ND-19-0666, Report of 10 CFR 50.59 Changes, Tests and Experiments and 10 CFR 52 Appendix D Departure Report

Report of 10 CFR 50.59 Changes, Tests and Experiments and 10 CFR 52 Appendix D Departure Report

ML19161A362
Person / Time
Site:	Vogtle
Issue date:	06/10/2019
From:	Aughtman A Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0666
Download: ML19161A362 (65)

Text

Southern Nuclear Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 June 10, 2019 Docket Nos.: 52-025 ND-19-0666 52-026 10 CFR 50.59 10 CFR 52 App. D U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 6RXWKHUQ1XFOHDU2SHUDWLQJ&RPSDQ\

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Ladies and Gentlemen:

This submission is made with regard to the Vogtle Electric Generating Plant (VEGP), Units 3 and 4, Combined License (COL) numbers NPF-91 and NPF-92, in accordance with the reporting requirements of 10 CFR 50.59(d)(2) and 10 CFR 52, Appendix D, paragraphs X.B.1 and X.B.3.b.

In accordance with VEGP 3&4 COL License Condition 2.D.(13)(b)2, included in this submission is a departure UHSRUWfrom Tier 2* information that was evaluated against the requirements for Tier 2 departures in 10 CFR Part 52, Appendix D, Paragraph VIII.B.5, as modified by the exemption in License Condition 2.D.(13)(a) and therefore does not require prior NRC approval under the exemption in License Condition 2.D.(13)(a).

For the period of November 11, 2018 through May 10, 2019, there were no changes, tests or experiments made pursuant to paragraph (c) of 10 CFR 50.59. provides the report containing a brief description of plant-specific departures, including a summary of the evaluation of each, as required by 10 CFR 52, Appendix D, paragraphs X.B.1 and X.B.3.b, for the period of November 11, 2018 through May 10, 2019. provides the report containing a brief description of the departure from Tier 2*

information that does not require prior NRC approval under the exemption in License Condition 2.D.(13)(a) and a summary of the evaluation of the departure, as required by License Condition 2.D.(13)(b)2 for the period of November 11, 2018 through May 10, 2019.

This letter makes no regulatory commitments. If you have questions, please contact Ms. Yasmeen Arafeh at 205-992-7190.

U.S. Nuclear Regulatory Commission ND-19-0666 Page 2 of4 Respectfully submitted, Ci~~~

Licensing Manager, Regulatory Affairs Southern Nuclear Operating Company Enclosures 1) VEGP Units 3 and 4, Departure Report for the Period of November 11, 2018 through May 10, 2019

2) VEGP Units 3 and 4, Tier 2* Departure Report for the Period of November 11, 2018 through May 10, 2019

U.S. Nuclear Regulatory Commission ND-19-0666 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)

Mr. 5*:HVW (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)

Mr. T. W. Yelverton (w/o enclosures)

Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. Blythe Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn

U.S. Nuclear Regulatory Commission ND-19-0666 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. T. Rubenstein (w/o enclosures)

Mr. M. Corletti Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-19-0666 Enclosure 1 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 (57 pages, including this cover page)

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2014-096 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PCCAWST Volume Surveillance Requirement Clarification Brief Description of the Plant-Specific Departure:

This activity changes the minimum volume of the passive containment cooling ancillary water storage tank (PCCAWST).

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 2 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2015-065 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PMS Valve Control Logic Clarification Brief Description of the Plant-Specific Departure:

This activity made changes to align normal control of the Passive Residual Heat Removal (PRHR) inlet isolation valve and Core Makeup Tank (CMT) balance line isolation valves to the Plant Control System (PLS). Signal prioritization for the safety opening of the valves is being revised to be performed within the Component Interface Module (CIM).

This departure resulted in changeV to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

ThLV departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.

Page 3 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2017-142 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Change to IRWST Loads in UFSAR Table 3.8.3-7 Brief Description of the Plant-Specific Departure:

This activity made changes to include revised mechanical and mechanical plus thermal loads for the west wall of the in-containment refueling water storage tank (IRWST).

