NL-17-1155, NFPA-805 Transition Due Date Extension

NFPA-805 Transition Due Date Extension

ML17226A291
Person / Time
Site:	Farley
Issue date:	08/11/2017
From:	Meier M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17226A290	List: NL-17-1155, NFPA-805 Transition Due Date Extension
References
NL-17-1155
Download: ML17226A291 (19)

Text

A Southern Nuclear Michael Meier Regulatory Affairs Vice President 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 7615 tel 205 992 5217 fax mdmeier@southernco.com Enclosure 3 to this letter contains Security-Related Information to be withheld from public disclosure under 10 CFR 2.390. When separated from Enclosure 3, this transmittal document and the other Enclosures are decontrolled.

August 11, 2017 Docket Nos.: 50-348 NL-17-1155 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Units 1 and 2 NFPA-805 Transition Due Date Extension Ladies and Gentlemen:

In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend Renewed Facility Operating License (FOL) No. NPF-2 and NPF-8 for Joseph M.

Farley Nuclear Plant (FNP) Units 1 and 2, respectively. This license amendment request (LAR) requests Nuclear Regulatory Commission (NRC) review and approval for a revision to existing obligations referenced in the FOL, NPF-2 and NPF-8. This request will extend the allowed time to complete all the required modifications necessary to achieve full compliance with 10 CFR 50.48(c). to this letter provides the proposed FOL change, the basis for the proposed change, and Significant Hazards Considerations. SNC has evaluated the proposed FOL change and has determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. Enclosure 2 provides the marked up and clean-typed pages of the FOL. Enclosure 3 provides the marked-up Attachment S, "Modifications and Implementation Items" page.

In accordance with 10 CFR 50.91 (b)(1), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Alabama officials.

SNC requests approval of the proposed license amendment prior to November 6, 2017.

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-17-1155 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the

..Jj__dayof Au~us+/- 2017.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

~

Vice President, Regulatory Affairs Southern Nuclear Operating Company MM/NDJ

Enclosures:

1. Basis for Proposed Change

2. Marked-up and Clean Typed FOL Pages

3. Marked-up Attachment S, "Modifications and Implementation Items" Cc: Regional Administrator, Region II NRR Project Manager- Farley Nuclear Plant Senior Resident Inspector- Farley Nuclear Plant RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant Units 1 and 2 NFPA-805 Transition Due Date Extension Enclosure 1 Basis for Proposed Extension of Project Implementation to NL-17-1155 Basis for Proposed Extension of Project Implementation Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 No Significant Hazards Consideration Determination 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions 5.0 Environmental Consideration E1-1 to NL-17-1155 Basis for Proposed Extension of Project Implementation 1.0 Summary Description This evaluation supports a request to amend Facility Operating Licenses (FOL), NPF-2 and NPF-8, for Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2, respectively.

This License Amendment Request (LAR) will revise the respective FNP FOL, Appendix C, to require Southern Nuclear Operating Company (SNC) to implement modification Item 11 to its facility as described in AttachmentS "Modifications and Implementation Items", Table S-2, "Plant Modifications Committed," of SNC letter dated April25, 2016 (SNC letter NL-15-2310) by the conclusion of the 1R28 Spring 2018 refueling outage instead of by November 6, 2017. All other FOL requirements remain unchanged.

2.0 Detailed Description By letter dated March 10, 2015, the NRC issued Amendment Nos. 196 and 192 to FNP Units 1 and 2, respectively, (ADAMS Accession No. ML14308A048) regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c).

The accompanying safety evaluation report (SER) included a statement that the licensee shall implement the modifications to its facility, as described in AttachmentS, Table S-2 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."

By letter dated April 25, 2016, SNC submitted a LAR to change fire protection license condition 2.C(4) for Unit 1 and license condition 2.C(6) for Unit 2. Transition license condition 2.C(4)c.2 was included in Amendment No. 196, and transition license condition 2.C(6)c.2 was included in Amendment No. 192. These transition license conditions referenced Table S-2, "Plant Modifications Committed," of the SNC letter dated August 29, 2014. Table S-2 described 12 plant modifications the licensee must complete by November 6, 2017. In the April 25, 2016 LAR, SNC proposed to revise Table S-2 to:

• Delete Fire Area 1-041 from Modification 6;

• Change a cable and conduit for Fire Area 2-035 in Modification 6, and

• Revise Modification 11, which is related to a code-compliant fire detection system.

The NRC approved this request (including the revised Table S-2) by letter dated October 17, 2016 (ML 16232AOOO).

The revised FOLs for Unit 1 and Unit 2 issued by the NRC on October 17, 2016 contain the date November 6, 2017 by which SNC shall implement the modifications to its facility, as described in AttachmentS, Table S-2, of SNC letter dated April25, 2016 (SNC letter NL-15-2310). These modifications are necessary to complete the transition to full compliance with 10 CFR 50.48(c).

