View source for BSEP 17-0017, Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material

{{Adams
| number = ML17331A484
| issue date = 11/15/2017
| title = Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material
| author name = Gideon W
| author affiliation = Duke Energy Progress, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person = 
| case reference number = BSEP 17-0017
| document type = Letter type:BSEP, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 50
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:William R. Gideon
( -, DUKE                                                                                              Vice President ENERGY                                                                                  Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 November 15, 2017                                                                   10 CFR 50.90 10 CFR 50.48(c)(2)(vii)
Serial: BSEP 17-0017 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

==Subject:==
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material

==Reference:==
: 1. Letter from Andrew Hon (NRC) to William R. Gideon (Duke Energy),
Issuance of Amendment Regarding Transition to a Risk-Informed ,
Performance-Based Fire Protection Program in Accordance With 10 CFR 50.48(c), dated January 28, 2015, ADAMS Accession Numer ML14310A808.
Lad ies and Gentlemen:
In accordance with 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.90, Duke Energy Progress, LLC (Duke Energy), is submitting a request for an amendment to the Renewed Facility Operating Licenses (RFOL) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment would modify the RFOL to allow, as a performance-based method ,
certain currently-installed thermal insulation materials to be retained and allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from the NFPA 805 Chapter 3, Section 3.3, Prevention .
Enclosure 1 provides the technical basis for this request. Enclosures 2 and 3 provide marked-up pages of the existing Unit 1 and 2 RFOLs, respectively. Enclosures 4 and 5 provide revised (i.e.,
typed) RFOL pages for Units 1 and 2, respectively. Enclosure 6 provides a copy, for information only, of the proposed update to Calculation OFP-1213, Code Compliance Evaluation NFPA 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants - 2001 Edition , which is cited in Section 9.5.1.2.1.2 in the BSEP Updated Final Safety Analysis Report as the plant's compliance documentation with Chapter 3 of NFPA 805.
Duke Energy requests approval of this proposed license amendment request by November 30, 2018, with the amendment being implemented within 120 days.
In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

U.S. Nuclear Regulatory Commission Page 2 of 3 Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 15, 2017.
s~
William R. Gideon WRM/wrm

==Enclosures:==
: 1. Technical Basis for Proposed License Amendment
: 2. Marked-up Renewed Facility Operating License Pages - Unit 1
: 3. Marked-up Renewed Facility Operating License Pages - Unit 2
: 4. Revised Renewed Facility Operating License Pages - Unit 1
: 5. Revised Renewed Facility Operating License Pages - Unit 2
: 6. Update to Calculation OFP-1213, Code Compliance Evaluation NFPA 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants -
2001 Edition

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosures):
U.S. Nuclear Regulatory Commission, Region II ATTN : Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN : Mr. Gale Smith, NRC Senior Resident Inspector 84 70 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN : Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville , MD 20852-2738 Andrew.Hon@nrc.gov Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh , NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)
Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh , NC 27699-1645 lee.cox@dhhs .nc.gov

Enclosure 1 BSEP 17-0017 Page 1 of 14 Proposed License Amendment for Performance-Based Fire Protection Alternative 1.0      Summary Description This evaluation supports a request to amend the Renewed Facility Operating Licenses (RFOL) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
The proposed license amendment request (LAR) revises fire protection license condition 2.B.(6) for BSEP, Units 1 and 2, to allow, as a performance-based method, certain currently-installed thermal insulation materials to be retained and allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from the NFPA 805 Chapter 3, Section 3.3, Prevention. This request is being made in accordance with 10 CFR 50.48(c)(2)(vii), to use a performance-based method fire protection program element.
By letter dated January 28, 2015, the NRC issued a license amendment approving the transition of the fire protection licensing basis for BSEP, Units 1 and 2, to National Fire Protection Association (NFPA) Standard 805. The updates to the RFOL associated with the NFPA 805 transition established provisions that allow Duke Energy Progress, LLC (Duke Energy), to make risk-informed changes to the Fire Protection Program provided the change has no more than minimal impact. The ability to make these risk-informed changes to the fire protection program is limited to four specific sections of NFPA 805, Chapter 3, as stipulated by RFOL Condition 2.B.(6)(b)1.
In several areas at BSEP, exposed thermal insulation materials are installed on various heating, ventilation and air conditioning (HVAC) system piping to prevent sweating. Although these materials comply with the flame spreading rating of 25 or less, these materials do not meet the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. This submittal requests NRC approval of a change to the RFOL to allow, as a performance-based method, certain currently-installed thermal insulation materials to be retained and allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from the NFPA 805 Chapter 3, Section 3.3, Prevention.
2.0      Assessment 2.1      Proposed Change The proposed amendment will revise fire protection license conditions 2.B.(6) and 2.B.6.(b)2 for BSEP, Units 1 and 2, as shown below:
License Condition 2.B.(6):
(6)     Fire Protection Duke Energy Progress, 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 license amendment requests dated September 25, 2012, as supplemented by letters dated December 17, 2012; June 28, 2013; July 15, 2013; July 31, 2013; August 29, 2013; September 30, 2013; February 28, 2014; March 14, 2014;

Enclosure 1 BSEP 17-0017 Page 2 of 14 April 10, 2014; June 26, 2014; August 15, 2014; August 29, 2014; November 20, 2014; and December 18, 2014; as approved in the safety evaluations dated January 28, 2015, and ((INSERT DATE)), 2017, as approved in the safety evaluation dated ((INSERT DATE)), 2018. 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 .
License Condition 2.B.(6)(b)2:
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval is 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 evaluations dated January 28, 2015, and ((INSERT DATE)), 2018, 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.
2.2      Basis for Request National Fire Protection Association (NFPA) Standard 805, Section 3.3.4, states:
Thermal insulation materials, rad iation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible .
NFPA 805 Section 1.6.36 has re-defined earlier definitions of non-combustible material to the now current definition of limited combustible material:
Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg) and either has a structural base of noncombustible material with a surfacing not exceeding a thickness of 1/8 in. (3.2 mm) that has a flame spread rating not greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.
As such, the definition of a limited combustible in NFPA 805 now includes requirements for materials to have a heat of combustion less than 3,500 BTU/lb.
A number of plant locations were identified where insulation material is used for maintaining efficiency of the system and/or preventing pipe sweat. Locations were identified in the Control Building , Reactor Buildings, Turbine Buildings. Radioactive Waste Building , and Augmented Off-Gas Building, on piping associated with heating, ventilation and air conditioning systems supporting Power Block structures including the following :

