NL-14-1937, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants

Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants

ML15016A199
Person / Time
Site:	Farley
Issue date:	01/16/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-1937, TAC ME9741, TAC ME9742
Download: ML15016A199 (24)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 A.

Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY J.AN 1 e, 2015 Docket Nos.: 50-348 NL-14-1937 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Ladies and Gentlemen:

By letter dated September 25, 2012, the Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Joseph M. Farley Units 1 and 2 (Ref. TAG NOS. ME9741 and ME9742). The proposed amendment requests the review and approval for adoption of a new fire protection licensing basis which complies with the requirements in Sections 50.48(a) and 50.48(c) to Title 10 to the Code of Federal Regulations (1 0 CFR), and the guidance in Regulatory Guide (RG) 1.205, Revision 1, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants.

By letter dated December 12, 2012, the Nuclear Regulatory Commission (NRC)

Staff requested supplemental information regarding the acceptance of the license amendment (Adams Accession No. ML12345A398). SNC provided the requested information by letter dated December 20, 2012. The NRC staff subsequently completed the acceptance review by letter dated January 24, 2013 (Adams Accession No. ML13022A158).

By letter dated July 8, 2013, the NRC Staff formally transmitted a request for additional information (RAI) related to the referenced license amendment. SNC's responses to these RAis are being provided by three submittals. By letter dated September 16, 2013, SNC provided the first set of responses. By letter dated October 30, 2013, SNC provided the second set of responses and by letter dated November 12, 2013, SNC provided the remaining set of responses.

U.S. Nuclear Regulatory Commission NL-14-1937 Page 2 By letter dated March 28, 2014, the NRC Staff formally transmitted the second round of requests for additional information related to the referenced license amendment request. By letter dated April 23, 2014, SNC provided the 30 day response to the second round of RAis. By letter dated May 23, 2014, SNC provided the 60 day response to six of the eight remaining RAis.

By letter dated July 3, 2014, SNC provided revised Attachments S, V, and W.

The updated total plant, Fire PRA, and delta risk values were provided in the updated Attachments V and W. These attachments provided the response to PRA RAis 06.a.01 and 35. The revised Attachment S reflected the updates associated with the RAI responses. Revisions to Table C-2 in Attachment C and Attachment G were to be provided in a separate submittal. Along with other revisions, a new modification item was added to Attachment S for installation of the Generation Ill Westinghouse shutdown seals for the reactor coolant pumps on both Unit 1 and Unit 2.

By letter dated July 11, 2014, the NRC staff transmitted additional RAis related to the credit for the next generation of the Westinghouse Reactor Coolant Pump shutdown seals (PRA RAI 35.01) and the composite analysis of the probabilistic risk assessment (PRA RAI 36). By letter dated August 11, 2014, SNC provided the response to PRA RAis 16.a.02 and 35.01. By letter dated August 29, 2014, SNC provided the response to PRA RAI 36.

By letter dated October 13, 2014, SNC provided clarifications and supplemental information involving the Farley PRA methodology and Revisions to Table C-1 in Attachment C, NFPA 805 Chapter 4 Compliance (NEI 04-02 Table B-3).

On December 3, 2014, the NRC requested SNC to revise certain wording in the clean Operating License pages and the revised Technical Specifications page.

The enclosures to this letter provide the revised Operating License pages and the revised Technical Specification page as requested.

The No Significant Hazards Consideration determination provided in the original submittal is not altered by the RAI responses provided herein.

This letter contains no new NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

U.S. Nuclear Regulatory Commission NL-14-1937 Page 3 Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true and correct.

Respectfully submitted, C. fl.~

C. R. Pierce Regulatory Affairs Director My commission expires: /D - Z - Zo I '1 : Revised Operating License Pages : Revised Technical Specifications Page cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. R. R. Martin, Regulatory Affairs Manager- Farley RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c)

NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Enclosure 1 Revised Operating License Pages

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. _ _ , are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated.

The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission.

(a) Southern Nuclear shall not operate the reactor in Operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

(b) Deleted per Amendment 13 (c) Deleted per Amendment 2 (d) Deleted per Amendment 2 (e) Deleted per Amendment 152 (f) Deleted per Amendment 2 (g) Deleted per Amendment 158 (h) Southern Nuclear shall maintain a secondary water chemistry monitoring program to inhibit steam generator tube degradation.

