NL-18-0668, Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material

Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material

ML18348A733
Person / Time
Site:	Farley
Issue date:	12/14/2018
From:	Wheat J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-18-0668
Download: ML18348A733 (21)

Text

~ Southern Nuclear Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 tel 205 992 7601 fax DEC 1 4 2018 Docket Nos.: 50-348 NL-18-0668 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material Ladies and Gentlemen:

In accordance with 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend Renewed Facility Operating License (FOL) No. NPF-2 for Farley Nuclear Plant (FNP) Unit 1 and Renewed FOL No. NPF-8 for FNP Unit 2. The proposed License Amendment Request (LAR) would modify the plant operating licenses to allow, as a performance-based method, use of thermal insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from National Fire Protection Association (NFPA) 805 Chapter 3, Section 3.3, Prevention. to this letter provides the technical basis for this request. 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 existing Unit 1 and 2 Renewed FOLs, respectively. Enclosure 3 provides the revised NFPA 805 LAR Attachment A, Table 8 markup pages. Enclosure 4 contains the revised NFPA 805 LAR Attachment A, Table B-1 clean typed pages.

In accordance with 10 CFR 50.91, SNC is providing a copy of the proposed license amendment to the designated representative for the State of Alabama.

SNC requests approval of this proposed license amendment by December 15, 2019.

This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the

'~ i'k day of December 2018.

U.S. Nuclear Regulatory Commission NL-18-0668 Page2 Respectfully submitted, Justin T. Wheat Licensing Manager JTW/ndj/sm

Enclosures:

1. Basis for Proposed Change

2. Plant Farley Operating License Mark-up and Clean Typed Pages

3. Farley NFPA 805 LAR Attachment A, Table B Mark-up Pages

4. Farley NFPA 805 LAR Attachment A, Table B Clean Typed Pages cc: Regional Administrator, Region II NRR Project Manager- Farley Nuclear Plant Senior Resident Inspector - Farley Nuclear Plant State Health Officer, Alabama State Department of Health RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material Enclosure 1 Basis for Proposed Change to NL-18-0668 Basis for Proposed Change Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 3.1 Technical Basis for the Request 3.2 Defense-in-Depth 3.3 Nuclear Safety and Radiological Release Performance Criteria 3.4 Future Installations 3.5 Conclusion 4.0 Regulatory Evaluation 4.1 No Significant Hazards Consideration Determination 4.2 Applicable Regulatory Requirements/Criteria 5.0 Environmental Considerations 6.0 References to NL-18-0668 Basis for Proposed Change 1.0 Summary Description This evaluation supports a request to amend the Renewed Facility Operating Licenses (FOLs) for the Farley Nuclear Plant (FNP), Unit Nos. 1 and 2.

The proposed license amendment request (LAR) revises the fire protection sections of the Renewed FOLs for FNP, Units 1 and 2, to allow, as a performance-based method, certain currently-installed thermal insulation materials to be retained and allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from National Fire Protection Association (NFPA) Standard 805, Chapter 3, Section 3.3, Prevention. This request is being made in accordance with 10 CFR 50.48(c)(2)(vii), to use a performance-based method fire protection program element.

By letter dated March 10, 2015, the NRC issued a license amendment approving the transition of the fire protection licensing basis for FNP, Units 1 and 2, to NFPA Standard 805. The updates to the FOL associated with the NFPA 805 transition established provisions that allow Southern Nuclear Operating Company (SNC) to make risk-informed changes to the Fire Protection Program provided the change has no more than minimal impact. The ability to make these risk-informed changes to the fire protection program is stipulated by Renewed FOL paragraph 2.C.(4) and 2.C.(6) for FNP Units 1 and 2 respectively.

In several areas at FNP, exposed thermal insulation materials are installed on various heating, ventilation and air conditioning (HVAC) system piping to prevent sweating. Although these materials comply with the flame spreading rating of 25 or less, these materials do not meet the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. This submittal requests NRC approval of a change to the Renewed FOL to allow, as a performance-based method, certain currently-installed thermal insulation materials to be retained and allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls, as a deviation from NFPA 805 Chapter 3, Section 3.3, Prevention.

2.0 Detailed Description Proposed Changes SNC requests that the response to the FNP NFPA 805 LAR Attachment A, Table B-1 Item 3.3.4, "Insulation Materials," be revised from "complies" to "Complies with NRC Approval." A markup and clean copy of the proposed change is provided in Enclosures 3 and 4 respectively.