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

ThLV departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.

Page 4 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2017-158 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 147 Unit 4 Amendment No.: 146 Departure

Title:

Containment Pressure Analysis (LAR-17-043)

Brief Description of the Plant-Specific Departure:

This activity made changes to the containment integrity analyses to reflect accumulated design changes which necessitated recalculation of geometry input to the WGOTHIC evaluation model (EM). Heat sinks, control volumes, and flow paths were recalculated, and in turn modeled in the WGOTHIC EM, mass and energy (M&E) releases for Loss of Coolant Accident (LOCA) and Main Steam Line Break (MSLB) events were recalculated and various methodology changes were made to the WGOTHIC methodology for the AP1000 design.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD), COL Appendix A Technical Specifications, and COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information, COL Appendix A Technical Specifications, COL Appendix C ITAAC, and UFSAR Tier 2 information that involved changes to Tier 1 (and associated COL Appendix C) and COL Appendix A Technical Specifications; therefore, a License Amendment and Exemption Request (LAR-17-043) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 147 and 146 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 5 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-013 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Updates to Hydrogen Switchover Station Brief Description of the Plant-Specific Departure:

This activity made changes to describe the flow path of hydrogen from the Plant Gas System (PGS) to the Chemical and Volume Control System (CVS) hydrogen injection package located in the turbine building, through the auxiliary building and into containment for injection into the Reactor Coolant System (RCS). Assessments of the potential for hydrogen explosion in the auxiliary building and containment are added. This activity makes changes to separately list the sources of pressurized gaseous hydrogen at the PGS hydrogen switchover station and the spare hydrogen cylinders, and to identify their explosion safe minimum distance and the AP1000 distance to systems, structures, and components (SSC). This activity makes changes to increase the evaluated maximum quantity of hydrogen gas.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 6 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-059 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Preservice Testing Program Brief Description of the Plant-Specific Departure:

This activity is the establishment of the initial Vogtle 3&4 Preservice Test Program Plan (Version 1.0) and the UFSAR changes to support its establishment.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 7 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-073 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Graded Approach, Organizational Updates, Prerequisite Clarification and Consistency Changes for the Initial Test Program Brief Description of the Plant-Specific Departure:

This activity made changes to the Initial Test Program (ITP) to incorporate a graded approach to testing based on the safety significance of the SSC being tested. This activity also corrected licensing basis inconsistencies and a prerequisite clarification.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 8 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-074 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Turbine Bypass Valve Pressure Testing Brief Description of the Plant-Specific Departure:

This activity made changes to the leaktightness confirmation method from a hydrostatic pressure test to an initial service test for the turbine bypass system piping. This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 9 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-084 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 152 Unit 4 Amendment No.: 151 Departure

Title:

RNS Pump Testing ITAAC Changes (LAR-18-016)

Brief Description of the Plant-Specific Departure:

This activity made changes to the normal residual heat removal system (RNS) ITAAC by revising the acceptance criteria for flow testing of low-pressure makeup from the cask loading pit (CLP) to the reactor coolant system (RCS), and by clarifying the method and acceptance criteria for single and dual RNS pump testing at reduced inventory.

This departure resulted in changes to Tier 1 (plant-specific DCD) and COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information and COL Appendix C ITAAC; therefore, a License Amendment and Exemption Request (LAR-18-016) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 152 and 151 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 10 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-094 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 155 Unit 4 Amendment No.: 154 Departure

Title:

Reactor Coolant System (RCS) Flow Coastdown (LAR-18-025)

Brief Description of the Plant-Specific Departure:

This activity made changes to reflect the full power safety analysis reactor coolant system flow coastdown curve. Related changes were made to text, tables, and figures for multiple UFSAR non-LOCA post-Core Reference Report (CRR) safety analyses to incorporate accumulated design debt into the licensing basis.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-025) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 155 and 154 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 11 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-096 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Connections for Post-72 Hour FLEX Equipment Brief Description of the Plant-Specific Departure:

This activity made changes to include the addition of a manually operated non-safety related transfer switch upstream of the safety-related voltage regulating transformers for the Class 1E DC and UPS System (IDS) Divisions B and C, clarify the two ways to electrically feed the safety-related voltage regulating transformer and show new locations for voltage regulating transformer alignment and additional pathways the operator could take in a post-accident scenario.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 12 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-108 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Valve-Live Load Packing Changes Brief Description of the Plant-Specific Departure:

This activity made changes to clarify the extent to which live loaded packing and other packing configurations are used to prevent valve stem leakage in the AP1000 design.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 13 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-109 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 156 Unit 4 Amendment No.: N/A Departure

Title:

Column Line 1 Wall Reinforcement Area Change (LAR-18-026)

Brief Description of the Plant-Specific Departure:

The activity made changes to the total area of steel reinforcement in Vogtle Unit 3 column line 1 wall (Wall 1).

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This departure made changes to UFSAR Tier 2* information that qualified as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a), and to the VEGP Units 3 and 4 COLs; therefore, a License Amendment Request (LAR-18-026) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendment 156 to COL NPF-91 for VEGP Unit 3.

Page 14 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-110 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

ALARA Compliance with Licensing Requirement for Highly Radioactive Equipment Drain/Vent Brief Description of the Plant-Specific Departure:

This activity made changes to the design of systems that are highly radioactive when in use, to allow infrequently used vents and drains from these highly radioactive systems to be directed to the collection system by temporary tubing.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 15 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-112 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Resolution of Inconsistencies Introduced in LDCR-2017-115 Brief Description of the Plant-Specific Departure:

This activity made editorial changes to accident source strength information to resolve editorial inconsistencies that were introduced in the licensing basis markups from previous SNC License Amendment Request /$5 .

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 16 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-116 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Valve Mission Times Brief Description of the Plant-Specific Departure:

This activity made changes to align the licensing basis with design documentation related to containment isolation valve mission times and Potable Water System (PWS) Main Control Room (MCR) isolation valve environmental zone designations. Inconsistencies were resolved within the licensing basis by adding containment vessel hatches, manual isolation valves, spent fuel transfer, and spent fuel cask loading pit gates to the environmentally qualified electrical and mechanical equipment table and by adding the spent fuel transfer and spent fuel cask loading pit gates to the seismic category 1 equipment outside containment by room number table.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 17 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-117 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Consistency and Editorial Changes - Chapter 1 and Associated Chapters Brief Description of the Plant-Specific Departure:

This activity made changes to include subsection cross-reference updates, clarifications to improve readers understanding, descriptions/summaries of exceptions related to Regulatory Guides (RGs) 1.142 and resolutions to inconsistencies within the licensing basis and with AP1000 design documentation.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 18 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-123 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 158 Unit 4 Amendment No.: 156 Departure

Title:

Editorial and Consistency Changes (LAR-18-027)

Brief Description of the Plant-Specific Departure:

This activity made editorial and consistency changes within the licensing basis.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD), COL Appendix A Technical Specifications, and COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made Tier 2 information and related changes to the VEGP Units 3 and 4 COL, COL Appendix A Technical Specifications, and COL Appendix C (and corresponding plant-specific DCD Tier 1); therefore, a License Amendment and Exemption Request (LAR-18-027) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 158 and 156 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 19 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-125 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Change of Fire Protection in Turbine Building Brief Description of the Plant-Specific Departure:

This activity made changes to nonsafety-related smoke control and fire protection design features in the turbine building to align the UFSAR (plant-specific DCD) to the as-designed fire protection and turbine building ventilation systems.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 20 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-126 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 157 Unit 4 Amendment No.: 155 Departure

Title:

Clarification of ASME Code Section III Compliance and Alternative Requirements for ASME Section III Pressure Tests Conducted Following the Completion of ASME Section III Construction Activities (LAR-18-031)

Brief Description of the Plant-Specific Departure:

This activity provides an alternative to the requirements of ASME Section III, NB-6221(a), NC-6221(a), and ND-6221(a) of the ASME Boiler and Pressure Vessel (B&PV) Code, 1998 Edition through the 2000 Addenda (code of record) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The alternative will allow pressure testing that occurs following completion of ASME Section III construction activities to be performed in accordance with ASME Section XI. Tier 1 (and COL Appendix C) Section 1.2 is clarified to allow the use of NRC approved code alternatives as meeting a specific Design Commitment or ITAAC.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-031) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 157 and 155 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 21 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-127 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Breaker Redesignation for the Fourth Circulating Water Pump Brief Description of the Plant-Specific Departure:

This activity made changes to re-designate the spare breaker on switchgear to be used for the fourth Circulating Water System (CWS) pump.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 22 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-129 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Change to Pre-Operational Test Conditions for the AP1000 Secondary Sampling System Brief Description of the Plant-Specific Departure:

This activity made changes to the Secondary Sampling System (SSS) preoperational test description prerequisites and general test method and acceptance and functional criteria to reflect that testing is performed using preoperational pressure and temperature.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 23 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-130 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Enhanced RCP Thrust Bearing Protection from Thermal Transients Brief Description of the Plant-Specific Departure:

This activity made a design change that adds lead-lag compensation to the Reactor Coolant Pump (RCP) High-2 bearing water temperature reactor and RCP trip. Also, a note was added to the manual initiation of auxiliary spray isolation actuation signal in UFSAR Table 7.3-1 to indicate that this function does not meet the criteria of 10 CFR 50.36(c)(2)(ii). Finally, this activity corrected terminology associated with reactor trip logic, as blocks are automatically reset when the specified process permissives are met instead of stating that reactor trips are automatically reset.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 24 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-131 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Incorrect Functions of the Switchboards Indicated Brief Description of the Plant-Specific Departure:

This activity revised the nomenclature for battery charger IDSB-DC-1 and clarified the functions of the Class 1E battery chargers serving the 24-hour battery banks to achieve consistency within the licensing basis

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 25 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-132 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to VES Relief Valve Vent Piping Brief Description of the Plant-Specific Departure:

This activity made changes to the Main Control Room Emergency Habitability System (VES) air storage bottle relief valve discharge, in which the piping is extended to the roof of the Auxiliary Building and the piping class was changed to Class D after exiting the roof. Additionally, a requirement was added for Fire Zone 1250 AF 12555 that will not allow permanent storage of combustibles in Room 12555. This activity also reduced the amount of cable insulation in Fire Zone 1250 AF 12555.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 26 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-133 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Corrections to the Local Leak Rate Test Direction for Relief Valves at Containment Penetrations Brief Description of the Plant-Specific Departure:

This activity made changes to add Nitrogen (N2) as a testing medium for all containment penetration leak rate tests (Type B) and containment isolation valve leak rate tests (Type C).

This activity also changed the normal position of select valves to open. Additionally, the testing directions for several valves were changed to the reverse testing direction.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 27 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-136 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Clarifications to Fuel Load Technical Specification Bases and Signal Compensation Brief Description of the Plant-Specific Departure:

This activity made a change to the signal compensation in the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS).

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

That portion of the departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.

Page 28 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-137 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Figure 9.4.1-1 to address inconsistencies with VBS P&IDs Brief Description of the Plant-Specific Departure:

This activity made changes to the nuclear island nonradioactive ventilation system (VBS) to perform the design function to serve the main control room (MCR), control support area (CSA),

Class 1E dc equipment rooms, Class 1E instrumentation and control (I&C) rooms, Class 1E electrical penetration rooms, Class 1E battery rooms, remote shutdown room, reactor coolant pump trip switchgear rooms, adjacent corridors, and the passive containment cooling system (PCS) valve room during normal plant operation and resolve editorial corrections and inconsistencies.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

That portion of the departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.