Enclosure 1 BSEP 17-0017 Page 3 of 14
* System 8260      - Turbine Building HVAC - piping routed in the Turbine Building
* System 8185      - Reactor Building HVAC- piping routed in the Reactor Building
* System 8220      - Control Building HVAC- HVAC Equipment Room
* System 8280      - Radwaste Building HVAC - piping routed in the Radwaste Building
* System 8270      - Augmented Off-Gas Building HVAC - piping routed in Augmented Off-Gas Building The locations are listed in Attachment 1.
These insulation materials meet requirements for flame spread rating of 25 or less, as measured using the test method of ASTM E-84, but do not meet the current decreased heat value content requirement based on the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. The heat contribution values of the thermal insulation materials installed at BSEP, Units 1 and 2, were noted as having heat contribution values of approximately 9,000 to 11 ,000 BTU/lb which , while higher than the definition , are not considered to contribute appreciably to the spread of fire nor represent a secondary combustible beyond those currently analyzed in the Fire Probabilistic Risk Analysis (PRA) due to the limited applications.
The basis for the approval of this request is:
* The forms in which the thermal insulation are installed, and the conditions anticipated, meet the intent of the revised limited combustible material definition because the materials used at BSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. Specifically, the thermal insulation materials used at BSEP have flame spread and smoke developed ratings of 25 and 50 per ASTM E-84, respectively. Although the thermal insulation materials exceed the NFPA 805 heat value of 3,500 BTU/lb, these insulation materials (i.e., polyisocyanurate/foam insulation) will not contribute significantly to fire per ASTM E-84.
* The three echelons of defense-in-depth are:
: 1) prevent fires from starting (i.e., combustible/hot work controls),
: 2) rapidly detect, control , and extinguish fires that do occur thereby limiting damage (i.e., fire detection systems, automatic fire suppression , manual fire suppression, pre-fire plans), and ,
: 3) provide an adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).
* The forms in which the thermal insulation are installed and the conditions anticipated do not impact the three echelons of defense-in-depth as discussed in Section 2.4 below.
* The forms in which the thermal insulation materials are installed and the conditions anticipated do not impact nuclear safety. The limited applications of exposed thermal insulation materials do not compromise post-fire safe shutdown capability as previously designed , reviewed , and considered . Essential safety functions are maintained and capable of being performed.

Enclosure 1 BSEP 17-0017 Page 4 of 14
* The identified installations were evaluated against the fire scenarios supporting the Fire PRA. In all instances, the supporting analyses and existing fire scenarios were found to be bounding (i.e., expanded zones of influence (ZOls) would not fail additional Fire PRA targets) or there were no Fire PRA credited targets in the area. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.
The identified installations were evaluated against the fire scenarios supporting the Fire PRA. In all instances, the supporting analyses and existing fire scenarios were found to be bounding or there were no Fire PRA credited targets in the area. The limited applications of exposed thermal insulation material were not of a quantity that would impact the fire scenarios or zones of influences and target failures developed in support of the fire and PRA analysis, and do not compromise automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability as previously designed , reviewed and considered . Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.
2.3      Nuclear Safety and Radiological Release Performance Criteria The use of thermal insulation material other than non-combustible and more than limited combustible in the plant does not affect nuclear safety. The limited applications of exposed thermal insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered. Essential safety functions are maintained and capable of being performed .
The forms in which the thermal insulation materials are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at BSEP have a flame spread rating of 25 or less and will not support continued progressive combustion. The selection and application of thermal insulation material is controlled per the BSEP piping and equipment thermal insulation specification . The Fire PRA development requires the inclusion of the effect of intervening or secondary combustibles to be documented and included in the analysis where determined to have fire effects as part of the performance-based approach. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.
Plant walkdowns concluded that there were no large concentration installations of thermal insulation in the plant. The most common applications are for maintaining efficiency of the system and/or preventing pipe sweat. The impact of the negligible quantities of exposed materials was noted to be bounded by the currently analyzed fire scenario ZOls, and did not result in new or expanded ZOls that impacted additional Fire PRA targets. No existing fire scenarios as considered in the Fire PRA were adversely impacted.
The use of insulation material other than non-combustible and more than limited combustible has no impact on the radiological release performance criteria . The radiological release review was performed based on the manual fire suppression activities in areas containing or potentially containing radioactive materials and is not dependent on the type of thermal insulation material.

Enclosure 1 BSEP 17-0017 Page 5 of 14 The insulation material, regardless of heat contribution value, does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained and smoke is monitored. The insulation materials do not add additional radiological materials to the area or challenge systems boundaries.
2.4       Safety Margin and Defense-in-Depth The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at BSEP have a flame spread rating of 25 or less and will not support continued progressive combustion .
The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not compromise automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability as previously designed, reviewed, and considered. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.
The insulation materials in the current configurations are considered as non-cable intervening combustibles and are bound by the Fire PRA, and safety margin is not affected . The selection and application of thermal insulation material is controlled per the BSEP piping and equipment thermal insulation specification. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required. The precautions and limitations on the use of these materials do not impact the fire safety analysis of the fi re event. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged.
As previously stated, the three echelons of defense-in-depth are:
: 1) prevent fires from starting (i.e., combustible/hot work controls),
: 2) rapidly detect, control, and extinguish fires that do occur, thereby limiting damage (i.e.,
fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans), and,
: 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).
The use of insulation material which is non-combustible or more than limited combustible does not affect Echelons 1, 2, and 3. The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not introduce new ignition sources, does not exceed the design bases of installed fire protection systems, does not compromise manual fire suppression functions, and does not adversely impact fire protection systems and features or post-fire safe shutdown capability as previously designed, reviewed, and considered.
Echelon 1: Prevent Fires from Starting :
With regard to Echelon 1, the thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at BSEP have a flame spread rating of 25 or less and will not support continued progressive combustion.

