ND-18-1504, 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

ML18341A340
Person / Time
Site:	Vogtle
Issue date:	12/07/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-18-1504
Download: ML18341A340 (85)

Text

Brian H. Whitley Southern Nuclear Director Operating Company, Inc.

Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 December 7, 2018 Docket Nos.: 52-025 ND-18-1504 52-026 10 CFR 50.59 10 CFR 52 App. D U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Report of 10 CFR 50.59 Changes, Tests and Experiments and 10 CFR 52 Appendix D Departure Report 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 from 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 May 11, 2018 through November 10, 2018, 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 May 11, 2018 through November 10, 2018. 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 May 11, 2018 through November 10, 2018.

This letter makes no regulatory commitments. If you have questions, please contact Ms. Jerri Byers 205-992-5742.

U.S. Nuclear Regulatory Commission ND-18-1504 Page 3 of 4 cc:

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

Mr. D. G. Bost (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 Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. E. Riffle Ms. K. Roberts 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-18-1504 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. C. Churchman (w/o enclosures)

Mr. M. Corletti Mr. M. L. Clyde 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-18-1504 Enclosure 1 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 (79 pages, including this cover page)

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2015-019 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to Thermal Expansion, Dynamic Effects, and Vibration Testing Program ASME Code Reference Brief Description of the Plant-Specific Departure:

This activity changes the code reference for the Thermal Expansion, Dynamic Effects and Vibration (TEDEV) preoperational testing program from the ANSI/ASME OM Code-1995 and 1996 Addenda to the ASME OM-S/G-2000 Code.

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 evaluation determined that NRC approval was not required prior to implementing this departure.

Page 2 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2016-159 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 129 Unit 4 Amendment No.: 128 Departure

Title:

Ventilation System Changes (LAR-16-030R1)

Brief Description of the Plant-Specific Departure:

This activity makes changes to the configuration of the containment recirculation fan coil unit assemblies of the containment recirculation cooling system (VCS), and revising the values for the various design parameters affected by this reconfiguration; adding a fourth pressure differential indicator to the VAS to be located in the auxiliary building component cooling system valve room; reducing the total ventilation flow provided through the VAS fuel handling area ventilation subsystem as a result of a reduction in heat loads in the areas serviced by the VAS and updating the radionuclide specific maximum airborne radioactivity concentrations in the auxiliary building, including the fuel handling area, to reflect the changes in ventilation flow rates as well as other input assumptions.

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 involved changes to Tier 1 information, Tier 2 information and associated COL Appendix C ITAAC; therefore, a License Amendment and Exemption Request (LAR-16-030R1) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 129 and 128 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 3 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-051 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 121 Unit 4 Amendment No.: 120 Departure

Title:

Class 1E Motor-Operated Valve Terminal Voltage Testing (LAR-17-018)

Brief Description of the Plant-Specific Departure:

This activity changes the ITAAC associated with verification of the acceptability of the voltage drop across applicable Class 1E dc and Uninterruptible Power Supply System (IDS) circuits supplying power to Class 1E powered motor-operated valves (MOVs) to provide the necessary verification that demonstrates that adequate voltage is provided to each MOV to support operation.

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 involved changes to Tier 1 information, Tier 2 information and associated COL Appendix C ITAAC; therefore, a License Amendment and Exemption Request (LAR-17-018) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 121 and 120 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 4 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-099 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 126 Unit 4 Amendment No.: 125 Departure

Title:

Changes to Containment Cooling and Spent Fuel Pool Makeup Strategies (LAR-17-021)

Brief Description of the Plant-Specific Departure:

This activity makes changes to the design and operation of the passive containment cooling system (PCS) and spent fuel pool cooling system (SFS) which includes revising the reactor and spent fuel pool (SFP) decay heat limits; revising the Technical Specifications (TS) for SFP makeup; revising the minimum required spent fuel pool (SFP), the fuel transfer canal (FTC), and cask washdown pit (CWP) water storage volumes and adding a new ITAAC to define the minimum volume of water in the cask loading pit (CLP).

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 involved Tier 1 information, COL Appendix A Technical Specifications, COL Appendix C ITAAC, and Tier 2 information which involved changes to Tier 1 information and Technical Specifications; therefore, a License Amendment and Exemption Request (LAR 021) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 126 and 125 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 5 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-105 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 138 Unit 4 Amendment No.: 137 Departure

Title:

Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024)

Brief Description of the Plant-Specific Departure:

This activity makes changes to the TS to address aspects of reactivity control and other miscellaneous changes to make them consistent with the remainder of the design, licensing basis, and the technical specifications.

This departure resulted in changes to COL Appendix A Technical Specifications.

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification; therefore, a License Amendment Request (LAR-17-024) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 138 and 137 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 6 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-109 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 122 Unit 4 Amendment No.: 121 Departure

Title:

Increase in MSIV Compartment Pressure (LAR-17-028)

Brief Description of the Plant-Specific Departure:

This activity makes a change to increase the design pressure of the main steam isolation valve (MSIV) compartments.

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

Summary of the Evaluation:

This departure involved Tier 2* information, and Tier 2 information in the UFSAR which involved changes to Tier 2* information; therefore, a License Amendment Request (LAR-17-028) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 122 and 121 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 7 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-115 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 123 Unit 4 Amendment No.: 122 Departure

Title:

Improvements to Main Control Room (MCR) Post-Accident Radiological Consequences (LAR-17-023)

Brief Description of the Plant-Specific Departure:

This activity revises the licensing basis associated with the Main Control Room (MCR) post-accident radiological dose consequences analysis including editorial and consistency changes.

