC) low pressure isolation alarm in lieu of the Shutdown Cooling cut-in pressure permissive.

Attachment 4 to NG-96-2322 October 30,1996 Page1 of2 Significant Changes to the NUREG-1433 Requirements which maintain the DAEC Current Licensing Basis

1. The DAEC ITS preserves our current philosophy of not entering LCOs for TS-required SRs (and other secondary modes of operation) by the addition of Allowed Outage Time Notes in the necessary LCO Actions.

l

2. The DAEC ITS does not include the NUREG-1433 SRs 3.1.4.2 and 3.1.4.3 for performing I certain control rod drive scram time tests.

3. The DAEC ITS does not include the NUREG-1433 SRs 3.6.4.1.1 and 3.6.4.1.4 to periodically verify the Secondary Containment is normally maintained at negative pressure conditions and to perform certain tests to verify that these conditions can be reached within a specified time.

4. The DAEC ITS does not include the NUREG-1433 SR 3.6.1.1.2 requirement to increase the frequency of testing after two successive failures of the SR. l

5. The DAEC ITS maintains the CTS by modifying the NUREG-1433 LCO 3.6.3.4 to only require one Containment Atmosphere Dilution subsystem to be Operable.

6. The DAEC ITS does not include various NUREG-1433 SRs for periodically verifying manual valves are in their required positions (e.g., NUREG-1433 SR 3.7.1.1).

7. The DAEC ITS does not include the NUREG-1433 LCO 3.4.4.a requirement for zero Reactor Coolant Pressure Boundary (RCPB) Leakage.

8. The DAEC ITS maintains the CTS by modifying the NUREG-1433 LCO 3.8.1 requirements by revising the Completion Time for one Off-site Source inoperable to " prior to entering Mode 2 from Modes 3 or 4."

9. The DAEC ITS revises the NUREG-1433 LCO 3.8.4 Completion Time for restoration of one inoperable 125 VDC subsystem from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Note: this is a compromise from the CTS allowance of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

10. The DAEC ITS maintains the CTS by modifying the NUREG-1433 LCO 3.3.4.2 to only require one of the two ATWS Recirculation Pump Trip systems to be Operable.

I1. The DAEC ITS revises the NUREG-1433 Allowed Outage Time for performing SRs 3.3.5.11 and 3.3.5.2 from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

12. The DAEC ITS does not include the NUREG-1433 LCO 3.4.5 requirements for Pressure Isolation Valve (PlV) Leakage.

i

. , Attachment 4 to NG-96-2322 October 30,1996 i Page 2 of 2 l

Significant Changes to the NUREG-1433 Requirements which maintain the DAEC Current Licensing Basis (continued)

13. The DAEC ITS does not include the NUREG-1433 LCO 3.3.7.2 requirements for the I Feedwater and Turbine Trip on Reactor Iligh Water Level.

14. The DAEC ITS does not include the NUREG-1433 LCO 3.6.1.4 requirements for a normal operating limit for Drywell Pressure.

15. The DAEC ITS does not include the NUREG-1433 SRs 3.3.5.1.7 and 3.3.6.1.8 for instrument response time tests for ECCS and PCIS logics, respectively.

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l Attachment 5 to NG-96-2322 October 30,1996  !

Page1of1 Technical Specification Task Force (T3 TF) Generic Changes to NUREG-1433 that have been incorocrated into the DAEC ITS TSTF-01: Make LCO 3.0.5 applicable to variables in addition to systems and equipment.

TSTF-02: Relocate the 10 year sediment cleaning of the fuel oil storage tank to licensee control. 1 I

TSTF-05: Delete Safety Limit violation notification requirements. '

TSTF-08: Revise the SR 3.0.1 Bases to allow credit for unplanned events to meet any Surveillance.

1 TSTF-16: Add Action to LCO 3.8.9 to require entry into LCO 3.0.3 when there is a loss of '

function.

TSTF-17: Extension of testing frequency of containment airlock interlock mechanism from 184 days to 24 months.

l TSTF-18: Require only one Secondary Containment access door per access opening to be closed.

TSTF-32: Slow / Stuck Control Rod separation criteria.

i l

TSTF-33: Specification 3.1.3, Required Action A.2 Completion Time Note. l TSTF-34: Delete requirements to disarm the associated CRD when two or more withdrawn l Control Rods are stuck.

TSTF-36: Addition of LCO 3.0.3 N/A to shutdown electrical power specifications.

TSTF-37: Generic Letter 94-01 implementation.

TSTF-38: Revise visual surveillance of batteries to specify inspection is for performance degradation.

TSTF-46: Clarify the CIV surveillance to apply only to automatic isolation valves.

TSTF-64: Clarification of applicability of Channel Calibration and Channel Functional Test.

TSTF-65: Use of generic titles for utility positions.

TSTF-86: Delete overtime requirements in Section 5.0.

To: - rcwx( kirr. c \it\

%td O h M_ o k BOX Loll Vol.1 Split Report / Relocated CTS Vol. 2 CTS Markup (in CTS order)

Vol. 3 DAEC ITS Chapter 1.0 Vol. 4 DAEC ITS Chapter 2.0 Vol. 5 DAEC ITS Section 3.0 Vol. 7 DAEC ITS Section 3.2 Vol. 8 DAEC ITS Section 3.3 (Book 1 of 3)

Vol. 9 DAEC ITS Section 3.3 (Book 2 of 3)

Vol.17 DAEC ITS Section 3.9 Vol. I8 DAEC ITS Section 3.10 Vol.19 DAEC ITS Chapter 4.0 Vol. 20 DAEC ITS Chapter 5.0

/

s INPO Instelcte of Nucle 39 Pocer Opnations M Jilw:2 ;r6: a-. W,

nen. GA 3C3 N33

'70-644.%CO FAX : 0 044-H.sg COPYRIGHT LICENSE The Institute of Nuclear Power Operations (fNP6) hereby grants the N Commission (NRC) a Copyright License that authorizes NRC to make, for a limit period of time, a reasonable number of copies of copyrighted documents that are currently or that may become in the possession of the NRC. Such copying wou necessary for NRC internal use and to fulfill its legal responsibilities regarding documents in its Public Do;ument Room. However, this agreement does n modify or change any of the NRC's obligations to INPO regarding the withh Proprietary Documents from public disclosure under 10CFR2.790(a)(4). T License covers generic documents published by INPO bearing a " General Distribu classification and copyright as well as periodicals published by INPO, such as its A Report, 7 he Nuclear Professional magazine, brochures, etc. This authorizatio with tbc understanding that any copies of a specific publication made by the hTC will ccatinue to bear [NPO's copynght notice, which will be reproduced along with an portion of the publication. This Copyright License and release is retroactive and will expire on December 31,1997.

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Vice President Government Relations November 5,19%

W?o 8 Tr.TAl P,O?