Enclosure 1 BSEP 17-0017 Page 6 of 14 Specifically, the thermal insulation materials used at BSEP have flame spread and smoke developed ratings of 25 and 50 per ASTM E-84, respectively. Although the thermal insulation materials exceed the NFPA 805 heat value of 3,500 BTU/lb, these materials will not contribute significantly to fire per ASTM E-84.
The selection and application of thermal insulation material is controlled per the BSEP piping and equipment thermal insulation specification. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.
Echelon 2: Rapidly Detect. Control and Extinguish Fires that do Occur thereby Limiting Damage:
With regard to Echelon 2, the limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not result in increased combustible loading which would challenge the design bases of the installed fire protection systems. The presence of the thermal insulation and associated procedural controls do not impact the ability of the automatic suppression and detection systems to perform credited functions, as the materials at BSEP are limited in application and will not support continued progressive combustion. Portable fire extinguishers and hose stations are available for manual firefighting activities by the site fire brigade. Therefore, if a fire was to occur, damage would be limited .
Echelon 3: Provide Adequate Level of Fire Protection for Systems and Structures so that a Fire will not Prevent Essential Safety Functions from being Performed:
With regard to Echelon 3, the limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not adversely impact the installed fire protection systems and features , and essential safety functions are maintained and capable of being performed. The insulation material does not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered . The forms in which the thermal insulation are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at BSEP have a flame spread rating of 25 or less and will not support continued progressive combustion . The identified installations were evaluated against the fi re scenarios supporting the Fire PRA. In all instances, the supporting analyses and existing fi re scenarios were found to be bounding (i.e. , expanded zones of influence would not fail additional Fire PRA targets) or there were no Fire PRA credited targets in the area. Duke Fleet Procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required . The presence of the thermal insulation does not compromise automatic/manual fire protection functions, or post-fire safe shutdown capability and will not prevent essential safety functions from being performed.

Enclosure 1 BSEP 17-0017 Page 7 of 14 2.5       Conclusion NRC approval is requested for use of ther.mal insulation materials that meet the flame spread criteria , but do not meet the heat value content criteria of NFPA 805. Duke Energy has determined that the approach satisfies the following criteria:
* the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiolog ical release;
* maintains safety margin ; and ,
* maintains fire protection defense-in-depth (i.e. , fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
3.0       Regulatory Evaluation 3.1       No Significant Hazards Consideration Analysis The proposed change will allow certain polyisocyanurate and foam thermal insulation materials which are currently installed on miscellaneous system piping at the Brunswick Steam Electric Plant, Units 1 and 2, to be retained , and to allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls. An evaluation of these materials has determined they do not contribute appreciably to the spread of fire, nor represent a secondary combustible beyond those currently analyzed in the Fire Probabilistic Risk Analysis (PRA) due to the limited applications where these materials are installed. As such, Duke Energy is requesting this license amendment pursuant to 10 CFR 50.48( c)(2)(vii) and 10 CFR 50.90.
Duke Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
: 1.        Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
A fire hazards evaluation was performed for the areas of the plant where the identified insulation materials are installed . The fire hazards evaluation demonstrates that these materials do not contribute appreciably to the spread of fire, nor represent a secondary combustible beyond those currently analyzed in the Fire Probabilistic Risk Analysis (FPRA) due to the limited applications where these materials are installed. Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated .
: 2.        Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response : No.
The identified installations of the insulation materials were evaluated against the fire scenarios supporting the FPRA. In all instances, the supporting analyses and existing

Enclosure 1 BSEP 17-0017 Page 8 of 14 fire scenarios were found to be bounding. Expanded zones of fire influence would not fail additional FPRA targets, or there were no FPRA credited targets in the area. Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated .
: 3.       Does the proposed change involve a significant reduction in a margin of safety?
Response : No.
The limited installations of the insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed , and considered. Essential fire protection safety functions are maintained and are capable of being performed. Because the insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered , it is concluded that this change does not involve a significant reduction in a margin of safety.
3.2      Future Installations Future installations of these insulation materials (i.e ., polyisocyanurate/foam insulation) will be controlled by the design engineering change process per procedure AD-EG-ALL-1132, Preparation and Control of Design Change Engineering Changes. This will ensure the necessary fire protection reviews per AD-EG-ALL-1502 , Fire Protection Impact Screening for Plant Design Changes, and AD-EG-ALL-1501 , Fire Protection Change Process, are completed ,
and evaluate the new installations and affects they would have on fire safety analyses and the Fire PRA. Specification 249-002 includes a requirement preventing installation of foam ,
polyisocyanurate, and other combustible insulations greater than 3,500 BTU/lb without a design change and fire protection review.
3.3      Applicable Regulatory Requirements By letter dated January 28, 2015, the NRC issued a license amendment approving the transition of the fire protection licensing basis for BSEP, Units 1 and 2, to National Fire Protection Association (NFPA) Standard 805.
Paragraph (2) of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, describes exceptions and modifications to the NRC's requirements regarding use of NFPA 805.
10 CFR 50.48(c)(2)(vii) states that performance-based methods may be used for fire protection program elements and minimum design requirements , subject to being submitted to the NRC in the fo rm of a license amendment request under 10 CFR 50.90.
NFPA 805 Section 3.3.4 states:
Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible .
NFPA 805 Section 1.6.36 has re-defined earlier definitions of non-combustible material to the now current definition of limited combustible material :
Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg) and either has a structural base of noncombustible material with a

Enclosure 1 BSEP 17-0017 Page 9 of 14 surfacing not exceeding a thickness of 1/8 in. (3.2 mm) that has a flame spread rating not greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.
As such, the definition of a limited combustible in NFPA 805 now includes requirements for materials to have a heat of combustion less than 3,500 BTU/lb.
In several areas at BSEP, exposed thermal insulation materials are installed on various HVAC system piping to prevent sweating. Although these materials comply with the flame spreading rating of 25 or less, these materials do not meet the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. As such, in lieu of replacing these insulation materials, and to allowed future use of these materials in selected applications, Duke Energy is requesting this license amendment pursuant to 10 CFR 50.48( c)(2)(vii) and 10 CFR 50.90.
3.4       Precedents Similar requests for performance-based methods have been included in other license amendment requests to transition to fire protection licensing basis under NFPA 805. Examples include:
: 1. On February 3, 2017, the NRC issued Amendment No. 249 to the H. B. Robinson Renewed Facility Operating License. The amendment authorized the transition of the fire protection program to a risk-informed, performance-based program based on NFPA Standard 805. Section 3.1.4.5 of the NRC Safety Evaluation discussed NFPA 805 Section 3.3.4 similar insulation materials and concluded it was an acceptable alternative.
: 2. On September 26, 2013, Duke Energy submitted a license amendment request for the McGuire Nuclear Station Units 1 and 2, to transition the fire protection program to a risk-informed, performance-based program based on NFPA Standard 805. By letter dated September 29, 2016, Duke Energy submitted a response to a request for additional information for similar insulation material concerns and compliance with NFPA 805, Section 3.3.4, Insulation Materials. On December 6, 2016, the NRC issued Amendment Nos. 291 and 270 to the Renewed Facility Operating License McGuire Nuclear Station, Units 1 and 2, respectively, authorizing the transition of the fire protection program to a risk-informed , performance-based program based on NFPA Standard 805.
4.0       Environmental Consideration A review has determined that the proposed amendments do not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, Standards for Protection Against Radiation, and do not change an inspection or surveillance requirement. The proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significance increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Because the proposed amendments meet the eligibility criterion for categorical exclusion and do not involve a special circumstance, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