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 involved changes to Tier 1 information, COL Appendix A Technical Specifications, COL Appendix C ITAAC, and Tier 2 information which involved changes to Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-17-023) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 123 and 122 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Additional editorial and consistency changes are also made to Tier 2 information that 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 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 8 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-118 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 144 Unit 4 Amendment No.: 143 Departure

Title:

Effect of Rod Shadowing on Excore Power Range Detectors, Changes to Nuclear Overpower Reactor Trips, and Changes to Monitoring of Moderator Temperature Coefficient and Core Power Distribution (LAR-17-031)

Brief Description of the Plant-Specific Departure:

This activity changes the design of the protection and safety monitoring system (PMS) automatic reactor trips and the crediting of PMS automatic reactor trips necessary to prevent exceeding the fuel design limits. Additionally, the power range detector indication uncertainty and reactor trip logic is clarified.

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

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification and Tier 2 information which involved changes to the Technical Specifications; therefore, a License Amendment Request (LAR-17-031) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 144 and 143 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

The additional clarification changes to Tier 2 information 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 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 9 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-141 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 131 Unit 4 Amendment No.: 130 Departure

Title:

Unqualified Service Level I Coatings Program (LAR-17-039)

Brief Description of the Plant-Specific Departure:

This activity describes a nonconformance evaluation process for management of unqualified coatings and makes a change to the acceptance criteria of the ITAAC to allow this ITAAC to be satisfied with a limited quantity of unqualified inorganic zinc coatings in Service Level I areas of the plant as administratively controlled under SNCs quality assurance program. Additionally, a consistency change to clarify Service level of coating inside containment is made.

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 involved changes to Tier 1 information, Tier 2 information and associated COL Appendix C ITAAC; therefore, a License Amendment and Exemption Request (LAR-17-039) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 131 and 130 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

An additional change made to Tier 2 information for consistency within the UFSAR 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 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 10 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-144 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Removal of Section XI Reference for Performance of Turbine Examinations and Various Consistency and Editorial Changes Brief Description of the Plant-Specific Departure:

This activity removes reference to ASME Section XI and the inservice inspection program for performance of turbine examinations.

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 evaluation determined that NRC approval was not required prior to implementing this departure.

Page 11 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-147 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 132 Unit 4 Amendment No.: 131 Departure

Title:

Changes to Natural Circulation and Passive Residual Heat Removal Heat Exchanger Startup Test (LAR-17-041)

Brief Description of the Plant-Specific Departure:

This activity makes changes to allow an exception to the requirements of COL Appendix A Technical Specifications 3.4.4 for the Natural Circulation (first plant test), and to revise the Passive Residual Heat Removal Heat Exchanger (first plant test) to perform the test as part of the Power Ascension Testing requirements.

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

Summary of the Evaluation:

This departure involved Tier 2* information and associated Tier 2 information and a change to the VEGP Units 3 and 4 COLs; therefore, a License Amendment (LAR-17-041) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 132 and 131 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 12 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-148 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 125 Unit 4 Amendment No.: 124 Departure

Title:

Tier 1 and Tier 2* Editorial and Consistency Changes (LAR-17-042)

Brief Description of the Plant-Specific Departure:

This activity makes editorial (i.e.; incorrect tag numbers, component descriptions, code case titles and references to regulations) and/or consistency changes (i.e.; inconsistencies between UFSAR [plant-specific DCD] and COL Appendix C information, and inconsistencies between information from various locations within COL Appendix C).

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 involved Tier 1 information, COL Appendix C information, Tier 2* information, and Tier 2 information which involved changes to both Tier 1 and Tier 2* information in the UFSAR; therefore, a License Amendment and Exemption Request (LAR-17-042) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 125 and 124 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 13 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-151 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 128 Unit 4 Amendment No.: 127 Departure

Title:

Consistency and Clarification Changes to Annex Building, Auxiliary Building and Basemat ITAAC (LAR-17-040)

Brief Description of the Plant-Specific Departure:

This activity adds the point of reference for the top basemat elevation below the containment vessel and clarifies the thickness of a wall in the Auxiliary Building to relieve inconsistencies.

Additionally, the thickness of a floor section in the Annex Building is also changed.

This departure resulted in changes to Tier 1 information, COL Appendix C information and Tier 2* information in the UFSAR (plant-specific DCD).

Summary of the Evaluation:

This departure involved Tier 1 information, COL Appendix C information and Tier 2* information.

Therefore, a License Amendment and Exemption Request (LAR-17-040) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 128 and 127 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 14 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2017-160 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 142 Unit 4 Amendment No.: 141 Departure

Title:

Changes to Tier 2* Departure Evaluation Process (LAR-17-037)

Brief Description of the Plant-Specific Departure:

This activity adds an exemption from certain change requirements in 10 CFR Part 52, Appendix D, to allow departures from Tier 2* information evaluated against criteria in License Condition 2.D.(13) without a license amendment by expanding the applicability of the existing Tier 2 departure evaluation process.

