ND-22-0419, Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report

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Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report
ML22165A328
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/14/2022
From: Whitley B
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-22-0419
Download: ML22165A328 (22)


Text

A Southern Nuclear Brian H. Whitley Southern Nuclear Director, Regulatory Affairs Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 June 14, 2022 Docket No.: 52-025 ND-22-0419 52-026 10 CFR 50.59 10 CFR 52 App. D U.S. Nuclear Regulatory Commission ATTN: 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, respectively, 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. provides the report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each, as required by 10 CFR 50.59(d)(2),

for the period of November 12, 2021 through May 11, 2022. provides the report containing a brief description of any plant-specific departures, including a summary of the evaluation of each, as required by 10 CFR 52, Appendix D, paragraphs X.B.1 and X.B.3.b, for the period of November 12, 2021 through May 11, 2022.

For the period of November 12, 2021 through May 11, 2022, there were no changes made to Tier 2* information pursuant to the exemption in License Condition 2.D.(13)(a).

This letter makes no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.

If you have questions, please contact Ms. Amy Chamberlain at 205-992-6361.

U.S. Nuclear Regulatory Commission ND-22-0419 Page 2 of 4 Respectfully submitted, Brian H. Whitley Regulatory Affairs Director Southern Nuclear Operating Company

Enclosures:

1) VEGP Units 3 and 4, 10 CFR 50.59 Report of Changes, Tests, or Experiments for the Period of November 12, 2021 through May 11, 2022
2) VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022

U.S. Nuclear Regulatory Commission ND-22-0419 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski Mr. P. P. Sena III Mr. H. Nieh Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. D. Pitts Mr. J. B. Williams Mr. D. L. McKinney Mr. T. W. Yelverton Mr. B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. J. M DeLano Ms. J. M. Coleman Mr. C. T. Defnall Ms. A. C. Chamberlain Mr. S. Leighty Ms. K. Roberts Mr. J. Haswell Mr. A. S. Parton Mr. A. Nix Mr. T.M. Drouin Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. M. King Mr. G. Bowman Ms. A. Veil Mr. V. Hall Mr. G.J. Khouri Mr. G. Armstrong Mr. C. Patel Mr. C. Santos Mr. B. Kemker Mr. J. Eargle Mr. C. J. Even Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. O. Lopez-Santiago Mr. M. Webb

U.S. Nuclear Regulatory Commission ND-22-0419 Page 4 of 4 Nuclear Regulatory Commission Mr. B. Gleaves Ms. K. McCurry Mr. B. Davis Mr. J. Parent Mr. B. Griman Mr. P. OBryan State of Georgia Mr. R. Dunn Oglethorpe Power Corporation Mr. David Sorrick Mr. B. Brinkman Mr. E. Rasmussen 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, Ph.D.

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

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

Mr. S. Roetger, Georgia Public Service Commission Mr. R. L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

Southern Nuclear Operating Company ND-22-0419 Enclosure 1 VEGP Units 3 and 4 10 CFR 50.59 Report of Changes, Tests, or Experiments for the Period of November 12, 2021 through May 11, 2022 (This Enclosure consists of 2 pages, including this cover page)

ND-22-0419 VEGP Units 3 and 4, 10 CFR 50.59 Report of Changes, Tests, or Experiments for the Period of November 12, 2021 through May 11, 2022 Change Number: LDCR-2022-005

Title:

Fire Protection - Miscellaneous Brief Description of the Changes, Tests and Experiments:

The fire protection program control of transient combustibles was revised to allow a fire watch to be established for unattended combustible packing material in addition to attending the material or storing it in approved containers.

Summary of the Evaluation:

This change did not result in 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; or result in a departure from a method of evaluation.

The 10 CFR 50.59 evaluation determined that NRC approval was not required prior to implementing this change.

Page 2 of 2

Southern Nuclear Operating Company ND-22-0419 Enclosure 2 VEGP Units 3 and 4 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 (This Enclosure consists of 16 pages, including this cover page)

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2020-044 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Chapter 19 Revision: Site-Specific PRA Update Brief Description of the Plant-Specific Departure:

This departure revised the description of the Probabilistic Risk Assessment (PRA) to reflect the updated and upgraded site-specific PRA.

This departure resulted in changes to the UFSAR (plant-specific DCD) and the Technical Specifications Bases.

Summary of the Evaluation:

This plant-specific departure and the Technical Specification Bases change activity do 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 a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, 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 and activity do 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 these changes.

Page 2 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-038 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

RTD Calibration Testing Description Brief Description of the Plant-Specific Departure:

This departure clarified that cross-calibration testing of the resistance temperature detectors (RTDs) against the in-core thermocouples to verify the RTD calibration coefficients is performed by collecting temperature data from the protection and safety monitoring system, rather than measuring the resistance of each RTD.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did 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 3 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-041 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

RCS Setpoint Values Consistency Brief Description of the Plant-Specific Departure:

This departure revised the specified reactor coolant system (RCS) pressure setpoints for the low-pressure safeguards actuation, low-pressure alarm, high-pressure alarm, and high-pressure reactor trip. This departure also changed the approximate pressurizer pressure at which pressurizer spray is initiated and the approximate pressurizer pressure that is reached during the boron concentration equalization transient.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did 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 4 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-042 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Relocation of DAS Setpoints from TRM to Setpoint Program Brief Description of the Plant-Specific Departure:

This departure removed the Diverse Actuation System automatic actuation setpoints from the Technical Requirements Manual (TRM) as the TRM setpoints are duplicates of the required setpoint values maintained in the setpoint program results report. A reference to the setpoint program results report was added to the TRM Bases.