BSEP 17-0017 Enclosure 1 Attachment 1 Page 10 of 14 Turbine Building (TB1)
Fire Zone    Description                                    Drawing Reference TB1-01 C     Refrigerant piping for 1-VA-1A-AHU-TB          1-RP-1 -2 1/8 and 1-RP-3-1 3/8 on has foam insulation on piping . HVAC           Drawing F-40039 units have not been in service for many years . Work order (WO) 20101461-01 completed removal of insulation that was not aluminum jacketed .
TB1 -01 D    Refrigerant piping for 1-VA-1A-AHU-TB          1-RP-1 -2 1/8 and 1-RP-3-1 3/8 on has foam insulation on piping . HVAC           Drawing F-40039 units have not been in service for many years. WR 20040553 to remove insulation not aluminum jacketed.
TB1-01 H     Refrigerant piping for 1-VA-1A-AHU-TB          1-RP-1-2 1/8, 1-RP-3-1 3/8, 1-RP-and 1-VA-18-AHU-TB have foam                   5-2 1/8, and 1-RP-7-1 3/8 on insulation on piping. Some of the piping       Drawing F-40039 has aluminum jacketing on the insulation ,
preventing additional secondary combustible fire spread . HVAC units have not been in service for many years . WR 20040553 to remove insulation not aluminum jacketed.
TB1 -01 G    Refrigerant piping for 1-VA-1A-AHU-TB          1-RP-1-2 1/8, 1-RP-3-1 3/8, 1-RP-and 1-VA-18-AHU-TB have foam                   5-2 1/8, and 1-RP-7-1 3/8 on insulation on piping . All piping in this zone Drawing F-40039 is aluminum jacketed , preventing secondary combustible spread . HVAC units have not been in service for many years . WR 20040553 to remove insulation not aluminum jacketed.
TB2-01C      Refrigerant piping for 2-VA-2A-AHU-TB          2-RP-25-2 1/8 and 2-RP-19-1 3/8 has foam insulation on piping . HVAC           on Drawing F-04039 units have not been in service for many years . WR 20040558 to remove insulation.
TB2-01D      Refrigerant piping for 2-VA-2A-AHU-TB          2-RP-25-2 1/8 and 2-RP-19-1 3/8 has foam insulation on piping . HVAC           on Drawing F-04039 units have not been in service for many years . WR 20040558 to remove insulation .

BSEP 17-0017 Enclosure 1 Attachment 1 Page 11 of 14 TB2-01 H Refrigerant piping for 2-VA-2A-AHU-TB          2-RP-25-2 1/8 , 2-RP-19-1 3/8, 2-and 1-VA-1B-AHU-TB have foam                   RP-31-2 1/8, and 2-RP-27-1 3/8 on insulation on piping . HVAC units have not     Drawing F-04039 been in service for many years. WR 20040558 to remove insulation .
TB2-01G  Refrigerant piping for 2-VA-2A-AHU -TB         2-RP-25-2 1/8, 2-RP-19-1 3/8, 2-and 1-VA-1 B-AHU-TB have foam                  RP-31-2 1/8, and 2-RP-27-1 3/8 on insulation on piping. HVAC units have not      Drawing F-04039 been in service for many years . WR 20040558 to remove insulation.
TB1-01 L Turbine Building Chilled Water runs to the     Evaporative Cooling Water (ECW) chilled water pumps in the Turbine             piping identified on drawing Building (TB) Supply Fan Room . The            F-04123 has sections of piping is covered in insulation and some       polyisocyanurate insulation .
of the insulation is in the 201 of the chilled water pumps. The majority of the piping is covered by aluminum jacketed fiberglass meeting the definition of limited combustible , but some sections do have polyisocyanurate. There is approximately 100 feet of piping covered with insulation in the room and the majority of the insulation includes an aluminum jacket adding additional defense in depth for fire spread. The Supply Fan Rooms have no PRA, SSD, or NPO targets in the room per Fire Safe Shutdown Program Management Database (FSSPMD), any additional targets have no impact to the Fire PRA or plant risk.

BSEP 17-0017 Enclosure 1 Attachment 1 Page 12 of 14 TB2-01 L     Turbine Building Chilled Water runs to the   ECW piping identified on drawing chilled water pumps in the TB Supply Fan     F-04123 has sections of Room . The piping is covered in insulation   polyisocyanurate insulation.
and some of the insulation is in the ZOI of the chilled water pumps. The majority of the piping is covered by aluminum jacketed fiberglass meeting the definition of limited combustible, but some sections do have polyisocyanurate. There is approximately 100 feet of piping covered with insulation in the room and the majority of the insulation includes an aluminum jacket adding additional defense in depth for fire spread. The Supply Fan Rooms have no PRA, SSD, or NPO targets in the room per FSSPMD, any additional targets have no impact to the Fire PRA or plant risk.
Rest of TB1 Field walk down of accessible areas identified no additional combustible insulation .
Control Building CB-24        Foam Insulation is installed on              The condensate drain piping can condensate drain piping to HVAC cooling      be located on Drawing F-04082.
coils, located near the floor along the north side of the room. Approximately 65 feet of 1-inch to 2-inch piping covered with foam insulation. Transient 9540 has the potential of igniting one section of the foam insulation and adds two new targets. See Attachment A for the new target set data. The additional targets are not PRA, SSD, or NPO credited and add no additional risk to the Fire PRA.
CB-25        Foam insulation is installed on condenser    The condenser units and refrigerant lines to the condenser units     refrigerant lines can be located on and could be hit by the condenser units      Drawing F-04330, sht. 1.
themselves , but since the ignition sources and foam insulation is outdoors with no additional targets in the area, there is no additional Fire PRA risk associated with the insulation.