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

Summary of the Evaluation:

This departure involved VEGP 3&4 COL information and a repetitive footnote providing Tier 2*

information and an exemption from NRC regulations governing the evaluation of departures from Tier 2* information; therefore, a License Amendment and Exemption Request (LAR 037) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 142 and 141 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 15 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-006 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 134 Unit 4 Amendment No.: 133 Departure

Title:

Fuel Management Related Technical Specifications (LAR-18-005)

Brief Description of the Plant-Specific Departure:

Changes are made to the Technical Specifications (TS) to address the differences between the TS and the Technical Specifications Task Force (TSTF) travelers. In addition to the TSTF changes, other changes are proposed to correct inconsistencies in the intent, scope, and nomenclature within the Technical Specifications.

This departure resulted in changes to COL Appendix A Technical Specifications.

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification; therefore, a License Amendment Request (LAR-18-005) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 134 and 133 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 16 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-007 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 135 Unit 4 Amendment No.: 134 Departure

Title:

Change to Battery Charger Output Amp Value in Technical Specification SR 3.8.1.2 and the Surveillance Frequency for SR 3.8.7.6 (LAR-18-003)

Brief Description of the Plant-Specific Departure:

This activity makes changes for consistency with the design and safety analysis requirements for battery charger output. The required ampere output for battery charger output testing is revised to 150 amps and changes are made to indicate that the ampere requirement is based on the design minimum charger size. Additional changes are made to clarify the applicability of Regulatory Guide (RG) 1.32 and 1.129 throughout the licensing basis to the IDS battery testing.

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

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification; therefore, a License Amendment Request (LAR-18-003) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 135 and 134 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Additional Tier 2 changes that are made to clarify the applicability of Regulatory Guide (RG) 1.32 and 1.129 throughout the licensing basis to the IDS battery testing 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 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 17 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-008 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 127 Unit 4 Amendment No.: 126 Departure

Title:

Changes to the Building Gap between the Nuclear Island and Adjacent Buildings (LAR-18-002)

Brief Description of the Plant-Specific Departure:

This activity reduces the minimum gap requirement above grade (Elevation 100'-0") between the structural elements of the Nuclear Island and the Annex and Turbine Building. The minimum gap requirements between the structural elements of Nuclear Island and the Radwaste Building is removed from the Inspections, Tests, Analyses and Acceptance Criteria (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 involved changes to Tier 1 information, Tier 2* information and associated COL Appendix C ITAAC, and Tier 2 information which involved changes to both Tier 2* and Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-18-002) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 127 and 126 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 18 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-009 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 124 Unit 4 Amendment No.: 123 Departure

Title:

Analytical Methods for Core Operating Limits Report and Consistency Changes (LAR-18-006)

Brief Description of the Plant-Specific Departure:

This activity makes changes to the core operating limits report (COLR) required documentation to include analytical methods which are described elsewhere in the TS and in the UFSAR, and an editorial change is made for high radiation areas to correct a typographical error. In addition, editorial changes are made to align the analytical methods identified in the UFSAR with the analytical methods used in the COLR.

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

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification and Tier 2 information which involved changes to the Technical Specifications; therefore, a License Amendment Request (LAR-18-006) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 124 and 123 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 19 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-010 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 133 Unit 4 Amendment No.: 132 Departure

Title:

Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

Brief Description of the Plant-Specific Departure:

This activity changes the Mode 4 Applicability of Pressurizer Safety Valve to require the pressurizer safety valves (PSVs) to be operable when all four cold leg temperatures are >

275°F. In addition, changes to support PSV Operability are made for consistency and the TS Limiting Conditions for Operation (LCO) Note is relocated.

This departure resulted in changes to COL Appendix A Technical Specifications.

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification; therefore, a License Amendment Request (LAR-18-004) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 133 and 132 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 20 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-012 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Resistance Temperature Detector Ranges and Functions Brief Description of the Plant-Specific Departure:

This activity replaces the use of the reactor coolant system (RCS) hot leg wide range temperature instruments with the residual heat removal system (RNS) inlet temperature instrumentation upstream of the heat exchanger as the primary temperature indication for reduced inventory conditions. This activity also changes the temperature range of the reactor coolant pump (RCP) bearing water temperature instrumentation and adds Reactor Trip (RT) and Engineered Safeguards Feature (ESF) functions to the reactor coolant system (RCS) cold leg dual range temperature elements.

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 21 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-014 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to CVAP Licensing Documentation Brief Description of the Plant-Specific Departure:

This activity makes changes to the Comprehensive Vibration Assessment and Testing Program (CVAP) and makes corrections and editorial changes to UFSAR Chapters 1,3 and 14.

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 evaluation determined that NRC approval was not required prior to implementing this departure.

Page 22 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-018 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Low-2 Reactor Coolant Pump (RCP) Reduced Reactor Trip Response Time Brief Description of the Plant-Specific Departure:

This activity changes the response time of reactor trip on Low-2 Reactor Coolant Pump (RCP) speed and revises Note 2 in WCAP-15776, as described in UFSAR subsection 7A.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 23 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-019 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Axial Offset Control Brief Description of the Plant-Specific Departure:

This activity makes changes to the function description of the axial offset (AO) control subsystem to remove the operator-selected I target control bands for the three modes of normal operation and clarify the existence of one axial offset (AO) bank.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-020 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Revision of Pressurizer Heater Logic Brief Description of the Plant-Specific Departure:

This activity makes changes to the design of the pressurizer heater logic to show the additional actuation logic path from the protection and safety monitoring system (PMS) function High-3 Pressurizer Water Level, to the pressurizer heater load center circuit breakers, and to indicate that all divisions generate a command to the plant control system to open the molded-case circuit breakers which provide a power feed to each individual pressurizer heater.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-024 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Revision of UFSAR Figure 8.3.2-2 and Appendix 7A Brief Description of the Plant-Specific Departure:

