NL-22-0850, Supplement to License Amendment Request to Revise the NFPA 805 Fire Protection Program

Supplement to License Amendment Request to Revise the NFPA 805 Fire Protection Program

ML22325A228
Person / Time
Site:	Hatch
Issue date:	11/18/2022
From:	Gayheart C Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML22325A227	List: NL-22-0850, Supplement to License Amendment Request to Revise the NFPA 805 Fire Protection Program
References
NL-22-0850
Download: ML22325A228 (1)

Text

Security-Related Information. Withhold from public disclosure per 10 CFR 2.390.

Decontrolled upon removal of Attachments 1 and 2

>-,, Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com November 18, 2022 Docket Nos.: 50-321 50-366 NL-22-0850 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Supplement to License Amendment Request to Revise the NFPA 805 Fire Protection Program Ladies and Gentlemen:

On June 11, 2020, with corrections dated June 17, 2020, the Nuclear Regulatory Commission (NRC) issued Amendment No. 304 to Renewed Facility Operating License (RFOL) No. DPR-57 and Amendment No. 249 to RFOL No. NPF-5 for Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2, respectively. These amendments adopted National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standards for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations, Part 50, Section 50.48(c), as the new HNP fire protection licensing basis.

During implementation of the NFPA 805 program at HNP, SNC determined that additional plant modifications were required to comply with these requirements. As discussed during the pre-submittal meeting with NRC Staff on October 5, 2021 (ML21278A557), the plant modifications impact Attachment S2, Table S-2 referenced in the Transition License Conditions of RFOL Nos. DPR-57 and NPF-5. Therefore, in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC), requested an amendment to RFOL No. NPF-5 for HNP Unit 1 and RFOL No. DPR-57 for HNP Unit 2 to reference an updated Table S-2 that reflects these additional plant modifications on March 31, 2022 [ML22090A278 (non-public version) and ML22090A279 (public version)].

While scheduling and performing the modifications listed in the updated Table S-2 provided with the March 31, 2022 license amendment request (LAR), an error was noted in newly added item number 15. The item was noted as being applicable to Hatch Unit 2 only; however, item number 15 applies to Hatch Unit 1 only. All other information regarding item 15, as well as the other changes to Table S-2 identified in the

U.S. Nuclear Regulatory Commission NL-22-0850 Page 2 of 3 March 31, 2022 LAR submittal, were correct as previously provided. This supplement revises Table S-2 to indicate that item number 15 applies to Unit 1 rather than Unit 2. The Unit 1 and Unit 2 RFOL markups are revised accordingly to refer to the revised Table S-2 provided in this supplement.

Additionally, SNC requests NRC approval sooner than previously requested. SNC is now requesting approval by February 24, 2023, which is eight days prior to the conclusion of the 2R27 refueling outage (RFO) as currently scheduled. The startup from the 2R27 RFO is implicitly specified in the 10 CFR 50.48(c) Transition License Conditions of Hatch RFOL Nos. DPR 57 and NPF-5 as currently written . The last remaining Unit 2 modifications will be implemented during the 2R27 RFO. Having the RFOLs amended (i.e., to refer to the revised Table S-2) prior to the conclusion of the 2R27 RFO aligns with the original intent of the Transition License Conditions for full compliance with 10 CFR 50 .48( c) by the startup of the 2R27 RFO. provides a new Section 2.4, "Description of the Proposed Change," which replaces the Section 2.4 provided in the LAR dated March 31, 2022.

Attachments 1 through 4 completely supersede the Attachments 1 through 4 provided in the LAR dated March 31, 2022. Attachment 5 provided in the submittal dated March 31, 2022 is not affected. provides the revised Markup of NL-19-1475 Attachment S2, Table S-2 Plant Modifications Committed. Attachment 1 contains security-related information and should be withheld from public disclosure. provides the revised clean version of Attachment S2, Table S-2 Plant Modifications Committed. Attachment 2 contains security-related information and should be withheld from public disclosure. provides revised markups of the license conditions. provides clean versions of the revised license conditions.

The conclusions of the No Significant Hazards Consideration Determination and Environmental Consideration contained in the original application have been reviewed and are unaffected by this supplement.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Georgia Officials.

This letter contains no new regulatory commitments.

If you should have any questions regarding this submittal, please contact Amy Chamberlain at 205.992.6361.