SNC also requests an amendment to the FNP FOL, paragraphs as shown below:

FNP Unit 1 License Condition 2.C. (4):

(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; December 14 2018; 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, E1-1 to NL-18-0668 Basis for Proposed Change 2015, and August 11, 2017, as approved in the safety evaluation reports dated March 10, 2015, October 17, 2016, November 1, 2017 and [INSERT DATE]. 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.

FNP Unit 2 License Condition 2.C. {6):

(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 December 14 2018; 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 August 11, 2017, as approved in the safety evaluation reports dated March 10,2015, October 17,2016, November 1, 2017, and [INSERT DATE]. 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.

The proposed changes and clean typed version of the pages are shown in Enclosure 2.

Basis for Request 3.0 Technical Evaluation 3.1 Technical Basis for the Request NFPA Standard 805, Section 3.3.4, states:

Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

NFPA 805 Section 1.6.36 has re-defined earlier definitions of non-combustible material to the now current definition of limited combustible material:

Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btullb (8141 kJ/kg) and either has a structural base of noncombustible material with a surfacing not exceeding a thickness of 1/8 in. (3.2 mm) that has a flame spread rating not E1-2 to NL-18-0668 Basis for Proposed Change greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.

The definition of a limited combustible in NFPA 805 now includes requirements for materials to have a heat of combustion less than 3,500 BTU/lb.

A number of plant locations were identified where insulation material is used for maintaining efficiency of the system and/or preventing pipe sweat. The insulation material is also used for safety applications.

The basis for the approval of this request is that the forms in which the thermal insulation are installed, and the conditions anticipated, meet the intent of the revised limited combustible material definition because the materials used at FNP have a flame spread rating of 25 or less and will not support continued progressive combustion. Specifically, the thermal insulation materials used at FNP have flame spread and smoke developed ratings of 25 and 50 per ASTM E-84, respectively. Although the thermal insulation materials exceed the NFPA 805 heat value of 3,500 BTU/Ib, these insulation materials (i.e., polyisocyanurate/foam insulation) will not contribute significantly to fire per ASTM E-84.

3.2 Defense-in-Depth The three echelons of defense-in-depth are:

• Prevent fires from starting (i.e., combustible/hot work controls);

• Rapidly detect, control, and extinguish fires that do occur, thereby limiting damage (i.e.,

fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); and,

• Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).

The use of insulation material which exceeds the NFPA 805 definition of limited combustible (i.e., exceeds the NFPA 805 heat value of 3,500 BTU/Ib) does not affect Echelons 1, 2, or 3.

The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not introduce new ignition sources, does not exceed the design bases of installed fire protection systems, does not compromise manual fire suppression functions, and does not adversely impact fire protection systems and features or post-fire safe shutdown capability as previously designed, reviewed, and considered.

Echelon 1: Prevent Fires from Starting The thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The selection and application of thermal insulation material is controlled per the SNC design change process. SNC Fleet Procedures that govern the Plant Modifications and Engineering Change Control process are in place to review future installation impacts to the Fire Protection Program, resulting in updates to the applicable analyses and calculations as required.

E1-3 to NL-18-0668 Basis for Proposed Change Echelon 2: Rapidly Detect, Control, and Extinguish Fires that do Occur, Thereby Limiting Damage The limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not result in increased combustible loading which would challenge the design bases of the installed fire protection systems. The presence of the thermal insulation in limited applications and associated procedural controls do not impact the ability of the automatic suppression and detection systems to perform credited functions. Portable fire extinguishers and hose stations are available for manual firefighting activities by the site fire brigade. Therefore, if a fire were to occur, damage would be limited.

Echelon 3: Provide Adequate Level of Fire Protection for Systems and Structures so that a Fire will not Prevent Essential Safety Functions from being Performed The limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not adversely impact the installed fire protection systems and features, and essential safety functions are maintained and capable of being performed. The insulation material does not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered. SNC Fleet Procedures that govern the Plant Modifications and Engineering Change Control process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.

3.3 Nuclear Safety and Radiological Release Performance Criteria In the plant, the use of thermal insulation material other than non-combustible and more than limited combustible does not affect nuclear safety. The limited applications of exposed thermal insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered. Essential safety functions are maintained and capable of being performed.

The forms in which the thermal insulation materials are installed and the conditions anticipated meet the intent of the revised limited combustible material definition because the materials used at SNC have a flame spread rating of 25 or less and will not support continued progressive combustion. The selection and application of thermal insulation material is controlled per the SNC design change process.