Page 29 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-138 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Alternative Requirements for Repair of N-Stamped Class 1, 2, and 3 Components Brief Description of the Plant-Specific Departure:

This activity added ASME Code Cases N-801 and N-802 as acceptable Code Cases in UFSAR (plant-specific DCD) Table 5.2-3 to allow flexibility for repairs of previously stamped components. Additionally, a note was added to reflect Code Cases N-801 and N-802 are acceptable per Reg. Guide 1.84 Revision 37.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

ThLV departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.

Page 30 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-139 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 149 Unit 4 Amendment No.: 148 Departure

Title:

Passive Core Cooling System Gutter Drain Line Vents (LAR-18-022)

Brief Description of the Plant-Specific Departure:

This activity made changes to reflect added vents in the redundant drain piping between the passive core cooling system (PXS) collection boxes and the in-containment refueling water storage tank (IRWST) to improve the condensate return flow rate.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-022) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 149 and 148 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 31 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-140 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Process Measurements in PSS Brief Description of the Plant-Specific Departure:

This activity made changes to provide a complete listing of the specific chemistry process measurement points that require sampling, analysis, evaluation, or corrective action when necessary to maintain chemistry control within the specified AP1000 standard plant design.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 32 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-001 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Addition of Relief Valves to ASME Section VIII Pressure Vessels Brief Description of the Plant-Specific Departure:

This activity revised the overpressure protection design for the spent fuel pool cooling system (SFS) heat exchangers, SFS demineralizers, SFS low pressure cartridge filters, and component cooling water system (CCS) heat exchangers are made to provide dedicated relief valves for these pressure vessels. This activity also relocated relief valves for several pressure vessels in the liquid radwaste system (WLS) to areas of lower dose for personnel dose reduction during maintenance and testing activities. Additionally, a number of relief valves are changed from welded to flanged connections to facilitate maintenance and testing, and relief valve discharge lines are added where feasible.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 33 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-002 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Removal of Division D MCR Isolation Brief Description of the Plant-Specific Departure:

This activity made changes to the divisions provided with system-level manual input for the main control room isolation, air supply initiation, and electrical load de-energization engineered safety feature actuations.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 34 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-004 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Inconsistencies for Principal Construction Code and Licensing Basis for the AP1000 Plant Spent Fuel Pool Weir Gates Brief Description of the Plant-Specific Departure:

This activity made clarifications to the principal construction code for the structural and non-structural components in the Spent Fuel Transfer Gate and the Spent Fuel Cask Loading Pit Gate. Additionally, an exception was added to reflect that Manufacturer's Standard may be used in lieu of Section III, Class 3 for Class C Fuel Handling System (FHS) weir gate pressure boundary components containing only compressed air.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 35 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-005 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 151 Unit 4 Amendment No.: 150 Departure

Title:

Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019)

Brief Description of the Plant-Specific Departure:

This activity made changes to credit the performance of three preoperational tests: The In-Containment Refueling Water Storage Tank (IRWST) Heatup Test; the Reactor Vessel Internals Vibration Testing; and the Core Makeup Tank Heated Recirculation Tests performed on currently operating AP1000 power reactor facilities in lieu of performing the tests at VEGP 3&4.

The ITAAC for reactor internal flow induced vibration testing was deleted and an editorial change was made to COL Appendix C to properly number sub-bullets.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD), and associated COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-019) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 151 and 150 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 36 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-007 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Identification of New PXS Instrumentation Line Break Brief Description of the Plant-Specific Departure:

This activity made changes to identify a new instrument line break and clarify the exceptions for consideration of small lines for leak-before-break (LBB) evaluation.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 37 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-008 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Battery Room 40412 Exhaust Fan Static Pressure Brief Description of the Plant-Specific Departure:

This activity made changes to increase the pressure drop of the Battery Room 40412 Exhaust Fan due to a design change that increased the system flowrate to account for additional heatloads in the room.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 38 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-010 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 154 Unit 4 Amendment No.: 153 Departure

Title:

Administrative Changes to Align Initial Test Program with Regulatory Guide 1.68 (LAR-18-024)

Brief Description of the Plant-Specific Departure:

This activity made changes to remove component testing as a phase of the Initial Test Program (ITP) and preoperational and startup test specifications from the ITP.