U.S. Nuclear Regulatory Commission NL-22-0850 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 18th day of November, 2022.

Respectfully submitted, C. A. Gay a Regulatory ffa s Director Southern Nuclear Operating Company CAG/AGQ

Enclosure:

Revised Section 2.4, "Description of the Proposed Change" Attachments: 1. Revised Markup of NL-19-1475 Attachment S2, Table S-2 Plant Modifications Committed (Security-related information)

2. Revised Clean Version of Revised Attachment S2, Table S-2, Plant Modifications Committed (Security-related information)

3. Revised Markups of License Conditions

4. Revised Clean Version of Revised License Conditions cc: Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch Director, Environmental Protection Division - State of Georgia Rtype: CHA02.004

Edwin I. Hatch Nuclear Plant- Units 1 and 2 License Amendment Request to Revise NFPA 805 Fire Protection Program Enclosure to NL-22-0850 Revised Section 2.4, "Description of the Proposed Change"

Enclosure to NL-22-0850 License Amendment Request to Revise NFPA 805 Fire Protection Program The following Section 2.4 entirely replaces the Section 2.4 provided with the Hatch license amendment request dated March 31, 2022 [ML22090A278 (non-public version) and ML22090A279 (public version)] .

2.4 Description of the Proposed Change HNP Unit 1 RFOL license condition 2.(C)(3) and HNP Unit 2 RFOL license condition 2.(C)(3)(a), "Fire Protection," as follows {double underline indicates inserted text):

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 April 4, 2018, supplemented by letters dated May 28, August 9, October 7, and December 13, 2019, and February 5, and March 13, 2020, and license amendment request dated March 31, 2022, supplemented by letter dated November 18, 2022, and as approved in the NRG safety evaluation~

(SE) dated June 11, 2020 and== = ==* 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 .

HNP Unit 1 RFOL license condition 2.(C)(3)(c) and HNP Unit 2 RFOL license condition 2.(C)(3)(a)(3), "Transition License Conditions," subparagraphs (2) and b) ,

respectively, as follows (strikethrough indicates deleted text, and double underline indicates inserted text):

"The licensee shall implement the modifications described in Attachment ~l.

Table S-2, "Plant Modifications Committed," of SNC letter NL 19 1475NL .o.B.50., dated December 13, 2019November 18, 2022, to its facility to complete 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 NRG SEU nit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024).

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

HNP Unit 1 RFOL license condition 2.(C)(3)(c)(3) and HNP Unit 2 RFOL license condition 2.(C)(3)(a)(3)c), "Transition License Conditions," as follows (strikethrough indicates deleted text, and double underline indicates inserted text):

The licensee shall implement items listed in Attachment S2, Table S-3, "Implementation Items," of SNC letter NL-19-1475, dated December 13, 2019, with 365 days after issuance of the NRG SE. An exception to this statement is for completion date for Implementation Item IMP-19. This item will be completed for each unit at a time not to exceed 180 days after all modifications for the respective unit (as listed in Attachment ~l. Table S-2, "Plant Modifications Committed," of SNC letter NL-22-0850, dated November 18, 2022) are operable.

Page 1 of 1

Edwin I. Hatch Nuclear Plant - Units 1 and 2 License Amendment Request to Revise NFPA 805 Fire Protection Program Attachment 3 to NL-22-0850 Revised Markups of License Conditions

• Blue underline (example) indicates text inserted by the markups provided on March 31 , 2022

• Red strikethrough (example) indicates text deleted by the markups provided on March 31, 2022

• Green strikethrough ~C'4!61'1'1!'1C) indicates text that this supplement deletes from the markups provided on March 31 , 2022

• Red text callout boxes indicate text that this supplement adds to the markups provided on March 31, 2022

for sample analysis or instrument calibration, or associated with radioactive apparatus or components (6) Southern Nuclear, 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 the facility.

(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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions specified or incorporated below:

( 1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady-state reactor core power levels not in excess of 2,804 megawatts thermal.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. ~ - '

are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:

SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.

supplemented by letter dated November 18, 2022 ,

(3) Fire Protection Southern Nuclear Operating Company shall implement and maintain in effect all provisio s of the approved fire protection program that comply with 10 CFR 50.4 (a) and 10 CFR 50.48(c), as specified in the licensee amendment requ st dated April 4, 2018, supplemented by letters dated 28, August , October 7, and December 13, 2019, and February 5, ch 13, 2 0, and license amendment request dated March 2022 and as approved in the NRC safety evaluation§. (SE) dated June 11, 2020 and . 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-57 Amendment No. ~ -

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 elementis adequate for the hazard.