This activity makes changes to the AP1000 Class 1E DC and UPS System (IDS) and the Protection and Safety Monitoring System (PMS) by removing the AC Output Breakers to eliminate a postulated failure mode and single point vulnerability, revising the design of the PMS Integrated Logic Cabinets (ILCs) to remove single point vulnerabilities in power supply to the Component Interface Modules (CIMs) and adding the Compressed and Instrument Air System (CAS) valve CAS-PL-V014 to WCAP-16438 and classified as a R-1 component.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-027 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 143 Unit 4 Amendment No.: 142 Departure

Title:

Updates to Tier 1 Table 2.5.2-3 (LAR-18-010)

Brief Description of the Plant-Specific Departure:

This activity revises discussion of the Protection and Safety Monitoring System (PMS)

Purification Line Isolation signal to provide consistent nomenclature for the signal. This activity also revises discussion of the valves which are affected by the isolation signal for clarity and consistency throughout the UFSAR text.

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 involved changes to Tier 1 information, COL Appendix C ITAAC, and Tier 2 information in the UFSAR which involved changes to Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-18-010) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 143 and 142 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 27 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-028 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to IDS and EDS Figures Brief Description of the Plant-Specific Departure:

This activity makes changes to UFSAR figures for the Class 1E dc and Uninterruptible Power System (IDS) and the Non-Class 1E dc and Uninterruptible Power System (EDS) to be consistent with the supporting technical documents and drawings, to correct drawing oversights during the creation of the UFSAR figures, to correctly incorporate missed impacts caused by changes in procured equipment, and to resolve an inconsistency internal to the 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 28 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-029 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 137 Unit 4 Amendment No.: 136 Departure

Title:

Remotely Operated Containment Isolation Valve Status (LAR-18-012)

Brief Description of the Plant-Specific Departure:

This activity makes changes to clarify the post-accident monitoring (PAM) category designation for containment isolation valves statuses and adds PAM requirements for the Normal Residual Heat Removal System (RNS), the Component Cooling Water System (CCS), and the Chemical and Volume Control System (CVS) containment isolation valve statuses.

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

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification and Tier 2 information which involved changes to the Technical Specifications; therefore, a License Amendment Request (LAR-18-012) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 137 and 136 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 29 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-030 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 146 Unit 4 Amendment No.: 145 Departure

Title:

Technical Specification Changes to Support Operability During Mode 5 Vacuum Fill Operations (LAR-18-009)

Brief Description of the Plant-Specific Departure:

This activity revised the OPERABILITY requirement of the Passive Residual Heat Removal (PRHR) Heat Exchanger (HX) to acknowledge that it is not needed during Reactor Coolant System (RCS) vacuum fill operations.

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

Summary of the Evaluation:

This departure involved changes to COL Appendix A Technical Specification and Tier 2 information which involved changes to the Technical Specifications; therefore, a License Amendment Request (LAR-18-009) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 146 and 145 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 30 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-032 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 139 Unit 4 Amendment No.: 138 Departure

Title:

Equipment Survivability Assessment (LAR-18-001)

Brief Description of the Plant-Specific Departure:

This activity makes changes to incorporate updates to the sustained hydrogen combustion equipment survivability assessment which involves renumbering Hydrogen Igniter 65 and 66; changing the approximate elevations to the nominal final installation elevation; removing redundant igniter elevations and power groups information; and providing more detail about the location of hydrogen igniters covering the In-containment Refueling Water Storage Tank (IRWST). Additionally, the passive autocatalytic recombiners (PARs) are credited in the equipment survivability assessment.

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

Summary of the Evaluation:

This departure involved changes to Tier 1 information, the Technical Requirements Manual (TRM), COL Appendix C ITAAC, and Tier 2 information in the UFSAR which involved changes to Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-18-001) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 139 and 138 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Additional clarifications are also made to Tier 2 information that 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 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 31 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-033 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to the AP1000 PTLR Curve Brief Description of the Plant-Specific Departure:

This activity updates the Pressure (and) Temperature Limits Report (PTLR) heatup and cooldown limitations in accordance with the latest NRC approved PTLR methodology and updates the current licensing basis to reflect the latest revision of this methodology and the PTLR.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-034 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Relocation of VES Purge Penetration Openings in the MCR Vestibule Wall Brief Description of the Plant-Specific Departure:

This activity relocates the two Main Control Room Emergency Habitability System (VES) discharge purge openings from the wall between the Main Control Room (MCR) vestibule and the adjacent corridor to the wall between the MCR vestibule and the Electrical Penetration Room Division A.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-037 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

CMU Wall Removal and HVAC Fire Damper Relocation Brief Description of the Plant-Specific Departure:

This activity removes the Concrete Masonry Unit (CMU) wall located in the Annex Building Room 40400.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-038 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Addition of Automatic RNS and Containment Isolation Signals on ADS Stage 4 Signal Brief Description of the Plant-Specific Departure:

This activity modifies the protection and safety monitoring system (PMS) to add automatic containment isolation and automatic normal residual heat removal system (RNS) isolation capabilities to mitigate RNS breaks during shutdown. This change adds a redundant automatic process for RNS and containment isolation. The ADS-4 actuation signal is changed to be an input for the actuation of RNS isolation and containment isolation. Low-4 RCS Hot Leg Level and Low-6 Core Makeup Tank Level are inputs for ADS-4 actuation and, therefore, are also added as inputs to RNS isolation and containment isolation.