The Fire PRA development requires the inclusion of the effect of intervening or secondary combustibles to be documented and included in the analysis where determined to have fire effects as part of the performance based approach. SNC fleet procedures which govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.

The use of insulation material other than non-combustible and more than limited combustible has no impact on the radiological release performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing or potentially containing radioactive materials and is not dependent on the type of thermal insulation material.

E1-4 to NL-18-0668 Basis for Proposed Change The insulation material, regardless of heat contribution value, does not change the radiological release evaluation performed which concluded that potentially contaminated water is contained and smoke is monitored. The insulation materials do not add additional radiological materials to the area or challenge systems boundaries.

3.4 Future Installations Future installations of insulation materials are controlled by the Plant Modifications and Engineering Change Control process, which requires the performance of an NFPA 805 Fire Protection Program Change Impact Screening. This process includes a screening requirement for insulation material to be noncombustible or limited combustible material.

Insulation materials that do not meet this screening criteria require a Fire Protection Program Change Evaluation.

3.5 Conclusion The use of thermal insulation materials that do not meet the limited combustible criteria of NFPA 805 has been previously approved and the basis for the previous approval remains valid.

SNC has determined that the approach satisfies the following criteria:

• Meets the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release;

• Maintains safety margin; and,

• Maintains fire protection defense-in-depth (i.e., fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

The change to the FNP Renewed FOLs are administrative in nature. The proposed change does not result in any physical changes in the plants or in any plant equipment nor in any changes to FNP NFPA 805 program procedures. No changes will be made to any of the previously evaluated NFPA 805 program modifications previously approved by the NRC .

4.0 Regulatory Evaluation 4.1 No Significant Hazards Consideration The proposed change will allow certain polyisocyanurate and foam thermal insulation materials which are currently installed on miscellaneous system piping at FNP, Units 1 and 2, to be retained, and to allow future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls. The foam is installed for safety applications and for anti-sweat applications for HVAC systems. An evaluation of these materials has determined they do not contribute appreciably to the spread of fire, nor represent a secondary combustible beyond those currently analyzed in the Fire Probabilistic Risk Analysis (PRA) due to the limited applications where these materials are installed. SNC is requesting this license amendment pursuant to 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.90.

E1-5 to NL-18-0668 Basis for Proposed Change SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No.

The proposed change does not 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 change is administrative in nature and does not affect the ability of structures, systems and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed amendment does not involve a physical change to the containment or spent fuel area systems, nor does it change the safety function of the containment, containment purge and exhaust ventilation system, penetration room filtration system, or associated instrumentation.

Therefore, it is concluded that these proposed changes do not involve a significant increase in the probability of consequences of an accident previously evaluated.

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

Response: No.

There is no risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) because this is an administrative change. Plant secondary combustibles, including insulating materials, are considered in the fire modeling input to the Fire PRA.

With respect to a new or different kind of accident, there are no proposed design changes to the safety related plant SSCs nor are there any changes in the method by which safety related plant SSCs perform their safety functions. The proposed change does not result in any new or different kinds of accidents from those previously evaluated because it does not change any precursors or equipment that is previously credited for accident mitigation.

The proposed amendment will not affect the normal method of plant operation or revise any operating parameters. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this proposed change and the failure modes and effects analyses of SSCs important to safety are not altered as a result of this proposed change. The proposed amendment does not alter the design or performance of the related SSCs, and, therefore, does not constitute a new type of test.

No changes are being proposed to the procedures that operate the plant equipment and the change does not have a detrimental impact on the manner in which plant equipment operates or responds to an actuation signal.

E1-6 to NL-18-0668 Basis for Proposed Change Therefore, the proposed change will not create the possibility of a new or different accident than previously evaluated.

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

Response: No.

The margin of safety is related to the ability of the fission product barriers to perform their design functions during and following an accident. These barriers include the fuel cladding, the reactor coolant system, and the containment.

Instrumentation safety margin is established by ensuring the limiting safety system settings (LSSSs) automatically actuate the applicable design function to correct an abnormal situation before a safety limit is exceeded. Safety analysis limits are established for reactor trip system and ESF actuation system instrumentation functions related to those variables having significant safety functions. The proposed change does not alter the design of these protection systems; nor are there any changes in the method by which safety related plant SSCs perform their specified safety functions.

