ML20272A121

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NRC-2020-000234 - Resp 1 - Interim, Agency Records Subject to Request Enclosed
ML20272A121
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Issue date: 09/22/2020
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NRC/OCIO
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ML20272A119 List:
References
FOIA, NRC-2020-000234
Download: ML20272A121 (167)
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 MEMORANDUM TO: Victor E. Hall, Chief Vogtle Project Offiice Office of Nuclear Reactor Regulation FROM: Jennivine Rankin, Project Manager Vogtle Project Offiice Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF A PUBLIC MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON JANUARY 16, 2020 The U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with Southern Nuclear Operating Company (SNC) on January 16, 2020. The purpose of the meeting was to discuss SNC's request for alternative regarding the inservice test interval code edition for Unit 4 and an upcoming license amendment request (LAR) regard ing Unit 3 auxiliary building Wall 11 seismic gap requirements.

The meeting notice can be found in Agencywide Documents Access and Management System (ADAMS) Accession No. ML19322C811. The meeting notice is also posted on the NRC public website. Enclosures 1 and 2 are the meeting agenda and attendance list for the meeting, respectively. The other documents referen ced during the discussion can be found at the ADAMS Accession Nos. given below:

  • IST-ALT-01: Alternative Requirements for ML19304C432 lnservice Test Interval Code Edition, Unit 4

V. Hall Summary of Meeting:

rrechnicaf Discussion of Request for Alternative Regarding the lnservice Test Interval Code Commented (RJ1]: Iii Nick - Can you please review this section mid help me fill in the blnnks7 I tried but oouldn 'I follow nil Edition for Unit 4 1hc n:,1sons for the d...:,ci.sion. P1c~sc foci free to OOi1. delete. modify as needed.

On January 23, 2020, staff from the NRC conducted a public meeting with representatives from SNC to discuss IST-ALT-01, which request authorization to use an alternative to the requirements of 10 CFR 50.55a(f)(4)(i) and 10 CFR 50.55a(f)(4)(ii) regard ing use of the latest edition and addenda of the ASME Operation and Maintenance of Nuclear Power Plants Code using in initial and successive inservice test intervals. The NRC staff is considering authorizing the alternative for the first 10-year interval, rather than for the life of the plant, as requested.

The NRC staff explained the reason for the limited authorization is due to ................... In addition, this is consistent with similar requests in the operating fleet. The NRC took an action to determine if an alternative request supplement was needed to proceed with authorizing the alternative for the first 10-year interval.

At the conclusion of the presentation, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from the public.

Pre-Submittal Discussion of LAR Regarding Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements pn] J~nuary 23, 2_020, staff from _the NRC con9ucted a public meeting with representativ_es from Commented [RJ2]: Amit anJ Pravin - Plcosc review this section for 1echnical accuracy. Please adjust, add. delete, as needed.

SNC to discuss a draft LAR regarding Unit 3 auxiliary building Wall 11 seismic gap requirements. SNC stepped through the draft LAR and the NRC staff noted the fol lowing for Thanks!

SNC to consider:

  • Clarify the elevations referenced in the LAR refer to intermediate elevation 141 '-0"s between floors.
  • Add a figure to the LAR to clearly show the distance between column line I of nuclear island and Wall 11H, the turbine first bay gap, and the gap betweei::iat the annex

~building and Wall 11 from Wall I of NI. Provide both buildings gap length(linear dimension) from Wall I to Col line J ??cof NI

  • Clarify that Appendix C, License Condition 2.D.12.(g)(1) which requires update to the seismic interaction analysis to reflect the as-built information will confirm that the gap is sufficient.
  • Provide additional information on the settlement oat;. monitonnq for the NRC staff to confirm the actual settlement trends and future p_rQjected total settlement

- clarify wording "SASSI is equal to or larger than 1.73" on page 7 of Enclosure 1 . The staff thinks wording "equal to" is not required. that SASSI value is greater than the l~asis-r~1.1ifeffieAl-<*+ffi6A-R'liAirnllffi-SeisrniG-§aJr.

At the conclusion of the presentation, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from the public.

Docket Nos.: 52-025 52-026

Enclosure:

V. Hall As stated cc w/encls: See next page

  • via e-mail NRC-001 OFFICE PM: NRR/VPO LA: NRR/VPO PM: NRRNPO BC: NRR/VPO NAME JRankin* (c) RButler* CSantos* VHall*

DATE 1/ /2020 1/ /2020 1/ /2020 1/ /2020 OFFICE PM: NRR/VPO ............. ............... .............

NAME JRankin (s) -----........_ -----........_ --..........._

DATE 1/ /2020 ~ ............... --..........._

AGENDA FOR PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION (NRC)

Thursday, January 23, 2020 Teleconference 9:00 a.m. - 12:00 p.m.

PURPOSE: To discuss issues associated with the safety review of licensing actions for Southern Nuclear Operating Company's (SNC) Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

9:00 a.m. Opening Remarks NRC 9:10 a.m. Discussion of Identified Topics NRC/SNC Opportunity for Public Comment NRG/Public Open Portion Concludes CLOSED (If needed) NRC/SNC 12:00 p.m. Adjourn Enclosure 1

PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION Thursday, January 23, 2020 One White Flint North, Room 0-1184 9:00 a.m. - 12:00 p.m.

List of Attendees Name Organization Representing the Nuclear Regulatory Commission Jennivine Rankin Jukka Kallionpaa Don Habib NRRNPO Tanny Santos Vic Hall Amitava Ghosh Pravin Patel NRR/DEX Nick Hansino Representing Industry Chris Pendleton*

Amy Chamberlain*

Mark Humphrey*

Eddie Grant*

Adam Quarles*

Jason Weathersby* Southern Nuclear Operating Company Johrn Varnadore*

Yasmeen Arafeh*

Stephanie Agee*

Neil Haggerty*

Anthony Schodel*

Ken Clough* Westinghouse Electric Company Brian Barnett*

Public Participants Steve Franzone* Florida Power and Light

  • = participated via teleconference Enclosure 2

Vog tle Mailing List (Revised 11/12/2019) cc:

Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 A ir Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham , AL 35243 Brian H. Whitley Regulatory Affairs Director An ne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, B IN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael Yox County Commissioner Site Regulatory Affairs Director Office of the County Commissioner Vogtle Units 3 & 4 Burke County Commission 7825 River Road, Building 302 (ESB)

Waynesboro, GA 30830 Bin 6031 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3

Vogtle Mailing List Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dlfulton@southernco.com (Dale Fulton) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David)

G2NDRMDC@southernco.com (SNC Document Control)

George.Taylor@opc.com (George Taylor) harperzs@westinghouse.com (Zachary S . Harper) james1.beard@ge.com (James Beard)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_ Hegner@dom.com (Joseph Hegner) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth 0 . Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeler@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mphumphr@southernco.com (Mark Humphrey)

MSF@nei.org (Marvin Fertel) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) ppsena@southernco.com (Peter Sena.Ill) r.joshi 15@comcast.net (Ravi Joshi) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak)

Page 2 of 3

Vogtle Mailing List sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver)

William.Birge@hq.doe.gov (William Birge)

X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)

X2hagge@southern.com (Neil Haggerty)

X2wwi11@southernco.com (Daniel Williamson)

Page 3 of 3

From: Greene Delores To: Santos. Cayetano

Subject:

Audit report and memo LAR 20-001 LA reviewed.docx Date: Tuesday, May 26, 2020 7:48:06 AM Attachments: Audit reQQ!1jlnd memo LAR 20-001 LA reviewed.docx Good Morning Ready for your electronic signature.

f5eforeJ !'i;reene Division Administrative Assistant Vogtle Project Office (VPO) 0-1 3H1 6 Office: 301 -4 15-1634 Delores.Greene@nrc.gov

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , O.C. 20555-0001 Note to the requester:

Date, 2020 Final Version available at ML20063H206 MEMORANDUM TO: Victor Hall, Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM : Cayetano Santos Jr., Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT PLAN FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3, REQUEST FOR LICENSE AMENDMENT AND EXEMPTION : UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (LAR 20-001)

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20038A939), Southern Nuclear Operating Company (the licensee) requested an amendment to Combined License (COL) Numbers NPF-91, for Vogtle Electric Generating Plant (VEGP) Unit 3.

The requested amendment proposes changes to COL Appendix C (and plant-specific Tier 1) and corresponding Tier 2* and Tier 2 information in the Updated Final Safety Analyses Report (UFSAR). Specifically, the request proposes to modify the north-south minimum seismic gap requirements above grade between the nuclear island and the annex building west of Column Line I from elevation 141 feet through 154 feet to accommodate as-built localized non conformances.

CONTACT: Cayetano Santos Jr. , NRR/VPO 301-415-7270

V. Hall The Structural , Civil, Geotech , Engineering Branch (ESEA) plans to conduct an audit to gain a better understanding of the proposed changes and to review related documentation and non-docketed information in order to evaluate the acceptability of the proposed changes to the license.

Docket Nos.: 52-025

Enclosure:

Regulatory Audit Plan cc: See next page

NR0-008 OFFICE NRRNPO/PM NRRNPO/LA NRR/DEX/ESEA/BC NRR/DEX/ESEB/BC NAME CSantos RButler DWilliams DATE 2/ /2020 2/ /2020 2/ /2020 OFFICE NRRNPO/BC

~

NAME VHall

~

DATE 2/ /2020 ~

AUDIT OF REPORTS AND CALCULATIONS IN SUPPORT OF REQUEST FOR LICENSE AMENDMENT RELATED TO UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (LAR-20-001)

SOUTHERN NUCLEAR OPERATING COMPANY VOGTILE ELECTRIC GENERATING PLANT, UNIT 3 Docket No.52-025 The purpose of the audit is to review the documentation and calculations needed by the U.S. Nuclear Regulatory Commission (NRC) staff to verify the information and conclusions in the "Request for License Amendment: Unit 3 Auxiliary Building Wall 11 Seismic Ga Requirements (LAR-20-001)," submitted by Southern Nuclear Operating Company (SNC) for the Vogtle Electric Generating Plant (VEGP), Unit 3 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939).

A. BACKGROUND:

In LAR 20-001, proposes changes to COL Appendix C (and plant-specific Tier 1) and corresponding Tier 2* and Tier 2 information in the Updated Final Safety Analyses Report (UFSAR). Specifically, the request proposes to modify the north-south minimum seismic gap requirements above grade between the nuclear island and the annex building west of Column Line I from elevation 141 feet through 154 feet to accommodate as-built localized nonconformances.

B. REGULATORY AUDIT BASIS This regulatory audit is based on the following:

C. REGULATORY AUDIT SCOPE AND METHODOLOGY The audit team will view the documentation and calculations that provide the technical support for LAR 20-001. Information to be reviewed includes:

(1) original analysis and prediction of the total and differential settlements for each structure, (2) settlement measurements of each structure along with the trend analysis of the total and differential settlement with time, especially when substantial loads were added at different construction stages, (3) construction sequence including time lag of construction among these structures.

Enlosure

In addition, the audit team w ill request to discuss these topics with subject matter expert(s).

D. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The staff requests that the documents, data, and calculations regarding the aforementioned topics be made available to the staff in the electronic reading room, especially calculations/documents ...

The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit.

E. AUDIT TEAM The following are the NRC audit team members:

  • Cayetano Santos Jr., Project Manager The licensee contact is Yasmeen Arafeh.

F. LOGISTICS Date: ???, 2020 - ???, 2020 Location: The audit will be conducted remotely using the licensee's electronic reading room and teleconferences. As needed, face-to-face discussions and some document review may occur at:

Westinghouse Electric Company, LLC Washington Operations 11333 Woodglen Drive, Suite 203 Rockville, Maryland 20852 Telephone: 301-881-7040/7042 G. SPECIAL REQUESTS None Cayetano Santos Jr., NRC Project Manager, can be reached at 301-415-7270 or Cayetano.Santos@NRC.GOV.

H. DELIVERABLES On completion of the aud it, the staff will prepare an audit summary report that will be declared and entered as an official agency record in ADAMS. The audit outcome may be used to identify any additional information to be submitted for making regulatory decisions and will assist the staff in the issuance of requests for additional information (if necessary) in completing its review of LAR 20-001.

2

From: Patel, Pravin Sent: Wed, 19 Feb 2020 17:55:47 +0000 To: Williams, Donna Cc: Rankin, Jennivine;Santos, Cayetano;Ghosh, Amitava

Subject:

FW: LAR 20-001

Donna, Please forward email for acceptance of LAR 20-001
Thanks, Pravin From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Wednesday, February 19, 2020 11:41 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

Re: LAR 20-001

Pravin, I also do not have any objection for accepting the LAR.
Thanks, Amit From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Wednesday, February 19, 2020 10:20 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

LAR 20-001

Amit, I have reviewed the LAR. I don't have objection for acceptance. Please let me know if you agree with acceptance.
Thanks, Structural Engineer Nuclear Regulatory Commission Office of Nuclear Reactor Regulation DEX/ESEA 0 -4G07

From: Patel, Pravin Sent: Fri, 1 May 2020 17:44:50 +0000 To: Colaccino, Joseph Cc: Ghosh, Amitava;Patel, Pravin

Subject:

Lar 20-001, path forward

Joe, Amit and I discussed on the Lar 20-001 non-conformance report (in ERR) SV3-1200-GNR-000014 , Rev. 0. Based on Table 3, "Comparison of Vogtle Site Specific Soil Displacement to Annex Building Measured Gap" of the report, a minimum SSE gap 1. 73" with respect to 2.17" measured gap at EL 140' to 154' exists. The Lar is requesting that the gap for the elevation 141' to 154' equal to be 2.0625" (2 1/16"). Therefore, we agreed to path forward to complete SER writeup. The task remains to include the latest document SV3-1200-GNR-0000 14, Rev. 0 in the audit report. We are planning to use the report for the reference purpose for the staff evaluation .

Thanks ,

Structural Engineer Nuclear Regulatory Commission Office of Nuclear Reactor Regulation DEX/ESEA 0-4G07

From: Hall, Victor Sent: Thu, 20 Feb 2020 13 :52 :56 +0000 To : Will iam s, Donna;Santos, Cayetano;Rankin, Jennivine Cc: Pat el, Pravin;Ghosh, Amitava

Subject:

RE: Acceptance Review for Vogtle 3 - LAR 20-001 (EPID: L-2020-LLE-0009)

Super! Thanks Donna!

-Vic From: Williams, Donna <Donna .W ill iams@nrc.gov>

Sent: Wednesday, February 19, 2020 4:05 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Cc: Patel, Pravin <Pravin .Patel@nrc.gov>; Ghosh, Am itava <Amitava.Ghosh@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>

Subject:

Acceptance Review for Vogtle 3 - LAR 20-001 (EPID: L-2020-LLE-0009)

By letter dated February 7, 2020 Southern Nuclear Operating Company submitted LAR 20-001 to make changes to VEGP Unit 3 COL ITAAC, and corresponding UFSAR Tier 2* and Tier 2 information to modify the minimum seismic gap requ irements between the nuclear island and the annex building .

ESEA staff has completed the acceptance review of the LAR and found the submittal is acceptable in accordance with NRR Office Instruction LIC-109. No major information insufficiencies were identified that would prevent the ESEA review from commencing .

Donna Williams Acting Branch Chief NRR/DEX/ESEA U.S. Nuclear Regulatory Commission Phone: 301-415-1322

From: Williams, Donna Sent: Mon, 2 Mar 2020 20:34:38 +0000 To: Santos, Cayetano;Ghosh, Amitava;Patel, Pravin

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXEMPTION: UNIT 3 AUXILIARY BUI LDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

I concur on the audit plan.

Donna Williams Acting Branch Chief NRR/DEX/ESEA U.S. Nuclear Regulatory Commission Phone: 301-415-1322 From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, March 02, 2020 3:10 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Williams, Donna

<Donna.Williams@nrc.gov>

Subject:

RE : ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREM ENTS (EPID NO. L-2020-LLE-0009)

Donna, Please review and concur on the attached audit plan for LAR 20-001. It is based on the input I received from Amit and Pravin.

Thank you Tanny From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Monday, March 02, 2020 2:45 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Patel, Pravin <Pravin .Patel@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISM IC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Tanny:

Here is the updated version of the audit plan with PP_AG extension. The highlights are the updates.

Please let us know if you have any questions.

Thanks a lot.

Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, M arch 02, 2020 2:19 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin < Pravin.Patel@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Amit I understand. Could you please update the draft audit plan I sent you and Pravin?

Thanks Tanny From: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Sent: Monday, March 02, 2020 9:32 AM To: Santos, Cayetano <Cayetano.Santos@ nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: ACCEPTANCE REVI EW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUI LDING WALL 11 SEISMIC GAP REQUIREM ENTS (EPID NO. L-2020-LLE-0009)

Good morning Tanny.

We need the Cale Numbers for the settlement calculations (original prediction) and periodic measurements with trend analysis.

Thanks, Amit

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov From : Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, February 27, 2020 4:31 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BU ILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Pravin/Amit Just wanted to check in and see if you've had a chance to update the draft audit report.

Thanks Tanny From : Patel, Pravin <Pravin .Patel@nrc.gov>

Sent: Tuesday, February 25, 2020 6:22 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Thanks, Pravin From : Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Monday, February 24, 2020 5:02 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY' S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Pravin/Amit Attached is a draft audit plan for LAR 20-001 . Please update/revise as needed.

Thanks Tanny From : Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Monday, February 24, 2020 11:22 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Please send us skeleton of audit plan . we will fill in .

