View source for ND-19-1416, Report of 10 CFR 50.59 Changes, Tests and Experiments and 10 CFR 52 Appendix D Departure Report

{{Adams
| number = ML19343B790
| issue date = 12/09/2019
| title = Report of 10 CFR 50.59 Changes, Tests and Experiments and 10 CFR 52 Appendix D Departure Report
| author name = Whitley B
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05200025, 05200026
| license number = 
| contact person = 
| case reference number = ND-19-1416
| document type = Inservice/Preservice Inspection and Test Report, Letter type:ND
| page count = 65
}}

=Text=
{{#Wiki_filter:B. H. Whitley               Southern Nuclear Director             Operating Company, Inc.
Regulatory Affairs    3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 December 9, 2019 Docket Nos.: 52-025                                                                   ND-19-1416 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 are departures from Tier 2* information that were 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 did not require prior NRC approval under the exemption in License Condition 2.D.(13)(a).
For the period of May 11, 2019 through November 11, 2019, there was one change (LDCR-2019-048) 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, 2019 through November 11, 2019. provides the report containing a brief description of the departure from Tier 2*
information that did 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, 2019 through November 11, 2019.
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 Mr. Adam Quarles at 205-992-7031.

U.S. Nuclear Regulatory Commission ND-19-1416 Page 2 of 4 Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company Enclosures    1) VEGP Units 3 and 4, Departure Report for the Period of May 11 , 2019 through November 11, 2019
: 2) VEGP Units 3 and 4, Tier 2* Departure Report for the Period of May 11, 2019 through November 11, 2019

U.S. Nuclear Regulatory Commission ND-19-1416 Page 3 of 4 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)
Mr. P. P. Sena III (w/o enclosures)
Mr. M. D. Meier (w/o enclosures)
Mr. D. H. Jones (w/o enclosures)
Mr. G. Chick Mr. M. Page Mr. D. L. McKinney (w/o enclosures)
Mr. T. W. Yelverton (w/o enclosures)
Mr. B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee Mr. M. Humphrey Ms. A. C. Chamberlain Mr. S. Leighty Mr. N. Kellenberger Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. Blythe Mr. K. Warren Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)
Mr. M. King (w/o enclosures)
Mr. C. Patel Mr. C. Santos Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. C. J. Even Mr. A. Lerch Mr. S. Walker Mr. N.D. Karlovich Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Ms. K. P. Carrington Mr. M. Webb Mr. P.J. Heher

U.S. Nuclear Regulatory Commission ND-19-1416 Page 4 of 4 State of Georgia Mr. R. Dunn Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)
Mr. T. Rubenstein (w/o enclosures)
Mr. M. Corletti Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.
Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-19-1416 Enclosure 1 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 (57 pages, including this cover page)

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2016-060          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Shield Building Door Opening and Architectural Feature Changes Brief Description of the Plant-Specific Departure:
This activity made changes to the design of the stairwells and doors providing access to and around the passive containment cooling system valve room and the stair tower on the shield building.
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, 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 2 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:       LDCR-2018-040           License Amendment:            Yes  No Exemption:                    Yes  No Unit 3 Amendment No.:         159 Unit 4 Amendment No.:         157 Departure

==Title:==
PORV Noise Mitigation Brief Description of the Plant-Specific Departure:
This activity made changes to the size of the power operated relief valve (PORV) block valves and the branch lines in which the PORV block valves are installed. The takeoffs for the branch lines to the PORV block valves were relocated to upstream of the main steam safety valves.
The size information for the branch lines that the PORV block valves are installed was removed from the Technical Specifications (TS) Bases.
This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD), COL Appendix C ITAAC, and TS Bases.
Summary of the Evaluation:
This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-021) was submitted to the NRC.
The NRC approved this License Amendment and Exemption Request and issued License Amendments 159 and 157 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.
The TS Bases change did not involve a change to Tier 1 information, Tier 2* information, or further TS changes. A 10 CFR 52, Appendix D, Section VIII / 50.59 screen/simplified evaluation determined that NRC approval was not required for this TS Bases change.
Page 3 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2018-118          License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            162 Unit 4 Amendment No.:            160 Departure