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

Summary of the Evaluation:

The change involves establishing an automatic RNS and Containment isolation upon ADS Stage 4 actuation while in MODES 4, 5 or 6. The addition of automatic RNS isolation provides the possibility of additional consequences resulting from spurious ADS Stage 4 actuation. This plant-specific departure did not result in a deviation from plant-specific DCD design information such that there is more than a minimal increase in the frequency of occurrence of an accident, likelihood of the occurrence of a malfunction of a structure, system or component (SSC) important to safety, consequences of an accident or malfunction; create the possibility of an accident of a different type or malfunction with a different result; result in a design basis limit for a fission product barrier being exceeded or altered; result in a departure from a method of evaluation; or a substantial increase in the probability of an ex-vessel severe accident previously determined to not be creditable such that it would become credible.

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 evaluation determined that NRC approval was not required prior to implementing this departure.

Page 35 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-039 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to the Diverse Actuation System (DAS), and Plant Control System (PLS) Involving PLS Startup Feedwater Pump Automatic Start Logic Brief Description of the Plant-Specific Departure:

This activity makes changes to the Plant Control System (PLS) by adding reactor coolant average temperature permissive (P-9) interlock and block for startup feedwater pump automatic start 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 36 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-041 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Rod Control Subsystem and Rod Insertion Limits Changes Brief Description of the Plant-Specific Departure:

This activity makes a change to the interface logic between the axial offset (AO) control subsystem and the power control subsystem to improve control of axial flux difference while continuing to provide adequate control of reactor temperature. In addition, a consistency change is made to the AO bank design description, a clarification of the control rod withdrawal sequence is made, and a change is made to the formula for calculating the control rod insertion limits for the AO and power control rod banks.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-042 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Control Rod Drive Mechanism Design, Inspection and Testing Clarifications Brief Description of the Plant-Specific Departure:

This activity makes editorial changes, consistency changes and clarification changes for reactor vessel dimensions, reactor vessel NDEs, CRDM testing, power capacities of the pressurizer heaters, core debris cooling, and reactor coolant pressure boundary valves.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-044 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to the PMS Failure Modes Effects Analysis (FMEA)

Brief Description of the Plant-Specific Departure:

This activity updates incorporated by reference (IBR) documents WCAP-16438 (PMS FMEA) and WCAP-16675 (PMS Architecture Technical Report) for consistency with previously approved design changes, expansion of the fault classifications for the FMEA, and clarification of the components receiving manual control from PMS. Additionally, the specific portions of WCAPs that are IBR are clarified in the 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 39 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-046 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Containment Debris Related Changes Brief Description of the Plant-Specific Departure:

This activity incorporates conforming containment debris related changes into the UFSAR into the UFSAR in accordance to the limitations delineated in the NRC approved WCAP-17938, Rev 3 and the Safety Evaluation Report. Also, the UFSAR is modified to state that a "suitable equivalent" to metal reflective insulation (MRI) can be used for consistency with existing provisions in other UFSAR sections. Portions of UFSAR Chapter 19 are being revised to remove the reflective designator for reactor vessel insulation.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-047 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to the I&C Data Communication and PMS Architecture Reports Brief Description of the Plant-Specific Departure:

This activity makes editorial, consistency, and clarifications changes to the AP1000 I&C architecture design as described in WCAP-16674, WCAP-16675 and WCAP-15575 which are documents that are incorporated by reference (IBR) into the UFSAR as shown in 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 41 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-048 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Corrections to MSS System Preoperational Testing Requirements Brief Description of the Plant-Specific Departure:

This activity makes changes to the main steam system preoperational test description purpose and general test method and acceptance criteria to reflect that the functions are not defense-in-depth, clarify the functions based on the valves included in the testing, update which valves are included in the testing, and revise the conditions of the testing.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-049 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Standby Diesel Generator Testing per TRS 3.8.1.4 Brief Description of the Plant-Specific Departure:

This activity makes changes to revise the Technical Requirements Manual (TRM) to separate the periodic 24-hr run of each standby diesel generator (SDG) from the periodic simultaneous start of both SDGs.

This departure resulted in changes to 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 43 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-050 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Addition of Collar to RV (Reactor Vessel) Cavity Brief Description of the Plant-Specific Departure:

This activity modifies the Reactor Vessel Insulation System (RVIS) by adding upper and lower shielding blocks to the reactor vessel (RV). As a result, the approximately six inch thick metal reflective insulation (MRI) in the areas of the blocks is replaced with a suitable equivalent to MRI.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-051 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 140 Unit 4 Amendment No.: 139 Departure

Title:

Containment Sump Level Instrumentation (LAR-18-014)

Brief Description of the Plant-Specific Departure:

This activity makes changes to the design of the containment sump level sensor from ultrasonic to guided wave radar type.

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 involved changes to Tier 1 information, COL Appendix C ITAAC, and Tier 2 information in the UFSAR which involved changes to Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-18-014) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 140 and 139 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 45 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-052 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 145 Unit 4 Amendment No.: 144 Departure

Title:

Fire Protection System Non-Safety Cable Spray Removal (LAR-18-015)

Brief Description of the Plant-Specific Departure:

This activity removes the fire protection system (FPS) nonsafety-related cable tray spray fire suppression system from containment fire zone 1100 AF 11300B and replaces it with passive fire stops.