Pravin From : Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, February 24, 2020 11:19 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

Not yet. I understand from Amit this is the information you would like to see:

I need two items on ERR: (1) settlement measurements along with original prediction for each structure and (2) Construction sequence for these structure (which one was first, followed by how much time gap for the next structure including adding of loads on a foundation from major structural additions). I think the tilt they are reporting is from interaction between the two stress

'bulbs' of these structures below the foundation level. I like to verify.

I can let SNC know this but we need to also prepare an audit plan.

Tanny From : Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Monday, February 24, 2020 8:58 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXIEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

DO we have ERR Docs for LAR 20-001?

Pravin

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Friday, February 21, 2020 8:37 PM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>; Brian Whitley (bhwhitle@southernco.com)

<bhwhitle@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>; Kelli Roberts (KROBERTS@southernco.com) <KROBERTS@southernco.com>; Kellenberger, Nicholas

<X2NRKELL@SOUTHERNCO.COM>; Hall, Victor <Victor.Hall@nrc.gov>; Patel, Pravin

<Pravin .Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Williams, Donna

<Donna.Williams@nrc.gov>

Subject:

ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (EPID NO. L-2020-LLE-0009)

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

3535 Colonnade Parkway, Bin N-226-EC Birmingham, AL 35243

SUBJECT:

ACCEPTANCE REVIEW OF SOUTHERN NUCLEAR OPERATING COMPANY'S REQUEST FOR LICENSE AMENDMENT AND EXEMPTION: UNIT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQU IREMENTS (EPID NO. L-2020-LLE-0009)

Dear Mr. Whitley:

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC) submitted a request for a license amendment and an exemption to Combined License (COL)

Number NPF-91 for Vogtle Electric Generating Plant, Unit 3. The requested amendment proposes changes to COL Appendix C (and plant-specific Tier 1) and corresponding Tier 2*

and Tier 2 information in the Updated Final Safety Analyses Report (UFSAR). Specifically, the request proposes to modify the north-south minimum seismic gap requirements above grade between the nuclear island and the annex building west of Column Line I from elevation 141 feet through 154 feet to accommodate as-built localized nonconformances.

SNC has also requested an exemption from the provisions of Title 1O of the Code of Federal Regulations (10 CFR) Part 52, Appendix D, Section 11 1.B, "Design Certification Rule for the AP1000 Design, Scope and Contents," to allow a departure from the elements of the certification information in Tier 1 of the generic Design Control Document.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission staff's acceptance review of these requests. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the staff to complete its detailed technical reviews. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of the 10 CFR, an amendment to the license must fully describe the changes requested, and follow as far as applicable, the form prescribed for original applications. Section 52.79 of the 10 CFR addresses content of technical information required.

This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features , and principal safety considerations .

The staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the staff to complete its detailed technical review and make an independent assessment regarding the acceptability, of the proposed amendment and exemption, in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. You will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.

SNC has requested staff approval of this LAR by August 7, 2020 . The staff intends to complete this action by November 21, 2020. However, the staff will try to expedite its review to have it completed by August 7, 2020 , unless we agree to a different date at a later time due to circumstances beyond our control. The staff estimates that it may take 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> to complete this licensing action.

If you have any questions, please contact me at (301) 415-7270 or Cayetano .Santos@NRC .GOV.

Sincerely, Cayetano Santos, Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation Docket No(s): 52-025

From: Santos, Cayetano Sent: Fri, 22 May 2020 14:31:10 +0000 To: King, Mike

Subject:

RE: Audit Report- Seismic Gap LAR Attachme nts: Audit report and memo LAR 20-001 LA reviewed.docx Here you go From: King, Mike <Michael.King2@nrc.gov>

Sent: Friday, May 22, 2020 10:29 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Hall, Victor <Victor.Hall@nrc.gov>

Cc: Butler, Rhonda <Rhonda.Butler@nrc.gov>

Subject:

Re: Audit Report- Seismic Gap LAR Can you send me attached version?

Thanks!

Mike From: "Santos, Cayetano" <Cayetano.Santos@nrc.gov>

Date: Friday, May 22, 2020 at 10:27 AM To: "Hall, Victor" <Victor.Hall@nrc.gov>, Mike King <M ichael. King2@ nrc.gov>

Cc: "Butler, Rhonda" <Rhonda.Butler@nrc.gov>

Subject:

RE: Audit Report- Seism ic Gap LAR Mike As usual Vic and Rhonda have overachieved and completed their reviews quickly. The audit report is ready to be issued but I wanted to still give you an opportunity to review it beforehand.

Please let me know what you would like to do.

View ADAMS Properties ML20141L698 Open ADAMS Document (Audit report LAR 20-001)

Thanks Tanny From: Hall, Victor <Victor.Hal l@nrc.gov>

Sent: Thursday, May 21, 2020 2:57 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; King, M ike <Michael.King2@nrc.gov>

Subject:

RE: Audit Report- Seismic Gap LAR

Tanny,

I started re-reviewing once Joe reviewed. Looks great -you did a wonderful job coordinating this one.

I concur.

-Vic From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Thursday, May 21, 2020 2:55 PM To: King, Mike <M ichael.King2@nrc.gov>; Hall, Victor <Victor.Hall@nrc.gov>

Subject:

Audit Report- Seismic Gap LAR

Vic, The draft audit report for LAR 20-001 (seismic gap) is available using the link below. Rhonda has graciously agreed to complete her review by Tuesday 5/26. After she completes her review I will be sending it to you for your review and concurrence. Olivia and Julie think it would be beneficial if this report were issued before OGC responds to the hearing request so they can reference it as part of the response. The deadline for OGC is 6/5. So I will be sending it to you with a quick turnaround request as soon as I resolve Rhonda's comments. Joe C. has already concurred.
Mike, Given the situation I thought you would at least want a chance to review this before it is issued.

I'll send it to you at the same time I send it to Vic.

View ADAMS Properties ML20141L698 Open ADAMS Document (Audit report LAR 20-001)

Tanny From: Butler, Rhonda <Rhonda .Butler@nrc.gov>

Sent: Thursday, May 21, 2020 2:46 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

RE: M L20141L698 Alright.

From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Thursday, May 21, 2020 2:45 PM To: Butler, Rhonda <Rhonda.Butler@nrc.gov>

Subject:

RE: M L20141L698 Importance: High Rhonda

The audit report below is ready for your review. Could you complete your review on or before Tuesday 5/26? I am trying to get this issued quickly.

View ADAMS Propert ies ML20141L698 Open ADAMS Document (Audit report LAR 20-001)

Thanks Tanny From: Butler, Rhonda <Rhonda.But ler@nrc.gov>

Sent: Wednesday, May 20, 2020 3:14 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Greene, Delores <Delores.Greene@ nrc.gov>

Subject:

RE: ML20141L698 Importance: High Alright.

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 3:13 PM To: Greene, Delores <Delores.G reene@nrc.gov>; Butler, Rhonda <Rhonda.Butler@nrc.gov>

Subject:

RE : ML20141L698

Rhonda, Actually, please hold off on reviewing this now. There may be some additional changes I'll let you know when it's ready for you.

Thanks Tanny From: Greene, Delores <Delores.Greene@nrc.gov>

Sent: Wednesday, May 20, 2020 2:58 PM To: Butler, Rhonda <Rhonda.But ler@nrc.gov>

Cc: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

ML20141L698 Good Afternoon Please Review.

View ADAMS Properties ML20141L698 Open ADAMS Document (Audit report LAR 20-001)

THANKS😊

Delo1'84 li',eene Division Administrative Assistant Vogtle Project Office (VPO) 0-13H16 Office: 301-415-1634 Delores.Greene@nrc.gov

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , O.C. 20555-0001 MEMORANDUM TO: Victor Hall , Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM : Cayetano Santos Jr., Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING PLANT UNIT 3, REQUEST FOR LICENSE AMENDMENT AND EXEMPTION : UN IT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (LAR 20-001)

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20038A939), Southern Nuclear Operating Company (the licensee) requested an amendment to Combined License (COL) Number NPF-91 , for Vogtle Electric Generating Plant (VEGP) Unit 3.

The requested amendment proposes changes to COL Appendix C (and plant-specific Tier 1) and corresponding Tier 2* and Tier 2 information in the Updated Final Safety Analyses Report (UFSAR). Specifica lly, the request proposes to modify the north-south minimum seism ic gap requ irements above grade between the nuclear island and the annex building west of Column Line I from elevation 141 feet through 154 feet to accommodate as-built localized nonconformances.

CONTACT: Cayetano Santos Jr., NRRNPO 301-415-7270

V. Hall The staff from the Structural , Civil, Geotech , Engineering Branch (ESEA) conducted an audit from March 10 to Apri l 30, 2020 , via the Westinghouse Electric Company electric reading room.

The purpose of the audit was to gain a better understanding of the proposed changes and to review related documentation and non-docketed information in order to evaluate the acceptability of the proposed changes to the license.

Docket Nos. : 52-025

Enclosure:

Regulatory Audit Report cc: See next page

ML20141L698 *via email NRR-106 OFFICE NRRNPO/PM NRRNPO/LA NRR/DEX/ESEA/BC NRRNPO/BC NAME CSantos RButler JColaccino* VHall

  • DATE 5/21/2020 5/21/2020 5/21/2020 5/ 21 /2020 Regulatory Audit Summary for License Amendment Request:

Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR-20-001)

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Unit 3 Docket No.52-025 A. Background By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC or licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric generating Plant (VEGP) Un it 3 Combined License (COL) Number NPF-91 ). The License Amendment Request (LAR)20-001 requested to revise the north-south minimum seismic gap requirements above grade between the Nuclear Island and the Annex Building west of Column Line I from elevation 141 feet through elevation 154 feet in the licensing basis to accommodate construction of as-built localized nonconformances at VEGP Unit 3. The proposed changes would revise VEGP Unit 3 COL Appendix C (and VEGP Unit 3 plant-specific Tier 1) Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC), and corresponding Updated Final Safety Analysis (UFSAR) Tier 2* and Tier 2 information applicable only to VEGP Unit 3.

The NRC issued an audit plan by letter dated March 20, 2020 (ADAMS Accession No. ML20063H206). The scope of the audit was primarily focused on the review of the documentation and calculations that provide the technical support for LAR 20-001.

B. Regulatory Aud it Basis This regulatory audit is based on the following:

C. Audit Location and Dates The regulatory audit was conducted remotely using the Westinghouse Electric Company (Westinghouse) electronic reading room from March 10, 2020 to April 30, 2020.

D. Audit Team members The following NRC staff members participated in the audit:

E. Licensee Participants The licensee contact is Yasmeen Arafeh.

The following personnel from SNC and Westinghouse participated in the audit:

  • Yasmeen Arafeh, SNC
  • Mark Humphrey, SNC
  • Amy Chamberlain , SNC
  • Amjid Qureshi, SNC
  • A nthony Schoedel, Westinghouse F. Documents Audited SNC and Westinghouse made the documents listed in Table 1 available on the portal for NRC staff to audit. The documents included the predicted and measured settlements at different locations of the Nuclear Island and the Annex Building including construction sequence with time lag of construction between these buildings, trend analysis of the total and differential settlement with time, and predicted Annex Building displacement during a safe-shutdown earthquake (SSE).

Table 1 - Documents Available for the Audit Number Westinghouse Revision Document Title Document No. No. Date 1 SV3-1200-GNR-000014 Auxiliary Building Wall 11 0 06/12/2019 Seismic Gap violation near Col Line J above Elev. 135'-

3" (ESR 50019720) 2 SV0-0500-XCR-800031 Interim Report No. 30. 0 04/29/2019 Settlement Monitoring of Power Block Structures for the Period from August 1, 2017 through December 31, 2018 3 APP-1000-GEF-250 Appendix F: Vogtle Specific 0 11/04/2019 Soil Settlement 4 APP-G9-XCR-002 Settlement Re-analysis of the 5 04/07/2014 AP1000 Buildings with Consideration to Construction Sequence Vogtle Units 3 and 4

5 APP-G9-XCR-004 Settlement Analysis of the 0 03/10/2015 AP1000 Buildings with Consideration to Construction Sequence for Vogtle Unit 4 6 NA Settlement Monitoring NA NA Figures 2

G. Description of Audit Activities and Summary of Observations The NRC staff reviewed the documents listed in Section F to verify the information and conclusions in LAR 20-001. In particular the staff focused its audit review on the first two documents in Table 1 for periodic settlement measurements conducted at selected points of the Nuclear Island and the Annex Building.

The staff conducted audit clarification teleconferences on April 6, April 8, and April 28, 2020 with the SNC and Westinghouse staff to better understand the reports, calculations, and data provided in the portal. The discussion topics included how the following factors support the specific gap identified in LAR 20-001:

  • applied loads during various phases of construction
  • the settlement monitoring data
  • the predicted settlement values
  • the stiffness of the turbine and annex buildings At these teleconferences, SNC and Westinghouse provided clarification regarding the staff discussion topics. As a result of these discussions, SNC also made additional information available on the portal for staff review (i.e., item number 6 in Table 1). This additional information consisted of figures based on specific data extracted from the other documents.

These figures were created to more clearly illustrate the information provided because some of the figures in the original documents were difficult to read and interpret.

Based on the review of the information made available in support of LAR 20-001 provided to the NRC staff to review via the internet portal, the NRC staff did not identify any outstanding issues or the need for the licensee to submit any additional information on the docket.

H. Exit Briefing No outstanding issues remained at the end of the audit and no exit briefing was held.

I. Request for Additional Information Resulting from Audit No request for additional information was issued resulting from the audit.

J. Open Items and Proposed Closure Paths No open items were identified resulting from the audit.

K. Deviations from the Audit Plan The audit was extended from March 27, 2020 to April 30, 2020 to allow staff additional time to examine the documents.

3

L. References

1. U. S. Nuclear Regu latory Commission. NRR Office Instruction LIC-1 11 , Revision 1, "Regu latory Aud its, " October 31, 20 19 (ADAMS Access ion No. ML19226A274).
2. Southern Nuclear Operating Company. Request for License Amendment and Exemption :

Unit 3 Auxi liary Building Wall 11 Seismic Gap Requirements (LAR-20-001 ), February 7, 2020 (ADAMS Accession No. ML20038A939).

3. U.S. Nuclear Regulatory Commission. Aud it Plan for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption : Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001), March 20 , 2020 (ADAMS Accession No. ML20063H206).

4

From: Santos, Cayetano Sent: Thu, 21 May 2020 18:39:22 +0000 To: Colaccino, Joseph Cc: Ghosh, Amitava;Patel, Pravin;Hall, Vict or;Mikula, Olivia;Ezell, Julie;Martin, Jody

Subject:

RE: JC Comments on Audit report and memo Attachments: Audit report and memo LAR 20-001 Rev 2.docx Joe Attached is a clean copy of the audit report we discussed earlier. Please review and concur.

Thanks Tanny From: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Thursday, May 21, 2020 1:06 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>; Mikula, Olivia <Olivia.Mikula@nrc.gov>; Ezell, Ju lie <Julie.Ezell@nrc.gov>;

Martin, Jody <Jody.Martin@nrc.gov>

Subject:

RE: JC Comments on Audit report and memo I have a 2:00 meeting on my calendar to discuss OGC's drafting of the background section.

You also appear to be invited, but with the problems I've been having with my calendar, it's only an assumption.

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, May 21, 2020 12:26 PM To: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>; Patel, Pravin <Pravin .Patel@nrc.gov>; Hall, Victor

<Victor. Hall@nrc.gov>; Mikula, Olivia <Olivia.M ikula@n rc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>;

Martin, Jody <Jody.Martin@nrc.gov>

Subject:

RE: JC Comments on Audit report and memo Thanks, Joe.

Are you referring to the ARB meeting this afternoon? Or another meeting? I only have the ARB meeting on my calendar.

Tanny From: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Thursday, May 21, 2020 11:58 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>; Mikula, Olivia <Olivia. M ikula@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>;

Martin, Jody <Jody.Martin@nrc.gov>

Subject:

JC Comments on Audit report and memo Tanny, Here are my comments.

In an effort to finalize this today, can folks bring their comments to the meeting this afternoon so that we can discuss after we discuss the response. We cou ld probably do this quicker at that time so that I can concur and the VPO can get this out.

Thanks ,

Joseph Colaccino Chief, Structural , Civil, and Geotechnical Engineering Branch (ESEA)

Acting Chief, Structural , Civil , and Geotechnical Engineering Branch (ESEB)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Commission 301-415-7102 r b)(6)  !(Mobile)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , O.C. 20555-0001 MEMORANDUM TO: Victor Hall , Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM : Cayetano Santos Jr., Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING PLANT UNIT 3, REQUEST FOR LICENSE AMENDMENT AND EXEMPTION : UN IT 3 AUXILIARY BUILDING WALL 11 SEISMIC GAP REQUIREMENTS (LAR 20-001)

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20038A939), Southern Nuclear Operating Company (the licensee) requested an amendment to Combined License (COL) Number NPF-91 , for Vogtle Electric Generating Plant (VEGP) Unit 3.

The requested amendment proposes changes to COL Appendix C (and plant-specific Tier 1) and corresponding Tier 2* and Tier 2 information in the Updated Final Safety Analyses Report (UFSAR). Specifica lly, the request proposes to modify the north-south minimum seism ic gap requ irements above grade between the nuclear island and the annex building west of Column Line I from elevation 141 feet through 154 feet to accommodate as-built localized nonconformances.

CONTACT: Cayetano Santos Jr., NRRNPO 301-415-7270

V. Hall The staff from the Structural , Civil, Geotech , Engineering Branch (ESEA) conducted an audit from March 10 to Apri l 30, 2020 , via the Westinghouse Electric Company electric reading room.