A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change hasnot affected the component, system, procedure, or physical arrangement functionality 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 3.10); 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 SE dated June 11, 2020 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) and (3) 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 November 18, 2022 described in (b)(2) above.

NL-22-0850 (2) he licensee shall impleme t the modifications described in 14.. chment S2, Table S-2, ' lant Modifications Committed," of SN etter NL 19 1475~~L 21 8918, dated December 13, 2G-4--9MereA XX, 2022, to its facility to complete transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage (for each unit) after the issuance of the NRG SUnit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024 ). The licensee shall maintain appropriate compensatory measures in place until completion of Renewed License No. DPR-57 Amendment No. ~ -

Note: These words are these modifications.

not actually being pushed onto this page. (3) The licensee shall implement the items listed in They just appear to be Attachment S2, Table S-3, "Implementation Items," of SNC letter because deleted text on NL-19-1475, dated December 13, 2019, with 365 days after previous page is still the issuance of the NRC SE. An exception to this statement is shown for the purpose for the completion date for Implementation Item IMP-19. This of markups. item will be completed for each unit at a time not to exceed 180 days after all modifications for the respective unit (as listed in Attachment S2, Table S-2, "Plant Modifications Committed/' of SNC letter f>IL J1 QQ1 i , eleioel Merelal )0( 2022) are operable.

(4.a) Physical Protection ~ NL-22-0850, dated November 18, 2022 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 is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear 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 Southern Nuclear CSP was approved by License Amendment No. 265, as supplemented by a change approved by License Amendment No. 274.

(4.b) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

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

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

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

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread 4 . Procedures for implementing integrated fire response strategy Renewed License No. DPR-57 Amendment No. JM_

(6) Southern Nuclear, 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 the facility.

(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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions 2 specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady sate reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. ~ _ are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(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 license supported by a favorable evaluation by the Commission.

(a) supplemented by letter dated November 18, 2022, Southern Nuclear Operati Company shall impleme t and maintain in effect all provisio of the approved fire p otection program that comply with 10 C 50.48(a) and 10 C R 50.48(c),

as specified in the licensee amen supplemented by letters dated May August 9, 0 tober 7, and December 13, 2019, and February 5, a March 13 2020, and license amendment request dated March ~ . 2022, nd as approved in the NRC safety evaluation§ (SE) dated June 11 , 2020 and . 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 2 The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Renewed License No. NPF-5 Amendment No. ~ -

would require prior NRC approval, the licensee may make changes Note: The only change to the fire protection program without prior approval of the to this page is the word Commission if those changes satisfy the provisions set forth in 10 "would" got rolled to this CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a page. Therefore, page 5 change to a technical specification or a license condition, and the of the license will get criteria listed below are satisfied .

replaced, and the Amendment No. in the (1) Risk-Informed Changes that May Be Made Without Prior NRC footer will have a Approval revision bar to indicate the page changed due A risk assessment of the change must demonstrate that the to page roll. 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 the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

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

b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1Q- 7/year (yr) for CDF and less than 1 x1Q-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.

(2) Other Changes that May Be Made Without Prior NRC Approval a) 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, Renewed License No. NPF-5 Amendment No. 249_

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)(b) above. NL-22 _08S0 November 18, 2022 The licensee shall implement the edifications described in ttachment S2, Table S-2, "Plan edifications Committed,"

o C letter NL 19 1475 ~ L £1 -6~H~. dated December 13,

~ , , to its facility to complete transition to full compliance with 10 CFR 50.48(c) by the startup of tRe second refueling outage (for each unit) after the issuance of the NRG SEUnit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024). The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

c) The licensee shall implement the items as listed in Attachment S2, Table S-3, "Implementation Items," of SNC letter NL-19-1475, dated December 13, 2019, within 365 days after the issuance of the NRC SE. An exception to this statement is for the completion date for Implementation Item IMP-19. This item will be completed for each unit at a time not to exceed 180 days after all modifications for the respective unit (as listed in Attachment S2, Table S-2, "Plant Modifications Committed " of SNC letter ~JL 21 0018 eleteel Mel'el-l )0(, 2022) are operable.