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 involved changes to Tier 1 information, COL Appendix C ITAAC, and Tier 2 information in the UFSAR which involved changes to Tier 1 information; therefore, a License Amendment and Exemption Request (LAR-18-015) was submitted to the NRC.

The NRC approved this License Amendment and Exemption Request and issued License Amendments 145 and 144 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 46 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-056 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Gland Seal System (GSS) Routing Changes Brief Description of the Plant-Specific Departure:

This activity makes changes to separate the GSS exhauster suction from the discharge drains.

The suction line to the two GSS exhauster blowers from the GSS condenser is also added.

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 47 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-057 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: 141 Unit 4 Amendment No.: 140 Departure

Title:

Changes to Construction Fitness-for-Duty (FFD) Commitments (LAR 018)

Brief Description of the Plant-Specific Departure:

This activity makes changes to document exceptions to commitments to Regulatory Guide (RG) 5.84, Fitness-for-Duty Programs at New Reactor Construction Sites, Revision 0. RG 5.84 endorses Nuclear Energy Institute (NEI) guidance NEI 06-06, Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, Revision 6 (April 2013). The exception modifies NEI 06-06 guidance to allow for temporary, pre-assignment access authorization for individuals defined in 10 CFR 26.4(f) who are subject to an FFD program that meets the requirements of 10 CFR Part 26, Subpart K.

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

Summary of the Evaluation:

This departure involved a change to the VEGP 3 and 4 UFSAR related to fitness-for-duty (FFD) requirements; therefore, a License Amendment Request (LAR-18-018) was submitted to the NRC.

The NRC approved this License Amendment Request and issued License Amendments 141 and 140 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.

Page 48 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-061 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

WWS Drain Slope Requirement Brief Description of the Plant-Specific Departure:

This activity makes changes to the design of the Waste Water System (WWS) to allow non-radioactive gravity drain piping to contain localized non-conforming slope sections.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-063 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Diesel Building & Module HVAC Revision Brief Description of the Plant-Specific Departure:

This activity involves a change to the design of the Diesel Generator Building Ventilation System (VZS) including the loads of components on the Diesel Generator, changes to the temperature range for the Diesel Oil Transfer (DOT) module enclosure, the location of various fans and ducting in the DOT module enclosure and Diesel Generator Building and their manner of operation, and the airflow rate and types of fans in the system.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-064 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Clarification of Switchyard Fault Initiation of Fast Bus Transfer Brief Description of the Plant-Specific Departure:

This activity clarifies that electrical faults in the switchyard zone will also initiate a fast bus transfer (FBT) to transfer loads to the reserve auxiliary transformers. In addition, cross-references are added, and redundant information is deleted from the 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 51 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-065 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

HVAC Changes in Chapter 9 and Table 3.2-3 Brief Description of the Plant-Specific Departure:

This activity makes changes to add ASME AG-1 Class R ducting and components to several HVAC systems, revise a reference to Article SA-4500 to Section SA of ASME AG-1, correct inconsistencies related to ducting and components within numerous HVAC systems, remove the pressure relief damper on the Containment Recirculation Cooling System (VCS) duct ring header, change the version of ANSI/AMCA 500 to the 2012 edition, change the code title to ANSI/AMCA 500-D and update Note 2 of UFSAR Figure 9.4.2-1, Figure 9.4.3-1 and Figure 9.4.10-1 to clarify that system components are the classes listed, unless noted otherwise.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-069 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Allowing Carbon Steel Inside Containment to be Uncoated Brief Description of the Plant-Specific Departure:

This activity changes the design of coatings to allow carbon steel inside containment (other than the containment vessel) to remain uncoated where coatings use is not practical.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-070 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes of FPS Valve Class Brief Description of the Plant-Specific Departure:

This activity changes the AP1000 equipment class designation for fire protection system (FPS) valve FPS-PL-V049 from Class B to Class F. The change in class also means that the valve no longer requires an individual listing in UFSAR Table 3.2-3, as the valve is already encompassed by the existing table entries in the FPS entry for the auxiliary building standpipe.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-071 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Corrections to IDS equipment safety functions in UFSAR Table 8.3.2-7 Brief Description of the Plant-Specific Departure:

This activity changes the Failure Modes and Effects (FMEA) for the Class 1E DC and uninterruptible power supply (UPS) system (IDS) to eliminate electrical protection as a safety function and add IEEE 384 isolation as a safety function. Additionally, the safety functions of the battery charger, battery, voltage regulating transformer (VRT) and the 208Y/120V AC distribution panel are clarified.

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 55 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-072 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

VFS Relocation of Outside Air Duct Connection to Containment Air Filtration Exhaust Units Brief Description of the Plant-Specific Departure:

The activity involves a change to relocate the Containment Air Filtration System (VFS) outside air makeup duct to upstream of the exhaust air filtration units, add a fail closed, automatic isolation damper on the outside air makeup duct upstream of the exhaust air filtration units, and change the class of certain components within the system from Equipment Class L to R.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-075 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Appendix 3B Bounding Analysis Curve and Notes Revisions Brief Description of the Plant-Specific Departure:

This activity updates the bounding analysis curves (BACs) for leak-before-break (LBB) to add an additional load case combination, clarify that stratification loads are calculated at 100%

power, clarify that the stress points located on the BAC are acceptable, include updated pressures and temperatures, add the in-containment refueling water storage tank (IRWST) injection line, add the direct vessel injection line, and to add a steam condition BAC for reactor coolant system (RCS) automatic depressurization system (ADS) lines and for RCS safety valve lines.