The purpose of the audit was to gain a better understanding of the proposed changes and to review related documentation and non-docketed information in order to evaluate the acceptability of the proposed changes to the license.

Docket Nos. : 52-025

Enclosure:

Regulatory Audit Report cc: See next page

ML20141L698 OFFICE NRRNPO/PM NRRNPO/LA NRR/DEX/ESEA/BC NRRNPO/BC NAME CSantos RButler JColaccino VHall DATE I /2020 I 12020 I 12020 I /2020 Regulatory Audit Summary for License Amendment Request:

Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR-20-001)

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Unit 3 Docket No.52-025 A. Background By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC or licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric generating Plant (VEGP) Unit 3 Combined License (COL) Number NPF-91). The License Amendment Request (LAR)20-001 requested to revise the north-south minimum seismic gap requirements above grade between the Nuclear Island and the Annex Building west of Column Line I from elevation 141 feet through elevation 154 feet in the licensing basis to accommodate construction of as-built localized nonconformances at VEGP Unit 3. The proposed changes would revise VEGP Unit 3 COL Appendix C (and VEGP Unit 3 plant-specific Tier 1) Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC), and corresponding Updated Final Safety Analysis (U FSAR) Tier 2* and Tier 2 information applicable only to VEGP Unit 3.

The NRC issued an audit plan by letter dated March 20, 2020 (ADAMS Accession No. ML20063H206). The scope of the audit was primarily focused on the review of the documentation and calculations that provide the technical support for LAR 20-001 .

B. Regulatory Audit Basis This regulatory audit is based on the following:

C. Audit Location and Dates The regulatory audit was conducted remotely using the Westinghouse Electric Company (Westinghouse) electronic reading room from March 10, 2020 to April 30, 2020.

D. Audit Team members The following NRC staff members participated in the audit:

  • Cayetano Santos Jr., Project manager E. Licensee Participants The licensee contact is Yasmeen Arafeh.

2

The following personnel from SNC and Westinghouse participated in the audit:

  • Yasmeen Arafeh , SNC
  • Mark Humphrey, SNC
  • Amy Chamberlain , SNC
  • Amjid Qureshi, SNC
  • Anthony Schoedel, Westinghouse F. Documents Audited SNC and Westinghouse made the documents listed in Table 1 available on the portal for NRC staff to audit. The documents included the predicted and measured settlements at different locations of the Nuclear Island and the Annex Building including construction sequence with time lag of construction between these buildings, trend analysis of the total and differential settlement with time, and predicted Annex Building displacement during a safe-shutdown earthquake (SSE).

Table 1. Documents Available for the Audit Number Westinghouse Revision Document Title Document No. No. Date 1 SV3-1200-GNR-000014 Auxiliary Building Wall 11 0 06/12/2019 Seismic Gap violation near Col Line J above Elev. 135'-

3" (ESR 50019720) 2 SV0-0500-XCR-800031 Interim Report No. 30. 0 04/29/2019 Settlement Monitoring of Power Block Structures for the Period from August 1, 2017 through December 31 ,

2018 3 APP-1 OOO-GEF-250 Appendix F: Vogtle Specific 0 11/04/2019 Soil Settlement 4 APP-G9-XCR-002 Settlement Re-analysis of the 5 04/07/2014 AP1000 Buildings with Consideration to Construction Sequence Vogtle Units 3 and 4

5 APP-G9-XCR-004 Settlement Analysis of the 0 03/10/2015 AP1000 Buildings with Consideration to Construction Sequence for VoQtle Unit 4 6 NA Settlement Monitoring NA NA Fiqures G. Description of Audit Activities and Summary of Observations The NRC staff reviewed the documents listed in Section F to verify the information and 2

conclusions in LAR 20-001 . In particular the staff focused its audit review on the first two documents in Table 1 for periodic settlement measurements conducted at selected points of the Nuclear Island and the Annex Building.

The staff conducted audit clarification teleconferences on April 6, April 8, and April 28, 2020 with the SNC and Westinghouse staff to better understand the reports, calculations, and data provided in the portal. The discussion topics included how the following factors support the specific gap identified in LAR 20-001:

  • applied loads during various phases of construction,
  • the settlement monitoring data
  • the predicted settlement values
  • the stiffness of the turbine and annex buildings.

At these teleconferences, SNC and Westinghouse provided clarification regarding the staff discussion topics. As a result of these discussions, SNC also made additional information available on the portal for staff review (i.e. , item number 6 in Table 1). This additional information consisted of figures based on specific data extracted from the other documents.

These figures were created to more clearly illustrate the information provided because some of the figures in the original documents were difficult to read and interpret.

Based on the review of the information made available in support of LAR 20-001 provided to the NRC staff to review via the internet portal , the NRC staff did not identify any outstanding issues or the need for the licensee to submit any additional information on the docket.

H. Exit Briefing No outstanding issues remai ned at the end of the audit and no exit briefing was held.

I. Request for Additional Information Resulting from Audit No request for additional information was issued resulting from the audit.

J. Open Items and Proposed Closure Paths No open items were identified resulting from the audit.

K. Deviations from the Audit Plan The audit was extended from March 27, 2020 to April 30, 2020 to allow staff additional time to examine the documents.

L. References

1. US Nuclear Regulatory Commission. NRR Office Instruction LIC-111, Revision 1, "Regulatory Audits," October 31 , 2019 (ADAMS Accession No. ML19226A274)
2. Southern Nuclear Operating Company. Request for License Amendment and Exemption:

Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR-20-001 ), February 7, 2020 (ADAMS Accession No. ML20038A939).

2

3. US Nuclear Regulatory Commission. Audit Plan for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption : Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ), March 20 , 2020 (ADAMS Accession No. ML20063H206).

2

From: Patel, Pravin Sent: Tue, 18 Feb 2020 18:37:57 +0000 To: Santos, Cayetano;Ghosh, Amitava Cc: Rankin, Jennivine;Williams, Donna

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Tanny, I will look at the LAR tomorrow. Today busy doing other LAR SE. I don't think will have acceptance problem. Since SNC remove Turbine building gap and rewrote the supplement, I have read. Please provide skeleton of audit plan once documents in ERR. Amit and I w ill fill rest in the audit plan.

Thanks, Get well and take rest.

Pravin From: Santos, Cayetano Sent: Tuesday, February 18, 2020 1:29 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>; Williams, Donna <Donna.Williams@nrc.gov>

Subject:

Re: LAR 20-001 expected submittal?(EOM)

Amit/Pravin I think that in order to ask to review those documents in the ERR we would have to begin an audit. We can definitely do that. But first we need to accept the LAR.

Do you think the LAR can be accepted? If so we can start preparing an audit plan.

Tanny On: 18 February 2020 08:59, "Ghosh, Amitava" <Amitava.Ghosh@nrc.gov> wrote:

Good morning Tanny.

I need two items on ERR: (1) settlement measurements along with original prediction for each structure and (2) Construction seq uence for these structure (which one was first, followed by how much t ime gap for the next structure including adding of loads on a foundation from maj or structu ral additions). I think the tilt they are reporting is from interaction between the two stress 'bu lbs' of these structures below the foundation level. I like to verify.

If they place these information on the ERR, I do not need to talk to them on 2/20/2020 as the information did not change from last meeting.

(b)(6) I am working from this week. l Hope this helps. Please contact me at - - - - - - if you have any questions. I

Thanks, Amit From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, February 18, 2020 7:43 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@ nrc.gov>; Ghosh, Amitava

<Amit ava.Ghosh@nrc.gov>; Williams, Donna <Donna.Williams@nrc.gov>

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Pravin/Amit Just want to confirm, do we still need to keep the phone call on 2/20 with SNC to discuss this LAR?

Tanny From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Wednesday, February 05, 2020 6:22 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>; Ghosh, Amitava

<Amitava.Ghosh@nrc.gov>; Williams, Donna <Donna.W illiams@nrc.gov>

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Ok, When SNC plan to put settlement documents on ERR? Please keep discussion phone call on 2/20. I will be out of office next week.

Pravin From: Santos, Cayetano Sent: Tuesday, February 04, 2020 4:01 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@ nrc.gov>; Ghosh, Amitava

<Amit ava.Ghosh@nrc.gov>

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Pravin/Amit, Just heard back from Mark Humphrey. SNC will not be able to provide us a markup of the LAR in time to support a call on Thursday 2/6 but they still plan to submit on 2/7. Given this, I don't think having a call with them on 2/6 would be helpful.

Maybe we should just plan on reviewing what they submit and if have topics for discussion we can bring it up during a public call on 2/13 or 2/20.

Tanny From: Patel, Pravin Sent: Tuesday, February 04, 2020 2:23 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>; Ghosh, Amitava

<Amitava .Ghosh@nrc.gov>

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Please provide phone number and time . I will not be here at HQ.

Pravin From: Santos, Cayetano Sent: Tuesday, February 04, 2020 12:20 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Subject:

RE: LAR 20-001 expected submittal?(EOM)

Pravin/Amitava, SNC still plans on submitting LAR 20-001 on Friday. But they do plan on making a change to the LAR as it was described during our presubmittal meeting. The version of the LAR described then discussed some non conformities that they are now saying are not there. So they plan to remove that discussion from the LAR.

I've asked them to highlight the specific sections in the draft LAR they provided that would be affected by this change.

They are also offering to discuss these changes and the reasons for them during a public call. Could you support a discussion on the morning of Thursday 2/6? Again they plan to submit it on 2/7.

Please let me know.

Thanks Tanny From: Patel, Pravin Sent: Monday, February 03, 2020 10:16 AM

To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

RE : LAR 20-001 expected submitta l?(EOM) thanks From: Santos, Cayetano Sent: Monday, February 03, 2020 9:50 AM To: Patel, Pravin <Pravin.Pat el@nrc.gov>

Subject:

RE : LAR 20-001 expected submitta l?(EOM)

This Friday. 2/7/20 From: Patel, Pravin Sent: Monday, February 03, 2020 9:32 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

LAR 20-001 expected submittal?(EOM)

Structural Engineer Nuclear Regulatory Commission Office of Nuclear Reactor Regulation DEX/ESEA 0 -4G07

From: Ghosh, Amitava Sent: Wed, 22 Apr 2020 14:05:08 +0000 To: Santos, Cayetano;Colaccino, Joseph;Pate l, Pravin

Subject:

RE: RE: Excel file in ERR not opening Hi Tanny.

We have not talked among ourselves because I am still plotting and interpreting the data. As we are not allowed to and PDF files are mostly useless to analyze, I am writing down the data from the PDF file and then inputting to an Excel spreadsheet for plotting. The EXCEL file on the ERR does not allow to do anything but see it as is. So, plotting is taking an enormous time. After that I need to interpret what is going on and then we will discuss among ourselves so that all of us is on the same page when we talk to SNC/Westinghouse.

With all the meetings/training lined up today and tomorrow, I think it will be hard to talk with SNC/Westinghouse tomorrow. My guess is Tuesday next week is a safer bet.

Thanks a lot.

Amit

~~kJ(

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07021 M 301-415-3268 Amitava.Ghosh@ nrc.gov From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Wednesday, April 22, 2020 9:36 AM To: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE : Excel file in ERR not opening Amit/Pravin, Just wanted to check in with you on the status of your review. Do you still want a clarification call with SNC/Westinghouse regarding the additional figures and plots that were posted in ERR? They can't support a Monday call so it would have to be Thursday this week or Tuesday next week. This Thursday may be difficult because there is an all day VRG meeting but we can try. I would also like to send them a question prior to the call so they can prepare.

Tanny

From : Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Thursday, April 16, 2020 11:42 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening We met and I'm convinced we don't need another RAI. The staff is having issues again reading information in the ERR.

From : Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, April 16, 2020 11:00 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening I was in another meeting this morning. Do we still need to discuss anything?

Tanny From : Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Sent: Thursday, April 16, 2020 8:59 AM To: Colaccino, Joseph <Joseph .Colaccino@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc .gov>;

Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening I am ready.

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov From : Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Thursday, April 16, 2020 8:58 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening I would like to understand the issue before we ask additional questions. Can we talk briefly now? I'm free until 9:30.

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, April 16, 2020 8:54 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening I think we would need to issue an RAI to get the file.

Tanny From: Patel, Pravin <Pravin .Patel@nrc.gov>

Sent: Thursday, April 16, 2020 8:31 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph .Colaccino@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening I put on big monitor and have same issue. Well we can wait till Monday for other data or Tanny can ask SNC for the file.

Pravin From: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Sent: Thursday, April 16, 2020 8:28 AM To: Patel, Pravin <Pravin .Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph .Colaccino@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening Good morning Tanny.

Any solution to this? Can they help or is this file just for reading only (font size is very small for me to read on my laptop for a long time)? I do not know what to do after reading.

Thanks Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M

301-415-3268 Amitava.Ghosh@nrc.gov From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Thursday, April 16, 2020 8:19 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening same From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, April 16, 2020 8:14 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: RE: Excel file in ERR not opening

Amit, I think it may be because the file is posted in the ERR. Since we're not able to copy or download the information in the ERR the file is opening in the internet browser and not Excel.

am not able to open the file in Excel either.

Tanny From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Wednesday, April 15, 2020 5:05 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>; Colaccino, Joseph <Joseph .Colaccino@nrc.gov>

Subject:

RE: Excel file in ERR not opening Hi Tanny.

I am facing a weird problem. When I am trying to open the Excel file in the ERR, it opens in the browser but only allows me to scroll up or down. There is a button that comes at the top of the spreadsheet "Open In Excel." However, whenever I try to open the file in Excel, it gives an error message that either I do not have Excel installed on my computer or the browser is not capable to displaying Excel file. I know neither is true as I have Excel in my computer and I can open an Excel file in both Chrome and IE browsers from the Microsoft cloud.

Is there a specific way to open the file? Can SNC/Westinghouse help?

Thanks a lot.

Amit

~w~

Amitava Ghosh, PhD

Geotechnical Engineer U.S. Nuclear Regulatory Comm ission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov

From : Ghosh, Amitava Sent: Wed, 20 May 2020 13:50:23 +0000 To: Santos, Cayetano

Subject:

RE: RE: Vogtle 3 LAR Audit Summary Attachments: Audit Summary LAR 20-001.docx I am sorry Tanny. I forgot to check.

Here it is.

Thanks, Amit

~w~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov From : Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 9:44 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: Vogtle 3 LAR Audit Summary I don't have access to that sharepoint site. Could you give me access or just email me the file?

Tanny From : Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Wednesday, May 20, 2020 9:36 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Prav in <Pravin.Patel@nrc.gov>

Subject:

RE: Vogtle 3 LAR Audit Summary Good morning Tanny.

We have completed the audit summary and it is ready for your review at

Please let me know if you have any questions.

Thanks a lot.

Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@i)nrc.gov

Regulatory Audit Summary for License Amendment Request:

Unit 3 Auxiliary Building1Wall 11 Seismic Gap Requirements

( LAR-20-001)

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VGEP) Unit 3 Docket No.52-025 A. Background By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric generating Plant (VGEP) Unit 3 Combined License (COL) Number NPF-91 ). The License Amendment Request (LAR)20-001 requested to revise the north-south minimum seismic gap requirements above grade between the Nuclear Island and the Annex Building west of Column Line I from El. 141' through El. 154' in the licensing basis to accommodate construction of as-built localized nonconformances at VEGP Unit

3. The proposed changes would revise VEGP Unit 3 COL Appendix C (and VEGP Unit 3 plant-specific Tier 1) Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC),

and corresponding Updated Final Safety Analysis (UFSAR) Tier 2* and Tier 2 information applicable only to VEGP Unit 3, to modify the north-south seismic gap requirement above grade. The requested amendment requires departures from the UFSAR (which includes the VEGP Unit 3 plant-specific Design Control Document (DCD) Tier 2* and Tier 2 information) Tier 2 Appendix 2.5E Section 5.2 and Subsection 3.7.2.8.1 information, and UFSAR Tier 2* Subsection 3.8.5.1 information, that involve changes to the VEGP Unit 3 COL Appendix C (and VEGP Unit 3 plant-specific Tier 1) information in ITAAC Table 3.3-6.

An audit plan was issued by the NRC staff by letter dated March 20, 2020 (ADAMS Accession No. ML20063H206). The scope of the audit was primarily focused on the review of the documentation and calculations that provide the technical support for LAR 20-001.

B. Regulatory Audit Basis This regulatory audit is based on the following:

  • C. Audit Location and Dates The regulatory audit was conducted remotely using the licensee's electronic reading room and teleconferences from March 10, 2020 to April 30, 2020.

D. Audit Team members The fol lo wing N RC staff members participated in the audit:

  • Pra vin Patel, Structural Engineer, Lead
  • Amita va Ghosh, Geotechnical Eng ineer
  • Cayetano Santos Jr., Project manager Th e licensee contact is Yasmeen Arafeh.

E. Licensee Participants The following personnel from SNC and Westinghouse participated in the audit:

  • Yasmeen Arafeh, SNC
  • Samuel Boakye, SNC?
  • XXXXX, Westinghouse F. Documents Audited SNC and Westinghouse made the documents listed in Table 1 available on the portal for NRC staff to review. The documents included the predicted and measured settlements at different locations of the Nuclear Island and the Annex Building including construction sequence with time lag of construction between these buildings, trend analysis of the total and differential settlement with time, and predicted Annex Building displacement during a safe-shutdown earthquake (SSE). The NRC staff reviewed these documents to verify and to gain better understanding of the bases in the LAR. The NRC staff did not consider the comparison of Turbine Building and Annex Building North-South Stiffness in the assessment in the report SV3-1200-GNR-000014 as relevant.