==Title:==
Changes to Passive Residual Heat Removal (PRHR) Instrumentation Minimum Inventory Displays Brief Description of the Plant-Specific Departure:
This activity made changes to plant-specific Tier 1 and UFSAR Tier 2 information and Technical Specifications Bases (TSB) to identify passive residual heat removal (PRHR) heat exchanger (HX) inlet isolation valve status and PRHR HX control valve status as requiring main control room (MCR) and remote shutdown workstation (RSW) display and alert indications. Additionally, a change was made to remove duplicate Tier 2 information from a document that is incorporated by reference into the UFSAR. Additional changes were made to UFSAR Tier 2 information and TSB to revise post-accident monitoring attributes for the in-containment refueling water storage tank (IRWST) to normal residual heat removal system (RNS) suction valve status and to update other post-accident mitigation text discussions in the UFSAR to conform with information provided elsewhere in the design and licensing bases.
This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC, and the Technical Specifications (TS) Bases.
Summary of the Evaluation:
This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-030) was submitted to the NRC.
The NRC approved this License Amendment and Exemption Request and issued License Amendments 162 and 160 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.
Additional changes were made to the Technical Specifications Bases and Tier 2 information with regard to post-accident monitoring and mitigation 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, 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, 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.
That portion of the departure did not involve a change to Tier 1 information, Tier 2* information or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required.
Page 4 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2018-120           License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           161 Unit 4 Amendment No.:           159 Departure

==Title:==
Routing of Class 1E Divisional Raceway Supporting Passive Containment Cooling Brief Description of the Plant-Specific Departure:
This activity rerouted the electrical raceways which are intended to support Class 1E dc and Uninterruptible Power Supply (UPS) System (IDS) Class 1E cabling supporting passive containment cooling system (PCS) components located in the PCS valve room.
In addition, the fire protection analysis in UFSAR Appendix 9A was revised as necessary to address internal discrepancies and were updated as a result of the rerouting electrical raceways.
This departure resulted in changes to the UFSAR (plant-specific DCD), Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC.
Summary of the Evaluation:
This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-18-028) was submitted to the NRC.
The NRC approved this License Amendment and Exemption Request and issued License Amendments 161 and 159 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.
Portions of the changes to the fire protection analysis 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, 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. These portions of the plant specific departures 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 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-031          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Changes Related to Containment and Auxiliary Building Radiation Zones Brief Description of the Plant-Specific Departure:
This activity updated the radiation dose information in UFSAR Chapters 11, 12, 15 and tables in Appendix 3D and Appendix 15A to reflect the results of more detailed analyses. This activity also updated various aspects of the plant design that have been finalized, verified or updated assumptions, and improved the accuracy of previous analyses.
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, did not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.
This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.
Page 6 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-036          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Protective Function Variables and Associated Response Time Requirements Brief Description of the Plant-Specific Departure:
This activity involved changes where channel accuracies were removed from the UFSAR and replaced with a reference indicating that accuracies are accounted for in the setpoint methodology. Similarly, the typical response times were replaced with response times used in the accident analysis. Information in WCAP-15776 that duplicates UFSAR material was removed. Finally, setpoints and time delays were revised to align with the accident analysis.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel sever accident assessment.
This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D Section VIII screening determined that NRC approval was not required prior to implementing this departure.
Page 7 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-037             License Amendment:             Yes  No Exemption:                     Yes  No Unit 3 Amendment No.:          N/A Unit 4 Amendment No.:          N/A Departure