This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD), and COL Appendix C ITAAC.

Summary of the Evaluation:

This departure made changes to Tier 2 information and related changes to the VEGP Units 3 and 4 COL and COL Appendix C (and corresponding plant-specific DCD Tier 1); therefore, a License Amendment and Exemption Request (LAR-18-024) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 154 and 153 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 39 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-011 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Section 7.7 Control System Changes Brief Description of the Plant-Specific Departure:

This activity made changes to clarify the design descriptions of the rod control system, the rapid power reduction system, the steam dump control system and the feedwater control system. In addition, this activity made an editorial change to several subsections and tables within the UFSAR. This activity also involved a change to resolve an inconsistency in the UFSAR that was created in a previous design change.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 40 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-012 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Feedwater/CVS Isolation Logic Deficiency - Undesirable Isolation of SFW and CVS During SG Fill-Up Brief Description of the Plant-Specific Departure:

This activity added divisional blocking logic enabling a manual block to prevent unnecessary startup feedwater system (SFW) and chemical and volume control system (CVS) isolation resulting from High (Narrow-Range) steam generator (SG) level in conjunction with the P-4 permissive as well as unnecessary SFW isolation, CVS isolation, PDLQIHHGZDWHU MFW isolation, and turbine trip signals resulting from a High-3 (Narrow-Range) SG level occurring when the average reactor coolant temperature is below 200° F to allow for temporary flooding of the steam generator for maintenance and inspection.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 41 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-013 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to RCS/PXS Valve Position Indication Alarms Brief Description of the Plant-Specific Departure:

This activity made changes to the failure detection method for multiple valves in the Passive Core Cooling System (PXS)/Reactor Coolant System (RCS) to align with the plant design.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 42 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-015 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to GSS Control Valve, CFS Motor Speed Controllers, and MSS Flows After Steam Line Isolation Brief Description of the Plant-Specific Departure:

This activity made changes to indicate where the Gland Seal System (GSS) excess steam flow is discharged to, to update the maximum steam flow from the main steam supply 066 to the auxiliary steam system and from the main steam supply to the turbine glands, and to update the operation of the turbine island Chemical Feed System (CFS) chemical feed rates to include automatic adjustment.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 43 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-017 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Primary Sampling System Gaseous Sample Radiation Monitor Brief Description of the Plant-Specific Departure:

This activity involved changing the detection concept of the primary sampling system (PSS) gaseous sample radiation monitor from measuring the concentration of radionuclides in the sample line to measuring the radiation dose rate from the process line. In addition, an editorial change was made regarding the component numbers for two detectors.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 44 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-018 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Physical Separation Requirements for Fiber Optic Cables Brief Description of the Plant-Specific Departure:

This activity made changes to remove separation requirements for fiber optic cables when cable would normally be considered a source of a potential fire.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 45 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-020 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Mixed Resin Ion Exchange Vessel Licensing Requirement Brief Description of the Plant-Specific Departure:

This activity deleted a requirement in the UFSAR that the leachable sulphur from the rubber in the condensate polishing system (CPS) deep bed mixed resin polishers is less than 20 ppb.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 46 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-021 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to DAS Initiation Signals to DAS NTS Values Brief Description of the Plant-Specific Departure:

This activity made changes to initiation signal setpoint values for the Diverse Actuation System (DAS) automatic actuation initiation signals to the Nominal Trip Setpoint (NTS) value. This activity also added an explanation to describe that certain setpoint values are DAS nominal trip setpoints of digital systems determined using the setpoint methodology referenced in UFSAR.