Table 1. Documents Available for the Audit Westinghouse Revision Document Title Document No. No. Date SV3-1200-G NR-000014 Auxiliary Building Wall 11 Seismic Gap 0 06/12/2019 violation near Col Line J above Elev.

135'-3" fESR 500197201 SV0-0500-XCR-800031 Interim Report No. 30. Settlement 0 04/29/2019 Monitorina of Power Block Structures for

the Period from August 1, 2017 through December 31 2018 G. Description of Audit Activities and Summary of Observations The NRC staff reviewed the documents listed in Section F via internet-based portal and periodic settlement measurements conducted at selected points of the Nuclear Island and the Annex Building. The NRC staff prepared two sets of discussion topics related to the LAR and the documents reviewed on the portal. The discussion topics are available at the following ADAMS Accession numbers.

  • Discussion Topics dated
  • Discussion Topics date~ Commented [GA1): Tanny, please see, related to References 4 and 5.

The staff conducted audit teleconferences on April 6, 2020 and April 28, 2020 with the SNC and Westinghouse staff to discuss the staff topics and proprietary design information. At these teleconferences, SNC provided information regarding the staff discussion topics. SNC also made additional information available on the portal for staff review.

Based on the review of the information and settlement measurement data made available in support of the proposed change provided to the NRC staff to review via the internet portal, the NRC staff did not identify any outstanding issues or the need for the licensee to submit any additional information on the docket.

H. Exit Briefing No outstanding issues remained at the end of the audit and no exit briefing was held.

I. Request for Additional Information Resulting from Audit No request for additional information was issued resu lting from the audit.

J. Open Items and Proposed Closure Paths No open items were identified resulting from the audit.

K. Deviations from the Audit Plan The-re was no deviation of time from the audit plan.

L. References

1. NRR LIC-11 1, Revision 1, "Regulatory Audits," October 31, 2019 (ADAMS Accession No. ML19226A274)
2. Vogtle Electric Generating Plant Unit 3, Request for License Amendment: Reconciliation of Environmental Conditions Inputs to Civil Structural Design Licensing Basis (l AR-20-001 ),

February 7, 2020 (ADAMS Accession No. ML20038A939).

3. US Nuclear Regulatory Commission. Audit Plan for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ). March 20. (ADAMS Accession No. ML20063H206).
4. Email, Audit discussion topic
5. Email, Audit Discussion topiq Commented [GA2J: Tanny, please add ML number if available.

From: Santos, Cayetano Sent: Tue, 24 Mar 2020 21 :02:34 +0000 To: Patel, Pravin

Subject:

RE: Safety Evaluation - VEGP Unit 3 LAR 20-001.docx Attachments: Draft Safety Evaluation LAR 20-001.docx

Pravin, Please use the attached document to complete your SE for LAR 20-001. I took the technical evaluation section you provided in your version and added it to the version I created based on our template. I didn't change anything in the technical evaluation section since that is still under development.

A few comments:

Please update to include a finding/conclusion that 52.47(b) is still met. I think you made a statement about the GDC but not about the ITAAC requirement.

I updated the regulatory evaluation section to include the 2 SRP sections mentioned. These 2 sections are also in the references.

Tanny From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Tuesday, March 24, 2020 12:39 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

Safety Evaluation - VEGP Unit 3 LAR 20-001.docx Draft SER. Still we have work on settlement. You can edit and send me back.

Thanks ,

Pravin

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. (XX)

TO THE COMBINED LICENSE NO. NPF-91 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNIT 3 DOCKET NO.52-025

1.0 INTRODUCTION

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC) requested that the Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP) Unit 3, Combined License (COL) Number NPF-91 . The License Amendment Request (LAR)20-001 requested changes to the VEGP Units 3 and 4 UFSAR in the form of departures from the incorporated plant-specific Design Control Document (PS-DCD) Tier 2 and Tier 2* information and involves changes to COL Appendrix C. Specifically, the request proposes to relax the north-south minimum seismic gap requirements above grade between the nuclear island (NI) and the annex building west of Column Line I from elevation (El.) 141 feet El. 154 feet to accommodate as-built localized nonconformances.

Pursuant to Section 52.63(b)(1) of Title 10 of the Code of Federal Regulations (10 CFR), SNC also requested an exemption from the provisions of Title 1O of the Code of Federal Regulations (10 CFR) Part 52, Appendix D, "Design Certification Rule for the AP1000 Design," Section 111.B, "Scope and Contents." The requested exemption would allow a departure from the

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient corresponding portions of the certified information in Tier 1 of the generic DCD.1 In order to modify the UFSAR (the plant-specific design control document (PS-DCD)) Tier 1 information, the NRC must find SNC's exemption request included in its submittal for the LAR to be acceptable. The staffs review of the exemption request, as well as the LAR, is included in this safety evaluation.

2.0 REGULATORY EVALUATION

LAR 20-001 proposes to change the minimum north-south seismic gap requirement above grade (grade is defined in licensing bases as El. 100 feet) between the NI and the annex building west of Column Line I from El. 14 1 feet through El. 154 feet to accommodate construction as-built localized nonconformances at VEGP Unit 3. The requested gap change is from 3 inches to 2-1/16 inches. The amendment requests departures from the UFSAR PS-DCD Tier 2

  • Subsection 3.8.5.1, "Description of the Foundations"; Tier 2 Section 3. 7 .2.8.1, "Annex Building"; Tier 2 Appendix 2 E Section 5.2, "AP1000 Site S pecific Seismic Evaluation Report";

and VEGP Unit 3 COL Appendix C (and VEGP Unit 3 pla nt-specific Tier 1) Table 3.3-6. The acceptance criteria associated with ITAAC (inspections, tests, analyses, and acceptance criteria) No. 3.3.00.13 is revised to add "except that the minimum north-south horizontal clearance between elevation 141 '-0" and 154'-0" between structural elements of the annex building and the nuclear island west of column line I is 2-1 /16 inches." Tier 1, Tier 2 and Tier 2*

information are defined in 10 CFR Part 52, Appendix D, Section 11.D.

The staff considered the following regulatory requirements in reviewing the LAR that included the proposed changes.

Appendix D,Section VIII.A.4 to 10 CFR Part 52 states that exemptions from Tier 1 information are governed by the requirements in 10 CFR 52.63(b)(1) and 10 CFR 52.98(f). It also states that the Commission will deny such a request if it finds that the design change will result in a significant decrease in the level of safety otherwise provided by the design.

Appendix D,Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2* information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section.

10 CFR 52.63(b)(1) allows the licensee who references a design certification rule to request NRC approval for an exemption from one or more elements of the certification information. The Commission may only grant such a request if it determines that the exemption will comply with the requirements of 10 CFR 52.7, which, in turn , points to the requirements listed in 10 CFR 50.12 for specific exemptions. In addition to the factors listed in 10 CFR 52.7, the Commission shall consider whether the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption. Therefore, any exemption from the Tier 1 information certified by Appendix D to 10 CFR Part 52 must meet the requirements of 10 CFR 50.12, 52.7, and 52.63(b)(1).

1 While SNC describes the requested exemption as being from Section 111.B of 10 CFR Part 52, Appendix D, the entirety of the exemption pertains to proposed departures from Tier 1 information in the plant-specific design control document (DCD). In the remainder of this evaluation, the NRC will refer to the exemption as an exemption from Tier 1 information to match the language of Section VIII.A.4 of 10 CFR Part 52, Appendix D, which specifically governs the granting of exemptions from Tier 1 information.

CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient 10 CFR 52.98(f) requires NRG approval for any modificatrion to, addition to, or deletion from the terms and conditions of a COL. These activities involve a change to COL Appendix C Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) information, with corresponding changes to the associated PS-DCD Tier 1 information. Therefore, NRG approval is required prior to making the plant specific proposed changes in this license amendment request.

10 CFR 52.97(b) requires that the Commission shall identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Atomic Energy Act, and the Commission's rules and regulations.

The specific NRG technical requirements applicable to LAR 20-001 are the general design criteria (GDC) in Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." In particular, these technical requirements include the following GDC:

GDC 1, "Quality standards and records," requires, in part, that structures, systems, and components (SSCs) important to safety be designed, fabrricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.

GDC 2, "Design bases for protection against natural phenomena," requires, in part, that SSCs important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami , and seiches without loss of capability to perform their safety functions.

GDC 4, "Environmental and dynamic effects design bases, " requires, in part, that SSCs important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operration, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.

Regulatory guidance referred to in this evaluation includes Standard Review Plan (SRP)

Section 3.5.8, "Foundation," and Section 3.7.2, "Seismic System Analysis."

3.0 TECHNICAL EVALUATION

3.1 TECHNICAL EVALUATION

OF THE REQUESTED CHANGES The staff evaluated the impact of changing the minimum gap requirement above grade between the NI and the annex building west of Column Line I from El. 141' through El. 154' from 3 inches to 2-1 /16 inches as mentioned in the Section 1.0 of this SE. In performing their evaluation, the staff considered SNC's design criteria described in UFSAR Subsection 3.7.2, "Seismic Analysis," for the annex building where the portion of the annex building adjacent to the NI is classified as a seismic Category II build ing. The seismic Category II building structures are designed for the safe shutdown earthquake (SSE) using the same methodology and design criteria as are used for seismic Category I structures. Also, for the LAR review, the staff considered Standard Review Plan (SRP) Section 3.8.5, "Foundation," and SRP Section 3.7.2, "Seismic System Analysis," which provide an acceptable method for meeting the requirements of GDC 1, 2, and 4, for guidance on the acceptance of the structure design. SNC categorized two changes:

CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient -B Gap between the NI and annex building/turbine building 2-j Gap between the NI and the radwaste building.

SNC proposed to change the minimum gap requirement above grade between the NI and annex building Column Line I from El. 141' through El. 154' from 3" to 2-1/16 inches. Currently, the requirement in the licensing bases for the minimum seismic gap between the NI and annex/turbine buildings is 3 i nches above grade, as specified in COL Appendix C, ITAAC No.

3.3.00.13, UFSAR Appendix 2.5E Section 5.2, and UFSAR Subsections 3.7.2.8. 1 and 3.8.5.1.

The purpose of the gap is to avoid contact between the NI and seismic Category 11 stru ctures (annex building/turbine building) during a seismic event. In the current licensing bases, the seismic response analyses, including soil-structure interaction between NI and the adjacent buildings, are performed using the System for Analysis of Soil-Structure Interaction (SASSI) program. As specified in UFSAR Subsection 3.7.2.8.4, the relative displacement between the NI and adjacent buildings is established from the SASSI 2 D analysis. SNC stated that previous design changes are incorporated into the latest AP 1000 generic 20 SASSI analysis, including changes to the NI (e.g., polar crane mass change) and adjacent buildings (e.g. , change of structures of turbine building first bay). The latest AP1000 generic 2D SASSI analysis shows that the maximum relative seismic displacement between the annex building and the N I is 0.95 inches, and between the turbine building and the NI is 1.04 inches. Both relative displacements are less than the proposed 2 inch maximum seismic relat1ive displacement. A site specific 2D SASSI analysis was performed for VEGP Units 3 and 4 to show the acceptability of the AP1000 plant at the VEGP site. Also, SNC stated that a study has been performed to compare the deflection at the perimeter walls from the generic SASSI analysis using models including the significant building changes to those that do not include the changes. The staff accepts SNC's study because it was based on the approved design bases methodology and the study confirmed that the recent changes do not have significant impact on the result of the relative displacement between buildings.

The staff performed audit on ERR (Electronic Reading Room) to review SNC's settlement evaluation in LAR 20-001 . The staff also considered SNC's information described in UFSAR Subsection 2.5.4.10.2, "Settlement Analysis," for acceptable settlement and differential settlement limits and settlement monitoring plan throughout the entire construction sequence.

The purpose of the staffs review is to determine if the differential settlement between the NI foundation and the foundations of the annex buildings will impose any adverse effect on the gaps between the NI and the annex buildings.

In its LAR, SNC stated that differential settlement of foundations may impact the gaps between the NI and adjacent buildings. Based on the evaluation of the VEGP Units 3 settlement survey data, collected from the settlement monitoring program for the past few years during all construction stages, SNC indicated that the walls of the NI and adjacent buildings will not tend to lean towards the gap. Therefore, SNC predicted that differential settlement does not have an adverse impact on the gaps between the NI and adjacent buildings.

The staff agrees that the required gap between the NI and the annex buildings can be maintained if the differential settlement of foundations will not cause the walls to tilt towards the gap. In order to verify the basis for SNC's conclusion, the staff conducted an audit on xxx ML #,

to review VEGP Unit 3 settlement survey data and related documentation.

During the audit, the staff reviewed the VEGP Unit 3 settlement survey data and related documentation. The staff noted that the reviewed documents contain the settlement survey CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient data and plots of VEGP Unit 3 the past few years through different construction stages. The plots, based on the survey data, present the settlement profile in the east-west direction and north-south direction for the foundations of the NI and the turbine building and the annex building. As mentioned previously, the survey data represents the beginning of the construction stage to the current stage. The staff further noted that measured actual settlements are at least 40 percent less than the calculated settlements using the analytical model. This indicates that the subsurface material properties under the foundations were conservatively assumed in analytical analysis. Based on this observation, the staff reasonably expects that settlement will be well controlled within the settlement limits throughout the entire construction sequence and through the long-term (plant operation).

The staff confirmed through its examination of the settlement survey data and plots that 1) the NI basemat has deflected more in the center and less at the perimeter, which would tend to cause the perimeter walls to lean towards the center of the nuclear building; 2) the foundation deflection contour of the turbine building is similar to that of the NI, which would tend to cause the turbine building first bay structures to lean away from the NI; and 3) the foundation deflection of the annex building is very uniform along the east-west direction and has a center-dipped trend along the north-south direction, which does not result in tilt of the perimeter structures to the west (NI direction). Based on above, the staff finds that the differential settlement of foundations will not impose any adverse effect on the gaps between the NI and the annex buildings.

Based on the above, the staff finds that the proposed changes to the gap requirements between the structures do not affect the structural integrity requirements on seismic Category I structures. The performance of the seismic Category II structures are not impacted. The design of the structures is consistent with the acceptance criteria specified in the SRP Subsections 3.7.2.8 and 3.8.5, and the UFSAR. Therefore, based on the reasons specified above, the staff finds that the proposed amendment meets relevant design provisions. Based on these findings and because the LAR meets the guidance in SRP Sections 3.7.2 and 3.8.5, the staff concludes that there is reasonable assurance that the requirements of GDC 1, 2, and 4 of Appendix A to 10 CFR Part 50 will continue to be met. Therefore, the staff finds the proposed changes to be acceptable.

3.2 EVALUATION OF EXEMPTION The regulations in Section 111.B of Appendix D to 10 CFR Part 52 require a holder of a COL referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in Tier 1 of the generic AP1000 DCD. Exemptions from Tier 1 information are governed by the change process in Section VIII.AA of Appendix D of 10 CFR Part 52. Because the licensee has identified changes to plant-specific Tier 1 information , with corresponding changes to the associated COL Appendix C information resulting in the need for a departure, an exemption from the certified design information within plant-specific Tier 1 material is required to implement the LAR.

The Tier 1 information for which a plant-specific departure and exemption was requested is described above. The result of this exemption would be that the licensee could implement modifications to Tier 1 information to the UFSAR as well as a COL Appendix C table. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule is requested for the involved Tier 1 information described and justified in LAR 20-001. This exemption is a permanent exemption limited in scope to the particular Tier 1 information specified.

CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient As stated in Section VIII.AA of Appendix D to 10 CFR Part 52, an exemption from Tier 1 information is governed by the requirements of 10 CFR 52.63(b)(1) and 52.98(f). Additionally,Section VIII.AA of Appendix D to 10 CFR Part 52 provides that the Commission will deny a request for an exemption from Tier 1 if it finds that the requested change will result in a significant decrease in the level of safety otherwise provided by the design. Pursuant to 10 CFR 52.63(b)(1 ), the Commission may grant exemptions from one or more elements of the certification information, so long as the criteria given in 10 CFR 52.7, which, in turn, references 10 CFR 50.12, are met and that the special circumstances, which are defined by 10 C FR 50.12(a)(2), outweigh any potential decrease in safety due to reduced standardization.

Pursuant to 10 CFR 52.7, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 52. As 10 CFR 52.7 further states, the Commission's consideration will be governed by 10 CFR 50.12, "Specific exemptions," which states that an exemption may be granted when: (1) the exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) special circumstances are present. Specifically, 10 CFR 50.12(a)(2) lists six circumstances for which an exemption may be granted. It is necessary for one of these bases to be present in order for the NRC to consider granting an exemption request. The licensee stated that the requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subparagraph defines special circumstances as when "[a]pplication of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. " The staffs analysis of these findings is presented below:

3.2.1 AUTHORIZED BY LAW The requested exemption would allow SNC to implement the amendment described above.

This exemption is a permanent exemption limited in scope to particular Tier 1 information.

Subsequent changes to this plant-specific Tier 1 information, and corresponding changes to Appendix C, or any other Tier 1 information would be subject to the exemption process specified in Section VIII.AA of Appendix D to 10 CFR Part 52 and the requirements of 10 CFR 52.63(b)(1). As stated above, 10 CFR Part 52, Appendix D, Section VIII.AA allows the NRC to grant exemptions from one or more elements of the Tier 1 information. The staff has determined that granting of SNC's proposed exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations . Therefore, as required by 10 CFR 50.12(a)(1), the exemption is authorized by law.