The limited installations of the insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed and considered. Essential fire protection safety functions are maintained and are capable of being performed. Because the insulation materials do not compromise post-fire safe shutdown capability as previously designed, reviewed and considered, it is concluded that this change does not involve a significant reduction in a margin of safety.

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.

4.2 Applicable Regulatory Requirements/Criteria By letter dated March 10, 2015, the NRC issued a license amendment approving the transition of the fire protection licensing basis for FNP, Units 1 and 2, to NFPA Standard 805.

Paragraph (2) of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, describes exceptions and modifications to the NRC's requirements regarding use of NFPA 805.

10 CFR 50.48(c)(2)(vii) states that performance-based methods may be used for fire protection program elements and minimum design requirements, subject to being submitted to the NRC in the form of a license amendment request under 10 CFR 50.90.

NFPA 805 Section 3.3.4 states:

Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

E1-7 to NL-18-0668 Basis for Proposed Change NFPA 805 Section 1.6.36 has re-defined earlier definitions of non-combustible material to the now current definition of limited combustible material:

Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btullb (8141 kJ/kg) and either has a structural base of noncombustible material with a surfacing not exceeding a thickness of 1/8 in. (3.2 mm) that has a flame spread rating not greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.

The definition of a limited combustible in NFPA 805 now includes requirements for materials to have a heat of combustion less than 3,500 BTU/lb.

In several areas at FNP, exposed thermal insulation materials are installed on various HVAC system piping to prevent sweating. These materials are also used in safety applications.

Although these materials comply with the flame spreading rating of 25 or less, these materials do not meet the definition of a limited combustible due to the heat value exceeding 3,500 BTU/lb. In lieu of replacing these insulation materials, and to allow future use of these materials in selected applications, SNC is requesting this license amendment pursuant to 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.90.

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.

6.0 References

1. National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805)

2. NRC Branch Technical Position CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," dated July 1981 E1-8

Joseph M. Farley Nuclear Plant Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material Enclosure 2 Plant Farley Operating License Mark-up and Clean Typed Pages

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.r - - - - - - - - - - ,

December 14, 2018;

i. Deleted per Amendment 152 (4) Fire Protection Southern Nuclear Operating Company shall implement and mai tain in effect all provisions of the approved fire protection program that amply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the I ensee amendment requests dated September 25, 2012; Apri125, 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, aR1 November 1, 201 . Except where NRC approval for changes or deviations i quired by 10 CFR 50.48(c), and provided no other regul * , technical specification, license condition or requirement would r 1re prior NRC approval, the licensee may make changes to the fire

,and [INSERT DATE]

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. ~

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; Apri125, 2016; December 14, 2018; 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, November 1, 2017, and [INSERT DATE]. 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.

December 14, 2018 ;

(6) Fire Protection Southern Nuclear Operating Company shall implement and rna tain in effect all provisions of the approved fire protection program that amply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the li ensee 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, October 17, 2016, afHi November 1, 2017.

Except where NRC approval for changes or deviations is requir by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require pri r NRC approval, the licensee may make changes to the fire protectio program without prior approval of the Commission if those changes sati fy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), he change does not require a change to a technical specification or a lie nse condition, and the criteria listed below are satisfied .

a.

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 o-changes that result in a risk increase less than 1x1 7/year (yr) for CDF and less than 1x1 o-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Farley- Unit 2 Renewed License No. NPF-8 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; April 25, 2016; December 14, 2018; 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, November 1, 2017, and [INSERT DATE]. 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 o-changes that result in a risk increase less than 1x1 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.

Joseph M. Farley Nuclear Plant Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material Enclosure 3 Farley NFPA 805 LAR Attachment A, Table B Mark-up Pages

Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requlrements_l_Guld_;m"~- ~tatement Compliance Basis PROC, FNP-0-AP-8.0 Rev. 48.0 [Appendix D]- Design Modification Control PROC, NMP-MA-011 Rev. 4 - Nuclear Coatings Program PROC, NMP-MA-011-GL01 Rev. 1 -Guideline for Nuclear Coatings Program 3.3.4 Insulation Materials 3.3.4 Insulation Materials. Complies Thermal insulation materials are addressed in specification Thermal insulation materials, radiation shielding materials, ventilation duct . "th SS110909, Section 3.6, which states that "insulation material, materials, and soundproofing materials shall be noncombustible or limited C Omp I18S WI including adhesives, shall have a flame spread rating of25 or combustible. NRC less and be impervious to oil when the insulation is placed in areas subject to oil contamination. Also, the smoke development Approval rating should be no higher than 50. Insulation material shall be

---'-'--------'UL listed."

