View source for CNS-15-101, License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants

{{Adams
| number = ML15350A014
| issue date = 12/11/2015
| title = License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants
| author name = Henderson K
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000413, 05000414
| license number = 
| contact person = 
| case reference number = CNS-15-101, TAC MF2936, TAC MF2937
| package number = ML15350A007
| document type = Letter type:CNS, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Report, Miscellaneous
| page count = 18
| project = TAC:MF2936, TAC:MF2937
| stage = Request
}}

=Text=
{{#Wiki_filter:*                                                                                                Kelvin Henderson
(~DUKE                                                                                              Vice President
  ~ ENERGY                                                                                Catawba Nuclear Station Duke Energy CNO 1VP I 4800 Concord    Road York, SC 297 45 O:  803. 701.4251 f: 803.701.3221 Enclosure 2, Attachment W to this letter contains security related information. Withhold from public disclosure in accordance with 10 CFR 2.390. When Enclosure 2, Attachment W is removed, this document is no longer security related.
CNS-15-101 December 11, 2015                                                            10 CFR 50.90 U.S. Nuclear Regulatory Commission (NRC)
Attention: Document Control Desk Washington, D.C. 20555

==Subject:==
Duke Energy Carolinas, LLC (Duke Energy)
Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants LAR Supplement to Address Outstanding Items (TAC Nos. MF2936 and MF2937)

==References:==
Letters fror:n Duke Energy to the NRC, dated September 25, 2013 (ADAMS Accession Number ML13276A503), January 13, 2015 (ADAMS Accession Number ML15015A409), January 28, 2015 (ADAMS Accession Number ML15029A697), February 27, 2015 (ADAMS Accession Number ML15065A107), March 30, 2015 (ADAMS Accession Number ML15091A339), April 28, 2015 (ADAMS Accession Number ML15119A533), July 15, 2015 (ADAMS Accession Number ML15198A036), August 14, 2015 (ADAMS Accession Number ML15231A010), and September 3, 2015 (ADAMS Accession Number ML 15310A1?3) www.duke-energy.com

Enclosure 2, Attachment W to this letter contains security related information. Withhold from public disclosure in accordance with 10 CFR 2.390. When Enclosure 2, Attachment W is removed, this document is no longer security related.
Document Control Desk Page 2 December 11, 2015 The reference letters comprise in their entirety Duke Energy's request for NRC review and approval for adoption of a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants", Revision 1, dated December 2009. The September 25, 2013 Reference 1 LAR was developed in accordance with the guidance contained in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)", Revision 2.
The purpose of this LAR supplement is to provide the following three items:
: 1. The final Facility Operating License (FOL) condition associated with the Catawba NFPA 805 LAR submittal;
: 2. Revised LAR pages associated with a recent decision to cancel the committed NFPA 805 plant modification Item 02 on Table S-2a (based on the revised EPRI pipe break frequencies and the consideration of the AL6XN piping materials installed as part of the Catawba Raw Water Project, the pursuit of watertight doors to protect the Train ETB essential switchgear would be of limited Core Damage Frequency (CDF) benefit and would not result in a significant CDF reduction); and
: 3. Duke Energy's disposition as to whether any of the previously submitted risk information should be considered as Sensitive Unclassified Non-Safeguards Information (SUNS!).
Enclosure 1 to this letter provides the final FOL conditions for Unit 1 and Unit 2.
Enclosure 2 to this letter provides the revised LAR pages. Duke Energy has determined that the entire Attachment W (Fire PRA Insights) of the LAR should be considered as SUNS! and has designated these pages as so. Duke Energy is requesting that Attachment W be withheld from public disclosure in accordance with 10 CFR 2.390.
The conclusions of the No Significant Hazards Consideration and the Environmental Consideration contained in the September 25, 2013 reference LAR are unaffected by this LAR supplement.
There are no regulatory commitments contained in this letter or its enclosures.
Pursuant to 10 CFR 50.91, a copy of this LAR supplement is being sent to the appropriate State of South Carolina official.
Inquiries on this matter should be directed to L.J. Rudy at (803) 701-3084.

Enclosure 2, Attachment W to this letter contains security related information. Withhold from public disclosure in accordance with 10 CFR 2.390. When Enclosure 2, Attachment W is removed, this document is no longer security related.
Document Control Desk Page 3 December 11, 2015 I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 11, 2015.
Very truly yours, Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Enclosures

Enclosure 2, Attachment W to this letter contains security related information. Withhold from public disclosure in accordance with 10 CFR 2.390. When Enclosure 2, Attachment W is removed, this document is no longer security related.
Document Control Desk Page 4 December 11, 2015 xc (with enclosures):
L.D. Wert Acting Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G.A. Hutto Ill Senior Resident Inspector (Catawba)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station G.E. Miller (addressee only)
NRC Project Manager (Catawba)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 S.E. Jenkins Manager Radioactive and Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201

Enclosure 1 Final FOL Condition

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 275, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
(4) Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5) Fire Protection Program Duke Energy Carolinas, LLC, shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013, as supplemented by letters dated January 13, 2015, January 28, 2015, February 27, 2015, March 30, 2015, April 28, 2015, July 15, 2015, August 14, 2015, September 3, 2015, and December 11, 2015 as approved in the SE dated                  . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the Renewed License No. NPF-35 Amendment No.