BSEP 17-0017 Enclosure 1 Attachment 1 Page 13 of 14 Rest of      No combustible insulation was identified    N/A Control      in the remainder of CB-23E, CB-7, CB-8, Building     CB-9, CB-10, CB-01 , CB-02, CB-12 and CB-13.
Unit 1 Reactor Building RB1 -01J     Polyisocyanurate/Foam Insulation is         Drawing F-40072 identifies the installed on Chilled Water Piping to        layout of fire zone RB1-01J with the cooling coils (1-VA-CLR-5095) in the        abandoned evaporative cooler and Reactor Building Supply Fan Room . The      louver opening on the perimeter of Chilled Water Piping runs from outside      the build ing , with all ignition the building through the air louvers on the sources located north of the perimeter of the building , to the cooling  evaporative cooler.
coils, south of the abandoned evaporative cooler (1-VA-1A-EC-RB). There are no ignition sources in the area of the chilled water piping and no added risk to the Fire PRA.
Rest of      No combustible insulation was identified    N/A RB1 -1       in any other accessible areas of the Unit 1 Reactor Building .
Unit 2 Reactor Building RB2-01J      Polyisocyanurate/Foam Insulation is         Drawing F-04072 identifies the installed on Chilled Water Piping to        layout of fire zone RB2-01 J with the cooling coils (2-VA-CLR-5095) in the        abandoned evaporative cooler and Reactor Building Supply Fan Room . The      louver opening on the perimeter of Chilled Water Piping runs from outside      the building , with all ignition the building through the air louvers on the sources located north of the perimeter of the building , to the cooling  evaporative cooler.
coils , south of the abandoned evaporative cooler (2-VA-2A-EC-RB). There are no ignition sources in the area of the chilled water piping and no added risk to the Fire PRA.
Rest of      No combustible insulation was identified    N/A RB2-1        in any other accessible areas of the Unit 2 Reactor Building .
Radwaste Building RW-01A       No combustible insulation identified on     N/A the -3 foot Elevation.

BSEP 17-0017 Enclosure 1 Attachment 1 Page 14 of 14 RW-01B       No combustible insulation identified on    N/A the 23 foot Elevation . Polyisocyanurate was identified on piping outside the Radwaste Building on the loading dock associated with the Drywall HVAC Cooling Pump, but switched to fiberglass within the building. There is no impact to plant equipment with the polyisocyanurate outside the building .
RW-01C       35 foot Elevation: Foam insulation with    Location of cooling coils are an aluminum jacket is installed inside the identified on drawing F-04077.
fan room on chilled water piping connected to the cooling coils and exits the building through the fan room . No ignition sources in the supply fan room .
Closest ignition sources are located on the roof of the supply fan room , not affecting the foam insulation . No additional risk to the Fire PRA.
RW-01D       No combustible insulation identified on    N/A the 47 foot Elevation.
Augmented Off-Gas Building AOG-1        Foam insulation was found wrapped          Drawing F-02319 identifies the around Air Handling Units (AHUs) on the    location of the AH Us on the 37 foot 37 foot platform. The foam insulation is   elevation of the AOG Building .
below the motor ignition source but was considered as a secondary combustible to be conservative. Additional targets were added to the fire scenarios for the AHUs. The additional targets are not PRA, SSD, or NPO credited and add no additional risk to the Fire PRA.
Diesel Generator Building - No combustible Insulation Service Water Building - No combustible Insulation Make-up Water Treatment Building - No Combustible Insulation RPDC No combustible Insulation RPDC No combustible Insulation

BSEP 17-0017 Enclosure 2 Marked-up Renewed Facility Operating License Pages - Unit 1

(2) Pursuant to the Act and 10 CFR Part 70, to receive , possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation , as described in the Final Safety Analysis Report, as supplemented and amended; (3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive , possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required ;
(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive , possess and use in amounts as required any byproduct, source and special nuclear material without restriction to chemical or physical form , for sample analysis or instrument calibration or associated with radioactive apparatus or components ;
REPLACE WITH INSERT       (5) Pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of Brunswick Steam Electric Plant, Unit Nos. 1 and 2, and H. B. Robinson Steam Electric Plant, Unit No. 2 .
Fire Protection Dul<e EneFgy Progress, LLG shall implement and maintain in effeet all pFOvisions of the approved fire proteetion program that eomply with 10 GFR 50.48(a) and 10 GFR 50.48(e) , as speeified in the lieense amendment request dated September 25 , 2012, as supplemented by letters dated December 17, 2012; June 28 ,
2013; July 15, 2013; Jttly 31 , 2013; August 29 , 2013; September 30, 201 a; February 28, 2014; March 14, 2014; April 10, 2014; June 26, 2014; August 15, 2014; August 29, 2014; November 20, 2014; and December 18, 2014; and as approved in the safety evaluation dated January 28 , 2015. E>Ecept where NRG appro*,al for ehanges or deviations is requi red by 1O GFR 50.48(0) , and provided no other regulation , teehnieal specifieation , license eondition or requirement would require prior NRG approval , the licensee may mal<e changes to the fire protection program without prior approval of the Commission if those ehanges satisfy the provisions set forth in 1O GFR 50 .48(a) and 1O GFR 50.48(e) , the change does not require a change to a technieal speeifieation or a license condition , and the criteria listed below are satisfied .
(a)      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 Renewed License No. DPR-71 Amendment No. 271

INSERT (6) Fire Protection Duke Energy Progress , 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 license amendment requests dated September 25, 2012 , as supplemented by letters dated December 17, 2012 ; June 28 ,
2013 ; July 15, 2013 ; July 31, 2013 ; August 29 , 2013; September 30 , 2013; February 28 , 2014 ; March 14, 2014 ;
April 10, 2014 ; June 26 , 2014 ; August 15, 2014; August 29 , 2014; November 20 , 2014 ; and December 18, 2014; aR4 as approved in the safety evaluation dated January 28 , 2015; and                    , 2017 ,
as approved in the safety evaluation dated                    , 2018 . Except where NRG 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 NRG 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 .

IFOR INFORMATION ONLY - NO CHANGES 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 Brunswick. 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.
: 1. 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.
: 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10*11year (yr) for CDF and less than 1x10-8/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.
(b) 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 is 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 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 Renewed License No. DPR-71 Amendment No. 266

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 functional ity 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:
                *       "Fire Alarm and Detection Systems" (Section 3.8);
               *        "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);
               *        "Gaseous Fire Suppression Systems" (Section 3.1O); and
               *        "Passive Fire Protection Features" (Section 3.11 ).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact           and              , 2018, evaluations    Prior NRC review and appr al is not required for changes to the licensee's fire rotection program that have been demonstrated to ha e no more than a minimal risk impact. The licens       may use its screening process as approved i the NRC safety evaluation dated January 28, 2015, 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.
Renewed License No. DPR-71 Amendment No. 266

                                                      'FOR INFORMATION ONLY - NO CHANGES (c)     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 NRG 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 Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation . The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2 , "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRG approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)      Maximum Power level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.
(2)      Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 281 , are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating license DPR-71 , the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203 , including SRs with modified acceptance criteria and SRs whose frequency of Renewed license No. DPR-71 Amendment No. 281

BSEP 17-0017 Enclosure 3 Marked-up Renewed Facility Operating License Pages - Unit 2