This departure resulted in changes to Tier 2 portions of the Technical Requirements Manual (TRM).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 47 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-022 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Submergence Qualification Requirements Brief Description of the Plant-Specific Departure:

This activity made changes to the submergence qualification operability time in the environmentally qualified electrical and mechanical equipment table for valve limit switches required for post-accident monitoring system (PAMS) that could become submerged. This activity also made changes to the equipment post-accident operability times table to explain when required post-accident operability time for submergence qualification may differ from other qualification times.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 48 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-024 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Spurious Actuation of the Containment Recirculation Squib Valves Brief Description of the Plant-Specific Departure:

This activity made changes to clarify the description of what will occur in a beyond design basis event involving the inadvertent opening of a containment recirculation squib valve.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 49 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-026 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Refueling Cavity Gate Removal and UFSAR Figure 3.8.2-4 Sh 5 Details Brief Description of the Plant-Specific Departure:

This activity made changes to depict a bellows assembly adapter ring plate for bellows on the transfer canal end of the Fuel Transfer Tube (FTT) and a guard pipe adapter ring plate on the refueling cavity end of the FTT. Additionally, this activity removed reference to the refueling cavity gate from the fuel handling and reactor component servicing equipment test since it is no longer part of the design.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 50 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-027 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Licensing Basis Update for Steam Generator Design Parameters Brief Description of the Plant-Specific Departure:

This activity made changes to the steam generator mass flow rates for consistency with corresponding design data. This activity also made clarifications to the physical location where moisture carryover is specified within the steam generator. In addition, an editorial change was made to improve the presentation of the data changed in this activity.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 51 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-028 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Correction of WLS Description Inconsistency Between UFSAR Chapters 11 and 12 Brief Description of the Plant-Specific Departure:

The activity made changes to resolve an inconsistency between UFSAR (plant-specific DCD)

Subsection 11.2.1.2.4 and Subsection 12.1.2.4.1 regarding the location of valves, vacuum breakers and fittings of the liquid radwaste system (WLS) to address 10 CFR 20.1406, Minimization of Contamination.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 52 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-029 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PMS Bypass Capability (for non-2oo4 logic)

Brief Description of the Plant-Specific Departure:

This activity made changes to revise local coincidence logic (LCL) software to allow the software bypassing of non-two out of four (2oo4) engineered safety feature (ESF) functions.

This activity made changes to the descriptions of the Protection and Safety Monitoring System (PMS) ESF actuation signal bypass logic.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 53 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-030 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

B31.1 Postweld Heat Treatment Code Year Option Brief Description of the Plant-Specific Departure:

This activity revised the methods and acceptance criteria for Post Weld Heat Treatment (PWHT) to allow the use of ASME B31.1, 2014 Edition for AP1000 Equipment Classes D, F, and G.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 54 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-032 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Revised Valve Alignment for the Spent Fuel Pool Cooling System Brief Description of the Plant-Specific Departure:

This activity made changes to the normal operating positions of several spent fuel pool cooling system (SFS) valves to provide an overpressure relief path for sections of SFS piping which would otherwise contain an isolated volume of fluid and be subject to over pressurization during a loss of HVAC. This activity also revised the positions of several SFS valves to show the normal operating valve alignment of the system consistent with design documents and to identify that the pump suction side valve on the non-operating pumps is closed to prevent backflow through the non-operating train of SFS.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a SSC such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel sever accident assessment.

This departure did not involve a change to plant-specific Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D Section VIII screening determined that NRC approval is not required prior to implementing this departure.

Page 55 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-033 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

CVS Flow Control Scheme Brief Description of the Plant-Specific Departure:

This activity made changes to add a Plant Control System (PLS) control function to control the position of the Chemical and Volume Control System (CVS) letdown line outside containment isolation valve based on letdown temperature; and the purification return valve was changed to a locked open valve during normal power operation. This activity also made consistency changes to the Updated Final Safety Analysis Report (UFSAR).

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 56 of 57

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-035 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Clarification of Quality Assurance Requirements for Equipment Class R Brief Description of the Plant-Specific Departure:

This activity made administrative/consistency changes to align with Regulatory Guide 1.140 and design changes to the radwaste building HVAC system (VRS) and containment air filtration system (CFS) that incorporate a simplified design of the VRS and system specific design features for the VFS exhaust air filtration fan static pressure requirements.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.