.. .                                      change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at CNS. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
a)    Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation; and b)    Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-1/year (yr) for CDF and less than 1X1 o-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changes that May Be Made Without Prior NRC Approval
: 1)    Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval 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);
Renewed License No. NPF-35 Amendment No.

                                     *.       "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.
: 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 SE dated                      to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program Transition License Conditions
: 1)   Before achieving full compliance with 10 CFR 50.48(c), as specified by 2) and 3), below, risk informed changes to the Duke Energy Carolinas, LLC 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-2, "Plant Modifications Committed," Attachment S, of the Duke Energy Carolinas, LLC LAR, dated September 25, 2013, to complete the transition to full compliance with 10 CFR 50.48(c) by December 31, 2017.
The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3)   The licensee shall complete the implementation items as listed in Table S-3, "Implementation Items," Attachment S, of the Duke Energy Carolinas, LLC LAR, dated September 25, 2013, within 180 days after issuance of the Safety Evaluation unless that falls within a scheduled outage window, then the completion of implementation items will occur 60 days after startup from the scheduled outage. Implementation Item 13 is associated with modifications and will be completed 180 days after modifications are complete.
Renewed License No. NPF-35 Amendment No.

(6)   Mitigation Strategies Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a)    Fire fighting response strategy with the following elements:
: 1.       Pre-defined coordinated fire response strategy and guidance
: 2.      Assessment of mutual aid fire fighting assets
: 3.       Designated staging areas for equipment and materials
: 4.       Command and control
: 5.      Training of response personnel (b)    Operations to mitigate fuel damage considering the following:
: 1.       Protection and use of personnel assets
: 2.       Communications
: 3.       Minimizing fire spread
: 4.       Procedures for implementing integrated fire response strategy
: 5.       Identification of readily-available pre-staged equipment
: 6.      Training on integrated fire response strategy
: 7.       Spent fuel pool mitigation measures (c)    Actions to minimize release to include consideration of:
: 1.       Water spray scrubbing
: 2.       Dose to onsite responders (7)   Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 253 are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Additional Conditions.
D. The facility requires exemptions from certain requirements of Appendix J to 10 CFR Part 50, as delineated below and pursuant to evaluations contained in the referenced SER and SSERs. These include, (a) partial exemption from the requirement of paragraph lll.D.2(b)(ii) of Appendix J, the testing of containment airlocks at times when the containment integrity is not required (Section 6.2.6 of the SER, and SSERs
   # 3 and #4), (b) exemption from the requirement of paragraph 111.A.(d) of Appendix J, insofar as it requires the venting and draining of lines for type A tests (Section 6.2.6 of SSER #3), and (c) partial exemption from the requirements of paragraph 111.B of Appendix J, as it relates to bellows testing (Section 6.2.6 of the SER and SSER #3).
These exemptions are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and are consistent with certain special circumstances as discussed in the referenced SER and SSERs. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
Renewed License No. NPF-35 Amendment No.

E. Physical Protection Duke Energy Carolinas, LLC 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 combined set of plans, which contains safeguards information protected under 10 CFR 73.21, is entitled: "Duke Energy Physical Security Plan," Revision 8 submitted by letter dated May 17, 2007.
Duke Energy Carolinas, LLC 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 Duke Energy Carolinas, LLC CSP was approved by License Amendment No. 266, as supplemented by a change approved by License Amendment No. 276.
F. Reporting to the Commission Deleted by Amendment No. 230 G. The licensees shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
: 3. This renewed license is effective as of the date of issuance and shall expire at midnight on December 5, 2043.
FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By:      J.E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
: 1. Appendix A - Technical Specifications
: 2. Appendix B - Additional Conditions
: 3. Appendix C - Antitrust Conditions Date of Issuance: December 5, 2003 Renewed License No. NPF-35 Amendment No.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 271, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than February 24, 2026, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
(4) Antitrust Conditions .
Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5) Fire Protection Program Duke Energy Carolinas, LLC, shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013, as supplemented by letters dated January 13, 2015, January 28, 2015, February 27, 2015, March 30, 2015, April 28, 2015, July 15, 2015, August 14, 2015, September3, 2015, and December 11, 2015 as approved in the SE dated                  . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A ri~k 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 Renewed License No. NPF-52 Amendment No.

change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at CNS. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
a)      Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation; and b)      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.
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:
Renewed License No. NPF-52 Amendment No.

g        "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.
: 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 SE dated                      to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program Transition License Conditions
: 1)      Before achieving full compliance with 10 CFR 50.48(c), as specified by 2) and 3), below, risk informed changes to the Duke Energy Carolinas, LLC 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-2, "Plant Modifications Committed," Attachment S, of the Duke Energy Carolinas, LLC LAR, dated September 25, 2013, to complete the transition to full compliance with 10 CFR 50.48(c) by December 31, 2017.
The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3) . The licensee shall complete the implementation items as listed in Table S-3, "Implementation Items," Attachment S, of the Duke Energy Carolinas, LLC LAR, dated September 25, 2013, within 180 days after issuance of the Safety Evaluation unless that falls within a scheduled outage window, then the completion of implementation items will occur 60 days after startup from the scheduled outage. Implementation lt~m 13 is associated with modifications and will be completed 180 days after modifications are complete.
* Renewed License No. NPF-52 Amendment No.