In addition, AttachmentS, Table S-2 of SNC letter NL-15-2310 also states these modifications will be completed by November 6, 2017.

This LAR requests to extend the time to implement Item 11 of this table, such that it will be required to be completed before the conclusion of the 1R28 spring 2018 refueling outage.

3.0 Technical Evaluation Below is the current status of the committed plant modifications as outlined in NL-15-231 0 dated April 25, 2016.

E1-2 to NL-17-1155 Basis for Proposed Extension of Project Implementation Items as outlined in Attachment S Table S Modifications and Implementation Items Item 1- Incipient Fire Detection (rank HIGH): This modification is complete.

Item 2- Hot Short (rank MEDIUM): This modification is complete.

Item 3- MDAFW to Steam Generator Flow Control (rank LOW): This modification is complete.

Item 4- Provide Train B power to RCS Temp Recorder (rank LOW): This modification is complete.

Item 5-125 VDC Breaker Trip Coordination (rank MEDIUM): This modification is complete.

Item 6- Cable tray and circuit modifications (rank HIGH): Implementation is ongoing and expected to be completed prior to the commitment date.

Item 7- C02 system upgrades (rank MEDIUM): Implementation is ongoing and expected to be completed prior to the commitment date.

Item 8- DC Shunt Protection (rank HIGH): This modification is complete Item 9- DC Shunt Protections (rank HIGH): This modification is complete Item 10- MCC Fire Sealing (rank HIGH): This modification is complete Item 11- Circuit Supervision (rank LOW): Implementation is ongoing and expected to complete prior to the commitment date. The progression of post-modification testing has been hampered by legacy issues with the interface between legacy and installed plant equipment.

Item 12- Reactor Coolant Pump Seal Upgrade (rank HIGH): This modification is complete For modifications that are not complete, appropriate compensatory measures will remain in place and be maintained until the modifications are completed This implementation date extension is requested due to possible delays in the completion of Item 11: Circuit Supervision.

For Item 11 multiple delays in the development of designs associated with this modification combined with late scope growth requiring design revisions resulted in the implementation starting late in the project life cycle schedule. The current schedule for design delivery is being met, however, there is very little margin in the schedule for discovery such as the items currently being resolved around legacy system interface issues in post-modification testing. To date all circuit supervision construction implementation is expected to complete prior to the commitment date, however, there remain concerns that post-modification testing may encounter legacy equipment issues and may not be able to be completed prior to the commitment date.

SNC is requesting that the completion date for the circuit supervision post-modification testing and final acceptance by site Operations be revised from November 6, 2017 to the conclusion of the 1R28 Spring 2018 refueling outage, to ensure legacy system interface issues are fully resolved including any issues encountered which require outage to correct. This is based on Unit 2 refueling outage in October 2017 and Unit 1 refueling outage in April 2018.

The requested extension of implementation date for the Circuit Supervision does not impact the fire PRA insights. Fire detection and suppression is still effective without the supervision as E1-3 to NL-17-1155 Basis for Proposed Extension of Project Implementation credited in the fire PRA. The supervision may be beneficial to recover the detection and suppression system if failed. However, since the recovery or repair of the failed detection and suppression system is not credited in the fire PRA, the implementation of Circuit Supervision does not impact the fire PRA.

The requested extension of the implementation date for the Circuit Supervision modification is an administrative change that does not impact the original defense-in-depth (DID) and safety margin evaluations associated with the original LAR.

4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration Southern Nuclear Operating Company (SNC) is requesting an amendment to the Joseph M. Farley Nuclear Plant (FNP) Facility Operating Licenses (FOL), Appendix C, to revise existing commitments regarding NFPA-805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants.

A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. Per 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

• Involve a significant increase in the probability or consequences of an accident previously evaluated; or

• Create the possibility of a new or different kind of accident from any accident previously evaluated; or

• Involve a significant reduction in a margin of safety As required by 10 CFR 50.91 (a), the SNC analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment revises the Joseph M. Farley (FNP) Unit 1 and Unit 2 facility operating licenses (FOLs), Appendix C, to require Southern Nuclear Operating Company (SNC) to implement modification Item 11 to its facility as described in AttachmentS, Table S-2 'Modifications and Implementation Items",

"Plant Modifications Committed," of SNC dated April25, 2016 (SNC letter NL 231 0) by the conclusion of the 1R28 Spring 2018 refueling outage instead of by November 6, 2017. All other FOL requirements remain unchanged.