==Title:==
Clarify a "loss of the plant ac electrical system" as Used in UFSAR Section 9.4 Brief Description of the Plant-Specific Departure:
This activity revised the UFSAR to clarify terminology consistent with other locations in the UFSAR. References to a loss of the plant ac electrical system was revised to refer to a loss of normal ac power and offsite power consistent with the description of the loss of power events identified within 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 system, structure, or component (SSC) such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel sever accident assessment.
This departure did not involve a change to 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 is not required prior to implementing this departure.
Page 8 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-038          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Removal of VBS System Fire Damper From MSIV Room Roof Penetration Brief Description of the Plant-Specific Departure:
The activity removed a combination fire/smoke damper from the nuclear island nonradioactive ventilation system (VBS) design and reduced the fan static pressure for the Division A & C Class 1 E Battery Room Exhaust Fans.
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, 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 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-040            License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Revision of Bases for TR 3.6.2 to provide additional basis for the identified Applicability MODES Brief Description of the Plant-Specific Departure:
This activity revised the Technical Requirements Manual (TRM) to adequately describe the bases for the selection of Applicability MODES for non-safety related hydrogen igniters and make an editorial correction.
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 system, structure, or component (SSC) such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 10 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-044           License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Correction of Minor Errors in the UFSAR Chapter 7 and Technical Specifications Bases Brief Description of the Plant-Specific Departure:
This activity resulted in changes to the UFSAR (plant-specific DCD) Chapter 7 for consistency with the current Technical Specifications (TS) requirements.
Summary of the Evaluation:
This plant-specific departure and the Technical Specification Bases change activity 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 and activity 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 these changes.
Page 11 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-046          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Diverse Actuation System Planning and Functional Design Changes Brief Description of the Plant-Specific Departure:
This activity revised the UFSAR and incorporated by reference document WCAP-17184 to incorporate previously approved changes shown in UFSAR Appendix 7A.3, b) the closure of CSI (a defunct company), a consistent description of manual and automatic signal conditioning equipment, an updated reference for NRC approval, a consistent description of what drives diverse actuation system (DAS) actuations to completion, a conservatively increased time window for select DAS manual commands, removal of information that duplicates other licensing basis text, and removal of descriptions of a seal-in circuit at the motor control center for DAS-controlled motor operated 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 system, structure, or component (SSC) such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel sever accident assessment.
This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D Section VIII screening determined that NRC approval is not required prior to implementing this departure.
Page 12 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-047          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Hydrogen Igniters 15 and 16 Location Change Brief Description of the Plant-Specific Departure:
This activity relocated two nonsafety-related hydrogen igniters so that they are as close as feasible to the oxygen coming through the vacuum breaker vents into the in-containment refueling water storage tank (IRWST).
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, 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, 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 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-048           License Amendment:                 Yes  No Exemption:                         Yes  No Unit 3 Amendment No.:              N/A Unit 4 Amendment No.:              N/A Departure

