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Revision as of 00:20, 2 April 2018

Monticello, Responses to Requests for Additional Information on Extended Power Uprate: Replacement Steam Dryer (TAC MD9990)
ML13071A615
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 03/07/2013
From: Schimmel M A
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-13-027, TAC MD9990
Download: ML13071A615 (35)


Text

ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATION -WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390SXcelEnergy Monticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362March 7, 2013 L-MT-13-02710 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Monticello Nuclear Generating PlantDocket 50-263Renewed License No. DPR-22Monticello Extended Power Uprate: Replacement Steam Dryer -Responses toRequests for Additional Information (TAC MD9990)References: 1) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"License Amendment Request: Extended Power Uprate (TACMD9990)," L-MT-08-052, dated November 5, 2008. (ADAMSAccession No. ML083230111)2) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Replacement Steam DryerSupplement (TAC MD9990)," L-MT-10-046, dated June 30, 2010.(ADAMS Accession No. ML102010462)3) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Updates to Docketed Information(TAC MD9990)," L-MT-10-072, dated December 21, 2010. (ADAMSAccession No. MLI103570026)4) Letter from M A Schimmel (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Supplement to Revise TechnicalSpecification Setpoint for the Automatic Depressurization SystemBypass Timer (TAC MD9990)," L-MT-12-091, dated October 30, 2012.(ADAMS Accession No. ML12307A036)5) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello NuclearGenerating Plant -Draft Requests for Additional Information re:Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs42 -53] dated November 8, 2012.

Document Control DeskPage 26) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello NuclearGenerating Plant -Draft Requests for Additional Information re:Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs54- 67] dated December 13, 2012.7) Email from K Feintuch (NRC) to J Fields (NSPM), "Monticello NuclearGenerating Plant -Draft Requests for Additional Information re:Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAI67e] dated December 17, 2012. (ADAMS Accession No.ML12353A053)8) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello NuclearGenerating Plant -Draft Requests for Additional Information re:Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs68 -80] dated January 4, 2013.9) Letter from T Beltz (NRC) to J Fields (NSPM), "Monticello NuclearGenerating Plant -Draft Requests for Additional Information re:Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs81 -84] dated January 16, 2013.Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesotacorporation (NSPM), doing business as Xcel Energy, requested in Reference 1 anamendment to the Monticello Nuclear Generating Plant (MNGP) Renewed OperatingLicense (OL) and Technical Specifications (TS) to increase the maximum authorizedpower level from 1775 megawatts thermal (MWt) to 2004 MWt.In Reference 2 NSPM provided a supplement to Reference 1 to provide detailed designand analysis results for a replacement steam dryer (RSD) for MNGP. Reference 3 wasprovided to correct reactor internal pressure differential information provided inReference 2.In References 5, 6, 7, 8 and 9 the NRC provided NSPM draft requests for additionalinformation (RAIs). Conference calls regarding these draft RAIs were held onDecember 4, 2012, January 18, 2013 and February 19, 2013.The purpose of this letter is to provide the NRC with responses to the EPU-EMCB-RSD-RAI-43, 45, 46, 48, 54, 59, 60, 63, 64, 72(a), 74, 75 and 79. This is the second in aseries of letters that will provide responses to all the NRC RAIs included in References5 through 9.Enclosure 1 contains Westinghouse Electric Company, LLC (WEC) letter LTR-A&SA-13-2, P-Attachment, Revision 1, "Monticello Replacement Steam Dryer RAI Responsesfor Acoustic/Structural Analyses Set #2," dated March 4, 2013. Enclosure 1 providesresponses to RAIs 43, 45, 46, 48, 54, 59, 60, 63, 64, 72(a), 74, 75 and 79. Enclosure 1contains proprietary information.