This program shall include:

1. Identification of a sampling schedule for the critical parameters and control points for these parameters;

2. Identification of the procedures used to quantify parameters that are critical to control points;

3. Identification of process sampling points;

4. A procedure for the recording and management of data; Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

5. Procedures defining corrective actions for off control point chemistry conditions; and

6. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events required to initiate corrective action.

(i) The Additional Conditions contained in Appendix C, as revised through Amendment No. 146, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the additional conditions.

0) Deleted per Amendment 152 (4) Fire Protection Southern Nuclear Operating Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2012 and supplements dated December 20, 2012; September 16, 2013; October 30, 2013; November 12, 2013; April 23, 2014; May 23, 2014; July 3, 2014; August 11, 2014; August 29, 2014; October 13, 2014; January 16, 2015, and as approved in the safety evaluation report 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.

(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 Farley. 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.

Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

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 7 8 1x10. /year (yr) for CDF and less than1x10. /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 are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is 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:

Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

• "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.

Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in NRC safety evaluation report dated _ _ __

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

(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 AttachmentS, Table S-2, "Plant Modifications Committed," of SNC letter NL-14-1273, dated August 29, 2014 to complete the transition to full compliance with 10 CFR 50.48(c) by November 6, 2017.

The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items as listed in Attachment S, Table S-3, "Implementation Items," of SNC letter NL-14-1273, dated August 29, 2014 within 180 days after NRC approval.

(5) Updated Final Safety Analysis Report Supplement The Updated Final Safety Analysis Report supplement, as revised, 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 license. Until that update is complete, Southern Nuclear may make changes to the programs and activities Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

described in the supplement without prior Commission approval, provided that Southern Nuclear evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(6) Reactor Vessel Material Surveillance Capsules All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the 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.

D. Southern Nuclear 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 plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," and was submitted on May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 186.

E. This renewed license is subject to the following additional conditions for the protection of the environment:

(1) Southern Nuclear shall operate the facility within applicable Federal and State air and water quality standards and the Environmental Protection Plan (Appendix 8).

(2) Before engaging in an operational activity not evaluated by the Commission, Southern Nuclear will prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated, or that is significantly greater than evaluated in the Final Environmental Statement, Southern Nuclear shall provide a written Farley- Unit 1 Renewed License No. NPF-2 Amendment No.

evaluation of such activities and obtain prior approval of the Director, Office of Nuclear Reactor Regulation, for the activities.

F. Alabama Power Company shall meet the following antitrust conditions:

(1) Alabama Power Company shall recognize and accord to Alabama Electric Cooperative (AEC) the status of a competing electric utility in central and southern Alabama.

(2) Alabama Power Company shall offer to sell to AEC an undivided ownership interest in Units 1 and 2 of the Farley Nuclear Plant. The percentage of ownership interest to be so offered shall be an amount based on the relative sizes of the respective peak loads of AEC and the Alabama Power Company (excluding from the Alabama Power Company's peak load that amount imposed by members of AEC upon the electric system of Alabama Power Company) occurring in 1976. The price to be paid by AEC for its proportionate share of Units 1 and 2, determined in accordance with the foregoing formula, will be established by the parties through good faith negotiations. The price shall be sufficient to fairly reimburse Alabama Power Company for the proportionate share of its total costs related to the Units 1 and 2 including, but not limited to, all costs of construction, installation, ownership and licensing, as of a date to be agreed to by the two parties, which fairly accommodates both their respective interests. The offer by Alabama Power Company to sell an undivided ownership interest in Units 1 and 2 may be conditioned, at Alabama Power Company's option, on the agreement by AEC to waive any right of partition of the Farley Plant and to avoid interference in the day-to-day operation of the plant.

(3) Alabama Power Company will provide, under contractual arrangements between Alabama Power Company and AEC, transmission services via its electric system (a) from AEC's electric system to AEC's off-system members; and (b) to AEC's electric system from electric systems other than Alabama Power Company's and from AEC's electric system to electric systems other than Alabama Power Company's. The contractual arrangements covering such transmission services shall embrace rates and charges reflecting conventional accounting and ratemaking concepts followed by the Federal Energy Regulatory Commission (or its successor in function) in testing the reasonableness of rates and charges for transmission services. Such contractual arrangements shall contain provisions protecting Alabama Power Company against economic detriment resulting from transmission line or transmission losses associated therewith.

(4) Alabama Power Company shall furnish such other bulk power supply services as are reasonably available from its system.