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 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-077 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Clarification of CET Components in Fire Area Brief Description of the Plant-Specific Departure:

This activity makes changes to revise the description of the core exit thermocouples (CETs) equipment that is located in Fire Zone 1100 AF 11500 to replace termination cabinets with cable assemblies.

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 58 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-078 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Main Control Room (MCR) Vestibule Discharge Openings Fire Protection Features Brief Description of the Plant-Specific Departure:

This activity credits the function of the two ventilation penetrations, as demonstrated by the performance of a full-scale fire test that was performed at an independent, qualified testing laboratory. This activity also provides a change to a UFSAR figure to more clearly depict the location of the two openings, in conformance with a previously-approved departure.

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 59 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-080 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Shield Building, SC Wall & AI Tension-Ring, Modified Weld Brief Description of the Plant-Specific Departure:

This activity involves a change to the design which allows a maximum 1/4 offset in shield building liner plate alignment and allows a maximum 1/4 gap between faying surfaces of the shield building liner plate butt joint landing on a backing bar.

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 60 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-081 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Section 11.5 Clarifications Brief Description of the Plant-Specific Departure:

This activity makes changes to clarify the steam generator radiation monitor applicability and correct the gaseous radwaste monitor detector type.

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 61 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-083 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Update to WLS RCDT Identified Leakage Brief Description of the Plant-Specific Departure:

This activity makes changes to clarify that the liquid level in the Reactor Coolant Drain Tank (RCDT) and total flow pumped out of the RCDT are used to monitor the identified leakage rate, and that the identified leak rate is automatically calculated by the plant computer using the liquid level in the RCDT. The RCDT influent rate is changed to accept 10 gpm of saturated reactor coolant for 30 minutes without discharge or overflow.

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 62 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-088 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Modifications for Service Level II Coatings Brief Description of the Plant-Specific Departure:

This activity makes changes to remove unnecessary detail on coatings used on concrete Substrates, to clarify that DBA Qualification of Service Level II coatings is for a particular coating formulation, and to reflect a broader type of coating appropriate for concrete substrates in containment.

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 63 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-090 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Annex/Auxiliary Buildings Nonradioactive HVAC System Brief Description of the Plant-Specific Departure:

This activity makes changes to revise the Annex/Auxiliary Buildings nonradioactive HVAC system (VXS) air handling unit (AHU) capacities for the annex building general, office, Main Steam Isolation Valve (MSIV) compartment, and mechanical equipment areas. Also, the AHU performance parameters for the switchgear and equipment rooms are revised.

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 64 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-092 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Ensure IDS Battery Capability Brief Description of the Plant-Specific Departure:

This activity makes changes to add a protection and safety monitoring system (PMS) time delay between RNS-V002A and V002B in Division B, a PMS time delay between RNS-V001A and V001B in Division D, and revise PMS logic in Division D to add RNS-V001A/B to the automatic Normal Residual Heat Removal System (RNS) containment isolation actuation that will result in an Class 1E DC and uninterruptible power supply (UPS) system (IDS) battery load profile that will not exceed the design of the IDS batteries.

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 65 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-093 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Modifications to the Post Accident Monitoring System Requirements Brief Description of the Plant-Specific Departure:

This activity makes changes to clarify the purpose of UFSAR (plant-specific DCD) Table 7.5-1.

The Post Accident Monitoring System (PAMS) requirements are changed for several variables.

An Engineered Safety Function (ESF) and a Reactor Trip (RT) function with a required operating time of 5 minutes are added for the Reactor Coolant Pump Bearing Water Temperature sensors. The description of the Hydrogen Control System (VLS) is expanded to include discussion of the hydrogen monitor pressure sensors and clarify the discussion on the hydrogen monitors. The discussion regarding two operable channels being from Protection and Safety Monitoring System (PMS) Divisions B and C is clarified. The information regarding the Reactor Coolant System (RCS) subcooling variable is modified. Editorial and consistency changes are made to PAMS tables in the 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 66 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-095 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Aux/Annex Bldg High Humidity Concerns Brief Description of the Plant-Specific Departure:

This activity makes changes to the controls of the nuclear island nonradioactive ventilation system (VBS) class 1E electrical room HVAC subsystem, the annex/auxiliary buildings nonradioactive HVAC system (VXS) switchgear room HVAC subsystem, and VXS equipment room HVAC subsystem to address operating scenarios that could result in high humidity levels in the areas served by those subsystems.

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 67 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-098 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Changes to Reactor Coolant Pump Design Brief Description of the Plant-Specific Departure:

This activity replaces references to specific ASTM examination and testing procedures in the UFSAR (plant-specific DCD) with ASME Section III Code procedures for the reactor coolant pump (RCP) flywheel structural components prior to final assembly. Changes are made related to examination and testing, and fabrication, of the RCP and RCP flywheel components. This activity also makes changes concerning allowable stress criteria for the RCP flywheels and clarifies that alloy 600 weld metal is used in a non-pressure boundary application of the RCP flywheel.