Page 57 of 57

Southern Nuclear Operating Company ND-19-0666 Enclosure 2 VEGP Units 3 and 4 Tier 2* Departure Report for the Period of November 11, 2018 through May 10, 2019 (4 pages, including this cover page)

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2018-134 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Elevator Machine Room Removal Brief Description of the Plant-Specific Departure:

This activity made changes to the elevator type for several elevators in the plant to be a Machine Room-Less (MRL) traction elevator. Additional changes were made to the associated ventilation systems, fire protection analysis, fire detection method, room configurations and to remove or repurpose the associated elevator machine rooms. This activity also made clarifications to the discussion of fire detection capability, the description of the Shield Building elevator, and the effluent monitoring after a fire for areas that utilize portable exhaust fans and flexible ductwork. Additionally, this activity made changes to move the pressurization fan inside the envelope of stairwell S01. Finally, this activity made changes to the Annex/Auxiliary Building Non-Radioactive Ventilation System (VXS) Exhaust Plenum penetrations.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This departure included departures from Tier 2* information and changes to Tier 2 information in the UFSAR (plant-specific DCD). These Tier 2* changes and involved Tier 2 changes were evaluated using the qualifying criteria for Tier 2* Departure Evaluations, and it was determined that this activity did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a). This departure also involved additional Tier 2 changes that did not involve departures from Tier 2* material.

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

Page 2 of 4

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-006 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PMS Changes Related to the MTP DVD Drive, Cable Access Control, the FMEA, Component Level Control, and Nonsafety-related Interfaces Brief Description of the Plant-Specific Departure:

This activity made changes to the content of the protection and safety monitoring system (PMS)

Failure Modes and Effects Analysis (FMEA) (WCAP-16438) and associated documents that are incorporated by reference (IBR) into the plants licensing basis to provide a more clear and internally consistent analysis of failure modes of the major PMS components to demonstrate the AP1000 PMS ability to maintain safety functions during single point failures, and to relocate FMEA information to the appropriate design and licensing basis documents. This activity also makes changes to the content of the IBR documents addressing the licensing basis of the PMS by revising the maintenance and test panel (MTP) digital virtual disc (DVD) description from a DVD-ROM to a generic DVD drive, deleting statements indicating that the communication isolation does not apply to discrete hardwired signals, deleting bullets describing diverse actuation system (DAS) Manual engineered safety features (ESF) component-level control, and adding statements to address access control of fiber optic cabling between each of the equipment rooms and the main control room (MCR) by routing the cabling in enclosed raceway.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This departure included departures from Tier 2* information and changes to Tier 2 information in the UFSAR (plant-specific DCD) that involved these Tier 2* departures, including incorporated by reference documents. These Tier 2* changes and involved Tier 2 changes were evaluated using the qualifying criteria for Tier 2* Departure Evaluations, and it was determined that this activity did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a). This departure also involved additional Tier 2 changes that did not involve departures from Tier 2* material.

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

Page 3 of 4

ND-19-0666 VEGP Units 3 and 4 Departure Report for the Period of November 11, 2018 through May 10, 2019 Departure Number: LDCR-2019-009 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Reinforcement Configuration Change in Tagging Room Ceiling Brief Description of the Plant-Specific Departure:

The activity made changes to the top reinforcement in the cast-in-place concrete slab along the E-W direction, the bottom reinforcement in the cast-in-place concrete slab along the E-W direction in the Plan View of Floor EL. 135'-3", Sections C and F. This activity added a note to clarify the size, spacing, and splicing of top reinforcement in the cast-in-place concrete slab along N-S direction at the south wall of tagging room near column line 9, and also revises the annotation of the top reinforcement in the cast-in-place concrete slab along the N-S direction to reference said note.

This departure resulted in changes to the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This departure included departures from Tier 2* information. These Tier 2* changes were evaluated using the qualifying criteria for Tier 2* Departure Evaluations, and it was determined that this activity did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a).

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

Page 4 of 4