(5) Alabama Power Company shall enter into appropriate contractual arrangements amending the 1972 Interconnection Agreement as last amended to provide for a reserve sharing arrangement between Alabama Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

Power Company and AEC under which Alabama Power Company will provide reserve generating capacity in accordance with practices applicable to its responsibility to the operating companies of the Southern Company System. AEC shall maintain a minimum level expressed as a percentage of coincident peak one-hour kilowatt load equal to the percent reserve level similarly expressed for Alabama Power Company as determined by the Southern Company System under its minimum reserve criterion then in effect. Alabama Power Company shall provide to AEC such data as needed from time to time to demonstrate the basis for the need for such minimum reserve level.

(6) Alabama Power Company shall refrain from taking any steps, including but not limited to, the adoption of restrictive provisions in rate filings or negotiated contracts for the sale of wholesale power, that serve to prevent any entity or group of entities engaged in the retail sale of firm electric power from fulfilling all or part of their bulk power requirements through self-generation or through purchases from some other source other than Alabama Power Company. Alabama Power Company shall further, upon request and subject to reasonable terms and conditions, sell partial requirements power to any such entity. Nothing in this paragraph shall be construed as preventing an applicant from taking reasonable steps, in accord with general practice in the industry, to ensure that the reliability of its system is not endangered by any action called for herein.

(7) Alabama Power Company shall engage in wheeling for and at the request of any municipally-owned distribution system:

(a) of electric energy from delivery points of Alabama Power Company to said distribution system(s); and (b) of power generated by or available to a distribution system as a result of its ownership or entitlemene in generating facilities, to delivery points of Alabama Power Company designated by the distribution system.

Such wheeling services shall be available with respect to any unused capacity on the transmission lines of Alabama Power Company, the use of which will not jeopardize Alabama Power Company's system. The contractual arrangements covering such wheeling services shall be determined in accordance with the principles set forth in Condition (3) herein.

Alabama Power Company shall make reasonable provisions for disclosed transmission requirements of any distribution system(s) in planning future transmission. "Disclosed" means the giving of reasonable advance notification of future requirements by said distribution system(s) utilizing wheeling services to be made available by Alabama Power Company.

2 "Entitlement" includes, but is not limited to, power made available to an entity pursuant to Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

an exchange agreement.

(8) The foregoing conditions shall be implemented in a manner consistent with the provisions of the Federal Power Act and the Alabama Public Utility laws and regulations thereunder and all rates, charges, services or practices in connection therewith are to be subject to the approval of regulatory agencies having jurisdiction over them.

Southern Nuclear shall not market or broker power or energy from Joseph M. Farley Nuclear Plant, Units 1 and 2. Alabama Power Company shall continue to be responsible for compliance with the obligations imposed on it by the antitrust conditions contained in this paragraph 2.F. of the renewed license. Alabama Power Company shall be responsible and accountable for the actions of its agent, Southern Nuclear, to the extent said agent's actions may, in any way, contravene the antitrust conditions of this paragraph 2.F.

G. Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas:

(1) Fire fighting response strategy with the following elements:

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel (2) Operations to mitigate fuel damage considering the following :

(a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (3) Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders H. In accordance with the requirement imposed by the October 8, 1976 order of the United States Court of Appeals for the District of Columbia Circuit in Natural Resources Defense Council vs. 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 such proceeding herein," this renewed license shall be subject to the outcome of such proceedings.

Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

I. This renewed operating license is effective as of the date of issuance and shall expire at midnight on June 25, 2037.

FOR THE NUCLEAR REGULATORY COMMISSION

11/)lf~..Z/

J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A- Technical Specifications

2. Preoperational Tests, Startup Tests and Other Items Which Must Be Completed Prior to Proceeding to Succeeding Operational Modes

3. Appendix B - Environmental Protection Plan

4. Appendix C - Additional conditions Date of Issuance: _ _ _ _ _ __

Farley - Unit 1 Renewed License No. NPF-2 Amendment No.

(2) Alabama Power Company, pursuant to Section 103 of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess but not operate the facility at the designated location in Houston County, Alabama in accordance with the procedures and limitations set forth in this renewed license.

(3) Southern Nuclear, 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; (4) Southern Nuclear, 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; (5) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and 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 Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 2775 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

Amendment No. are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

(3) Deleted per Amendment 144 (4) Deleted per Amendment 149 (5) Deleted per Amendment 144 (6) Fire Protection Southern Nuclear Operating Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2012 and supplements dated December 20, 2012; September 16, 2013; October 30, 2013; November 12, 2013; April23, 2014; May 23, 2014; July 3, 2014; August 11, 2014; August 29, 2014; October 13, 2014; January 16, 2015, and as approved in the safety evaluation report 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.