==Title:==
Descriptions of VBS Operation for Fires in Areas Containing MCR/CSA Equipment Brief Description of the Plant-Specific Departure:
This activity changed four nuclear island nonradioactive ventilation system (VBS) dampers from combination fire/smoke dampers to fire dampers, changed two VBS outdoor air inlet dampers to an opposed blade design, added clarifying detail concerning the separation of the Class 1E electrical room HVAC subsystem, and changed the UFSAR descriptions of how the VBS might operate to control smoke during a fire in one of the fire areas containing main control room /
control support area (MCR/CSA) HVAC subsystem equipment.
This departure resulted in change to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
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 screening and evaluation determined that NRC approval was not required prior to implementing this departure.
Page 14 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-049          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Relocation of RCS Temperature Elements Brief Description of the Plant-Specific Departure:
This activity relocated two reactor coolant system temperature elements (in parallel automatic depressurization system discharge lines) from upstream of the adjacent orifice to downstream of the adjacent orifice in a UFSAR Chapter 5 Figure.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 15 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-050          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Safe Shutdown Evaluation for Fire Zone 1100 AF 11303 Brief Description of the Plant-Specific Departure:
This activity made changes to correct the temperature instrument locations inside containment.
This activity also made consistency and editorial changes within UFSAR Chapter 9A.
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, 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 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-051           License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Exemption from the Requirements of 10 CFR Part 26 Visitor Access Requirements Brief Description of the Plant-Specific Departure:
This activity made changes to UFSAR Appendix 1A to reflect an exemption granted by the NRC from the requirements of 10 CFR 26.4(f) to permit SNC to use technical and vendor experts to construct or direct the construction of safety- or security-related systems, structures, and components for a limited period of time as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26.
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
In accordance with the provisions of 10 CFR 26.9, Specific Exemptions, SNC requested an exemption from the requirements of 10 CFR 26.4(f). 10 CFR 26.4(f) requires individuals who construct or direct the construction of safety- or security-related structures, systems, and components (SSCs) to be subject to a fitness-for-duty (FFD) program that meets 10 CFR Part 26, Subpart K, requirements. The requested exemption was granted by the NRC by letter dated June 7, 2019. The approved exemption permits SNC to use technical and vendor experts to construct or direct the construction of safety- or security-related SSCs for a limited period of time as a visitor under the control of an escort subject to the FFD requirements of 10 CFR Part 26. This LDCR incorporates changes into the licensing basis (UFSAR) that address the exemption granted by the NRC. Therefore, NRC approval was required, and obtained, prior to implementation of this activity (exemption from 10 CFR 26.4(f)). (Note that further NRC approval is not required to implement the UFSAR changes, as they are within the scope of the exemption that was granted by the NRC.)
Page 17 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-052          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Cable Tray Reclassification Brief Description of the Plant-Specific Departure:
This activity made changes to plant-specific Tier 2 information in the UFSAR to reclassify cable trays in raceway systems that carry Class 1E circuits, to clarify that the cable trays are Equipment Class D, seismic Category II (D/II) components and are installed on seismic Category I supports to make up a seismic Category I raceway 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, 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 18 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-053          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Revise and Clarify Ultrasonic Examination Requirement for Valve Bodies, Bonnets, Discs, and Stems Brief Description of the Plant-Specific Departure:
The activity involved changes to the nondestructive examination requirements for reactor coolant system (RCS) 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, 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, 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 19 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-055          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Turbine-Generator Control System Changes Brief Description of the Plant-Specific Departure:
This activity made changes to the main turbine control and diagnostic system, including the normal turbine speed control function, the power/load unbalance circuit, the turbine control and protection system for the thrust bearing trip device, the emergency and backup turbine overspeed trip functions, and the high moisture separator/reheater level trip function.
This departure resulted in changes to the Tier 2 information in 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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 20 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-056          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Addressing Missing Lead Pipe Shield and Incorporating Post-Accident Zone Changes Brief Description of the Plant-Specific Departure:
This activity involved changes to, or addition of, radiation zone boundaries, access pathways, dominant post-accident sources, and radiation zone designations to various rooms and yards in the plant radiation zones normal operations/shutdown and the radiation zones post-accident figures in the UFSAR. This activity also revised 1-year post-accident total integrated doses for Environmental Zones 5 and 9 and added information to show the total integrated dose in the spent fuel and spent resin handling areas inside and outside containment. In addition, several editorial and/or consistency changes were made to UFSAR Chapter 12 text and figures.
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, 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 21 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-059          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
UFSAR Reference to 10 CFR 50.55a Affected by Rule Change Brief Description of the Plant-Specific Departure:
This activity made changes within the UFSAR to change references of 10 CFR 50.55a(a)(3) to 10 CFR 50.55a(z) because of a 2014 rule change to 10 CFR 50.55a which relocated the requirements related to "requests for alternatives" from 10 CFR 50.55a(a)(3) to 10 CFR 50.55a(z).
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 22 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-060          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Removal of Flow Transmitter Control Interlocks for VAS and VBS Supply Fans Brief Description of the Plant-Specific Departure:
This activity eliminated the automatic trip on low air flow of the radiologically controlled area ventilation system (VAS) auxiliary/annex building ventilation subsystem and the VAS fuel handling area ventilation subsystem, added the power generation design basis temperature range (60-80&#xba;F) of the main control room emergency habitability system (VES) air storage room, and eliminated the high airflow setpoint for the nuclear island nonradioactive ventilation system main control room / control support area ventilation subsystem and the two independent Class 1E electrical room HVAC 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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 23 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-061          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Pressurizer Water Level Control and Pressurizer Pressure Control Systems Design Change Brief Description of the Plant-Specific Departure:
This activity made changes to the design of the plant control system pressurizer water level control and pressurizer pressure control systems. The pressurizer water level control system was changed to no longer shift the reference level to account for Tavg fluctuations. The pressurizer pressure control system was changed to no longer actuate the backup heaters on a large insurge of water to the pressurizer and to no longer actuate an anticipatory 100%
pressurizer spray demand upon a large load rejection.
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, 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 24 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-062          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
PCS Electrical Raceway Routings Brief Description of the Plant-Specific Departure:
This activity relocated the Class 1E dc and Uninterruptible Power Supply System (IDS) raceways and cables that support passive containment cooling system (PCS) components located in the PCS valve room (Room 12701) that are currently embedded in the shield building due to structural interferences introduced due to the enhanced shield building design. The scope of this change activity also impacted electrical raceways routing through Room 12541 (upper annulus) to the Room 12701 (PCS valve room).
