MNS-15-099, Submittal Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program

Submittal Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program

ML16029A188
Person / Time
Site:	Mcguire, McGuire
Issue date:	01/14/2016
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16029A193	List: MNS-15-099, Submittal Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program
References
MNS-15-099, TAC MF2934, TAC MF2935
Download: ML16029A188 (25)

Text

Steven D. Capps

• C* DUKE McGuire Nuclear Station Vice President EERGYO Duke Energy MG01VP 1 12700 Hagers Ferry Road Huntersville, NC 28078 a: 980.875.4805 f: 980.875.4809 Steven.Capps~duke-energy.com Serial: MNS-15-099 10 CFR 50.90 January 14, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station (MNS), Units 1 and 2 Docket Numbers 50-369, 50-370 Renewed License Numbers NPF-9 and NPF-17

Subject:

Submittal Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program (TAC Nos. MF2934 and MF2935).

References:

1. MNS Letter, License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants, dated September 26, 2013, Agencywide Document and Management System (ADAMS) Accession Number ML13276A126.

2. NRC Letter, McGuire Nuclear Station, Units 1 and 2 - Acceptance Review Results RE:

License Amendment Request to Adopt National Fire Protection Association 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants, (TAC Nos. MF2934 and MF2935), dated December 31, 2013, ADAMS Accession Number ML13354B879.

3. MNS Letter, Supplemental Information For License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants, dated January 8, 2014, ADAMS Accession Number ML14016A097.

4. NRC Letter, McGuire Nuclear Station, Units 1 and 2 - Acceptance of Requested Licensing Action RE: License Amendment Request to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (TAC Nos. MF2934 and MF2935), dated January 15, 2014, ADAMS Accession Number ML14014A279.

,'United States Nuclear Regulatory Commission

'January 14, 2016 Page 2

5. NRC Letter, Request for Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program (TAC Nos. MF2934 and MF2935), dated August 28, 2014, ADAMS Accession Number ML14233A366.

6. MNS Letter, Response to August 28, 2014, NRC Request for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated October 13, 2014, ADAMS Accession Number ML14297A162.

7. NRC Letter, Request for Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program (TAO Nos. MF2934 and MF2935), dated October 27, 2014, ADAMS Accession Number ML14295A307.

8. MNS Letter, Response to August 28, 2014, NRC Request for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated November 12, 2014, ADAMS Accession Number ML14328A628.

9. MNS Letter, Response to August 28, 2014, NRC Request for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated December 12, 2014, No ADAMS Number.

10. MNS Letter, Response to August 28, 2014, NRC Re'quest for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated January 26, 2015, ADAMS Accession Number ML15036A084.

11. MNS Letter, Response to August 28, 2014, NRC Request for Additional Information Regarding License Amendment Request to Implement A Risk-Informed Performance-Based Fire Protection Program, dated February 27, 2015, No ADAMS Number.

12. MNS Letter, Response to August 28, 2014, NRC Request for Additional Information Regarding License Amendment Request to Implement A Risk-Informed Performance-Based Fire Protection Program, dated March 13, 2015, No ADAMS Number.

13. NRC Letter, Request for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated May 8, 2015, ADAMS Accession Number ML15125A328.

14. NRC Letter, Request for Additional Information Regarding License Amendment Request To Implement A Risk-Informed Performance-Based Fire Protection Program, dated June 18, 2015, ADAMS Accession Number ML15147A628.

15. MNS Letter, Response to June 18, 2015, NRC Request for Additional Information Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program, dated July 15, 2015.

16. NRC Letter, Request for Additional Information Regarding License Amendment Request To Implement a Risk-Informed Performance-Based Fire Protection Program, dated August 18, 2015.

17. MNS Letter, Response to June 18, 2015, and May 8, 2015, NRC Requests for Additional Information Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program, dated August 20, 2015.

United States Nuclear Regulatory Commission ianuary 14, 2016 Page 3

18. MNS Letter, Response to August 18, 2015, NRC Request for Additional Information Regarding License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program, dated September 9, 2015.