(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 Farley. 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.

Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 o* /year 7

(yr) for CDF and less than 1x1 o* /yr for LEAF. The 8

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 are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is 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:

• "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 0);

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.

Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

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

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

(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 AttachmentS, Table S-2, "Plant Modifications Committed," of SNC letter NL-14-1273, dated August 29, 2014 to complete the transition to full compliance with 10 CFR 50.48(c) by November 6, 2017.

The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items as listed in AttachmentS, Table S-3, "Implementation Items", of SNC letter NL-14-1273, dated August 29, 2014 within 180 days after NRC approval.

(7) Deleted per Amendment 144 (8) Deleted per Amendment 144 (9) Deleted per Amendment 144 (1 0) Deleted per Amendment 144 (11) Deleted per Amendment 144 (12) Deleted per Amendment 144 (13) Deleted per Amendment 144 (14) Deleted per Amendment 144 (15) Deleted per Amendment 144 Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

{16) Deleted per Amendment 144

{17) Deleted per Amendment 144 (18) Deleted per Amendment 144 (19) Deleted per Amendment 144

{20) Deleted per Amendment 144 (21) Deleted per Amendment 144

{22) Additional Conditions The Additional conditions contained in Appendix C, as revised through Amendment No. 137, are hereby incorporated in the renewed license.

The licensee shall operate the facility in accordance with the additional conditions.

{23) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement 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 license. Until that update is complete, Southern Nuclear may make changes to the programs and activities described in the supplement without prior Commission approval, provided that Southern Nuclear evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21{d), describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

{24) Reactor Vessel Material Surveillance Capsules All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the 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.

D. Southern Nuclear 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 FA 27817 and 27822) and to the authority of Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," and was submitted on May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 181.

E. Deleted per Amendment 144 F. Alabama Power Company shall meet the following antitrust conditions:

(1) Alabama Power Company shall recognize and accord to Alabama Electric Cooperative (AEC) the status of a competing electric utility in central and southern Alabama.

(2) Alabama Power Company shall offer to sell to AEC an undivided ownership interest in Units 1 and 2 of the Farley Nuclear Plant. The percentage of ownership interest to be so offered shall be an amount based on the relative sizes of the respective peak loads of AEC and Alabama Power Company (excluding from the Alabama Power Company's peak load that amount imposed by members of AEC upon the electric system of Alabama Power Company) occurring in 1976. The price to be paid by AEC for its proportionate share of Units 1 and 2, determined in accordance with the foregoing formula, will be established by the parties through good faith negotiations. The price shall be sufficient to fairly reimburse Alabama Power Company for the proportionate share of its total costs related to the Units 1 and 2 including, but not limited to, all costs of construction, installation, ownership and licensing, as of a date, to be agreed to by the two parties, which fairly accommodates both their respective interests. The offer by Alabama Power Company to sell an undivided ownership interest in Units 1 and 2 may be conditioned, at Alabama Power Company's option, on the agreement by AEC to waive any right of partition of the Farley Plant and to avoid interference in the day-to-day operation of the plant.

(3) Alabama Power Company will provide, under contractual arrangements between Alabama Power Company and AEC, transmission services via its electric system (a) from AEC's electric system to AEC's off-system members; and (b) to AEC's electric system from electric systems other than Alabama Power Company's, and from AEC's electric system to electric systems other than Alabama Power Company's. The contractual arrangements covering such transmission services shall embrace rates and charges reflecting conventional accounting and ratemaking concepts followed by the Federal Energy Regulatory Commission (or its successor in function) in testing the reasonableness of rates and charges for transmission services. Such contractual arrangements shall contain provisions protecting Alabama Power Company against economic Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

detriment resulting from transmission line or transmission losses associated therewith.

(4) Alabama Power Company shall furnish such other bulk power supply services as are reasonably available from its system.

(5) Alabama Power Company shall enter into appropriate contractual arrangements amending the 1972 Interconnection Agreement as last amended to provide for a reserve sharing arrangement between Alabama Power Company and AEC under which Alabama Power Company will provide reserve generating capacity in accordance with practices applicable to its responsibility to the operating companies of the Southern Company System. AEC shall maintain a minimum level expressed as a percentage of coincident peak one-hour kilowatt load equal to the percent reserve level similarly expressed for Alabama Power Company as determined by the Southern Company System under its minimum reserve criterion then in effect. Alabama Power Company shall provide to AEC such data as needed from time to time to demonstrate the basis for the need for such minimum reserve level.