This departure resulted in changes to Tier 2 portions of the 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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did 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 5 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-046 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Office Area HVAC Subsystem Humidifier Brief Description of the Plant-Specific Departure:

This departure removed the requirement to provide a minimum space relative humidity for the areas serviced by the office area handling units, thus removing the need for a humidifier in the system serving that area.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 6 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-049 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Adding Missing Notes to the Annex Normal Operation/Shutdown Radiation Zone Drawings Brief Description of the Plant-Specific Departure:

This departure provided three annex building rooms with a note explaining that while the rooms are typically Zone I, they may temporarily reach Zone II locally as a result of transient sources in the room(s) located below.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 7 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2021-053 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

WLS Degasifier Purge Addition Brief Description of the Plant-Specific Departure:

This departure added a continuous purge line, including a degasifier vacuum purge pump, to the liquid radwaste system (WLS) degasifier column. The departure also describes that the degasifier vacuum purge pump is stopped upon indication of a fire in the charcoal delay beds. The departure also revised the description of the plant conformance with Regulatory Guide (RG) 1.112, Revision 0-R, to specify that plant-specific adsorption coefficients are used instead of the generic adsorption coefficients defined in NUREG-0017, Revision 1.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 8 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-004 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

PCS Recirculation Pump Modification Brief Description of the Plant-Specific Departure:

This departure changed the nominal design total differential head of the passive containment cooling system (PCS) recirculation pump. This departure also revised the post-72 hours nominal load requirements for the PCS recirculation pumps and ancillary generator fuel tank 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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 9 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-006 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Modifications to Room 40404 Air Transfer Brief Description of the Plant-Specific Departure:

This departure removed the airflow path between the Control Support Area (CSA) and the toilet room serving the CSA and removed this toilet room from the CSA pressure boundary.

Additionally, this departure reduced the gross volume of the CSA which resulted in recalculated radiation doses.

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

Summary of the Evaluation:

This change did not result in a deviation from plant-specific DCD design information such that there was 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 result in a substantial increase in the probability of an ex-vessel severe accident previously determined to not be credible such that it would become credible.

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

Page 10 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-007 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

NFPA 22 FPS Fire Water Tank Compliance Brief Description of the Plant-Specific Departure:

This departure documented an exception to an NFPA 22 requirement regarding the orientation of the flow discharge from the over-the-top fil line of the fire water storage tanks.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did 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 11 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-014 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Emergency Boration Nomenclature Brief Description of the Plant-Specific Departure:

This departure clarified the term emergency boration and the appropriate control rod insertion alarm that requires boration.

This departure resulted in changes to the UFSAR (plant-specific DCD) and the Technical Specifications Bases.

Summary of the Evaluation:

This plant-specific departure and the Technical Specification Bases change activity do 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 a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, 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 and activity do 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 these changes.

Page 12 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-017 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Diesel Generator Automatic Load Sequencer Timing Clarification Brief Description of the Plant-Specific Departure:

This departure revised the diesel generator operational testing to reflect changes to the automatic load sequencer logic, sequence internals, and appropriate sequencing.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 13 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-018 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Auxiliary Steam Supply System Capabilities Brief Description of the Plant-Specific Departure:

This departure revised the design description of the capability and use of the auxiliary steam supply system during the condensate system and feedwater system recirculation and cleanup operation steps and during plant heatup following these steps.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did 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 14 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-019 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

UFSAR Table 6.2.3-1 Update for Alternate Containment Leak Rate Type Tests Brief Description of the Plant-Specific Departure:

This departure clarified that alternate Type tests can be used for repair and modification activities in accordance with regulatory guidance.

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, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 15 of 16

ND-22-0419 VEGP Units 3 and 4, 10 CFR 52, Appendix D Departure Report for the Period of November 12, 2021 through May 11, 2022 Departure Number: LDCR-2022-020 License Amendment: Yes No Exemption: Yes No Unit 3 Amendment No.: N/A Unit 4 Amendment No.: N/A Departure

Title:

Safety Classification of ASME Pipe Caps and Plugs Brief Description of the Plant-Specific Departure:

This departure added a note to the simplified piping and instrumentation diagrams for the normal residual heat removal system, containment leak rate test system, passive core cooling system, main control room habitability system, spent fuel pool cooling system, component cooling water system, central chilled water system, compressed and instrument air system, primary sampling system, chemical and volume control system, containment air filtration system, and fire protection system. The note clarifies that the caps and plugs are nonsafety Class E, ASME B31.1 and can be installed in accordance with the nonsafety requirements.

The departure added a cap to the demineralized water transfer and storage system with a note clarifying that the caps and plugs are nonsafety Class E, ASME B31.1 and can be installed in accordance with the nonsafety requirements.

This departure replaced the quick disconnects with caps or test flanges, and a note was added to clarify that caps and plugs are nonsafety Class E, ASME B31.1 and can be installed in accordance with nonsafety requirements.

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

Summary of the Evaluation:

This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, had no impact on plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation used in establishing design bases or in the safety analysis, did not represent tests or experiments outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.

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

Page 16 of 16