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 68 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-099 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Impact of CVS Spent Resin Transfer on Radiation Zones in Containment Brief Description of the Plant-Specific Departure:

This activity modifies the radiation zones at the 100 and 117 6 elevations in rooms 11300 and 11400 by a note during Chemical and Volume Control System (CVS) resin transfer operations that the areas around and above the penetrations west of the elevator on the maintenance floor may reach Zone VI.

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 69 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-100 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Equipment Tag Numbers, Qualification, and Classification Changes to UFSAR Chapter 3 Brief Description of the Plant-Specific Departure:

This activity makes changes to eliminate inconsistent equipment tag numbers, post-accident monitoring system (PAMS) requirements and equipment classifications from UFSAR Section 3.11 consistent with the design of the plant.

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 70 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-101 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PRHA Accident Temperatures Revised for Auxiliary Building Room Brief Description of the Plant-Specific Departure:

This activity changes the room temperatures for auxiliary building Rooms 12156 and 12244 to align with the latest pipe rupture hazards analysis (PRHA) results. The accident environment temperature for two auxiliary building rooms was increased to incorporate environmental conditions resulting from a high energy line break.

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 71 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-103 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Chapter 3 and Chapter 7 Editorial/Consistency/Clarification Changes Brief Description of the Plant-Specific Departure:

This activity includes several unrelated changes which are editorial in nature. These changes include corrections to code of federal regulations (CFR) reference, code/standard citations, Teflon abbreviation and Regulatory Guide (RG) references; clarification of automatic depressurization system (ADS) transient and equipment qualification requirements; addition of comment and new row regarding reactor pressure vessel (RPV) tag numbers, a new note regarding correct code/standard citation, new cross-reference for RG 1.180 and rows for iodine and noble gas detectors; revision of the description of the particulate detector; and a change to the environmental zone.

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 72 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-104 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Change to Reactor Decay Heat Level for TRM 3.6.1 Maintenance Activity Brief Description of the Plant-Specific Departure:

This activity revises the reactor core decay heat limit for performing planned maintenance on the passive containment cooling ancillary water storage tank (PCCAWST) to 4.0 MWt.

This departure resulted in changes to 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 73 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-105 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Resolution of Gaseous Radwaste System (WGS) Shield Wall Location, Relocation of Temperature Sensor, and Editorial/Clarification Changes Brief Description of the Plant-Specific Departure:

This activity makes changes to relocate Temperature sensor, WGS-JE-TE008 downstream of the gas cooler. The radiation shield wall between V029 and the guard bed is removed and the radiation shield wall between V008 and the guard bed is relocated. The average mass of the activated carbon delay beds is replaced with the minimum and maximum masses.

Editorial/Clarification changes are made to update table references, remove duplicative information and correct tag numbers.

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 74 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-106 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Correction of RCS Draindown Description Brief Description of the Plant-Specific Departure:

The activity removes reference to the "refueling draindown mode" for CVS-V047 because the AP1000 design does not have this mode, and clarifies that the RCS level is manually controlled as the level approaches the top of the RCS hot leg. The activity also removes the discussion of the RCS hot leg water level instruments providing a signal for letdown control using CVS-V047 because there is no such signal.

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 75 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-113 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Reactor Cavity Flooding, Shutdown Analyses and Tech Spec Alignment Changes Brief Description of the Plant-Specific Departure:

This activity makes editorial changes to correct or remove references to the Technical Specifications (TS) and to UFSAR figures in UFSAR (plant-specific DCD) Chapter 19.

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 76 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-114 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Requirements for Containment Flood Up Level Sensors Brief Description of the Plant-Specific Departure:

This activity makes changes to the UFSAR to remove the passive core cooling system (PXS) containment level instrument requirement and adds a description that containment water level sensors provide a diverse backup for main steam line leakage and adding a cross reference.

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 77 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-115 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Plant Lighting System (ELS) Design Changes Brief Description of the Plant-Specific Departure:

This activity makes changes to the design of the ELS in the Main Control Room (MCR) and Remote Shutdown Room (RSR) to use adjustable dimming features in the normal lighting and emergency lighting in the ELS and remove the requirements for fluorescent lighting from the emergency lighting in the ELS.

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 78 of 79

ND-18-1504 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-119 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Relocation of the Passive Containment Cooling Ancillary Water Storage Tank (PCCAWST)

Brief Description of the Plant-Specific Departure:

This activity makes changes to relocate the PCCAWST 25 feet plant west and 8 feet plant south, to clarify the description of how the PCCAWST soil structure is analyzed, and to show the PCCAWST as a component instead of a structure.

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 79 of 79

Southern Nuclear Operating Company ND-18-1504 Enclosure 2 VEGP Units 3 and 4 Tier 2* Departure Report for the Period of May 11, 2018 through November 10, 2018 (2 pages, including this cover page)

ND-18-1504 VEGP Units 3 and 4 Tier 2* Departure Report for the Period of May 11, 2018 through November 10, 2018 Departure Number: LDCR-2018-107 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PMS Common Q Watchdog Timer and Design Description Changes Brief Description of the Plant-Specific Departure:

This activity makes changes to clarify the design and use of watchdog timers within the Common Q portion of the protection and safety monitoring system (PMS). This activity addresses an issue identified by Westinghouse in Nuclear Safety Advisory Letter (NSAL) 17-2, AC160 Processor Module Stall Timers Not Activated as Described in Licensing Basis. This activity also makes several changes to the design description of the Common Q platform, as presented in the UFSAR and various supporting technical reports that are incorporated by reference into the UFSAR.

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 does 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.

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