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 25 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-063           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Revision to UFSAR Subsection 9.1.3.1.3.1 to Clarify 120 hrs for Core Offload Start Not an Operational Restriction Brief Description of the Plant-Specific Departure:
This activity clarified the appropriate code related to material procurement for the new and spent fuel storage racks to be ASME Section II, Part A. The capability of the spent fuel pool cooling system (SFS) was clarified in a partial core off-load scenario to not limit when the off-load may begin. The descriptions of the fuel transfer tube quick opening transfer tube closure were made to consistently refer to the component as a hatch/blind flange.
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, did not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.
This departure did not involve a change to Tier 1 information, Tier 2* information, or the Technical Specifications. A 10 CFR 52 Appendix D, Section VIII screening/simplified evaluation determined that NRC approval was not required prior to implementing this departure.
Page 26 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-064          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Technical Requirements Manual (TRM) 3.9.1 Container Barrier Clarifications Brief Description of the Plant-Specific Departure:
This activity resulted in changes to the Technical Requirements Manual (TRM) 3.9.1 Bases for Surveillance TRS 3.9.1.2, Containment Penetrations, which is incorporated by reference into the Updated Final Safety Analysis Report (UFSAR) as standard content. The change clarified appropriate compliance with testing frequencies to verify the required Containment Air Filtration System can maintain a pressure when alternate barrier configuration has changed. Changes also made to consistently refer to the phase alternate barrier in TRM 3.9.1 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 27 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-065          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Corrections to WCAP-15871, Document No. APP-0000-N4R-001 in support of Licensing Change Package NL-0444 Brief Description of the Plant-Specific Departure:
This activity changed compliance statements in incorporated by reference document WCAP-15871 to align the assessment described in WCAP-15871 with the minimum flow requirement for the Class III seismic standpipe description currently provided in UFSAR Chapter 9 and completed an incomplete compliance statement regarding the fire resistance ratings of barriers enclosing stairways, elevator shafts, and other vertical shafts and plenums and openings in such barriers. This activity also revised a Chapter 9 table to address an exception to NFPA 14, Section 3-6.1 whereby pressure instruments with local and remote readout capability at the plant control system (PLS) that meet or exceed the NFPA 14 requirement are provided in lieu of the listed dial spring pressure gauges.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 28 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-066          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Squib Valve Qualification Time Brief Description of the Plant-Specific Departure:
This activity made a revision to UFSAR Chapter 6 text to replace several days with 72 hours with respect to the timing of an automatic depressurization without a reactor coolant system break and with condensate return when the in-containment refueling water storage tank level decreases very slowly and recirculation may not initiate for 72 hours.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 29 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-067          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Exception to Vacuum Box Examination in UFSAR Subsection 3.8.4.2 Brief Description of the Plant-Specific Departure:
This activity made changes to UFSAR Chapter 3 text to add an exception that vacuum box testing is not required where geometry prevents vacuum box testing from being performed and where an alternative leak detection method can be performed.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 30 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-068          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Modification to Negative Pressure Control Scheme for VAS, VHS & VRS Brief Description of the Plant-Specific Departure:
This activity made changes to the design of the radiologically controlled area ventilation system (VAS), the radwaste building HVAC system (VRS), and the health physics and hot machine shop HVAC system (VHS) to maintain a slightly negative pressure in the radiologically controlled areas of the plant by maintaining a constant supply airflow and balancing the exhaust flow for each area served to a constant air flow that is greater than the supply air flow. High and low air flow rate alarms were added as needed to inform operators of abnormal system performance that could affect the building air flow. This activity made revisions to UFSAR Chapters 9 and 12 to reflect these changes.
This departure made 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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 31 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-070          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Removal of Sound Powered Phone from Annex Building Computer Room Brief Description of the Plant-Specific Departure:
The sound-powered phone in Area 4034 - Computer room L3 was removed.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 32 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-071            License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Defining Turbine Stop Valve and Turbine Control Valve Operability for Tech Spec 3.7.2 Brief Description of the Plant-Specific Departure:
This activity made changes to UFSAR Chapters 3 and 10 for consistency with the design of the turbine inlet steam lines and the intent of the current Technical Specifications (TS) limiting condition for operation (LCO) 3.7.2 requirement. Additionally, TS 3.7.2 Bases were also revised for consistency with the design of the turbine inlet steam lines and the intent of the current TS LCO 3.7.2 requirement.
This departure resulted in changes to the UFSAR (plant-specific DCD) and TS Bases.
Summary of the Evaluation:
This plant-specific departure and the Technical Specification Bases change activity 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 and activity 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 these changes.
Page 33 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-072          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Operational Limitations During Unavailability of Undervoltage Relays Supporting ESF Actuations Brief Description of the Plant-Specific Departure:
The activity involved changes to clarify and add details to the licensing basis as described in the UFSAR regarding operational limitations when substituting the Class 1E DC and Uninterruptible Power Supply (UPS) System (IDS) spare battery and spare battery charger to any one IDS division 250 Vdc switchboard.
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, 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 34 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-073          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
VBS Heating Controls Revision for 1E Electrical Rooms Brief Description of the Plant-Specific Departure:
This activity changed the temperature control input for the nuclear island nonradioactive ventilation system (VBS) Class1E electrical room hot water temperature control valve from the VBS Class1E electrical room air handling unit (AHU) return air temperature controller to the VBS Class1E electrical room AHU supply air temperature controller. UFSAR Chapter 9 was revised to reflect this design change.
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 35 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-074          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Changes to the Fire Protection System for the Diesel Generator building and Annex Building Brief Description of the Plant-Specific Departure:
This activity removed the fire and smoke detection interlocks for the ventilation system, added fire detectors, and added a water-based fire protection system for the Diesel Generator Building and the Ancillary Diesel Generator Room located in the Annex Building. This change also corrected the room number for the waste monitor tank room on a UFSAR Chapter 9 figure.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 36 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-075          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Correction of Cask Loading Pit to Cask Washdown Pit in UFSAR Table 11.2-4 Brief Description of the Plant-Specific Departure:
This activity made corrections to a UFSAR Chapter 11 table to identify the cask washdown pit (CWP) instead of the cask loading pit as the pit used for temporary storage of waste fluid.
UFSAR Chapter 9 text was revised to clearly state that the CWP is connected to both the spent fuel pool for spent fuel cooling needs and to the liquid radwaste system (WLS) for temporary storage of WLS effluents, but that the CWP can only perform either spent fuel pool cooling or temporary storage of WLS effluents at a time.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 37 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-078            License Amendment:             Yes  No Exemption:                     Yes  No Unit 3 Amendment No.:          N/A Unit 4 Amendment No.:          N/A Departure