(6)      Mitigation Strategies Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a)    Fire fighting response strategy with the following elements:
: 1.         Pre-defined coordinated fire response strategy and guidance
: 2.         Assessment of mutual aid fire fighting assets
: 3.         Designated staging areas for equipment and materials
: 4.         Command and control
: 5.         Training of response personnel (b)    Operations to mitigate fuel damage considering the following:
: 1.         Protection and use of personnel assets
: 2.         Communications
: 3.         Minimizing fire spread
: 4.         Procedures for implementing integrated fire response strategy
: 5.         Identification of readily-available pre-staged equipment
: 6.         Training on integrated fire response strategy
: 7.         Spent fuel pool mitigation measures (c)    Actions to minimize release to include consideration of:
: 1.         Water spray scrubbing
: 2.         Dose to onsite responders (7)      Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 254, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Additional Conditions.
D. The facility requires exemptions from certain requirements of Appendix J to 10 CFR Part 50, as delineated below and pursuant to evaluations contained in the referenced SER and SSER. These include, (a) partial exemption from the requirement of paragraph lll.D.2(b)(ii) of Appendix J, the testing of containment airlocks at times when the containment integrity is not required (Section 6.2.6 of the SER, and SSER #5), (b) exemption from the requirement of paragraph 111.A.(d) of Appendix J, insofar as it requires the venting and draining of lines for type A tests (Section 6.2.6 of SSER #5), and (c) partial exemption from the requirements of paragraph 111.B of Appendix J, as it relates to bellows testing (Section 6.2.6 of the SER and SSER #5). These exemptions are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and are consistent with certain special circumstances, as discussed in the referenced SER and SSER. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
Renewed License No. NPF-52 Amendment No.

E. Physical Protection Duke Energy Carolinas, LLC 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 combined set of plans, which contains safeguards information protected under 10 CFR 73.21, is entitled:
              "Duke Energy Physical Security Plan," Revision 8 submitted by letter dated May 17, 2007.
Duke Energy Carolinas, LLC 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 Duke Energy Carolinas, LLC CSP was approved by License Amendment No.
262, as supplemented by a change approved by License Amendment No. 272.
F.      Reporting to the Commission Deleted by Amendment No. 226 G. The licensees shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
: 3. This renewed license is effective as of the date of issuance and shall expire at midnight on December 5, 2043.
FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By:       J.E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:
: 1. Appendix A - Technical Specifications
: 2. Appendix B - Additional Conditions
: 3. Appendix C - Antitrust Conditions Date of Issuance: December 5, 2003 Renewed License No. NPF-52 Amendment No.

Enclosure 2 Revised LAR Pages

Duke Energy Carolinas, LLC Catawba Nuclear Station Transition to 10 CFR 50.48{c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition J_~DUKE
                         ~   ENERGY" Transition Report Revision 3 November 2015

Duke Energy Carolinas, LLC                                                                  Attachment S - Modifications and Implementation Items Table S-2a Plant Modifications Committed - Internal Events PRA In      Comp               Risk Informed Item   Rank    Unit         Problem Statement                   Proposed Modification IEPRA    Measure            Characterization 01   High    1, 2   Auxiliary Shutdown Panels A        Harden stairwell doorways and              y         N       This modification will provide and B are located in the CA        associated flow paths to protect the                         an internal flood risk reduction (Aux. Feed water) Pump room        Auxiliary Feedwater Pump Rooms                               to offset the Fire PRA risk and are theoretically              against water intrusion for both                             increase post-transition.
susceptible to being rendered      Units.
non-functional by an internal flood from a pipe break at a       Completion Date:
higher elevation within the        December 31, 2017 Auxiliary Building.
02                  Deleted via Letter CNS-15-101.
03   High    1, 2   The current installation and       Replace/upgrade turbine building            y        N       This modification will provide maintenance program of the         siding fasteners and institute a                             an internal events high winds turbine building siding fasteners  preventative maintenance program                             risk reduction to offset the Fire leave the siding susceptible to    to periodically inspect the fasteners.                       PRA risk increase post-being affected by low speed                                                                     transition.
(73-114 mph) straight line         Completion Date:
winds thus increasing the PRA      December 31, 2017 risk probability of a LOOP event.
Rev3                                                                                                                                            Page S-3}}