(b.1) Physical Protection NL-22-0850, dated November 18, 2022 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 the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear 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 Southern Nuclear CSP was approved by License Amendment No. 209, as supplemented by a change approved by License Amendment No. 219.

Renewed License No. NPF-5 Amendment No. 249_

Edwin I. Hatch Nuclear Plant - Units 1 and 2 License Amendment Request to Revise NFPA 805 Fire Protection Program Attachment 4 to NL-22-0850 Revised Clean Version of Revised License Conditions

for sample analysis or instrument calibration, or associated with radioactive apparatus or components (6) Southern Nuclear, 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 the facility.

(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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady-state reactor core power levels not in excess of 2,804 megawatts thermal.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. ,

are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:

SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.

(3) 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 April 4, 2018, supplemented by letters dated May 28, August 9, October 7, and December 13, 2019, and February 5, and March 13, 2020, and license amendment request dated March 31, 2022, supplemented by letter dated November 18, 2022, and as approved in the NRC safety evaluations (SE) dated June 11, 2020 and . 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-57 Amendment No.

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 elementis adequate for the hazard.

A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change hasnot affected the component, system, procedure, or physical arrangement functionality 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 3.10); 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 SE dated June 11, 2020 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) and (3) 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 (b)(2) above.

(2) The licensee shall implement the modifications described in Attachment 2, Table S-2, "Plant Modifications Committed," of SNC letter NL-22-0850, dated November 18, 2022, to its facility to complete transition to full compliance with 10 CFR 50.48(c) by the startup of Unit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024). The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

Renewed License No. DPR-57 Amendment No.

(3) The licensee shall implement the items listed in Attachment S2, Table S-3, "Implementation Items," of SNC letter NL-19-1475, dated December 13, 2019, with 365 days after the issuance of the NRC SE. An exception to this statement is for the completion date for Implementation Item IMP-19. This item will be completed for each unit at a time not to exceed 180 days after all modifications for the respective unit (as listed in Attachment 2, Table S-2, "Plant Modifications Committed," of SNC letter NL-22-0850, dated November 18, 2022) are operable.

(4.a) Physical Protection 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 is entitled: "Southern Nuclear Operating Company Security Plan , Training and Qualification Plan ,

and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear 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 Southern Nuclear CSP was approved by License Amendment No. 265, as supplemented by a change approved by License Amendment No. 274.

(4.b) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

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

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

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

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy Renewed License No. DPR-57 Amendment No.

(6) Southern Nuclear, 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 the facility.

(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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions 2 specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady sate reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(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 license supported by a favorable evaluation by the Commission.

(a) 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 April 4, 2018, supplemented by letters dated May 28, August 9, October 7, and December 13, 2019, and February 5, and March 13, 2020, and license amendment request dated March 31, 2022, supplemented by letter dated November 18, 2022, and as approved in the NRC safety evaluations (SE) dated June 11, 2020 and 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 2 The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Renewed License No. NPF-5 Amendment No.

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.

(1) 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 the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

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

b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1Q- 7/year (yr) for CDF and less than 1 x10-8/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.

(2) Other Changes that May Be Made Without Prior NRC Approval a) 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, Renewed License No. NPF-5 Amendment No.

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)(b) above.

b) The licensee shall implement the modifications described in Attachment 2, Table S-2, "Plant Modifications Committed," of SNC letter NL-22-0850, dated November 18, 2022, to its facility to complete transition to full compliance with 10 CFR 50.48(c) by the startup of Unit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024).

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

c) The licensee shall implement the items as listed in Attachment S2, Table S-3, "Implementation Items," of SNC letter NL-19-1475, dated December 13, 2019, within 365 days after the issuance of the NRC SE. An exception to this statement is for the completion date for Implementation Item IMP-19. This item will be completed for each unit at a time not to exceed 180 days after all modifications for the respective unit (as listed in Attachment 2, Table S-2, "Plant Modifications Committed," of SNC letter NL-22-0850, dated November 18, 2022) are operable.

(b.1) Physical Protection 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 the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan is entitled: "Southern Nuclear Operating Company Security Plan , Training and Qualification Plan, and Safeguards Contingency Plan ," with revisions submitted through May 15, 2006.

Southern Nuclear 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 Southern Nuclear CSP was approved by License Amendment No. 209, as supplemented by a change approved by License Amendment No. 219.

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