==Title:==
Technical Specification Bases 3.4.15 Change Brief Description of the Plant-Specific Departure:
The activity involved a change to the Technical Specifications Bases 3.4.15 description of how Reactor Coolant System Pressure Isolation Valve leak test data is evaluated to determine acceptable test results.
This departure resulted in changes to the Technical Specifications Bases.
Summary of the Evaluation:
This Technical Specifications Bases change activity 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 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 38 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-082            License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Consistent Description of Seismic Criteria Used to Determine the Need for Plant Shutdown Brief Description of the Plant-Specific Departure:
This activity made clarifications to reflect that the one-third safe shutdown earthquake (SSE) exceedance consists of surpassing both the specified response spectrum limit and the cumulative absolute velocity limit.
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, 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 39 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-083          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Electrical System Changes Brief Description of the Plant-Specific Departure:
This activity involved changes to several UFSAR subsections to incorporate electrical design changes, clarify the design descriptions, address missed impacts, reduce the potential for operator error and provide consistency and alignment between the UFSAR and design documents.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 40 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-084           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Consistency Changes to the UFSAR to Refer to the Correct Version of the ASME Code, Correct the Containment Vessel Design Pressure Test Multiplier, and Correction of Environmental Zone Room Numbers Brief Description of the Plant-Specific Departure:
This activity made consistency changes to replace the citation of Regulatory Guide 1.18 with reference to ASME Code, Section III, Paragraph NE-6321, to correct the design pressure multiplier from 1.15 to 1.1, and to correctly note the test pressure is a minimum, not maximum value. Additionally, missing rooms were added to the list of room numbers for Environmental Zone 7, and a room is added to the list of rooms subject to submergence conditions in Environmental Zone 7.
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, 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 41 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-086            License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Revision of UFSAR Chapter 14 Startup Testing Abstracts Brief Description of the Plant-Specific Departure:
The activity involved changes to the initial test program as described in UFSAR Chapter 14 to reflect the Vogtle Unit 3 and 4 plant design, clarify performance criteria, or modify the test methods based on lessons learned from the China AP1000 plant startup testing program. An additional change is made to Technical Specifications Bases 3.9.3 to correct the source range neutron flux monitors instrument range to be consistent with the design and licensing basis.
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 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 and activity 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 these changes.
Page 42 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-091           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Resolution of Effluent Radiation Monitoring Function Class Inconsistency Brief Description of the Plant-Specific Departure:
This activity reclassified the effluent radiation monitoring function from AP1000 equipment Class C to AP1000 equipment Class E by moving the description of this function with UFSAR Chapter 9.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 43 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-094           License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Changes to Chapter 14 Startup Tests for Rod Control Brief Description of the Plant-Specific Departure:
This activity revised the Initial Startup Tests descriptions in UFSAR Chapter 14 text by removing the two reactor coolant pump coastdown tests from the reactor coolant system pre-critical flow coastdown tests; removing the cold control rod tests before first criticality; clarifying the use of temporary neutron detectors as optional during initial fuel load testing; and removing the test requirement for a non-existent low capacity chilled water system (VWS) pump discharge pressure monitoring.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 44 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-096          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Change to Condenser Water Box Leakage Testing Methods Brief Description of the Plant-Specific Departure:
This activity changed the requirement for in-place leak testing of the condenser water boxes in UFSAR Chapter 10 by replacing the existing prescriptive requirement for condenser shell testing with a requirement to perform leak testing in accordance with the in-leakage detection methods identified in the 2008 version of ASME PTC 19.11.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 45 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-097           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Post-Core Reference Report Editorial Corrections Brief Description of the Plant-Specific Departure:
A change was made to provide clarification and consistency related to the topics covered within WCAP-17524-P-A Rev. 1, AP1000 Core Reference Report, identified since the previous incorporation of the WCAP identified changes.
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 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 and activity 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 these changes.
Page 46 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-098          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Updates to the External Pressure Analysis Brief Description of the Plant-Specific Departure:
This activity made changes to revise the description of the containment external pressure analysis including analysis parameters for containment initial humidity, containment wind speed at the riser region, and the containment heat rate. The results for the performance of the vacuum relief system and the maximum expected containment external pressure versus time were also 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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel severe accident assessment.
This departure did not involve a change to Tier 1 information, Tier 2* information, or the COL including the Technical Specifications. A 10 CFR 52 Appendix D Section VIII screening determined that NRC approval is not required prior to implementing this departure.
Page 47 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-099          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Plant Vent Radiation Monitor Scale Model Testing Brief Description of the Plant-Specific Departure:
The activity involves a change to permit the use of scale model testing of plant vent flow per ANSI N13.1-1999 to demonstrate compliance with the Radiation Monitoring System preoperational test requirements as required in UFSAR Chapter 11.
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, 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 48 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-104          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             164 Unit 4 Amendment No.:             162 Departure