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source, and special nuclear materials without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components ;
(5) Pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be REPLACE WITH     produced by the operation of Brunswick Steam Electric Plant, Unit Nos. 1 INSERT           and 2, and H. B. Robinson Steam Electric Plant, Unit No. 2.
Fire Protection Duke Energy Progress, LLC shall implement and maintain in effeot all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(0) , as speoified in tho license amendment request dated September 25 , 2012, as supplemented by let-tors dated December 17, 2012; June 28 , 201 a; July 16, 201a; July a1 , 201a; August 29, 201a; September ao, 2013; February 28, 2014; March 14, 2014; April 10, 2014; Juno 26 ,
2014; August 16, 2014; August 29, 2014; November 20, 2014; and December 18, 2014; and as appro*,ed in the safety evaluation dated January 28, 2016 . E>mept where NRG approval for ohanges or deviations is required by 10 CFR 50 .48(0) , and provided no other regulation, teohnioal speeifioation, license condition or requirement would require prior NRG approval , the licensee may make changes to the firn protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 GFR 50.48(a) and 10 CFR 60.48(0) , the change does not require a change to a teohnioal specification or a license condition ,
and the criteria listed below are satisfied.
(a)      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 Renewed License No. DPR-62 Amendment No. 2:00

(6) Fire Protection Duke Energy Progress , 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 license amendment requests dated September 25, 2012, as supplemented by letters dated December 17, 2012; June 28, 2013; July 15, 2013; July 31 , 2013; August 29, 2013; September 30 ,
2013; February 28, 2014; March 14, 2014; April 10, 2014; June 26, 2014; August15, 2014; August29, 2014; November 20, 2014; and December 18, 2014; aoo as approved in the safety evaluation dated January 28, 2015; and                   , 2017, as approved in the safety evaluation dated                   , 2018. 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 .

IFOR INFORMATION ONLY - NO CHANGES 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 Brunswick. 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.
: 1. 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.
: 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10*1tyear (yr) for CDF and less than 1x10-8/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.
(b) 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 is 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 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 Renewed License No. DPR-62 Amendment No. 294

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:
                *       "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 ).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact          and               , 2018, evaluations    Prior NRC review and appr wal is not required for changes to the licensee's fire rotection program that have been demonstrated to ha e no more than a minimal risk impact. The licens may use its screening process as approved i the NRC safety evaluation dated January 28, 2015, 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 .
Renewed License No. DPR-62 Amendment No. 2Q4

IFOR INFORMATION ONLY - NO CHANGES (c)     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 Table S-1 , "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20 , 2014, within 180 days after NRC approval unless the 180"' day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2 ,
Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation .
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30 , Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)      Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).
(2)      Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 309 , are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating license DPR-62 , the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233 . For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 309

BSEP 17-0017 Enclosure 4 Revised Renewed Facility Operating License Pages - Unit 1

(2) Pursuant to the Act and 10 CFR Part 70 , to receive , possess , and use at any time special nuclear material as reactor fuel , in accordance with the limitations for storage and amounts required for reactor operation , as described in the Final Safety Analysis Report, as supplemented and amended ;
(3) Pursuant to the Act and 10 CFR Parts 30 , 40 , and 70, to receive , possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required ;
(4) Pursuant to the Act and 10 CFR Parts 30 , 40 , and 70 , to receive , possess and use in amounts as required any byproduct, source and special nuclear material without restriction to chemical or physical form , for sample analysis or instrument calibration or associated with radioactive apparatus or components ;
(5) Pursuant to the Act and 10 CFR Parts 30 and 70 to possess , but not separate, such byproduct and special nuclear materials as may be produced by the operation of Brunswick Steam Electric Plant, Unit Nos. 1 and 2, and H. B. Robinson Steam Electric Plant, Unit No. 2.
(6) Fire Protection Duke Energy Progress , 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 license amendment requests dated September 25 , 2012 , as supplemented by letters dated December 17, 2012 ; June 28 ,
2013; July 15, 2013 ; July 31 , 2013 ; August 29 , 2013 ;
September 30, 2013 ; February 28 , 2014 ; March 14, 2014; April 10, 2014; June 26, 2014; August 15, 2014 ; August 29, 2014 ;
November 20, 2014 ; and December 18, 2014; as approved in the safety evaluation dated January 28 , 2015 ; and ((INSERT DATE)), 2017 , as approved in the safety evaluation dated ((INSERT DATE)) , 2018 . 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 .
Renewed License No. DPR-71 Amendment No.

(a) 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 Brunswick. 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.
: 1. 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 .
: 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/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.
Renewed License No. DPR-71 Amendment No.

(b) 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 is 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 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 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 :
           "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 ).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805 .
Renewed License No. DPR-71 Amendment No .
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRG review and approval is 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 NRG safety evaluations dated January 28 , 2015 , and
((INSERT DATE)), 2018, 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 .
(c) 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 NRG 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 Table S-1, "Plant Modifications Committed ," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48( c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122 , dated November 20, 2014, within 180 days after NRG approval unless the 180th day falls within an outage window; then , in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.
Renewed License No. DPR-71 Amendment No.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:
( 1)     Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.
(2)      Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. ((         )), are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71 , the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended , the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 203.
(a)     Effective June 30, 1982, the surveillance requirements listed below need not be completed until July 15, 1982. Upon accomplishment of the surveillances, the provisions of Technical Specification 4.0.2 shall apply .
Specification 4.3.3.1, Table 4.3.3-1, Items 5.a and 5.b (b)      Effective July 1, 1982, through July 8, 1982, Action statement "a" of Technical Specification 3.8.1.1 shall read as follows:
ACTION:
: a.      With either one offsite circuit or one diesel generator of the above required A.C . electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C .
sources by performing Surveillance Requirements 4.8.1.1.1 .a and 4.8.1.1.2.a.4 within two hours and at least once per 12 hours thereafter; restore at least two offsite circuits and four diesel generators to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
(3)     Deleted by Amendment No. 206.
Renewed License No. DPR-71 Amendment No.

D. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification , and safeguards contingency plans, including amendments made pu rsuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50 .90 and 10 CFR 50.54(p). The plans , which contain Safeguards Information protected under 10 CFR 73.21 are entitled: "Physical Security Plan ,
Revision 2," and "Safeguards Contingency Plan , Revision 2," submitted by letter dated May 17, 2006, and "Guard Training and Qualification Plan , Revision O,"
submitted by letter dated September 30 , 2004.
The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP) , including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 258, as supplemented by changes approved by License Amendment Nos. 261 and 265.
E. This license is subject to the following additional conditions for the protection of the environment:
: a.      Deleted per Amendment 54 , 3-11 -83
: b.      Deleted per Amendment 54 , 3-11 -83
: c.      The licensee shall comply with the effluent limitations contained in National Pollutant Discharge Elimination System Permit No. NC0007064 issued pursuant to Section 402 of the Federal Water Pollution Control Act, as amended.
F. In accordance with the requirement imposed by the October 8, 1976, order of the United States Court of Appeals for the District of Columbia Circu it in Natural Resources Defense Council v. Nuclear Regulatory Commission , No. 74-1385 and 74-1586 , that the Nuclear Regulatory Commission "shall make any licenses granted between July 21 , 1976 and such time when the mandate is issued subject to the outcome of the proceedings herein," the license issued herein shall be subject to the outcome of such proceedings .
G. Deleted by Amendment No. 206.
H. This license is effective as of the date of issuance and shall expire at midnight on September 8, 2036.
I. Deleted per Amendment No. 70 dated 5-25-84.
J. Deleted per Amendment No. 70 dated 5-25-84.
K. Deleted by Amendment No. 206.
L. Power Uprate License Amendment Implementation The licensee shall complete the following actions as a condition of the approval of the power uprate license amendment (Amendment No. 183):
(1)     Deleted by Amendment No. 206.
(2)     Deleted by Amendment No. 206.
Renewed License No. DPR-71 Amendment No.

(3)      Fuel Pool Decay Heat Evaluation The decay heat loads and the decay heat removal systems available for each refueling outage shall be evaluated , and bounding or outage specific analyses shall be used for various refueling sequences. Where a bounding engineering evaluation is in place , a refueling specific assessment shall be made to ensure that the bounding case encompasses the specific refueling sequence. In both cases (i.e .,
bounding or outage specific evaluations) , compliance with design basis assumptions shall be verified .
(4)      Deleted by Amendment No. 206.
(5)      Deleted by Amendment No. 206.
M.      The UFSAR supplement, as revised , submitted pursuant to 10 CFR 54.21 (d) ,
shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71 (e)(4) following the issuance of this renewed operating license. Until that update is complete , CP&L* may make changes to the programs and activities described in the supplement without prior Commission approval , provided that CP&L
* evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
N.      The UFSAR supplement, as revised , describes certain future activities to be completed prior to the period of extended operation. Duke Energy Progress, LLC shall complete these activities no later than September 8, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection .
: 0.      All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRG-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP)
Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. Any changes to the BWRVIP ISP capsule withdrawal schedule, including spare capsules , must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion . Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50 , Appendix H.
* On April 29, 2013, the name "Carolina Power & Light Company" (CP&L) was changed to "Duke Energy Progress, Inc." On August 1, 2015, the name "Duke Energy Progress ,
Inc." was changed to "Duke Energy Progress , LLC ."
Renewed License No. DPR-71 Amendment No.

P. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(1)     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 (2)     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 (3)     Actions to minimize release to include consideration of:
: 1. Water spray scrubbing
: 2. Dose to onsite responders Q. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20 , 2006 , except the last action that requires incorporation of the strategies into the site security plan , contingency plan, emergency plan and/or guard training and qualification plan , as appropriate.
: 3. Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 269 , are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Additional Conditions.
FOR THE NUCLEAR REGULATORY COMMISSION
                                      /RA/
J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
: 1. Unit 1 - Technical Specifications - Appendices A and B Date of Issuance: June 26 , 2006 Renewed License No. DPR-71 Amendment No.

BSEP 17-0017 Enclosure 5 Revised Renewed Facility Operating License Pages - Unit 2

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70 , to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration , and as fission detectors in amounts as required ;
(4) Pursuant to the Act and 10 CFR Parts 30 , 40 and 70 , to receive, possess and use in amounts as required any byproduct, source, and special nuclear materials without restriction to chemical or physical form , for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of Brunswick Steam Electric Plant, Unit Nos. 1 and 2, and H. B. Robinson Steam Electric Plant, Unit No. 2.
(6) Fire Protection Duke Energy Progress, 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 license amendment requests dated September 25, 2012, as supplemented by letters dated December 17, 2012; June 28, 2013; July 15, 2013; July 31 , 2013 ; August 29, 2013; September 30 ,
2013; February 28, 2014; March 14, 2014; April 10, 2014; June 26, 2014; August15 , 2014; August29 , 2014; November20, 2014; and December 18, 2014; as approved in the safety evaluation dated January 28, 2015; and ((INSERT DATE)), 2017, as approved in the safety evaluation dated ((INSERT DATE]), 2018. Except where NRG 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 NRG 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 .
Renewed License No. DPR-62 Amendment No.

(a) 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 Brunswick. 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.
: 1. 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 .
: 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8 /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 .
Renewed License No. DPR-62 Amendment No.

(b) Other Changes that May Be Made Without Prior NRG Approval
: 1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRG review and approval is 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 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 NRG 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 :
       *   "Fire Alarm and Detection Systems" (Section 3.8) ;
           "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9) ;
       *   "Gaseous Fire Suppression Systems" (Section 3.1 O) ; and "Passive Fire Protection Features" (Section 3.11 ).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805 .
Renewed License No. DPR-62 Amendment No.
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval is 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 evaluations dated January 28, 2015 , and ((INSERT DATE)),
2018 , 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 .
(c)     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 Table S-1, "Plant Modifications Committed ," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122 , dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then , in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30 , Section 40.41 of Part 40, Sections 50 .54 and 50 .59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
Renewed License No. DPR-62 Amendment No.

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A , as revised through Amendment No. ((         )), are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facil ity in accordance with the Technical Specifications.
For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62 , the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233 . For SRs that existed prior to Amendment 233 ,
including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended , the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 233.
(a)     The end of the current surveillance period for the surveillance requirements listed below may be extended beyond the time limit specified by Technical Specification 4.0.2a. After May 1, 1982, the plant shall not be operated in Conditions 1, 2 , or 3 until the surveillance requirements listed below have been completed .
Upon accomplishment of the surveillances , the provisions of Technical Specification 4.0 .2a shall apply.
Specification     4.3.1.1; Table  4 .3.1-1, items 9 & 10 4.3 .1.2 4.3.1.3; Table  3.3.1-2, item 10 4.3.2.1; Table  4.3.2- 1, items 1.d & 1.f 4.3.2.3; Table  3.3.2-3 , item 1.a.1 4.3.3.2; Table  4.3.3- 1, items 4.c & 4.f 4.5.2.a 4.8.1.1.2.d.2 4.8.1.1.2.d.3 4.8.1.1 .2.d.6 4.8.1.1.2.d.7 (b)     Effective June 30, 1982, the surveillance requirements listed below need not be completed until restart for Cycle 5 or July 15, 1982, whichever occurs first. The unit shall not be operated in Conditions 1, 2 or 3 until the surveillance requirements listed below have been completed . Upon accomplishment of the surveillances , the provisions of Technical Specification 4 .0.2 shall apply.
Specification 4.3 .3.1 Table 4.3.3-1 , Items 5.a and 5.b.
Renewed License No. DPR-62 Amendment No.