Document Control DeskPage 3Enclosure 2 contains WEC letter LTR-A&SA-13-2, NP-Attachment, Revision 1,"Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural AnalysesSet #2," dated March 4, 2013. This is a non-proprietary version of the responsesprovided in Enclosure 1.Enclosure 3 contains a WEC affidavit executed to support withholding Enclosure 1 frompublic disclosure. The affidavit sets forth the basis on which the information may bewithheld from public disclosure by the NRC and addresses with specificity theconsiderations listed in 10 CFR 2.390(b)(4). NSPM requests that the proprietaryinformation in Enclosure 1 be withheld from public disclosure in accordance with10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Accordingly, it is respectfullyrequested that the information which is proprietary to WEC be withheld from publicdisclosure in accordance with 10 CFR 2.390.Correspondence with respect to the copyright or proprietary aspects of WECinformation or the supporting WEC affidavit in Enclosure 3 should be addressed to J. A.Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC,Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.The RAI responses provided herein do not change the conclusions of the No SignificantHazards Consideration and the Environmental Consideration evaluations provided inReference 1 as revised by References 3 and 4.In accordance with 10 CFR 50.91(b), a copy of this application supplement, withoutenclosures is being provided to the designated Minnesota Official.Summary of CommitmentsThis letter makes no new commitments and no revisions to existing commitments.

Document Control DeskPage 4I declare under penalty of perjury that the foregoing is true and correct.Executed on: March c.', 2013Mark A. SchimmelSite Vice-PresidentMonticello Nuclear Generating PlantNorthern States Power Company-MinnesotaEnclosures (3)cc: Administrator, Region III, USNRC (w/o enclosures)Project Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC (w/oenclosures)Minnesota Department of Commerce (w/o enclosures)