==Title:==
Steam Generator System / Main Steam System UFSAR/Tier 1 Figure Discrepancies Brief Description of the Plant-Specific Departure:
The auxiliary steam header isolation valve was relocated from the same header as the turbine bypass valve to a new header, all the turbine bypass valves were relocated to the same branch line, and an editorial revision was made to a UFSAR Chapter 10 figure.
This departure resulted in changes to the UFSAR (plant-specific DCD) and Tier 1 (plant-specific DCD) and associated COL Appendix C ITAAC.
Summary of the Evaluation:
This departure made changes to Tier 1 information, and UFSAR Tier 2 information that involved a change to or departure from Tier 1 (and associated COL Appendix C); therefore, a License Amendment and Exemption Request (LAR-19-004) was submitted to the NRC.
The NRC approved this License Amendment and Exemption Request and issued License Amendments 164 and 162 to COL NPF-91 for VEGP Unit 3 and COL NPF-92 for VEGP Unit 4, respectively.
Portions of 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.
These portions 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 prior to implementing this departure.
Page 49 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-108          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Inconsistent Vogtle 3&4 UFSAR Criticality Monitoring Requirements Brief Description of the Plant-Specific Departure:
The activity involved changes to the UFSAR to remove references to 10 CFR 70.24 and replace with references to 10 CFR 50.68, to note that Regulatory Guide 8.5 has been withdrawn, and to accordingly remove references to this Regulatory Guide where appropriate.
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, 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 50 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-122          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Inconsistent Reference to ASME Section III Code of Record Brief Description of the Plant-Specific Departure:
This activity made changes to a UFSAR Chapter 10 table to update a note to reference ASME Section III 1998 Edition with the 2000 Addenda.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 51 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-125          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Discrepancies with Design Transient Document Brief Description of the Plant-Specific Departure:
This activity revised the descriptions of control rod drop transients and reactor coolant system design transients. The transient descriptions are changed for clarity, consistency between UFSAR sections, and clarity/consistency with supporting transient analyses.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 52 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-126          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Updates to AP1000 Tritium Production Rate Brief Description of the Plant-Specific Departure:
This activity made revisions to the expected amounts and sources of tritium calculated to be produced and released into the Reactor Coolant 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, 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, 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 53 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-128           License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Updating DCD to Reference Correct Plans in Section 7.1.2.14.1 Brief Description of the Plant-Specific Departure:
This activity replaced three obsolete documents identified for the protection and safety monitoring system (PMS) planning phase documents with new planning phase documents.
Specifically, Document 1, Document 2, and Document 3 in UFSAR Chapter 7 were replaced with four other PMS planning phase documents and the title of Document 4 was changed.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not involve a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 54 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-129            License Amendment:              Yes  No Exemption:                      Yes  No Unit 3 Amendment No.:           N/A Unit 4 Amendment No.:           N/A Departure