3.2.2 NO UNDUE RISK TO PUBLIC HEALTH AND SAFETY As discussed above in the technical evaluation, the proposed changes comply with the NRC's substantive safety regulations. Therefore, there is no undue risk to the public health and safety.

3.2.3 CONSISTENT WITH COMMON DEFENSE AND SECURITY The proposed exemption would allow changes as described above in the technical evaluation, thereby departing from the AP1000 certified (Tier 1) design information. The change does not alter or impede the design, function, or operation of any plant structures, systems, or components associated with the facility's physical or cyber security and, therefore, does not affect any plant equipment that is necessary to maintain a safe and secure plant status. In addition, the changes have no impact on plant security or safeguards. Therefore, as required CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient by 10 CFR 50.12(a)(1 ), the staff finds that the common defense and security is not impacted by this exemption.

3.2.4 SPECIAL CIRCUMSTANCES Special circumstances, in accordance with 10 CFR 50.12(a)(2), are present, in part, whenever application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. The underlying purpose of the Tier 1 information is to ensure that a licensee will safely construct and operate a plant based on the certified information found in the AP1000 DCD, which was incorporated by reference into the VEGP Unit 3 licensing basis. The proposed changes described in the above technical evaluation do not impact the ability of any SSCs to perform their functions or negatively impact safety.

Special circumstances are present in the particular circumstances discussed in LAR 20-001 because the application of the specified Tier 1 information is not necessary to achieve the underlying purpose of the rule. The proposed changes are equal or provide additional clarity to the existing requirement. The proposed changes do not affect any function or feature used for the prevention and mitigation of accidents or their safety analyses, and no safety-related SSC or function is involved. This exemption request and associated revisions to the Tier 1 information and corresponding changes to Appendix C demonstrate that the applicable regulatory requirements will continue to be met. Therefore, for the above reasons, the staff finds that the special circumstances required by 1 O CFR 50.12(a)(2)(ii) for the granting of an exemption from the Tier 1 information exist.

3.2.5 SPECIAL CIRCUMSTANCES OUTWEIGH REDUCED STANDARDIZATION This exemption would allow the implementation of changes to Tier 1 information in the plant-specific DCD and corresponding changes to Appendix C that are being proposed in the LAR.

The justification provided in LAR 20-001 , the exemption request, and the associated licensing basis mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD. The design functions of the system associated with this request will continue to be maintained because the associated revisions to the Tier 1 information support the design function of the nuclear island and annex building. Consequently, the safety impact that may result from any reduction in standardization is minimized, because the proposed design change does not result in a reduction in the level of safety. Based on the foregoing reasons, as required by 10 CFR Part 52.63(b)(1), the staff finds that the special circumstances outweigh any decrease in safety that may result from the reduction of standardization of the AP1000 design.

3.2.6 NO SIGNIFICANT REDUCTION IN SAFETY This exemption would allow the implementation of changes discussed above. The exemption request proposes to depart from the certified design by allowing changes discussed above in the technical evaluation. The changes for consistency willl not impact the functional capabilities of this system. The proposed changes will not adversely affect the ability of the nuclear island and annex building to perform their design functions, and the level of safety provided by the current systems and equipment therein is unchanged. Therefore, based on the foregoing reasons and as required by 10 CFR 52.7, 10 CFR 52.98(f), and 10 CFR Part 52, Appendix D, Section VIII.AA, the staff finds that granting the exemption would not result in a significant decrease in the level of safety otherwise provided by the design.

CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient 4.0 STATE CONSU LTATION In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendment on [insert date]. The State official had [no] comments.

[If comments were provided, they should be addressed here).

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no sign ificant hazards consideration, and there has been no public comment on such finding (85 FR 13944 published on March 20, 2020). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Because the exemption is necessary to allow the changes proposed in the license amendment, and because the exemption does not authorize any activities other than those proposed in the license amendment, the environmental consideration for t he exemption is identical to that of the license amendment. Accordingly, the exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the exemption.

6.0 CONCLUSION

The staff has determined that pursuant to Section VIII.A.4 of Appendix D to 10 CFR Part 52, the exemption (1) is authorized by law, (2) presents no undue risk to the public health and safety, (3) is consistent with the common defense and security, (4) presents special circumstances, and (5) does not reduce the level of safety at the licensee's facility. Therefore, the staff grants the licensee an exemption from the Tier 1 information requested by the licensee.

The staff has concluded, based on the considerations discussed in Section 3. 1 that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, the staff finds the changes proposed in this license amendment acceptable.

7.0 REFERENCES

CHOOSE SENSITIVITY FROM DROP DOWN MENU

CHOOSE SENSITIVITY FROM DROP DOWN MENU Recipient 1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR-20-001 ), February 7 , 2020 (ADAMS Accession No. ML20038A939).

2. Audit Plan for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ), dated March 20, 2020 (ADAMS Accession No. ML20063H206).
3. Audit Summary for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ), dated XXXXX (ADAMS Accession No. XXXX).

4 . Vogtle Electric Generating Plant, Unit 3 Current Facility Combined License NPF-91 ,

(ADAMS Accession No. ML14100A106).

5. Vogtle Electric Generating Plant Units 3 and 4, Updated Final Safety Analysis Report, Revision 8, June 14, 2019 (ADAMS Accession No. ML19171A096).
6. AP1000 Design Control Document, Revision 19, June 13, 2012 (ADAMS Accession No. ML11171A500).
7. U.S. Nuclear Regulatory Commission , "Final Safety Evaluation Report Related to the Combined Licenses for Vogtle Electric Generating Plant, Units 3 and 4 ,"

NUREG-2124, Volume 1, September 30, 2012 (ADAMS Accession No. ML12271A045).

8. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation Report Related to Certification of the AP1000 Standard Plant Design," NUREG-1793, Supplement 2, August 5, 201 1 (ADAMS Accession No. ML112061231 ).
9. U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition)," NUREG-0800, Section 3.7.2, "Seismic System Analysis," dated September 2013 (ADAMS Accession No. ML13198A233)
10. U.S. Nuclear Regulatory Commission , "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition)," NUREG-0800, Section 3.8.5, "Foundations," dated September 2013 (ADAMS Accession No. ML13198A267)

CHOOSE SENSITIVITY FROM DROP DOWN MENU

From: Santos, Cayetano Sent: Wed, 8 Apr 2020 15 :42 :29 +0000 To: Colaccino, Joseph;Ghosh, Am itava;Patel, Pravin

Subject:

Staff question for clarification call Here's the question we agreed to during our call:

Staff does not understand how the data provided in the ERR supports the specific gaps in LAR 20-001 . Our discussion this afternoon should focus on determining how the data presented supports the as built measurements as you have provided in your justification of LAR 20-001 .

ifhe data should rovide a projection to support the proposed changes in LAR 20-001 .

1. Provide clear visualization of settlement measurement at different points with time

( currently ending at December 2018; but include 2019 measurements as stated in the LAR page 8).

2. Walk with the staff through the timeline of settlement measurements at critical points versus prediction to COLA license plant fuel load)J(b)(4) I (b)(4)

(b)(4)

3. Walk through with the staff and explain how to confirm in actual measurements that the Annex Buildin is settlin in the o osite direction of the Nuclear Island, (b)(4)

(b)(4) IS.

Staff does not understand how the data provided in the ERR supports the specific gaps in LAR 20-001. Our discussion th is afternoon should focus on determining how the data presented upports the as built measurements as you have provided in your justification of LAR 20-001 .

he data should provide a rojection to supRort the proposed changes in LAR 20-001 .

Clarification Questions - 4/28/20

1. (b)(4)
2. (b}(4}
3. l(bX41

From: Patel, Pravin Sent: Tue, 24 Mar 2020 19:34:03 +0000 To: Santos, Cayetano Cc: Colaccino, Joseph;Patel, Pravin;Ghosh, Amitava

Subject:

FW: Audit Questions Attachments: Clarification questions related to Audit of LAR 20 PM .docx Tanny, Here is the management approval of the questions. Please set up phone call with SNC.

Thanks ,

Pravin From: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Tuesday, March 24, 2020 3:23 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

Audit Questions Please go ahead and transmit questions to VPO projects with a cc to me.

Thanks ,

Joseph Colaccino Chief, Structural , Civil, and Geotechnical Engineering Branch (ESEA)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Commission 301 -415-7102

!(b)(6) ] (Mobile)

Clarification questions related to Audit of LAR 20-001

1. Are there any additional loadings applied (reconciled from as built of structures to the Nuclear Island, Turbine Building, and Annex Building (b)(4)
2. It is almost impossible to track the settlement history at a monitoring point in the black and white plots in the Settlement Monitoring Report (SV0-0500-XCR-800031), for example , Figures 9 and 11. Can the data from these figures be provided in tabular form? If not, could SNC describe the trend of the data?

4

3. When does th~ (b)( ) !of the Rizzo Report (APP-GY-XCR-002)'?
4. In P.33 of the Rizzo Reoort it is stated that ,j(b)(4l (b)(4)

Do the measurements of settlement across these buildings show that the tilt towards the Nuclear Island is negligible?

5. The Rizzo Report is dated April 2014J(b)( )

4 I

(b)(4)

What is the actual settlement histories monitored at the Nuclear Island, the Turbine Building, and the Annex Building near the area of non-conformance?

From: Ghosh, Amitava Sent: Tue, 7 Apr 2020 19:08:18 +0000 To: Patel, Pravin

Subject:

FW: LAR-20-001 Clarification Call Follow Up Attachments: Clarification questions.docx Pravin, Here it is for your review.

l (b)(4)

I rechecked the Rizzo report. They claim l(b)(4) !My mistake. ------------------

Tanny is now asking us to state these points at the beginning of the meeting.

Thanks a lot.

Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava .Ghosh@nrc.gov From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 07, 2020 2:56 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>; King, Mike <Michael.King2@nrc.gov>; Ghosh, Amitava

<Amitava.Ghosh@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Hall, Victor

<Victor.Hall @nrc.gov>

Subject:

RE: LAR-20-001 Clarification Call Follow Up Pravin/Amit, For tomorrow's discussion SNC/Westinghouse plan to walk us through the 2 documents in ERR to highlight the specific tables, text, and figures to try and address your questions/concerns. So before they do this Mike is suggesting that we explain to them what exactly it is we are looking to understand or verify. Can you and Amit do this at the beginning of the meeting?

Tanny From: Patel, Pravin <Pravin .Patel@nrc.gov>

Sent: Tuesday, April 07, 2020 11:56 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; King, Mike <M ichael.King2@nrc.gov>; Ghosh,

Amitava <Amitava.Ghosh@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>

Subject:

RE: LAR-20-001 Clarification Call Follow Up

Tanny, First of all I need to understand what SNC proposing to discuss as they took actions and how.

We had proper questions but SNC was not prepared. Please contact SNC first for their plan.

Mean while Joe, Myself and Amit will discuss.

Thanks, Pravin From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 07, 2020 11:43 AM To: King, Mike <Michael.King2@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Amitava

<Amitava.Ghosh@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>

Subject:

RE: LAR-20-001 Clarification Call Follow Up I am trying to setup the followup call with SNC and WEC to continue our discussions on this topic. The latest proposed date/time is tomorrow (Wed) from 12:30-2:00 pm. That's the best I could find for everyone's schedule. I know SNC can support this time but I am trying to figure out how to use Webex for this meeting. More details w ill come in the scheduler.

Pravin/Amit, In the meantime, could you help me by documenting what precisely you are trying to verify per Mike's suggestion below?

Tanny From: King, Mike <Michael.King2@nrc.gov>

Sent: Monday, April 06, 2020 5 :02 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Patel, Pravin <Pravin .Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Hall, Victor

<Victor.Hall@nrc.gov>

Subject:

Re: LAR-20-001 Clarification Call Follow Up Thanks Tanny, When we have the follow-up discussion with SNC, let's be sure to open up each new topic with a discussion clearly explaining what we are trying to verify as opposed to jumping into the information we requested. This will be critical to ensuring we make the most out of the call.

For example, if we are being challenged read ing a chart because it is too small to read, let's start by saying what we are trying to verify in our review by interpreting data from the chart. This way, if they

are unable to provide higher resolution chart data, they may be able to offer up something else to enable us to achieve the verification we are trying to do.

Mike From: "Santos, Cayetano" <Cayetano.Santos@nrc.gov>

Date: Monday, Apri l 6, 2020 at 4:55 PM To: "Patel, Pravin" <Pravin.Patel@nrc.gov>, "Ghosh, Am itava" <Amitava .Ghosh@nrc.gov>,

"Colaccino, Joseph" <Joseph .Colaccino@nrc.gov>, " Hall, Victor" <Victor.Hall@nrc.gov>, Mike King <Michael. King2@nrc.gov>

Subject:

FW: LAR-20-001 Clarification Ca ll Follow Up

All, See attached. SNC is sharing the answers they provided during this afternoon's phone call to the clarification questions.

Tanny From : Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 4:46 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] LAR-20-001 Clarification Call Follow Up Hi Tanny, while we look into our options on what we can provide for more clarification, I wanted t o send you a write up of our responses to the five audit questions. I have highlighted the responses that point to page numbers in the reports. Please let me know if this helps address some of the Staff's concerns, or if the Staff would like to walk through these pages with our team. I'd be happy to help set up a webex call.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com A Southern Nuclear
1. Provide clear visualization of settlement measurement at different points with time

( currently ending at December 2018; but include 2019 measurements as stated in the LAR page 8).

2. Walk with the staff through the timeline of settleme,,...._........,.....,,...._........_......_......,...................................,

versus prediction to COLA license (plant fuel load). (b)(4)

(b)(4)

3. Walk through with the staff and explain how to confirm in actual measurements that both the Aux Buildin and the Turbine buildin are settlin in the o osite direction of the Nuclear Island, (b)(4)

SNC needs to a!,-::r::=,,..,....,=: - - - - - - - - - - - - - - - - - - - - - - - - '

LAR 20-001 , Seismic GAP Between Annex Building and Nuclear Island, Vogtle 3

Background:

SNC submitted LAR 20-001 to revise the seismic gap in ITAAC (No. 819, 3.3.0013), Tier 2 and Tier 2* of the license and UFSAR. The proposed gap will be revised from 3" to 2 1/6" between the Annex Building and Nuclear Island (N I) in the North-South direction above-grade El 141' to El 154'. In a previous LAR, the seismic gap between these building was reduced from 4" to 3".

Issues:

  • A margin of 1/16" between a Cat I structure (N I) and a non-safety structure (Annex Building) in the North-South direction can reduce further due to continued settlement.
  • There is no settlement data between these two structures in the North-South direction and the predicted settlement is significantly different that what has been observed in the licensee document.

Regulatory Bases:

10 CFR Part 50 Appendix A, GDC 2 "Design Bases for Protection Against Natural Phenomena" and GDC 4 '" Environmental and Dynamic Effects Design Bases" SRP 3.7.2 Section 1.8 "Interaction of Seismic Cat 1 structure with Non-seismic Structures" 10 CFR Part 52 Appendix D, V III "Processes for Changes and Departures" Safety Significance: The seismic gap between Cat 1 and Cat II (Annex Building) structure is small. Potential Safety significance occurs if the gap between Cat 1 and Cat II closes to zero because there is no analysis presented showing that a zero gap will not affect the structural integrity of the CAT I structure by the Licensee.

Staff Review Activities:

While reviewing the LAR, the ESEA staff noted that the margin is extremely small (only 1/16")

and decided to audit the SNC documents in the ERR. The staff had two clarification calls to further understand the data provided by SNC.

The staff used information in the ERR to develop their settlement curves (see graph) to characterize the trend in the settlement between the nuclear island and the annex building.

Based on these data, the staff concluded thatl(b)(4) I (b)(4) l\u/\ql I Therefore, the staff has another issue of using the predicted settlement to assess the seismic gap during Safe Shutdown Earthquake (SSE).

Path Forward: SNC needs either (1) to provide a realistically predicted settlement affecting the seismic gap in the North-South direction from the remaining loadings of the completed structures or (2) to address that the zero gap is acceptable based on an analysis demonstrating that a Cat II structure (Annex Building) will not affect the structural integrity of the Cat 1 Nuclear Island during an SSE.

References:

(1] Westinghouse Electric Company, LLC . 2019. E&DCR No. APP-1000-GEF-250, Rev. 0.

[2] P.C. Rizzo Associates , Inc. 2014. Settlement Re-Analysis of the AP1000 Buildings with Consideration to Construction Sequence Vogtle Units 3 and 4. APP-G9-GEF-005, Rev. 5.

(b)(4)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0 .C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 182 TO THE COMBINED LICENSE NO. NPF-91 SOUTHERN NUCLEAR OPERATING COMPANY. INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNIT 3 DOCKET NO.52-025

1.0 INTRODUCTION

By letter dated February 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20038A939), Southern Nuclear Operating Company (SNC) requested that the Nuclear Regulatory Commission (NRC or Commission) amend Vogtle Electric Generating Plant (VEGP) Unit 3 Combined License (COL) Number NPF-91 . License Amendment Request (LAR)20-001 requests changes to the VEGP Units 3 and 4 Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document (PS-DCD) Tier 2 and Tier 2* information. It also includes changes to plant-specific Tier 1 information with corresponding changes to COL Appendix C Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC). Specifically, the request proposes to relax the north-south minimum gap requirement above grade 1 between the Nuclear Island and the Annex Building west of Column Line I from elevation (El.) 141 feet through El. 154 feet to accommodate as-built localized nonconformances.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 52.63(b )(1 ), SNC also requested an exemption from the provisions of 10 CFR Part 52, Appendix D, "Design Certification Rule for the AP1000 Design," Section 111.B, "Scope and Contents." This e*xemption 1 Grade is defined as elevation (El.) 100 feet.