Temporary shielding materials are addressed in procedure FNP-0-RCP-15, Section 3.9.2 which states to "consider transient fire load analysis for combustible materials associated with shielding packages."

Duct external insulation wrap and internal acoustical insulation are addressed in Specification SS-1102-054. This specification Thermal anti-sweat insulation previously installed in the plant does not requires that the materials meet NFPA 90A Standards and have a UL and/or FM label rated for a 25 or less flame spread .

meet the definition of noncombustible or limited combustible. All new thermal anti-sweat insulation beyond thermal ductwork material for ~mplementation Item: Plant documentation will be updated to address this design requirement for permanent shielding safety hazards or condensation on ductwork will meet the required material or sound proofing materials (other than acoustical duct noncombustible or limited combustible definitions. insulation).

See Implementation Item in Table S-3 of Attachment S.

References DocumentiD PROC, FNP-0-RCP-15 Rev. 38 [Section 3.9.2] - Temporary Shielding PROC, SS1102054 Rev. 24 [Section 6.3.6]- Containment and Engineered Safeguard and Plant HVAC Systems Ductwork for FNP 1 & 2 PROC. SS110909 Rev. 36 [Section 3.6]- Specification for Thermal Insulation for Piping and Equipment for Farley Nuclear Plant- Units 1 & 2 Open Item ID 3.3.4 Description Plant documentation will be updated to address this design requirement for permanent shielding material or sound proofing materials (other than acoustical duct insulation).

Date Entered Disposition Open Yes Fire Safety Analysis Data Manager (4.1) Farley Run: 08/30/2012 16:55 Page: 11 of 49

Joseph M. Farley Nuclear Plant Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material Enclosure 4 NFPA 805 LAR Attachment A, Table B-1 -Clean Typed Pages

Attachment A NEI 04-02 Table 8-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements I GUidance Statement Compliance Basis PROC, FNP-0-AP-8.0 Rev. 48.0 [Appendix D) - Design Modification Control PROC, NMP-MA-011 Rev. 4 - Nuclear Coatings Program PROC, NMP-MA-011-GL01 Rev. 1- Guideline for Nuclear Coatings Program 3.3.4 Insulation Materials 3.3.4 Insulation Materials. Complies with Thermal insulation materials, radiation shielding materials, ventilation duct NRC Approval Thermal Insulation materials are addressed in specification SS110909, materials, and soundproofing materials shall be noncombustible or limited Section 3.6, which states that 'insulation material including adhesives, combustible. shall have a flame spread rating of 25 or less and be impervious to oil when the insulation is placed in areas subject to oil contamination.

Also, the smoke development rating should be no higher than 50.

Insulation material shall be UL listed. *,

Temporary shielding materials are addressed in procedure FNP RCP-15, Section 3.9.2 which states to 'consider transient fire load analysis for combustible materials associated with shielding packages."

Duct external insulation wrap, and internal acoustical insulation are addressed in Specification SS-11 02-054. This specification requires that the materials meet NFPA 90A Standards and have a UL and/or FM label rated for a 25 or less flame spread.

Thermal anti-sweat insulation previously installed in the plant does not meet the definition of noncombustible or limited combustible. All new thermal anti-sweat insulation beyond thermal ductwork material for safety hazards or condensation on ductwork will meet the required noncombustible or limited combustible definitions.

Implementation Item: Plant documentation will be updated to address this design requirement for permanent shielding material or sound proofing materials (other than acoustical duct insulation).

See Implementation Item in Table S-3 of AttachmentS.

References Document ID PROC, FNP-0-RCP-15 Rev. 38 [Section 3.9.2)- Temporary Shielding PROC, SS1102054 Rev. 24 [Section 6.3.6]- Containment and Engineered Safeguard and Plant HVAC Systems Ductwork for FNP 1 & 2 PROC, SS110909 Rev. 36 (Section 3.6)* Specification for Thermal Insulation for Piping and Equipment for Farley Nuclear Plant- Units 1 & 2 Open Item ID 3.3.4 Description Plant documentation will be updated to address this design requirement for permanent shielding material or sound proofing materials (other than acoustical duct insulation).

Date Entered D isposition Open Yes Fire Safety Analysis Data Manager (4.1) Farley NL-18-0668 LAR revision Page: 11 of 49