19. MNS Letter, Administrative Changes to LAR Submittal Package Made at NRC Request, dated October 1,2015.

By letter dated September 26, 2013 (Reference 1), Duke Energy submitted a LAR to adopt a new, risk-informed, performance-based (RI-PB) fire protection licensing basis for the MNS Units 1 and 2.

On December 31, 2013 (Reference 2), the NRC requested supplemental information in order to make the September 26, 2013, LAR complete and acceptable for review by the NRC. By letter dated January 8, 2014 (Reference 3), Duke Energy provided the requested supplemental information to the NRC. By letter dated January 15, 2014 (Reference 4), the NRC accepted the September 26, 2013, LAR for review.

By letters dated August 28, 2014, and October 27, 2014 (References 5 and 7, respectively), the NRC requested additional information (RAI) in order to complete their review of the September 26, 2013, LAR. Those letters grouped the RAls into 60-day, 90-day, 120-day, and radiation release responses. Duke Energy provided the 60-day, 90-day, and some of the 120-day RAI responses by letters dated October 13, 2014, November 12, 2014, and December 12, 2014 (References 6, 8, and 9, respectively). Responses to the radiation release RAls and some of the remaining 120-day RAls were provided by letter dated January 26, 2015 (Reference 10).

By letter dated February 27, 2015 (Reference 11 ), Duke Energy submitted responses to all remaining first-round RAls, excluding Probabilistic Risk Assessment (PRA) RA! 03. This submittal also included revised responses to PRA RAI 12 and PRA RAl 17. By letter dated March 13, 2015 (Reference 12), Duke Energy submitted response to PRA RAl 03.

By letters dated May 8, 2015, June 18, 2015, and August 18, 2015 (References 13, 14, and 16, respectively), the NRC submitted second-round RAls to complete their review of the September 26, 2013, LAR.

By letters dated July 15, 2015 (Reference 15), August 20, 2015 (Reference 17), and September 9, 2015 (Reference 18), Duke Energy submitted responses to the second-round RAIs.

By letter dated October 1, 2015 (Reference 19), Duke Energy submitted several administrative changes to the LAR submittal package.

By email dated October 28, 2015, the NRC requested a clean copy of Attachment S of the LAR and requested final administrative changes to Attachment M of the LAR. See Enclosures 1 and 2 for this information. Additionally, Enclosure 3 resubmits Attachment W of the LAR with the request that it be submitted as Security-Related Information to be withheld from public disclosure under 10 CFR 2.390. When Enclosure 3 is separated from the rest of the letter, this submittal is de-controlled.

'United States Nuclear Regulatory Commission January 14, 2016 Page 4 This submittal does not contain any new or revised regulatory commitments.

Please direct any questions on this matter to Brian Richards at (980) 875-5171.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 14, 2016.

Sincerely, Steven 0. Capps Enclosures 1, 2, and 3

• United States Nuclear Regulatory Commission January 14, 2016 Page 5 xc:

C. Haney, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1 257 R. E. Martin, NFPA Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station W. L. Cox Ill, Section Chief North Carolina Department of Health and Human Services Division of Health Service Regulation Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1 645

ENCLOSURE I Duke Energy MNS NFPA 805 LAR Attachment M Revisions Note: The revised LAR pages in this enclosure replace the corresponding pages in the September 26, 2013, LAR in their entirety. The revised content of the LAR pages is denoted by a revision bar in the margin of the page.

Duke Energy Carolinas, LLC Attachment M~- License Condition Changes M. LICENSE CONDITION CHANGES 8 Pages Attached Rev 4 Rev 4Page M~-1

Duke Energy Carolinas, LLC Attachment IVl- License Condition Changes Replace the current MNS fire protection license condition 2.C.(4) for both Unit 1 and Unit 2 with the standard license condition in Regulatory Position 3.1 of RG 1 .205, modified as shown below.