OFFICIAL USE ONLY PROPRIETARY INFORMATION request will allow a departure from the corresponding portions of the certified information in Tier 1 of the generic DCD. 2 In order to modify the UFSAR (the plant-specific DCD) Tier 1 information, the NRC must find SNC's exemption request. included in its submittal for the LAR to be acceptable. The staffs review of the exemption request, as well as the LAR, is included in this safety evaluation.

On March 10, 2020, the NRC staff published a proposed no significant hazards consideration determination in the Federal Register (85 Fed. Reg. 13944) for the proposed amendment.

2.0 REGULATORY EVALUATION

LAR 20-001 proposes to change the minimum north-south seismic gap requirement above grade between the Nuclear Island and the Annex Building west of Column Line I from El. 141 feet through El. 154 feet in the licensing basis to accommodate construction as-built localized nonconformances at VEGP Unit 3. The requested change in the seismic gap is from 3 inches to 2-1/16 inches. The amendment requests departures from the UFSAR Unit 3 PS-DCD Tier 2*

Section 3.8.5.1; Tier 2 Section 3.7.2.8.1; Tier 2 Appendix 2E Section 5.2; and VEGP Unit 3 COL Appendix C (and VEGP Unit 3 plant-specific Tier 1) Table 3.3-6, ITAAC No. 3.3.00.13. The acceptance criteria for this ITAAC would be revised to add "; except that the minimum horizontal clearance between elevations 141 '-0" and 154'-0" between structural elements of the annex building and the nuclear island between column lines I and J is 2-1/16 inches."

The staff considered the following regulatory requirements in reviewing the LAR that included the proposed changes.

10 CFR Part 52, Appendix D ,Section VIII.A.4, states that. exemptions from Tier 1 information are governed by 10 CFR 52.63(b)(1) and 52.98(f). It also states that the Commission will deny a request for an exemption from Tier 1 if it finds that the design change will result in a significant decrease in the level of safety otherwise provided by the design.

10 CFR Part 52, Appendix D ,Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2" information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section .

10 CFR 52.63(b )( 1) allows the licensee who references a design certification rule to request NRC approval for an exemption from one or more elements of the certification information. The Commission may only grant such a request if it determines that the exemption will comply with the requirements of 10 CFR 52.7, which, in turn , points to the requirements listed in 10 CFR 50.12 for specific exemptions. In addition to the factors listed in 10 CFR 52.7, the Commission shall consider whether the special circumstances present outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

2 While SNC describes the requested exemption as being from Section 111.B of 10 CFR Part 52, Appendix D, the entirety of the exemption pertains to proposed departures from Tier 1 information in the generic DCD. In the remainder of this evaluation, the NRC will refer to the exemption as an exemption from Tier 1 information to match the language of Section VIII.A.4 of 10 CFR Part 52, Appendix D, which specifically governs the granting of exemptions from Tier 1 information.

OFFICIAL USE ONLY PROPRIETARY INFORMATION-

OFFICIAL USE ONLY PROPRIETARY INFORMATION Therefore, any exemption from the Tier 1 information certified by Appendix D to 10 CFR Part 52 must meet the requirements of 10 CFR 50.12, 52.7, and 52.63(b)(1 ).

10 CFR 52.98(f) requires NRC approval for any modificat1ion to, addition to, or deletion from the terms and conditions of a COL. These activities involve a change to COL Appendix C ITAAC information with corresponding changes to the associated plant-specific DCD Tier 1 information.

Therefore, NRC approval is required prior to making the plant-specific proposed changes in this LAR.

10 CFR 52.97(b) requires the ITAAC in a COL to be necessary and sufficient to provide reasonable assurance that, if the ITAAC are satisfied, the facility has been constructed and will be operated in conformity with the license, the provisions of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations.

The specific NRC technical requirements applicable to LAR 20-001 are the general design criteria (GDC) in Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." In particular, these technical requirements include the following GDC:

GDC 1, "Quality standards and records," provides, in part, that structures, systems, and components (SSCs) important to safety shall be designed, fabricated , erected, and tested to quality standards commensurate with the importance of safety functions to be performed.

GDC 2, "Design bases for protection against natural phenomena ," provides, in part, that SSCs important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami , and seiches without loss of capability to perform their safety functions.

GDC 4, "Environmental and dynamic effects design bases," provides, in part, that SSCs important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-cooling accidents.

Regulatory guidance referred to in this evaluation includes Standard Review Plan (SRP)

Section 3.5.8, "Foundation," and Section 3.7.2, "Seismic System Analysis."

3.0 TECHNICAL EVALUATION

3.1 TECHNICAL EVALUATION

OF PROPOSED CHANGES The staff evaluated the impact of changing the minimum gap requirement above grade between the Nuclear Island and the Annex Building west of Column Line I from El. 141 feet through El.

154 feet from 3 inches to 2-1/16 inches. In performing its evaluation, the staff considered SN C's design criteria described in UFSAR Section 3.7.2, "Seismic System Analysis," for the Annex Building where the portion of the Annex Building adjacent to the Nuclear Island is classified as a seismic Category II building. Seismic Category II building structures are designed for the safe shutdown earthquake (SSE) using the same methodology and design criteria used for seismic Category I structures. For the LAR review, the staff considers SRP Section 3.8.5, "Foundation,"

and SRP Section 3.7.2, "Seismic System Analysis," which provide acceptable methods for OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION meeting the requirements of GDC 1, 2, and 4 for guidance on the acceptance of the structure design.

As a part of the review, the staff performed an audit in the Westinghouse Electric Company (Westi nghouse) Electronic Reading Room (ERR) to review SNC's settlement evaluation in LAR 20-001 (ADAMS Accession Number ML20141L698). SNC and Westinghouse made several documents available on the ERR for the NRC staff to audit. The documents included the predicted and measured settlements at different locations of the Nuclear Island and the Annex Building including construction sequence with time lag of construction between these buildings, trend analysis of the total and differential settlement w ith time, and predicted Annex Building displacement due to soil-structure interaction during a safe-shutdown earthquake. The staff reviewed the following areas supporting the revised seismic gap identified in LAR 20-001:

(1) applied loads during various phases of construction, (2) the settlement monitoring data, (3) the predicted settlement values, and (4) the stiffness of the turbine and annex buildings.

Soil-Structure Interaction SNC proposes to change the minimum gap requirement above grade between the Nuclear Island and Annex Building west of Column Line I from El. 141 feet through El. 154 feet from 3 inches to 2-1/16 inches. LAR 20-001 states the following:

Currently, the requirement in the licensing basis for the minimum gap between the nuclear island and annex building is 3 inches, as specified in COL Appendix C, ITAAC No. 3.3.00. 13, UFSAR Appendix 2.5E Section 5.2, and UFSAR Subsections

3. 7.2.8.1 and 3.8.5.1. UFSAR Subsection 3.8.5.1 requires that a minimum 1-inch gap be maintained between the nuclear island and annex building considering the displacements of the buildings during the SSE events. The purpose of the licensing basis requirements is to prevent interaction between the nuclear island and annex building during SSE events.

In the UFSAR, the seismic response analyses, including soil-structure interaction between the Nuclear Island and the adjacent buildings, are performed using the System for Analysis of Soil-Structure Interaction (SASSI) program. As specified in UFSAR Section 3.7.2.8.4, "Seismic Modeling and Analysis of Seismic Category II Building Strructures," the relative displacement between the Nuclear Island and adjacent buildings is established from the SASSI two-dimensional (20) analysis. LAR 20-001 states that previous design changes are incorporated into the latest AP1000 generic 20 SASSI analysis, including changes to the Nuclear Island (e.g., polar crane mass change) and adjacent buildings (e.g. , change of structures of turbine building first bay). A site-specific 20 SASSI analysis was performed for VEGP Units 3 and 4 to show the acceptability of the AP1000 plant at the VEGP site. Also, LAR 20-001 states that a study was performed to compare the deflections at the perimeter walls from the generic SASSI analysis using models including the significant building changes to those that do not include the changes. The staff accepts this study because it was based on the approved design bases methodology. The study confirmed that the recent changes do not have significant impact on the result of the relative displacement between buildings. LAR 20-001 states that "the gap between the auxiliary building and annex building at locations w ith nonconformances during a seismic event calculated based on the VEGP Unit 3 site-specific SASSI [analysis] is la.rger than 1.73 inches." The staff confirmed these results during the audit. Therefore, the gap at locations OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION with nonconformances is larger than the licensing basis requirement of a 1-inch minimum seismic gap.

Settlement In LAR 20-001, SNC states that differential settlement of foundations may impact the gap between the Nuclear Island and adjacent buildings. SNC measured the settlement at different selected survey points on the Nuclear Island and adjacent buildings of VEGP Unit 3 during all construction stages as a part of the settlement monitoring program. Based on the VEGP Unit 3 settlement survey data, LAR 20-001 states that the walls of the Nuclear Island tend to tilt away from the Annex Building and, thereby, increase the gap between structures. In addition, the deflection contour of the Annex Building is uniform near the Nuclear Island. Consequently, the Annex Building is not showing any tendency to tilt towards the Nuclear Island. Therefore, SNC concluded in the LAR that differential settlement of the Nuclear Island and the Annex Building does not have an adverse impact on the gap between these two structures.

The purpose of the staffs review of settlement information is to determine whether the measured differential settlement between the foundations of the Nuclear Island and the Annex Building would reduce the current gap between these two structures further and, therefore, would impose an adverse effect on these structures during an SSE.

UFSAR Section 2.5.4, "Stability of Subsurface Materials and Foundations," describes the subsurface materials and foundation at the VEGP site. The staff notes the following information from this UFSAR Section:

  • Section 2.5.4.2, "Properties of Subsurface Materials," provides the description and characteristics of the subsurface materials below the foundation of the buildings.
  • Section 2.5.4.2.2.2, "Blue Bluff Marl (Lisbon Formation)," describes the characteristics of the Blue Bluff Marl layer at the site.
  • Section 2.5.4.5, "Excavation and Backfill," describes the properties and design of the backfill placed underneath the foundations replacing the Upper Sand Stratum.
  • Section 2.5.4.8, "Liquefaction Potential," describes the possibility of liquefaction of the subsurface materials and the factor of safety against it.
  • Section 2.5.4.10.1, "Bearing Capacity," describes the allowable bearing capacity of the subsurface materials below the foundations including backfill.
  • Section 2.5.4.1 0.2, "Settlement Analysis," describes the acceptable total and differential settlements between the buildings and across the Nuclear Island foundation mat and the settlement monitoring plan throughout the construction.

LAB 20-001 states the following~

The long-term (cgnsolidationl settlement is expected to be relatively small because the Voqtle site has thick engineered compacted backfill and over-consolidated Blue Bluff Marl overlying the lower sand stratum, Based on the site-specific settlement data through 2019, no significant changes are anticipated to the aforementioned short-term and long-term settlement trends.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY - PROPRIETARY INFORMATION The Nuclear Island of VEGP Unit 3 is constructed over a 90-foot-thick compacted Seismic Category 1 backfill. The backfill is placed at the top of Blue Bluff Marl layer having a thickness of approximately 76 feet. The Lower Sand stratum is 900 to 1,000 feet thick and lies between the Blue Bluff Marl Layer and the rock layer. Based on the laboratory and field-measured experimental results and analyses, the UFSAR concludes that both the compacted backfill and the Blue Bluff Marl have an adequate factor of safety aga1inst liquefaction during an SSE.

Laboratory tests have established that the Blue Bluff Marl and the Lower Sand stratum behave elastically and are very dense and stiff (i.e., very high modulus). In addition, the Blue Bluff Marl is an overconsolidated material with an overconsolidated ratio of approximately 8. Therefore, the settlement from construction of the structures would be small and a significant portion of it would occur immediately as the load is applied or within a short time thereafter due to this high overconsolidation stress in addition to the high modulus of the materials and slow loading rate.

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the 'J.fJglle site has thieH-fH'tf}iRf*N9J..e@mpaeteJ saeMi.'.' fjf'UiJ- f>WJf-6@R~fl8tei Blt;e i!uf! A4ar.' 9,,,,9,r:..l;'iRg tJq9 !evl@r saRfJ st,ratblm. iasefi @R the site spe@ifi@ sett.lem91*

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&OOFi te,m aRi !@Rf! t@.'Wi sett.'emeRt treRfis:

During the audit, the staff reviewed the VEGP Unit 3 settlement survey data and related documents. The audited documents contain measured settlement data at different locations around the Nuclear Island and adjacent buildings from the beginning of construction through the current state. Plots of the settlement survey data present the total settlement at the various measurement points as a function of time from the start of construction. In addition, several settlement profiles in the east-west and north-south directions of the foundations of the Nuclear Island and adjacent buildings were provided.

(b)(4}

(b}(4} actual settlement values at the survey points and the predicted settlement values in the UFSAR are within the acceptable limits given in Table 5.0-1, "Site Parameters," of the AP1000 DCD and UFSAR. Based on these observations, the staff reasonably expects that settlement will be well controlled within the acceptable settlement limits throughout the entire construction sequence and through plant operation.

The staff also confirmed through examination of the settlement survey data and plots during the audit that the Nuclear Island basemat has deflected more in the center (where the Shield Building is located) and less at the perimeter. This pattem of basemat deflection would tend to cause the perimeter walls to lean towards the center of the Nuclear Island. Additionally, the staff confirmed that the foundation deflection of the Annex Buildin is uite uniform near the Nuclear Island. (b}(4}

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY- PROPRIETARY INFORMATION 4

!(b)( ) ~ his observation indicates that the walls of the Annex Building near the Nuclear Island are not exhibiting a tendency to lean towards the Nuclear Island thereby, reducing the seismic gap between the two buildings, especially in the North-South direction. Based on above, the staff finds that the differential settlement of the foundations of the Nuclear Island and the Annex Building will not impose an adverse effect on the seismic gap between these two structures by reducing the currently available gap, especially at the area of nonconformance.

UFSAR Tier 1 Table 5.0-1 states that the site will not liquefy during an SSE. UFSAR Section 2.5.4.10.1 states that the subsurface materials underneath the foundations of the structures have adequate bearing capacity to withstand an SSE. Therefore, based on the above, the staff finds that any change in settlement of the Annex Building due to nonconformance during an SSE will be negligible.

Conclusions Based on the above, the staff finds that the proposed changes to the gap requirements between the Nuclear Island and the Annex Building at the area of nonconformance do not affect the structural integrity of the seismic Category I structures. Similarly, the structural integrity of the seismic Category II structures is not impacted. The design of the structures is consistent with the acceptance criteria specified in the SRP Sections 3.7.2.8 and 3.8.5 and the UFSAR.

Therefore, based on the reasons specified above, the staff finds that the proposed amendment meets the design requirements of UFSAR Sections 3.7 and 3.8. Based on these findings and because the LAR meets the guidance in SRP Sections 3. 7.2 and 3.8.5, the staff concludes that there is reasonable assurance that the requirements of GDC 1, 2, and 4 of Appendix A to 10 CFR Part 50 will continue to be met. Therefore, the staff finds the proposed changes to be acceptable.

The staff also finds that the LAR's proposed revision to ITAAC 3.3.00.13 will continue to be sufficient to verify that the facility has been constructed and will operate in accordance with the license, the provisions of the Atomic Energy Act, and the Commission's rules and regulations.

This finding is based on the fact that the revised acceptance criteria in this ITAAC is consistent with the revised gap requirement between the Nuclear Island and Annex Building in the area of the nonconformance. Therefore, within the scope of this !l icense amendment, the NRC finds that 10 CFR 52.97(b) is satisfied. These changes will enable the licensee to safely construct and operate the facility consistent with the design certified by the NRC.

3.2 EVALUATION OF EXEMPTION The regulations in Section 111.B of Appendix D to 10 CFR Part 52 require a holder of a COL referencing Appendix D to 10 CFR Part 52 to incorporate Appendix D by reference and comply with its requirements, including certified information in Tier 1 of the generic AP1000 DCD.

Exemptions from Tier 1 information are governed by the change process in Section VI 11.A.4 of Appendix D of 10 CFR Part 52. Because SNC has identified changes to plant-specific Tier 1 information, with correspond ing changes to the associated COL Appendix C information resulting in the need for a departure, an exemption from the certified design informatio n within plant-specific Tier 1 material is required to implement the LAR.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION The Tier 1 information for which a plant-specific departure and exemption was requested is described above. The result of this exemption would be that SNC could implement the requested modifications to Tier 1 information, with corresponding changes to COL Appendix C.

Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule is requested for the involved Tier 1 information described and justified in LAR 20-001 . This exemption is a permanent exemption limited in scope to the particular Tier 1 information specified.

As stated in Section VIII.A.4 of Appendix D to 10 CFR Part 52, an exemption from Tier 1 information is governed by the requirements of 10 CFR 52.63(b)(1) and 52.98(f). Additionally,Section VIII.A.4 of Appendix D to 10 CFR Part 52 provides that the Commission will deny a request for an exemption from Tier 1 if it finds that the requested change will result in a significant decrease in the level of safety otherwise provided by the design. Pursuant to 10 CFR 52.63(b)(1 ), the Commission may grant exemptions from one or more elements of the certification information, so long as the criteria given in 10 CFR 52.7, which, in turn, references 10 CFR 50.12, are met and that the special circumstances, which are defined by 10 CFR 50.12(a)(2), outweigh any potential decrease in safety due to reduced standardization.