L-MT-13-027ENCLOSURE 2WESTINGHOUSE LETTER, LTR-A&SA-13-2, NP-ATTACHMENT, REVISION 1MONTICELLO REPLACEMENT STEAM DRYERRAI RESPONSES FOR ACOUSTIC/STRUCTURAL ANALYSES SET #2This Enclosure covers the following NRC Requests for Additional Information:1) MNGP EPU-EMCB-RSD-432) MNGP EPU-EMCB-RSD-453) MNGP EPU-EMCB-RSD-464) MNGP EPU-EMCB-RSD-485) MNGP EPU-EMCB-RSD-546) MNGP EPU-EMCB-RSD-597) MNGP EPU-EMCB-RSD-608) MNGP EPU-EMCB-RSD-639) MNGP EPU-EMCB-RSD-6410) MNGP EPU-EMCB-RSD-72(a)11) MNGP EPU-EMCB-RSD-7412) MNGP EPU-EMCB-RSD-7513) MNGP EPU-EMCB-RSD-7922 pages follow Westinghouse Non-Proprietary Class 3LTR-A&SA-13-2 NP-AttachmentRevision 1Monticello Replacement Steam DryerRAI ResponsesforAcoustic/Structural Analyses Set #2March 4, 2013Westinghouse Electric Company LLC1000 Westinghouse DriveCranberry Township, PA 16066 USA© 2013 Westinghouse Electric Company LLCAll Rights Reserved LTR-A&SA- 13-2 NP-AttachmentRevision IMonticello Replacement Steam DryerRAI Responses for Acoustic/Structural Analyses Set #2MNGP EPU-EMCB-RSD-RAI-43 (a, b)As described on page 3-16 of section 3.3 of WCAP-1 7540-P, Rev. 0, the licensee utilizes theacoustic model parameters, including bias and uncertainties (B&U) derived fromasC(a) The licensee is therefore requested to include [a,cResponse[Ia,c2 LTR-A&SA- 13-2 NP-AttachmentRevision 1The ACE Revision 2.0 model will be developed as such:ac3 LTR-A&SA- 13-2 NP-AttachmentRevision I(b) All bias errors and uncertainties should also include frequencies belowa,cThe licensee is requested to provide measured pressure dataa,cResponseL]a,c4 FLTR-A&SA- 13-2 NP-AttachmentRevision Ia, bFigure RAI-43-1PSDs for RSD Pressure Transducer Channel P01, All Power Levels5 LTR-A&SA-13-2 NP-AttachmentRevision Ia, bFigure RAI-43-2PSDs for RSD Pressure Transducer Channel P03, All Power Levelsa, bFigure RAI-43-3PSDs for RSD Pressure Transducer Channel P04, All Power Levels6 LTR-A&SA- 13-2 NP-AttachmentRevision 1a, bFigure RAI-43-4PSDs for RSD Pressure Transducer Channel P08, All Power Levelsa, bFigure RAI-43-5PSDs for RSD Pressure Transducer Channel P1O, All Power Levels7 LTR-A&SA- 13-2 NP-AttachmentRevision 1a,ba, bFigure RAI-43-6PSIs for RSD Pressure Transducer Channel P13, All Power LevelsFigure RAI-43-7PSDs for RSD Pressure Transducer Channel P14, All Power Levels8 LTR-A&SA- 13-2 NP-AttachmentRevision 17a, ba, bFigure RAI-43-8PSDs for RSD Pressure Transducer Channel P17, All Power LevelsFigure RAI-43-9PSDs for RSD Pressure Transducer Channel P18, All Power Levels9 LTR-A&SA- 13-2 NP-AttachmentRevision IaFigure RAI-43-10PSDs for RSD Pressure Transducer Channel P21, All Power LevelsaFigure RAI-43-11PSDs for RSD Pressure Transducer Channel P22, All Power Levels10 LTR-A&SA- 13-2 NP-AttachmentRevision 1 IFigure RAI-43-12RMS Pressure Around Peak at Approximately 18 Hz, P01a, bacMNGP EPU-EMCB-RSD-RAI-45The licensee is requested to provide details on the frequency and location]acResponse[I1I LTR-A&SA- 13-2 NP-AttachmentRevision IMNGP EPU-EMCB-RSD-RAI-46Referring to Section 2.2 of report WCAP-1 7540-P, which discusses the acoustic circuit analysis,the licensee is requested to explain [Ia,c Please explain how thecharacteristics of these dipoles are determined.ResponseBased on the approach mentioned in MNGP EPU-EMCB-RSD-RAI-43(a), []a.cMNGP EPU-EMCB-RSD-RAI-48The discussion on Page 3-14 of WCAP-1 7540-P refers to pressure fluctuations due to vortexshedding from the lateral beams of the dryer. The licensee is requested to provide]a,cResponseMNGP EPU-EMCB-RSD-RAI-54acIn response to RAI MNGP-EMCB-SD-RAI-35 (LTR-A&SA-1 2-10, Rev. 1), the licensee statesthat there are several non-structural fillet welds which are not critical to the design qualificationof the dryer. Section 3.1 of WCAP-1 7549-P mentions non-structural components.I]a,c12 LTR-A&SA- 13-2 NP-AttachmentRevision 1Response[]a~c13 LTR-A&SA- 13-2 NP-AttachmentRevision 1-1 a,c14 LTR-A&SA- 13-2 NP-AttachmentRevision 17 a,c15 LTR-A&SA- 13-2 NP-AttachmentRevision 17 ac16 LTR-A&SA- 13-2 NP-AttachmentRevision Ia,cMNGP EPU-EMCB-RSD-RAI-59 (a, b, c)In Section 5.0 of WCAP-17549-P, the licensee discusses the modal analysis of the dryerperformed in the frequency range of [ ]ac. The staff requests the following additionalinformation:(a) Please explain the purpose of this [Ia,cResponseIf,c(b) Provide a comparison ofIaxC17 LTR-A&SA- 13-2 NP-AttachmentRevision IResponseThe measured RSD modes matched very well with the simulated modes and frequencies fromthe FEM. These results are summarized in the response to Action Item #6 from the NRC auditheld on April 7-8, 2011.