Duk~e Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program th'at comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 26, 2013, as supplemented by letters dated January 8, 2014, October 13, 2014, November 12, 2014, December 12, 2014, January 26, 2015, February 27, 2015, March 13, 2015, July 15, 2015, August 20, 2015, September 9, 2015, October 1, 2015, and January 14, 2016, and as approved in the safety evaluation dated ______.Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at MNS. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 xl0-F/year (yr) for CDF and less than 1 xl 0-8 /yr for LERE. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Other Changes that May Be Made Without Prior NRC Approval

1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is Rev 4 Page M-2

Duke Energy Carolinas, LLC Attachment M - License Condition Changes functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NEPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is 'adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

SFire Alarm and Detection Systems (Section 3.8);

[]Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.10); and,

[]Passive Fire Protection Features (Section 3.11).

2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated _______to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

Transition License Conditions

1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

2) The licensee shall implement the modifications to its facility, as described in Attachment 5, Table S-2, "Plant Modifications Committed," of Duke Energy letter dated January 14, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the Unit 1 refueling outage currently scheduled for Spring 2016 (1EOC24). The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

Rev 4 Page iVl-3

Duke Energy Carolinas, LLC Atcmn M - License Attachment ies Condition odto Changes hne

3) The licensee shallItems,"

"Implementation implement the Energy of Duke items asletter listed in Attachment dated January 14,S, 2016, Table within S-3, 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then, implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation Item 1,2 is associated with modifications in Table S-2 andl will be completed 180 days after completion of the last risk related modification. Implementation Item 19 is associated with thermoplastic cable analysis and will be completed by June 30, 2017.

License condition 2.C.(4) for both Unit 1 and Unit 2 shall be superseded:

2.C.(4) Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SER dated March 1978 and Supplements 2, 5, and 6 dated March 1979, April 1981, and February 1983, respectively, and the safety evaluation dated May 15, 1989, subject to the following provisions:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

It is Duke Energy's understanding that implicit in the revocation of this license condition, all prior Fire Protection Program Safety Evaluations and commitments have been superseded in their entirety by the revised license condition.

No other license conditions need to be revised or superseded.

MNS implemented the following process for determining that these are the only license conditions required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c):

• A review was conducted of the MNS Renewed Facility Operating License NPF-9 and NPF-17, by MNS licensing staff and the NFPA 805 Transition Team. The review was performed by reading the Operating License and performing electronic searches. Outstanding LARs that have been submitted to the NRC were also reviewed for potential impact on the license conditions.

Page M-4 Rev 4 4 Page M-4

Duke Energy Carolinas, LLC Attachment M - License Condition Changes Duke Energy Carolinas, LLC Attachment M License Condition Changes Proposed Changes to Facility Operating License - Markup The current version of Renewed Facility Operating Licenses NPF-9 and NPF-17 have been marked up to reflect the proposed change.

Page M-5 Rev 4 Rev Page IVi-5

IMNS-Renewed Facility Operating License - Unit 1

(,1) Fire Protction,,, Pro..ram INSERT ATTACHMENT Duk nergyn te Caolifs LL halimfmntidrent. n fec provAditional CofnthitpponscntiedfrpotcionAprogrixam as dcreibed intheog theSRdtdMrh17 ndmnNo -,ar Supbicoplraeme 2,5 intohs ende6daed Marchin eluaioense Dated Maery 15ro1989, LubjCt tosheafllowingt throvaiioyn:

acodukce mayh make cAngeitiona Codthiapons. ieprtcinrga (5) Addtionalt Conditions The Adiioensehallcdtons cotinhted intirs AppndixtBns reviseaedthrug Ampendmen No 2of r eeyicoprtdit this renewed lcne operating (6) Anti~qtrutonSraeqLinsCoditions Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

A) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel B) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures C) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Renewed License No. NPF-9 Amendment No. 2-64 Page M-6

IMNS-Renewed Facility Operating License - Unit 2I (1) Fire, Protectio;,n Pro..r.m INSERT ATTACHMENT provi!sions of* thc.. ppro..d fire* prote÷,tion program.. as d.scibe in* , the UdtdFnlSfty Analysi Repo, for.the, faciit .. nd a.. ppro...ed in 1979,tApri 1981, an'-doFebuar 1983 thespc'- t l and he rfet e5)aluaetion dfathed MaE 1,199,sbjcttotefoloigerontos Thfoe lienseein ma" maketina changstrutionthe apperatovad fcireprtiectwion changresul would sinifcat adversel afenvrnetipct thebltoachet wasndt evaluated or that is significantly greater than that evaluated in the Final Environmental Statement dated April 1976, the licensee shall provide written notification to the Office of Nuclear Reactor Regulation.