(6) Alabama Power Company shall refrain from taking any steps, including but not limited, to the adoption of restrictive provisions in rate filings or negotiated contracts for the sale of wholesale power, that serve to prevent any entity or group of entities engaged in the retail sale of firm electric power from fulfilling all or part of their bulk power requirements through self-generation or through purchases from some other source other than Alabama Power Company. Alabama Power Company shall further, upon request and subject to reasonable terms and conditions, sell partial requirements power to any such entity. Nothing in this paragraph shall be construed as preventing an applicant from taking reasonable steps, in accord with general practice in the industry, to ensure that the reliability of its system is not endangered by any action called for herein.

(7) Alabama Power Company shall engage in wheeling for and at the request of any municipally-owned distribution system:

(a) of electric energy from delivery points of Alabama Power Company to said distribution system(s); and (b) of power generated by or available to a distribution system as a 2

result of its ownership or entitlement in generating facilities, to delivery points of Alabama Power Company designated by the distribution system.

Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

2 "Entitlement includes, but is not limited to, power made available to an entity pursuant to an exchange agreement.

Such wheeling services shall be available with respect to any unused capacity on the transmission lines of Alabama Power Company, the use of which will not jeopardize Alabama Power Company's system. The contractual arrangements covering such wheeling services shall be determined in accordance with the principles set forth in Condition (3) herein. Alabama Power Company shall make reasonable provisions for disclosed transmission requirements of any distribution system(s) in planning future transmission. "Disclosed" means the giving of reasonable advance notification of future requirements by said distribution system(s) utilizing wheeling services to be made available by Alabama Power Company.

(8) The foregoing conditions shall be implemented in a manner consistent with the provisions of the Federal Power Act and the Alabama Public Utility laws and regulations thereunder and all rates, charges, services or practices in connection therewith are to be subject to the approval of regulatory agencies having jurisdiction over them.

Southern Nuclear shall not market or broker power or energy from Joseph M. Farley Nuclear Plant, Units 1 and 2. Alabama Power Company shall continue to be responsible for compliance with the obligations imposed on it by the antitrust conditions contained in this paragraph 2.F. of the renewed license. Alabama Power Company shall be responsible and accountable for the actions of its agent, Southern Nuclear, to the extent said agent's actions may, in any way, contravene the antitrust conditions of this paragraph 2.F.

G. The facility requires relief from certain requirements of 10 CFR 50.55a(g) and exemptions from Appendices G, H and J to 10 CFR Part 50. The relief and exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 5. They are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, the relief and exemptions are hereby granted.

With the granting of these relief and 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.

H. Southern Nuclear shall immediately notify the NRC of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.

I. Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions that include the following key areas:

Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

(1) Fire fighting response strategy with the following elements:

(a) Pre-defined coordinated fire response strategy and guidance (b) Assessment of mutual aid fire fighting assets (c) Designated staging areas for equipment and materials (d) Command and control (e) Training of response personnel (2) Operations to mitigate fuel damage considering the following:

(a) Protection and use of personnel assets (b) Communications (c) Minimizing fire spread (d) Procedures for implementing integrated fire response strategy (e) Identification of readily-available pre-staged equipment (f) Training on integrated fire response strategy (3) Actions to minimize release to include consideration of:

(a) Water spray scrubbing (b) Dose to onsite responders J. Alabama Power Company 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.

K. This renewed operating license is effective as of the date of issuance and shall expire at midnight on March 31, 2041.

FOR THE NUCLEAR REGULATORY COMMISSION J. E. Dyer, Director Office of Nuclear Reactor Regulation

Attachment:

1. Appendix A- Technical Specifications (NUREG-0697, as revised)

2. Appendix B - Environmental Protection Plan

3. Appendix C - Additional conditions Date of Issuance: _ _ _ _ __

Farley - Unit 2 Renewed License No. NPF-8 Amendment No.

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c)

NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants Enclosure 2 Revised Technical Specifications Page

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978;

b. Quality assurance for effluent and environmental monitoring, using the guidance in Regulatory Guide 4.15, February 1979; and

c. All programs specified in Specification 5.5.

Farley Units 1 and 2 5.4-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)