==Title:==
Tavg Uncertainty Discrepancy Brief Description of the Plant-Specific Departure:
This activity made revisions to UFSAR Chatper 3 text to remove explicit references to 4&deg;F.
Technical Specifications Bases for SR 3.4.1.1 and SR 3.4.1.2 were modified to also describe the averaging of pressurizer pressure and Tavg indications.
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 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 and activity 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 these changes.
Page 55 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-130          License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
PXS P&ID Updates to Gas Intrusion Mitigation Notes Brief Description of the Plant-Specific Departure:
This activity made changes to UFSAR Chatper 5 and 6 figures to provie clarification by identifying the layout requirements for gas intrusion mitigation related to vents for passive core cooling system piping segments which perform a safety-related function.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not result in a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 56 of 57

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:        LDCR-2019-131           License Amendment:                Yes  No Exemption:                        Yes  No Unit 3 Amendment No.:             N/A Unit 4 Amendment No.:             N/A Departure

==Title:==
Clarification of SG Secondary Side Hydrostatic Test Parameters Brief Description of the Plant-Specific Departure:
This activity changed the minimum temperature for hydrostatic testing of the steam generator secondary side from 120&deg;F to 70&deg;F.
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 such that a design function is adversely affected, did not impact plant operating procedures or a method of control that adversely affects a design function, did not involve a revision or replacement to a method of evaluation, did not represent a test or experiment outside the reference bounds of the design basis, and did not alter the assumptions or results of the ex-vessel 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 determined that NRC approval is not required prior to implementing this departure.
Page 57 of 57

Southern Nuclear Operating Company ND-19-1416 Enclosure 2 VEGP Units 3 and 4 Tier 2* Departure Report for the Period of May 11, 2019 through November 11, 2019 (4 pages, including this cover page)

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-069           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Update the UFSAR, including WCAP-15776, to align the IEEE 603-1991 Compliance Evaluation with the PMS Design Brief Description of the Plant-Specific Departure:
This activity involved changes to several UFSAR Chapters to align the AP1000 plant IEEE 603-1991 compliance evaluation in WCAP-15776, Revision 1, with the existing protection and safety monitoring system (PMS) design, to provide design description clarifications, and to remove duplicated text. The compliance evaluation changes regarding WCAP-15776, Revision 1 excluded Section 3.13 for which Revision 0 remains the applicable revision.
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
This departure included departures from Tier 2* information and changes to Tier 2 information in the UFSAR (plant-specific DCD) that involved these Tier 2* departures, including incorporated by reference documents. These Tier 2* changes and involved Tier 2 changes were evaluated using the qualifying criteria for Tier 2* Departure Evaluations, and it was determined that this activity did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a). This departure also involved additional Tier 2 changes that did not involve departures from Tier 2* material.
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, 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.
Page 2 of 4

ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:          LDCR-2019-076            License Amendment:             Yes  No Exemption:                     Yes  No Unit 3 Amendment No.:          N/A Unit 4 Amendment No.:          N/A Departure

==Title:==
Wall 1 Reinforcement Configuration Change Brief Description of the Plant-Specific Departure:
This activity revised the configuration of reinforcement in Wall 1 of the auxiliary building. The design of Wall 1 is changed to show the use of a #11@6" U-bar spliced to the #11@6" transverse reinforcement and to show the #8@12" rebar and terminating with a 180 degree standard hook (rather than a 90 degree standard hook).
This departure resulted in changes to the UFSAR (plant-specific DCD).
Summary of the Evaluation:
This departure included departures from Tier 2* information. These Tier 2* changes were evaluated using the qualifying criteria for Tier 2* Departure Evaluations, and it was determined that this activity did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a).
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, 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.
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ND-19-1416 VEGP Units 3 and 4 Departure Report for the Period of May 11, 2019 through November 11, 2019 Departure Number:         LDCR-2019-085           License Amendment:               Yes  No Exemption:                       Yes  No Unit 3 Amendment No.:            N/A Unit 4 Amendment No.:            N/A Departure

==Title:==
Additional Modifications to Governing AP1000 Codes and Standards Brief Description of the Plant-Specific Departure:
This activity made changes to codes and standards cited in the UFSAR. The changes were necessary so that the codes and standards are cited correctly, clearly, and consistently within 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 did not qualify as requiring prior NRC approval in accordance with License Condition 2.D.(13)(a). This departure also involved additional Tier 2 changes that did not involve departures from Tier 2* material.
This plant-specific departure did not result in a modification, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, 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.
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