Pursuant to 10 CFR 52.7, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 52. As 10 CFR 52. 7 further states, the Commission's consideration will be governed by 10 CFR 50.12, "Specific exemptions," which states that an exemption may be granted when: (1) the exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) special circumstances are present. Specifically, 10 CFR 50.12(a)(2) lists six circumstances for which an exemption may be granted. It is necessary for one of these bases to be present in order for the NRC to consider granting an exemption request. SNC stated that the requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subparagraph defines special circumstances as when "[a]pplication of the regulation in t he particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." The staff's analysis of these findings is presented below.

3.2.1 AUTHORIZED BY LAW The requested exemption would allow SNC to implement the amendment described above.

This exemption is a permanent exemption limited in scope to particular Tier 1 information.

Subsequent changes to this plant-specific Tier 1 information, and corresponding changes to Appendix C, or any other Tier 1 information would be subject to the exemption process specified in Section VIII.A.4 of Appendix D to 10 CFR Part 52 and the requirements of 10 CFR 52.63(b)(1). As stated above, 10 CFR Part 52, Appendix D, Section VIII.A.4 allows the NRC to grant exemptions from one or more elements of the Tier 1 information. The NRC staff has determined that granting of SNC's proposed exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations. Therefore, as required by 10 CFR 52.7 and 10 CFR 50.12(a)(1), the exemption is authorized by law.

3.2.2 NO UNDUE RISK TO PUBLIC HEALTH AND SAFETY As discussed above in the technical evaluation, the proposed changes comply with the NRC's substantive safety regulations. Therefore, there is no undue risk to the public health and safety.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION 3.2.3 CONSISTENT WITH COMMON DEFENSE AND SECURITY The proposed exemption would allow changes as described above in the technical evaluation, thereby departing from the AP1000 certified (Tier 1) design information. The change does not alter or impede the design, function, or operation of any plant structures, systems, or components associated with the facility's physical or cyber security and, therefore, does not affect any plant equipment that is necessary to maintain a safe and secure plant status. In addition, the changes have no impact on plant security or safeguards. Therefore, as required by 10 CFR 50.12(a)(1), the staff finds that the common defense and security is not impacted by th is exemption.

3.2.4 SPECIAL CIRCUMSTANCES Special circumstances, in accordance with 10 CFR 50.12(a)(2), are present, in part, whenever application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. The underlying purpose of the Tier 1 information is to ensure that a licensee will safely construct and operate the plant based on the certified information found in the AP1000 DCD, which was incorporated by reference into the VEGP Unit 3 licensing basis. The proposed changes described in the above technical evaluation do not impact the ability of any SSCs to perform their functions or negatively impact safety.

Special circumstances are present in the particular circumstances discussed in LAR 20-001 because the application of the specified Tier 1 information is not necessary to achieve the underlying purpose of the rule. The proposed changes are equal or provide additional clarity to the existing requirement. The proposed changes do not affect any function or feature used for the prevention and mitigation of accidents or their safety analyses, and no safety-related SSC or function is involved. This exemption request and associated revisions to the Tier 1 information and corresponding changes to Appendix C demonstrate that the applicable regulatory requirements will continue to be met. Therefore, for the above reasons, the staff finds that the special circumstances required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption from the Tier 1 information exist.

3.2.5 SPECIAL CIRCUMSTANCES OUTWEIGH REDUCED STANDARDIZATION This exemption would allow the implementation of changes to Tier 1 information in the plant-specific DCD and corresponding changes to Appendix C that are being proposed in the LAR.

The justification provided in LAR 20-001 , the exemption request, and the associated licensing basis mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD. The design functions of the system associated with this req uest will continue to be maintained because the associated revisions to the Tier 1 information support the design function of the Nuclear Island and Annex Building.

Consequently, the safety impact that may result from any reduction in standardization is minimized, because the proposed design change does not result in a reduction in the level of safety. Based on the foregoing reasons, as required by 10 CFR Part 52.63(b)(1 ), the staff finds that the special circumstances outweigh any decrease in safety that may result from the reduction of standardization of the AP1000 design.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION 3.2.6 NO SIGNIFICANT REDUCTION IN SAFETY This exemption would allow the implementation of changes discussed above. The exemption request proposes to depart from the certified design by allowing changes discussed above in the technical evaluation. The proposed changes will not adversely affect the ability of the Nuclear Island and Annex Building to perform its design functions , and the level of safety provided by the current systems and equipment therein is unchanged. Therefore, based on the foregoing reasons and as required by 10 CFR 52.7, 10 CFR 52.98(f), and 10 CFR Part 52, Appendix D, Section VIII.A.4, the staff finds that granting the exemption would not result in a significant decrease in the level of safety otherwise provided by the design.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendment on [insert date]. The State official had [no] comments. [If comments were provided, they should be addressed here].

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, "Standards for Protection Against Radiation." The staff has determined t hat the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite. Also, there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (Federal Register, 85 FR 13944, dated March 10, 2020). Accordingly, the amendment meets the eligibility criteria for categorica l exclusion set forth in 10 CFR 51 .22(c){9). Under 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Because the exemption is necessary to allow the changes proposed in this LAR, and because the exemption does not authorize any activities other than those proposed in this LAR, the environmental consideration for the exemption is identical to that of the license amendment.

Accordingly, the exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), the staff finds that no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the exemption.

6.0 CONCLUSION

The staff has determined that pursuant to Section VIII.A.4 of Appendix D to 10 CFR Part 52, the exemption proposed in this LAR (1) is authorized by law; (2) presents no undue risk to the public health and safety; (3) is consistent with the common defense and security; (4) presents special circumstances and; (5) does not reduce the level of safety at the licensee's facility.

Therefore, the NRG staff grants the exemption from the Tier 1 information requested by SNC.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION The staff has also concluded, based on the technical evaluation presented in Section 3 .1 that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, the NRC staff finds the changes proposed in this LAR acceptable.

7.0 REFERENCES

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR-20-001 ), February 7, 2020 (ADAMS Accession No. ML20038A939).
2. Vogtle Electric Generating Plant Units 3 and 4, Updated Final Safety Analysis Repo rt, Revision 8, June 14, 2019 (ADAMS Accession No. ML19171A096).
3. U.S. Nuclear Regulatory Commission, Audit Plan for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ), dated March 20, 2020 (ADAMS Accession No. ML20063H206).
4. U.S. Nuclear Regulatory Commission, Audit Summary for Vogtle Electric Generating Plant Unit 3, Request for License Amendment and Exemption: Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements (LAR 20-001 ), dated May 26, 2020 (ADAMS Accession No. ML20141L698).
5. AP1000 Design Control Document, Revision 19, dated June 13, 2011 (ADAMS Accession No. ML11171A500).
6. Vogtle Electric Generating Plant, Unit 3 Current Facility Combined License NPF-91, (ADAMS Accession No. ML14100A106).
7. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 3.7.2, "Seismic System Analysis," (ADAMS Accession No. ML100630323).
8. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 3.8.5, "Foundations" (ADAMS Accession No. ML100630323).

OFFICIAL USE ONLY PROPRIETARY INFORMATION

From: Santos, Cayetano Se nt: Mon, 23 Mar 2020 21:00:35 +0000 To: Ghosh, Amitava;Patel, Pravin Subje ct: RE: Areas that may need discussion Attachments: Clarification questions related to Audit of LAR 20.docx See attached. I cleaned up the format a little bit.

From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Monday, M arch 23, 2020 4:34 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

RE: Areas that may need discussion Tanny. You are correct.

My calendar is up-to-date._  !(b_)(_B)_ _ _ _ _ _ _ _ _ l

Thanks, Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@ nrc.gov From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Monday, March 23, 2020 4:00 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: Areas that may need discussion You got it From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Se nt: Monday, March 23, 2020 3:57 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: Areas that may need discussion Will do. Did I understand the questions correcty?

From : Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Monday, March 23, 2020 3:44 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

RE: Areas that may need discussion My calendar is update except it say wah. Let me know when phone call will be.

From : Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Monday, March 23, 2020 3:31 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: Areas that may need discussion Amit/Pravin, I wanted to make sure I understand what you're asking. See my comments in highlight below.

Am I understanding this correctly? Are you ready to try and have a clarification call with SNC?

can try this week. I assume your calendars are up to date.

Tanny From : Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Monday, M arch 23, 2020 1:25 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

Re: Areas that may need discussion Thanks Pravin. I will change it.

Amit From : Patel, Pravin <Pravin .Patel@nrc.gov>

Sent: Monday, March 23, 20201:17 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: Areas that may need discussion

Amit, Minor adjustment.

Pravin From : Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Monday, March 23, 2020 11:57 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: Areas that may need discussion

Pravin and Tanny:

I find the following areas that may need some discussions.

Pravin: Please check these and add/modify as you see fit.

1. Is there any additional loading applied (rer ndled Imm As built of structures) to t e Nuclear Island, Turbine Building, and Annex Building (b)(4)
2. It is almost impossible to track the settlement history at a monitoring point in the black and white plots in the Settlement Monitoring Report (SV0-0500-XCR-800031), for example, Figures 9 and 11. Are we asking if t hey can provide the data in th is figure in t abula r form ? If not available in a table are we asking t hem to describe the t rend of t he data?

4

3. When does the ...,

l(b,.)(. , ,...,.l..,....,,..,,.....,,....,,. . , . .,. .,

, , . . . . . - - - - - - - - - - - - - - - - - - - 'lof the Rizzo Report (APP-G9-XCR-002)?

Do the measurements of settlement across these buildings show hat the tilt towards the Nuclear Island is negligible?

5. The Rizzo Report is dated .April, 2014J(b)(4}

(b)(4)

l(b)(4)

6. What is the actual settlement histories monitored at the Nuclear Island, the Turbine Building, and the Annex Building near the area of non-conformance?

They just gave two reports for us to figure all these out. As a result, I am not able to interpret these reports in those areas without some clarification from them.

Please let me know if you have any comments.

Thanks, Amit

From: Ghosh, Amitava Sent: Tue, 17 Mar 2020 21:15:00 +0000 To: Patel, Pravin;Santos, Cayetano

Subject:

Re: Need change in RPS RAI due date Tanny, Pravin is correct. I am lookin (b)(4) One more year plus have passed since then. Did the buildings continue to settle so that maximum and differential settlements are now higher than given in the report? From the visual trend, it did not seem to me that settlement would flatten out after 2018.

4 There is one more auestion I am t rvine: to f ind measurem ent to refuteJ(b)( )

(b)(4) l (b)(4), (b)(5) II am checking on that.

If you look at the measurement report, the plot for tota l displacement is extremely crowded with eight lines in one plot. It is impossible for me to understand the differential settlement between two lines in the plot.

As I said before, I am trying to understand how much is t h e short-term and long-term (consolidation) settlement, both added give the tota l settlement. I am looking for the parameters used to estimate the consolidation, although the Rizzo report states t hat it wou ld be relatively small, which makes sense for this case. But t hd (b)(4)

!(b)(4) 11 am trying to understand and make sense of bot._ h_p_r_e_d-ic-ti_o_n_a_n_d_m

_ e-as_u_r_e_m_e_n_t-s.- -

Hope to get a preliminary sense in a few days.

I am formi ng questions to get clarification. I w ill surely give t hem to you in advance for your comments.

Please let me know if you have any comments.

Thanks, Amit From : Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Tuesday, March 17, 2020 2:49 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Subject:

RE: Need change in RPS RAI due date If I am not wrong Amit is looking for prediction for as built and future prediction plot so seismic gap of two structures not close. FYI after 2018 lot more loads are added.

From : Santos, Cayetano <Cayetano.Santos@nrc.gov>

Se nt: Tuesday, March 17, 2020 2:35 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: Need change in RPS RAI due date So I took a quick look at the 2 reports in ERR. At least one of them seems to have tables of settlement data as far back as 2012. Maybe I'm just not understanding what you are looking for. Is this data not in the right locations? SNC did confirm that the latest data they have is 2018. So there isn't anything after that.

I can try and setup a call if we need to discuss.

From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Tuesday, March 17, 202010:46 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: Need change in RPS RAI due date I mean to say Tanny look at ERR From: Patel, Pravin Sent: Tuesday, March 17, 202010:44 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@ nrc.gov>

Subject:

RE : Need change in RPS RAI due date Try to look ERR. Let us know what is your understanding.

From: Santos, Cayetano <Cayet ano.Santos@ nrc.gov>

Sent: Tuesday, March 17, 202010:35 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

Re: Need change in RPS RAI due date Pravin/Amit I can try and schedule a call with SNC later this week. Unfortunately I haven't had a chance to look at the documents they posted in the ERR. I just want to make sure I understand the question we want to ask. Did they not post actual as-built settlement measurements in the ERR? Are we asking them to provide as-built settlement dat a? or something else?

Tanny From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Monday, M arch 16, 2020 9:21 AM To: Ghosh, Amitava <Amit ava.Ghosh@nrc.gov>; Santos, Cayet ano <Cayetano.Santos@ nrc.gov>

Subject:

RE: Need change in RPS RAI due date I think clarification call with SNC worthwhile. I am in the HQ today. Rest of the week telework.

We don't know SNC have asbuilt settlement.

Pravin From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Monday, March 16, 2020 9:13 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

Re: Need change in RPS RAI due date

Tanny, I am estimating approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />, given the volume of data.

I do not anticipate so far any RAls. That being said, we are not allowed to download the data to plot in a manner to develop own understanding quickly of what is going on below the surface with application of the loads. I have to depend on what they provided. The plots in the settlement measurement report are developed for the purpose of the report, not to develop a quick understanding of the processes going on at the subsurface for me. I may like to plot some in a different way to clear my understanding.

If we can get the data plotted by them as I need, I may not need RAls. I am currently t r ying to get my arms around one question from the data: what settlement phase (immediate settlement or consolidation is currently going on and why. I shou ld be able to articulate my question much better once I am through reading both documents.

5 5 I am working from home (homei... (b-)(_)_ _ _..,I, Cell: ._!

(b_)(_)_ _ _....~. Please contact me if you have any questions.

Thanks a lot.

Amit From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Sunday, March 15, 2020 9:12 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: Need change in RPS RAI due date

Amit, You estimated 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> in RPS. What is your new estimate? Are you certain that RAls will be needed? What date would you think that RAls could be provided, if needed?

I will ask if SNC can add more recent info than 2018.

Tanny

From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Saturday, March 14, 2020 5:12 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: Need change in RPS RAI due date Hi Tanny.

I have received an overdue notice from the RPS system. I just received the documents in the ERR. I think I need more recent information as the settlement measurements end on end of 2018. Need to know what is happening since then.

Therefore, I need more time to develop meaningful RAls so that one round of RAls should be sufficient.

Additionally, my time estimate in the RPS system was documents unseen. I believe that I need more time to go through these measurements and make sense to develop a reasonable conclusion.

Thanks a lot.

Amit

From: Santos, Cayetano Se nt: Wed, 15 Apr 2020 12:26:34 +0000 To: Patel, Pravin Cc: Colaccino, Joseph;Ghosh, Am itava

Subject:

RE: RE:: Document in ERR of Vogt le Those additional plots we requested should be available on 4/20.

From: Patel, Pravin <Pravin.Patel@nrc.gov>

Sent: Wednesday, April 15, 2020 7:34 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subje ct: FW: RE: Document in ERR ofVogtle Tanny, Any progress from SNC for additional request including coordinates vs column line relation. ?

Pravin From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, April 09, 2020 5:24 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Hall, Victor <Victor.Hall@nrc.gov>

Subject:

RE : RE: Document in ERR of Vogtle

All, Just heard back from SNC. The report, APP-G9-XCR-004, is now in the ERR. The additional plots we requested should be up by Monday 4/20.

Tanny From: Patel, Pravin <Pravin .Patel@nrc.gov>

Sent: Thursday, April 09, 2020 10:50 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: RE: Document in ERR of Vogtle

Tanny, The plot results were shown yesterday were from E&DCR. The E&DCR is written against APP-G9-XCR-004. Therefore, Please ask SNC to put APP-G9-XCR-004 calc on ERR. SNC still preparing some documents based on actions yesterday. Thanks Pravin

From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Thursday, April 09, 2020 10:39 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Patel, Pravin <Pravin.Patel@nrc.gov>; Co laccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

RE: Document in ERR of Vogtle Good morning Tanny.

I was going through the documents uploaded yesterday to ERR. I came across the document number (APP-G9-XCR-004) referred in the document (E&DCR No.: APP-1000-GEF-250 Rev.

0). There is no list of reference in E&DCR No.: APP-1000-GEF-250 Rev. 0. So I do not know what this document is; however, first and second paragraphs on Page 3 of E&DCR No.: APP-1000-GEF-250 Rev . 0 states that APP-G9-XCR-004 contain s soil properties of each soil layer and settlement analysis.

Can we have a look at this report to know how the results defer from what we are reviewing in APP-G9-XCR-002 (Rizzo Report)?

Thanks ,

Amit

~w~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov

From: Colaccino, Joseph Se nt: Mon, 27 Apr 2020 13:13:05 +0000 To: Santos, Cayetano;Ghosh, Amitava Cc: Patel, Pravin

Subject:

RE: RE:: DRAFT questions/topics I have looked at these questions and approved them.

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, April 27, 2020 9:12 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: DRAFT questions/topics Thanks, Amit. Does this include any comments from Pravin and Joe as well? Do you think we will need to share a document to discuss these things? Or can we just use an audio only bridgeline?

Tanny From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Se nt: Monday, April 27, 2020 8:42 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: DRAFT questions/topics Good morning Tanny.