(6) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 1-8-1, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Additional Conditions.

(7) Antitrust Conditions The licensee shall comply with the antitrust conditions delineated in Appendix C of this renewed operating license.

(8) Mitigqation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

A) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel B) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread Renewed License No. NPF-17 Amendment No. 2-44 Page M-7

Attachment - Replacement Fire Protection License Condition Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 26, 2013, as supplemented by letters dated January 8, 2014, October 13, 2014, November 12, 2014, December 12, 2014, January 26, 2015, February 27, 2015, March 13, 2015, July 15, 2015, August 20, 2015, September 9, 2015, October 1, 2015, and January 14, 2016, and as approved in~the safety evaluation dated ______.Except where NRC approval for changes or deviations is required by 10 CFR 50 .48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission ifthose changes satisfy the provisions set forth in 10 CER 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met.

The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at MNS. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than Ix 10-7 /year (yr) for CDF and less than Ix 10-8/yr for LERF.

The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Other Changes that May Be Made Without Prior NRC Approval

1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard."

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall Page M-8

Attachment - Replacement Fire Protection License Condition perform the engineering evaluation and procedure, conclude that or the change has not affected functionality of the component, system, physical arrangement, using the a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

,Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

• Gaseous Fire Suppression Systems (Section 3.10); and,

=Passive Fire Protection Features (Section 3.11).

2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated

___________to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

Transition License Conditions

1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

2) The licensee shall implement the modifications to its facility, as described in Attachment 5, Table S-2, "Plant Modifications Committed," of Duke Energy letter dated January 14, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the Unit 1 refueling outage currently scheduled for Spring 2016 (1E0C24). The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3) The licensee shall implement the items as listed in Attachment 5, Table S-3, "Implementation Items," of Duke Energy letter dated January 14, 2016, within 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then, implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation Item 12 is associated with modifications in Table S-2 and will be completed 180 days after completion of the last risk related modification. Implementation Item 19 is associated with thermoplastic cable analysis and will be completed by June 30, 2017.

Page M-9

ENCLOSURE 2 Duke Energy MNS NFPA 805 LAR Attachment S Note: The LAR pages in this enclosure constitute a clean copy of Attachment S of the LAR. They may replace the version of Attachment S found in the September 26, 2013, LAR in its entirety, but no revision bars are shown. All changes are traceable in previous correspondence letters.

Duke Energy Carolinas, LLC Attachment S - Modifications anc S. MODIFICATIONS AND IMPLEMENTATION ITEMS 8 Pages Attached Rev 3

Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Tables S-i, Plant Modifications Completed, and S-2, Plant Modifications Committed, provided below, include a description of the modifications along with the following information:

• A problem statement,

• Risk ranking of the modification,

• An indication if the modification is currently included in the Fire PRA,

. Compensatory Measure in place, and

• A risk-informed characterization of the modification and compensatory measure.

Table S-I Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification Fire PRA Measure Characterization 1 N/A 1, 2 Current Transformers The Current Transformers were N N N/A associated with a non-safety permanently bypassed by shorting power monitoring system in the them out.

Turbine Buildings created a situation in which a fire could potentially disable both safety related trains of the respective unit.

2 N/A 1, 2 Fire area conflict analysis The control power is now derived N N N/A determined that a control from the same source as the device in the circuit supplying pressurizer heaters.

assured electrical power to each of the two (2) Technical Specification required groups of pressurizer heaters received control power from a non-diesel generator backed power source.