[]a,c(c)]a,cPlease include these low frequency pressure signals in the dryer stress analysis and submit theresults for the staffs review.ResponseMNGP EPU-EMCB-RSD-RAI-60 (a, b)Page 6-1 of WCAP-1 7549-P, Revision 0, dated May 2012, states the following:a,cac18 LTR-A&SA- 13-2 NP-AttachmentRevision 1Responsea,c(b) Submit WCAP-17251-P for review by the NRC staff because it was not included in theprevious submittals by the licensee.ResponseWCAP-17251-P was submitted to the NRC in Northern States Power- Minnesota (NSPM) letterL-MT-10-046, dated June 30, 2010 (ADAMS Accession No. ML102010462), Enclosure 5.MNGP EPU-EMCB-RSD-RAI-63The licensee is requested to validate the [Ia,cResponseLI a,cMNGP EPU-EMCB-RSD-RAI-64 (a. b, c)In Section 3.4 of WCAP-17540-P, the licensee discusses end-to-end B/U.]a.c The staff requests the following additionalinformation:(a) Provide an example showingIa,c19 LTR-A&SA- 13-2 NP-AttachmentRevision IResponse(b) Provide the final summed end-to-end bias and uncertainty determined at CLTPResponse(c)[a,cIa,c20 LTR-A&SA- 13-2 NP-AttachmentRevision IResponseLI a,cMNGP EPU-EMCB-RSD-RAI-72Ia,cPlease provide the following information:(a) Describe and show examples of how theIa,cResponseLI a,cMNGP EPU-EMCB-RSD-RAI-74Plots of Measured and Predicted StrainFigure 3-17 of WCAP-1 7540-P provides a comparison of measured strain and predicted straina,cResponseWCAP-17716-P will provide comparison of measured and predicted strain for all []acMNGP EPU-EMCB-RSD-RAI-75 (a. b)IIa,cThe NRC staff notes that the magnitudes of the strain correction factors presented in Table 3.9of WCAP-1 7540-P are [ ]a,cPlease provide the following information:21 LTR-A&SA- 13-2 NP-AttachmentRevision I(a)a,c(b) Explain whether the[a,cResponseMNGP EPU-EMCB-RSD-RAI-79Pressure Amplitude for P2 and P3 Pressure TransducersFigure 3-8 in WCAP-1 7540-P indicates that the []` However, the pressure spectra given in Figure 5-23 of WCAP-17548-P suggest that the [ ]a,cPlease clarify the discrepancy between these two figures.Response[]a~c22 L-MT-13-027ENCLOSURE 3WESTINGHOUSE AFFIDAVIT FORWITHHOLDING PROPRIETARY INFORMATION7 pages follow Westinghouse Westinghouse Electric CompanyNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852 Proj letter: LTR-EP-13-008CAW-13-3642March 7, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-A&SA-13-2 P-Attachment, Revision I "Monticello Replacement Steam Dryer RAIResponses for Acoustic/Structural Analyses Set #2" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-13-3642 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference CAW-13-3642, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,/James A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3642AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared James A. Gresham, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:James A. Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis 7th day of March 2013NotaaPbiCOMMONWEALTH OF PENNSYLVANIA.. NOTARIAL SEALRenee Giampole, Notary Public IPenn Township, Westmoreland CountyMy Commission Expires , 2013J 2CAW-13-3642(1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse ElectricCompany LLC (Westinghouse), and as such, I have been specifically delegated the function ofreviewing the proprietary information sought to be withheld from public disclosure in connectionwith nuclear power plant licensing and rule making proceedings, and am authorized to apply forits withholding on behalf of Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.'(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation 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 heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe 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 inconfidence. The application of that system and the substance of that system constitutesWestinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-13-3642Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

CAW-13-3642(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.(iv) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in LTR-A&SA-13-2 P-Attachment, Revision 1, "MonticelloReplacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #2"(Proprietary), for submittal to the Commission, being transmitted by Xcel Energy letterand Application for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk. The proprietary information as submitted by Westinghouse isthat associated with the Monticello Replacement Steam Dryer Project, and may be usedonly for that purpose.

5CAW-13-3642This information is part of that which will enable Westinghouse to:(a) Provide Westinghouse recommendations related to the new steam dryerinspection following operation at EPU conditions presently scheduled for Spring2015.Further this information has substantial commercial value as follows:(a) Westinghouse plans to sell the use of the information to its customers for thepurpose of the Monticello Replacement Steam Dryer Project.(b) The information requested to be withheld reveals the distinguishing aspects of amethodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin 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 theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified asproprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.