The proposed change does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems and components (SSCs) to perform E1-4 to NL-17-1155 Basis for Proposed Extension of Project Implementation their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not increase the probability or consequence of an accident as verified by the risk analysis performed.

Therefore, this proposed change does not involve an increase in the probability or consequences of an accident previously identified.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment revises the FNP Unit 1 and Unit 2 FOLs, Appendix C, to require SNC to implement modification Item 11 to its facility as described in AttachmentS, Table S-2, of SNC dated April25, 2016 (SNC letter NL-15-2310) by the conclusion of the 1R28 Spring 2018 refueling outage instead of by November 6, 2017. All other FOL requirements remain unchanged.

This change is administrative in nature and therefore does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment revises the FNP Unit 1 and Unit 2 FOLs, Appendix C, to require SNC to implement modification Item 11 to its facility as described in AttachmentS, Table S-2, of SNC dated April25, 2016 (SNC letter NL-15-2310) by the conclusion of the 1R28 Spring 2018 refueling outage instead of by November 6, 2017. All other FOL requirements remain unchanged.

The proposed change is administrative in nature and hence does not increase the probability or consequence of an accident and does not reduce the margin of safety as verified by the risk analysis performed.

Therefore, this proposed change does not involve a significant reduction in a margin of safety.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, {2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. SNC has evaluated the proposed amendment and determined that it involves no significant hazards consideration.

E1-5

Enclosure 1 to NL-17-1155 Basis for Proposed Extension of Project Implementation 4.2 Applicable Regulatory Requirements/Criteria On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative fire protection requirements.

10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants- 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning.

The voluntary adoption of 10 CFR 50.48(c) by FNP does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, GDC 3, Fire Protection.

The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a), which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 805." Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the fire protection program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48 (a) and GDC 3 have corresponding requirements in NFPA 805.

4.3 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 Environmental Considerations SNC has evaluated the proposed amendment and determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

E1-6

Joseph M. Farley Nuclear Plant Units 1 and 2 NFPA-805 Transition Due Date Extension Enclosure 2 Marked-up and Clean Typed FOL Pages

5~

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.

h. 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.

i. 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 requests dated September 25, 2012; April 25, 2016; 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; January16, 2015, and August 11, 2017 as approved in the safety evaluation reports dated March 10, 2015, aRG-October 17, 2016, 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) and1 0 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~lnformed 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. 2GS

• "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 reports dated March 10, 2015, and October 17, 2016, 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-15-231 0, dated April 25, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by November 6, 2017 before the conclusion of the 1R28 Spring 2018 Refueling Outage as provided in SNC letter dated August 11. 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, except for items 30 and

32. Items 30 and 32 shall be implemented by February 6, 2018.

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

(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 requests dated September 25, 2012; April 25, 2016; 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 August 11. 2017 as approved in the safety evaluation reports dated March 10, 2015, aR1-0ctober 17, 2016.._gn_d . 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.

2) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 o*7fyear (yr) for CDF and less than 1x10'8/yr for LEAF. 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. 2G+

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-15-231 0 dated April 26, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) by November 6, 2017 before the conclusion of the 1828 Spring 2018 Refueling Outage as provided in SNC letter dated Auwst 11. 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, except for items 30 and 32. Items 30 and 32 shall be implemented by February 6, 2018.

(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 (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.

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

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.

h. 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.

i. 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 requests dated September 25, 2012; April25, 2016; 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; January16, 2015; and August 11, 2017, as approved in the safety evaluation reports dated March 10, 2015, October 17, 2016, 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) and10 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.

• "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.

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 reports dated March 10, 2015, and October 17, 2016, 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 Attachment S, Table S-2, "Plant Modifications Committed," of SNC letter NL-15-2310, dated April25, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) before the conclusion of the 1R28 Spring 2018 Refueling Outage as provided in SNC letter dated August 11, 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, except for items 30 and

32. Items 30 and 32 shall be implemented by February 6, 2018.

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

(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 requests dated September 25, 2012 ; April25 , 2016; 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 August 11, 2017, as approved in the safety evaluation reports dated March 10, 2015, October 17, 2016, 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.

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.

2) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x1 0-8/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.

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

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-15-2310, dated April 25, 2016, to complete the transition to full compliance with 10 CFR 50.48(c) before the conclusion of the 1R28 Spring 2018 Refueling Outage as provided in SNC letter dated August 11, 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, except for items 30 and 32. Items 30 and 32 shall be implemented by February 6, 2018.

(7) Deleted per Amendment 144 (8) Deleted per Amendment 144 (9) Deleted per Amendment 144

( 10) 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 (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.

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

Joseph M. Farley Nuclear Plant Units 1 and 2 NFPA-805 Transition Due Date Extension Enclosure 3 Marked-up Attachment 5, "Modifications and Implementation Items"