Page 1 Rev 3 Rev Page 1

Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In CompRisk Informed Item Rank Unit Problem Statement Proposed ModificationIn C p Fire PRA Measure Characterization 1 Med 1, 2 Turbine Driven Auxiliary Engineering Change (EC) will N Y The modification will eliminate Feedwater Pump Suction resolve spurious operation, potential spurious operation Isolation Valve, which is Details/scope being developed, and is required as a result of normally open, required open the DID evaluation.

for HSB, is affected by spurious Unit 1 will be completed: 1 E0C24 operation due to cable failures. (Spring 2016) Appropriate compensatory FAs 4 (U2), 14 (U2), and 21 Unit 2 will be completed: 2EOC23 measures needed for any (U2) have possible IN 92-18 (Fall 2015) outstanding NFPA 805 related concerns, also. The credited compliance modifications will TDCAP, which starts on loss of be in place at the time of NFPA offsite power, will be damaged 805 program implementation if the suction valve goes and will be maintained until closed, associated modifications are complete.

Component: 1CA VA0007AC VFDRs: 04-040,14-014 19-10,21-012, and 24-008 Component: 2CA VA0007A VFDRs: 04-024,14-078, 14-079, 20-7,21-071, 21-072, and 24-082 2 High 1, 2 The Unit 2 overall LERF value Reduce WL inlet or vent to have a YY This modification improves is above the acceptable pipe restriction of 4 inches or less, overall LERF values.

threshold.

Unit 1 will be completed: 1 EOC24 Appropriate compensatory (Spring 2016) measures needed for any Unit 2 will be completed: 2EOC23 outstanding NFPA 805 related (Fall 2015) compliance modifications will be in place at the time of NFPA 805 program implementation and will be maintained until associated modifications are complete.

3 High 1, 2 The following cabinets have Seal the top surface of the Unit I Y Y This activity is considered a unsealed penetrations: 1 MLC, Fire Area 19, cabinets 1 MLC, maintenance activity and being Rev 3 Page 2

Duke Energy Carolinas, LLCAtahetS-MdfctosndmpmnainIes Attachment S - Modifications and Implementation Items Table 5-2 Plant Modifications Committed Itm anPobe ni SatmetPrpoedMdiictinIn Comp Risk Informed Ite RnkPrblmni Satmet PopsedMoifiaton Fire PRA Measure Characterization 1SCTC1, 1SCTC2, 1SCTC1, 1 SCTC2, 1 UCTC1, performed by work orders. This 1UCTC1, 1IUCTC2, IUCTC2, and 1UCTC3. activity is required to be done 1UCTC3, and 2MLC. due to credit taken in the Fire Seal the top surface of the Unit 2 PRA for sealed cabinets. This Fire Area 20, cabinet 2MLC. activity will reduce risk.

Unit 1 will be completed: I EOC24 Appropriate compensatory (Spring 2016) measures needed for any Unit 2 will be completed: 2EOC23 outstanding NFPA 805 related (Fall 2015) compliance modifications will be in place at the time of NFPA 805 program implementation and will be maintained until associated modifications are complete.

4 Low 1, 2 Valves 1(2) CA161C and 1(2) Engineering Change (EC) will install NN This modification will eliminate CA1 62C are a rising stem a bypass around both valves, impact of a hot gas layer concern in Fire Area 03, 04, Manual butterfly valves will be impairing operation of the rising and 14. installed around these valves, stem valve.

Component: 1 CA161C Unit 1 will be completed: 1 E0C23 Appropriate compensatory VFDR: 04-092,14-030 (Fall 2014) measures needed for any Unit 2 will be completed: 2EOC23 outstanding NFPA 805 related Component: 2CA161C (Fall 2015) compliance modifications will VFDR: 03-01 be in place at the time of NFPA 805 program implementation Component: 1CAI62C and will be maintained until VFDR: 04-093,14-031 associated modifications are complete.

Component:.2CA1 62C VFDR: 03-02 Page 3 Rev 3 Page 3

Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-3, Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program. This will occur within 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage. Then, implementation will occur within 60 days after startup from that scheduled refueling outage. Note that Implementation Item 12 is associated with modifications in Table S-2 and will be completed 180 days after completion of the last risk related modification. Implementation Item 19 is associated with thermoplastic cable analysis and this item will be completed by June 30, 2017.