(c)      Effective July 1, 1982, through July 8, 1982, Action statement "a" of Technical Specification 3.8.1.1 shall read as follows :
ACTION :
: a.      With either one offsite circuit or one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C .
sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1 .2.a.4 within two hours and at least once per 12 hours thereafter; restore at least two offsite circuits and four diesel generators to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
(3) Deleted by Amendment No. 236 .
(4) Equalizer Valve Restriction The valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation , except for one bypass valve which is left open to prevent pressure build-up due to ambient and conduction heating of the water between the equalizer valves .
(5) Deleted by Amendment No. 233 .
(6) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification ,
and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50 .90 and 10 CFR 50 .54(p) . The plans , which contain Safeguards Information protected under 10 CFR 73 .21 , are entitled : "Physical Security Plan , Revision 2," and "Safeguards Contingency Plan , Revision 2," submitted by letter dated May 17, 2006 ,
and "Guard Training and Qualification Plan , Revision O," submitted by letter dated September 30 , 2004 .
The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP) , including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p) .
The licensee's CSP was approved by License Amendment No. 286 , as supplemented by changes approved by License Amendment Nos. 289 and 293 .
Renewed License No. DPR-62 Amendment No.

D. This license is subject to the following additional conditions for the protection of the environment:
: a.      Deleted per Amendment 79 , 3-11-83
: b.      Deleted per Amendment 79 , 3-11-83
: c.      Deleted per Amendment 79 , 3-11-83
: d.      The licensee shall comply with the effluent limitations contained in National Pollutant Discharge Elimination System Permit No. NC0007064 issued pursuant to Section 402 of the Federal Water Pollution Control Act, as amended .
E. This license is effective as of the date of issuance and shall expire at midnight on December 27 , 2034.
F. Deleted per Amendment No. 98 dated 5-25-84.
G. Deleted per Amendment No. 98 dated 5-25-84 .
H. Deleted by Amendment No. 236.
I. Power Uprate License Amendment Implementation The licensee shall complete the following actions as a condition of the approval of the power uprate license amendment (Amendment No. 214):
(1)     Deleted by Amendment No. 236.
(2)     Deleted by Amendment No. 236.
(3)     Fuel Pool Decay Heat Evaluation The decay heat loads and the decay heat removal systems available for each refueling outage shall be evaluated, and bounding or outage specific analyses shall be used for various refueling sequences. Where a bounding engineering evaluation is in place, a refueling specific assessment shall be made to ensure that the bounding case encompasses the specific refueling sequence. In both cases (i.e.,
bounding or outage specific evaluations) , compliance with design basis assumptions shall be verified.
(4)     Deleted by Amendment No. 236.
(5)     Deleted by Amendment No. 236.
Renewed License No. DPR-62 Amendment No.

J.       The UFSAR supplement, as revised , submitted pursuant to 10 CFR 54.21(d) ,
shall be included in the next scheduled update to the UFSAR required by 10 CFR 50 .71 (e)(4) following the issuance of this renewed operating license. Until that update is complete , CP&L
* may make changes to the programs and activities described in the supplement without prior Commission approval , provided that CP&L
* evaluates such changes pursuant to the criteria set forth in 10 CFR 50 .59 and otherwise complies with the requirements in that section .
K.       The UFSAR supplement, as revised , describes certain future activities to be completed prior to the period of extended operation. Duke Energy Progress, LLC shall complete these activities no later than December 27, 2014 , and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection .
L.       All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRG-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVI P)
Integrated Surveillance Program (ISP) appropriate for the configuration of the specimens in the capsule. Any changes to the BWRVIP ISP capsule withdrawal schedule , including spare capsules , must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion . Any changes to storage requirements must be approved by the NRC, as required by 10 CFR Part 50 , Appendix H.
M.       Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas :
(1)      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
* On April 29, 2013, th e name "Carolina Power & Light Company" (CP&L) was changed to "Duke Energy Progress, Inc."
On August 1, 2015, the name "Duke Energy Progress, Inc." was changed to "Duke Energy Progress , LLC ."
Renewed License No. DPR-62 Amendment No.

(2)     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 (3)     Actions to minimize release to include consideration of:
: 1. Water spray scrubbing
: 2. Dose to onsite responders N. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137 , issued June 20 , 2006 , except the last action that requires incorporation of the strategies into the site security plan , contingency plan , emergency plan and/or guard training and qualification plan , as appropriate.
: 3. Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 297 , are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Additional Conditions.
FOR THE NUCLEAR REGULATORY COMMISSION
                                      /RA/
J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
: 1. Unit 2 - Technical Specifications - Appendices A and B Date of Issuance: June 26 , 2006 Renewed License No. DPR-62 Amendment No.

BSEP 17-0017 Enclosure 6 Update to Calculation OFP-1213, Code Compliance Evaluation NFPA 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants - 2001 Edition

CALCULATION NO. OFP-1 213                                                                                      PAGE: NO. 29 of 146 REVISION 1 Attachment 3 - NEI 04-02 Table B-1 NFPA 805 Ch. 3 Transition Details CPL-XXXX-W-005, Nuclear Power Plant Protective             Appendix A Coatings, Appendix A UFSAR, Updated Final Safety Analysis Report                Section 9.5.1 Applicable FSA's for the applicable Fire Areas             All EER 94-0009, Evaluation of Floor Coatings on Combustible Loading                                        All AMERCOAT, Amerlock 400 Series Data Sheet Qualifications                                             Qualification Section ESR 99-00 109, Control Room Carpet Add itions              All EC 47763, Control Room Project                             All Table B-1 NFPA 805 Ch.3 Transition Details Chapter 3 

==Reference:==
3.3.4 Insu lation Materials Chapter 3 Requirement:             3.3.4 Insulation Materials.
Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.
Compliance Statement               Compliance Basis Complies per additional         In several areas at BSEP, exposed thermal insulation materials are installed on various heating , ventilation and air conditioning (HVAC) system piping to prevent sweating . Although these materials comply with the flame spreading NRC Approval rating of 25 or less, these materials do not meet the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. These materials will not contribute appreciably to the spread of fire nor represent a secondary combustible beyond those currently analyzed in the Fire Probabilistic Risk Assessment due to the limited applications. Future installations would be controlled by the current design engineering change process including fire protection engineering review and fire protection impact change process.}}