Table S-3 Implementation Items Item Unit Description LAR Section / Source 1, 2 Perform the following recommendations from the Radiological Release 4.4.2 and Attachment E Evaluation:

1. Within each yard area fire strategy, identify RCA boundaries within the strategy and any potential escape paths. This includes building sumps and storm drains, where applicable. For consistency, it is recommended that even hardened barriers are identified. Examples of these would include: the containment hatch, fuel handling access hatch, water tight doors to the outside, as well as passage doors and roll-up doors.

2. Enhance Fire Brigade Guidelines (Procedure RP/0/A/5700/025, Fire Brigade Response) to include more detail on the control measures used to maintain radioactive release limits where monitoring cannot be accomplished. Examples include:

= Water fog streams used for smoke scrubbing.

• Controlling water runoff during fire suppression activities.

[] Covering drains and other similar containment measures.

3. Enhance Fire Brigade Guidelines (Procedure RP/0/A/5700/025, Fire Brigade Response) to instruct Radiation Protection personnel to respond to all fires within RCAs inside and outside the Protected Area.

4. Enhance Fire Brigade Guidelines (Procedure RP/0/A/5700/025, Fire Brigade Response) to include guidance for crossing RCA/RCZ boundaries including escape routes.

5. Develop a Standard Operating Guideline (SOG) for fires involving contaminated material outside of the power block.

6. Create new fire strategies for yard areas that contain RCJAs.

_This includes Radwaste Facility, Warehouse 7, and the open yard areas where tanks and land-sea containers are stored.

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Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source

7. Within each fire strategy, identify the RCA or Radioactive Control Zone in the written text.

8. Fire Brigade training will be revised to ensure the new guidance included in Procedure RP/0/A/5700/025, Fire Brigade Response for radioactive release is covered during the established training interval.

9. Add a standard statement for water runoff to all RCA fire strategies similar to the caution contained for smoke removal.

10. Incorporate all fire fighting strategies into the electronic records

• management retrieval system (internally referred to as NEOL).

This will provide consistency for current users and the ability to conduct effective reviews to ensure all radioactive release recommendations have been incorporated.

11. Add an appendix to the fire strategies for building sump drainage and site storm drains. This is NOT intended to be a detailed plan, but a site overview that identifies areas where runoff has the potential to route to a storm drain or an automatic sump that will pump without radiation monitoring.

12. Develop a SOG to address owner controlled area RCAs. This would include, for example, Warehouse 7 and outage equipment stored there.

13. Develop administrative guidance, in collaboration with radiation protection, to support ensuring that radioactive release(s) do not exceed limits in the event of a fire in areas where engineering controls will not contain the potential release.

21, 2 After the approval of the LAIR, in accordance with 10 CFIR 50.71(e), the 5.4 MNS UFSAR will be revised. The format and content will be consistent with NEI 04-02 FAQ 12-0062.

31, 2 Revise station documentation (Design Basis Specification for Fire 4.1.2 and Attachment A, 3.2.2.4 Protection) to state the NRC is the AHJ for fire protection changes requiring approval.

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Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 4 1, 2 Revise appropriate fire protection program document(s) to provide a 4.1.2 and Attachment A, 3.2.3(1 )

requirement that if a plant elects to implement the methodologies in EPRI Report TR-1 006756, that the methodologies will be implemented in their entirety as they pertain to the fire protection systems or features being evaluated.

5 1, 2 The monitoring program required by NFPA 805 Section 2.6 will be 4.1.2 and Attachment A, 3.2.3(3) implemented after the LAR approval as part of the fire protection program 4.6.2 transition to NFPA 805, in accordance with NFPA 805 FAQ 10-0059, and will include a process that reviews the fire protection performance and trends in performance.

6 1, 2 Revise station procedures/directives to comply with NFPA 805 Section 4.1.2 and Attachment A, 3.3.1.2(1) 3.3.1.2(1).

7 1, 2 Revise appropriate station documentation to include the requirements for 4.1.2, Attachment A, 3.3.5.1, and Attachment L, installation of cable above suspended ceilings. Approval Request #2 8 1, 2 Review MNS fire strategies for compliance with NFPA 805 requirements 4.1.2 and Attachment A, 3.4.2.1 and update as applicable.

9 1, 2 The Fire Protection Design Basis Document described in Section 2.7.1.2 4.7.1 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation. Appropriate cross references will be established to supporting documents as required by MNS processes.

10 1, 2 Ensure the MNS configuration control process follows the requirements in 4.7.2 NFPA 805 and the guidance outlined in RG 1.174 which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered. The configuration control requirements should be implemented in accordance with FAQ 12-0061.

11 1, 2 Develop Engineering training guidelines to identify and document 4.7.3 required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.

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Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 12 1, 2 Following installation of the risk related modifications and the as-built 4.8.2 installation details, additional refinements surrounding the modifications and procedural implementation items (Table S-3 Items 13 and 14) will be incorporated into the Fire PRA model and Internal Events model, as required. In addition, a verification will be performed to confirm that the risk results are not appreciably changed. If the as-built change-in-risk estimates exceed the RG 1.174 acceptance guidelines, the responsible feature will be identified and evaluated. Actions taken to address such a case may be one or more of the following: 1) implementing additional modifications, 2) refining the analytical estimates, or 3) requesting that exceeding the guidelines be deemed acceptable in a new LAR,.

13 1, 2 Revise.Shutdown Risk Management procedures to reflect the appropriate 4.3.2 recommendations noted in FAQ 07-0040, as determined in the calculation Attachment D entitled, "NFPA 805 Transition - NPO".

14 1,2 Implementation items resulting from the feasibility evaluation include: Attachment G

• Corrective action to add hard hat lights in control room and operation's kitchen to procedure, ]PI/OB/3260/031.

[] Add 60 minutes time to throttle Turbine Driven Auxiliary Feedwater valves to "Time Critical" program.

• ] Add 60 minutes time to trip NC Pumps (for FA-13(Units 1 and 2))

to 'Time Critical" program (this is not a loss of seal cooling event).

15 1, 2 Revise the QA Topical, as appropriate, to update the definition of QA 3 to 4.7.3 match post NFPA 805 criteria. QA Topical currently defines QA 3 as:

"QA Condition 3 covers those systems, components, items, and services which are important to fire protection as defined in the Hazards Analysis for each station. The Hazards Analysis is in response to Appendix A of NRC Branch Technical Position APCSB 9.5-1."

16 1,2 Update the transient combustible control procedure to reflect the Attachment C, FRE, PIP 13-6092.

requirements in NFPA 805 analysis documentation.

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Duke Energy Carolinas, LLC Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description I-AR Section / Source 17 1, 2 The following MCCs where one or more external failures involved Attachment V components with a RAW greater than 10 were flagged for increased PM frequency: 1EPEMXEMXA2, 1EPEMXEMXA3, 1EPEMXEMXD, 1 EPEMXEMXH, 2EPEMXEMXA2, 2EPEMXEMXB5, and 2EPEMXEMXD.

Revise the PMs associated with these MCCs to increase the PM frequency.

18 1, 2 Update station documentation to indicate requirements for interior floor Attachment A, 3.3.3 finishes.

19 1, 2 Revise the MNS Fire PRA analysis to reflect the quantities of RAI FM-02a, RAI FM-02b, RAI FM-01 .j.01, RAI thermoplastic cable installed in the plant. Guidance in NUREG/CR-6850 PRA-03.d and other NRC accepted documents will be used to perform the analysis. The impact on the Fire CDF/LERF and the delta CDF/LERF will be reviewed to verify the results are within RG 1.174 acceptance guidelines. An MSO Expert Panel will also be conducted as part of the Fire PRA update. MNS will complete this analysis by June 30, 2017.

If the impact on risk estimates exceed the RG 1.174 acceptance guidelines, actions taken to address this case may be one or more of the following: 1) refining the analytic estimates, 2) communicating to the NRC the need and proposed schedule to implement additional modifications, or

3) requesting that exceeding the guidelines be deemed acceptable in a new LAR." Until the post Fire PRA reanalysis is complete and the results are within the RG 1.174 acceptance guidelines, the use of the Fire PRA for self-approval of plant changes affecting the fire protection program will be restricted to changes that are not greater than minimal for the fire areas with greater than 5% thermoplastic cable.

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