Here are the draft questions that we like to discuss with SNC/Westinghouse.

Thanks.

Amit Draft Questions:

1 (b)(4)

3. (b)(4)

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov

From: Santos, Cayetano Se nt: Tue, 28 Apr 2020 14:54:14 +0000 To: Ghosh, Amitava Cc: Colaccino, Joseph;Patel, Pravin

Subject:

RE: RE:: DRAFT questions/topics Attachme nts: Audit Question Responses.pdf This was part of their response to our earlier set of questions. See attached.

From : Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Tuesday, April 28, 2020 10:53 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: DRAFT questions/topics Hi Tanny, Would you please point to me where they said that?

l(b)(4)

In APP-1000-GEF-250 on Page 3, last paragraph, they stated (b)(4) pre 1ct1on We know NI and AB are moving towards each other in the East-West direction. We do not know anything in the North-South direction. How do we proceed? Our comment #3.

This is my response while attending the Branch Meeting.

Thanks, Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268

Amitava.Ghosh@nrc.gov From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 28, 2020 10:38 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: DRAFT questions/topics Amit/Pravin Another question for my own understanding: In their response to our first set of clarification questions, SNC stated that (b)(4) ears to me that (b)(4)

Tanny From: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Sent: Monday, April 27, 2020 9:30 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: DRAFT questions/topics Hi Tanny. We need to share the screen.

Thanks, Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, April 27, 2020 9: 12 AM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: RE: DRAFT questions/topics Thanks, Amit. Does this include any comments from Pravin and Joe as well? Do you think we will need to share a document to discuss these things? Or can we just use an audio only bridgeline?

Tanny From: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>

Sent: Monday, April 27, 2020 8:42 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

RE: DRAFT questions/topics Good morning Tanny.

Here are the draft questions that we like to discuss with SNC/Westinghouse.

Thanks.

Amit Draft Questions:

(b)(4) 1

2. (b)(4)

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Comm ission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-4 15-3268 Amitava.Ghosh@nrc.gov

Clarification questions relat ed to Audit of LAR 20-001

1. Are there any additional load\lJ. .lio...:w.u.=.i...u.liilo.l,u.u.iu....i.l..U.l,u.u..a.;u,LW.UJ..l,IJUJr.ructures) to the Nuclear Island, Turbine Buildin and Annex Buildin (b)(4)

(b)(4)

2. It is almost impossible to track the settlement history at a mon itoring point in the black and white plots in the Settlement Monitoring Report (SV0-0500-XCR-800031), for example, Figures 9 and 11. Can the data from 1 figures be proyjded in tabular form? It not, could SNCdescrjbe the trend of the data-.,

rx,these 3.

l~K4)

When does the _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ of the Rizzo Report (APP- I G9-XCR-002)?

4. In P.33 of the Rizzo Report, (b)(4) l(b)(4)

Do the measurements of settlement across these buildings show that the tilt towards the Nuclear Island is negligible?

(b)(4)

Clarification questions related to Audit of LAR 20-001 What are the actual settlement histories monitored at the Nuclear Island, the Turbine Building, and the Annex Build ing near the area of non-conformance?

(b)(4)

From: Santos, Cayetano Se nt: Mon, 27 Apr 2020 13:42:58 +0000 To: Arafeh, Yasmeen N.

Cc: Hall, Victor;King, Mike;Patel, Pravin;Ghosh, Amitava;Colaccino, Joseph

Subject:

RE: RE:: RE: RE: RE: FW: Settlement Plots on ERR

Yasmeen, Here are the clarification questions staff would like to discuss during the call on Tuesday 4/28:

1 (b)(4)

(b)(4) 2 3 l(bX4J From: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Se nt: Monday, April 27, 2020 9:41 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subje ct: [External_Sender] RE: RE: RE: RE: FW: Settlement Plots on ERR Hi Tanny, I received an email invitat ion from Luis Betancourt. W ill we be receiving the clarification questions today?

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh @southernco.com A Southern Nuclear

From: Santos, Cayetano <Cayet ano.Santos@ nrc.gov>

Se nt: Monday, April 27, 2020 8:39 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subje ct: RE: RE: RE: RE: FW: Settlement Plots on ERR EXTERNAL MAIL: Caution Opening Links or Files I just forwarded you a webex invitation for tomorrows call.

Did you receive it?

From : Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Sent: Thursday, April 23, 2020 1:16 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: FW: Settlement Plots on ERR Hi Tanny, Tuesday works for us as long as it's between 11-2 eastern, so that our WEC team can support.

Please let me know if this time works for the staff.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com A Southern Nuclear From : Santos, Cayetano <Cayet ano.Santos@ nrc.gov>

Sent: W ednesday, April 22, 2020 9:10 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subje ct: RE: RE: RE: FW: Settlement Plots on ERR EXTERNAL MAIL: Caution Opening Links or Files

Yasmeen, Staff is still reviewing the information. We may not be ready for a discussion tomorrow (Thursday). I will let you know soon. Would you be able to support a call on Tuesday 4/28? My plan would be to give you questions ahead of time to better prepare.

Thanks Tanny

From: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Sent: Tuesday, April 21, 2020 12:15 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: FW: Settlement Plots on ERR Tanny, my team is not available on Monday, so Thursday is our only option, but it will be a little tricky working around the VRG meeting. Please let me know when the staff confirm s, and what the availabilities on Thursday look like.

Also, if possible, please let us know what questions the staff has on the plots, to allow us to better prepare for the discussion.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com A Southern Nuclear From: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Tuesday, April 21, 2020 9:58 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

RE: RE: FW: Settlement Plots on ERR EXTERNAL MAIL: Caution Opening Links or Files

Yasmeen, Staff may want to have a clarification call to discuss the information posted in the ERR. I hope to be able to confirm this by tomorrow. Could SNC and Westinghouse support a call on Thursday 4/23 or Monday 4/27?

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 20, 2020 10:01 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: FW: Settlement Plots on ERR Tanny, we are working to resolve this issue. I will let you know what I hear. Thanks!

Best, Yasmeen Arafeh Nuclear Development, Licensing

Work: (205)992-7190 ynarafeh@southernco.com A Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, April 20, 2020 7:55 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Ghosh, Amitava <Amitava .Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Humphrey, Mark Phillips <MPHUMPHR@southernco.com>; Schoedel, Anthony JJ <schoeda j@westinghouse.com>

Subject:

RE: FW: Settlement Plots on ERR EXTERNAL MAIL: Caution Opening Links or Files Yasmeen/Anthony, I am no longer able to get access to the ERR. I know Westinghouse was doing a migration of the ERR. I don't know if this is the cause or something else. Pravin is also not able to access the ERR.

Could you let us know what we can do to fix this?

Thanks, Tanny From : Arafeh, Yasmeen N.<YNARAFEH@sout hernco.com>

Sent: Thursday, April 16, 2020 6:21 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] FW: Settlement Plots on ERR Hi Tanny, the plots that were discussed on the clarification call last Wednesday (4/8) have been uploaded to the ERR. Please let me know if your team has any questions, and if you would like to schedule another Webex call to further discuss.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com A Southern Nuclear

From : Schoedel, Anthony J <schoeda j@w est inghouse.com>

Sent: Thursday, April 16, 2020 5:00 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <M PHUM PH R@southernco.com>; Chamberlain, Amy Christine

<AC CHAM BE@southernco.com>

Subject:

Settlement Plots on ERR EXTERNAL MAIL: Caution Opening Links or Files Yasmeen:

Following our discussion, I have placed the figures/plots for settlement on the LAR-229 ERR folder for NRC access. The file is posted as "Settlement Monitoring Figures 1-5." Please notify NRC that th is file is available and let us know if t hey want to have a Webex to discuss.

Thanks, Anthony J. Schoedel Westinghouse Licensing Westinghouse Electric Company 1000 Westinghouse Drive CWHQ-1, 258F Cranberry Township, PA 16066 USA Office: 1-412-374-6118 Cell:!(b}(6) I E-Mail: schoeda j@westinghouse.com This e-mail ma o rietary Information of the sending organization. Any unauthorized or improper disclos , 1stribution, or use of the contents of this e-ma1 document(s) is prohibited. The informa *
  • n is e-mail and attached document(s) is intended only for the personal and pnva named above. If you have received this communication in error, please notify the sender i email and delete the original e-mai an ocument(s).

From: Ghosh, Amitava Sent: Thu, 23 Apr 2020 21:39:42 +0000 To: Patel, Pravin

Subject:

RE: Talking points for meeting with SNC

Pravin, Here is the list of three points I made:

1 (b)(4)

(b)(4) 2 31(bK41 Please comment.

Thanks, Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/DEX/ESEA OWFN 07021 Mail Stop O -07D21M 301-415-3268 Amitava.Ghosh@nrc.gov

From: Ghosh, Am itava Sent: Wed, 22 Apr 2020 20:04 :08 +0000 To : Patel, Pravin 1-page Settlement Plot ,

Attachments: Settlement Plot.pdf, Settlement.xlsx and Settlement (Excel Spreadsheet) are being withheld in their entirety under FO IA Ex. 4

Pravin, Here they are .

Amit

~~~

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Comm ission NRR/DEX/ESEA OWFN 07D21 Mail Stop O -07D21 M 301-415-3268 Amitava.Ghosh@nrc.gov

From: Patel, eravin To: Santos. Cayetano; Colaccino. Joseph 4-page attachment to be Cc: Hall, Victor; Mikula. Olivia; Ghosh. Amjtaya; Ezell, Julie

Subject:

RE: Attorney Client Privilege: LAR 20-001 withheld in its entirety Date: Thursday, May 21, 2020 6:52:47 AM under FOIA Ex. 5/Attorney Attachments: draft Audit summary LAR 20-001 dated s-20-20 JC comments PDP.docx -Client Privilege

Tanny, One typo. File is good.
Thanks, Pravin From: Sa nt os, Cayet ano <Cayeta no.Santos@nrc.gov>

Sent: Wednesday, M ay 20, 2020 5:49 PM To: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Cc: Hall, Vict or <Victor. Hall@ nrc.gov>; Mikula, Ol ivia <Olivia.Miku la@nrc.gov>; Ghosh, Amit ava

<Am itava.G hosh@nrc.gov>; Patel, Pravin <Pravin .Pat el@nrc.gov>; Ezel l, Julie <J ulie.Ezell @nrc.gov>

Subject:

RE : At t orney Client Privilege: LAR 20-001 Joe/Pravin/Amit Please see attached. I made some proposed revisions to try and address Joe's comments. (changes are in redline strikeout)

Let me know what you think Tanny From: Colaccino, Joseph <Joseph Colaccjno@nrc.gov>

Sent: Wednesday, M ay 20, 2020 4 :52 PM To: Santos, Cayetano <Cayetano Santos@nrc gov>

Cc: Hall, Vict or <Victor Ha ll @nrc gov>; M ikula, Olivia <Olivia Mjku la@nrc gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc gov>; Patel, Pravin <Pravio.Patel@orc.gov>; Ezell, Julie <Julie.Eze ll @nrc.gov>

Subject:

RE: At torney Client Privilege: LAR 20-001

Tanny, The only issue I have with the draft as transmitted to O livia and Julie is that the sett lement figures are not explicitly identified in the table or discussed in the text. We may want to state somewhere that these figures were data that was extracted from the data in the other referenced documents for better readability by the staff as certain data files in the referenced documents were unreadable.

Everything else is fine.

Thanks,

Joseph Colaccino Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEA)

Acting Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEB)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Comm ission 301 -415-7102

!(b)(6) I(Mobile)

From: Santos, Cayeta no <Cayetano Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 4:11 PM To: Mikula, Olivia <Olivia.Miku la@nrc.gov>; Ghosh, Amitava <Amitava .Ghosh@nrc.gov>; Patel, Pravin <Pravin,Patel@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>; Colaccino, Joseph

<Joseph Colaccioo@nrc gov>

Cc: Hall, Victor <Victor Hall @nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Olivia/Julie, Attached is the draft audit report. Please let us know if you think any of the language is problematic. Hopefully this can also help with your pleading.

Note that this draft has not been reviewed by the BCs (Joe and Vic) but if there are any significant changes as a result of their review I will let you know.

Tanny From: Mikula, Olivia <Olivia M ikula@nrc gov>

Sent: Wednesday, May 20, 2020 3:58 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Am itava Ghosh@nrc.gov>;

Patel, Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>; Colaccino, Joseph

<Joseph Colaccioo@nrc gov>

Cc: Hall, Victor <Victor Hall @nrc gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Hey Tanny, (b)(5)

(b)(5) Thank you for always being so

'""Tr,,-,--...,.,,.......,,------------------

Olivia From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent : Wednesday, May 20, 2020 2:12 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Mikula, Olivia <Olivia.Miku la@nrc gov>; Patel,

Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>; Colaccino, Joseph

<Joseph .Colaccino@ore.gov>

Cc: Hall, Victor <Victor Hall @nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 AmiUPravin/Joe, I provided my comments to the audit report on the SP site. Please take a look and let me know if you would like to discuss my comments/suggestions. Could you also let me know when you think you will be able to get back to me? It would help in my giving an estimate to Olivia,

Olivia, Given the situation would OGC want to review the audit report before it's issued? I don't think OGC typically provides an NLO on audit reports.

Tanny From: Ghosh, Am itava <Amitava Ghosh@nrc gov>

Sent: Wednesday, May 20, 2020 1:39 PM To: Mikula, Ol ivia <Olivia Miku la@nrc gov>; Patel, Pravin <Pravio.Patel@orc gov>; Ezell, Julie

<Julie.Eze ll @nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Cc: Santos, Cayetano <Cayetano Santos@nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Good afternoon Olivia.

We have completed the Audit Summary Report and Tanny has received it today.

I am copying Tanny as he probably is the best person to give an estimate.

Thanks, Amit

' ~ £';( ~;)If Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -07021M 301-415-3268 Amitava.Ghosh@nrc.,;:ov From: Mikula, Olivia <Olivia M ikula@nrc gov>

Sent: Wednesday, May 20, 2020 1:34 PM To: Patel , Pra vin <Pravin .Patel@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc gov>; Eze ll, Jul ie

<Julie.Ezel l@nrc.gov>; Co laccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

Attorney Cl ient Privi lege : LAR 20-001 Good afternoon ,

As I mentioned earlier in the week, l(b)(5)

(b)(5)

Thanks, Ol ivia

From: Mikula, Olivia To: Colaccino. Joseph; J>atel. Prayin; Santos. Cayetano 4-page attachment is being Cc: Hall. Victor; Ghosh. Amitaya; Ezell. Julie withheld in its entirety under

Subject:

RE: Attorney Client Privilege: LAR 20-001 FOIA Ex. 5/Attorney-Client Date: Thursday, May 21, 2020 8: 12:44 AM Privilege Attachments: draft Audit summary LAR 20-001 dated s-20-20 OGC cmts.docx Julie and I made comments on the first version you sent us, please take a look at the attached and let us know if you have any concerns.

Best, Olivia From: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Sent: Thursday, May 21, 2020 7:50 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Hall, Victor <Victor.Hall@nrc.gov>; Mikula, Ol ivia <0livia.Mikula@nrc.gov>; Ghosh, Amitava

<Amitava.Ghosh@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 I agree.

From: Patel, Pravi n <Pravin.Patel@orc gov>

Sent: Thursday, May 21, 2020 6:53 AM To: Santos, Cayetano <Cayetano Santos@nrc.gov>; Colaccino, Joseph <Joseph Colaccjno@nrc gov>

Cc: Hall, Victor <Victor Ha ll @orc.gov>; Mikula, Olivia <Olivia Mikula@nrc.gov>; Ghosh, Am itava

<Am itava.Ghosh@orc.gov>; Ezell, Julie <Julie.Ezell@orc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001

Tanny, One typo. File is good.
Thanks, Pravin From: Sa ntos, Cayetano <Cayetano.Santos@orc.gov>

Sent: Wednesday, May 20, 2020 5:49 PM To: Colaccino, Joseph <Josepb.Colaccino@nrc.gov>

Cc: Hall, Victor <Victor Hall @nrc.gov>; Mikula, Olivia <Olivia.Mikula@nrc.gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc.gov>; Pat el, Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie <Julie.Eze ll @nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Joe/Pravin/Amit Please see attached. I made some proposed revisions to try and address Joe's

comments. (changes are in redline strikeout)

Let me know what you think Tanny From: Colaccino, Joseph <Joseph Colaccjno@nrc gov>

Sent: Wednesday, May 20, 2020 4:52 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Hall, Victor <Victor.Ha ll @nrc.gov>; Miku la, Olivia <Olivia. Mikula@nrc.gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc gov>; Patel, Pravi n <Prayin Patel@nrc.gov>; Ezell, Julie <Julie.Eze ll @orc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Tanny, The only issue I have with the draft as transmitted to Olivia and Julie is that the settlement figures are not explicitly identified in the table or discussed in the text. We may want to state somewhere that these figures were data that was extracted from the data in the other referenced documents for better readability by the staff as certain data files in the referenced documents were unreadable.

Everything else is fine.

Thanks, Joseph Colaccino Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEA)

Acting Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEB)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Commission 1-41 -7 2 (b)(6) (Mobile)

From: Santos, Cayetano <Cayetano.Santos@n rc.gov>

Sent: Wednesday, May 20, 2020 4:11 PM To: Mikula, Olivia <Olivia.M iku la@nrc.gov>; Ghosh, Amitava <Amitava .Ghosh@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>; Colaccino, Josep h

<Joseph.Colaccino@nrc.gov>

Cc: Hall, Victor <Vjctor.Ha ll @nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Olivia/Julie, Attached is the draft audit report. Please let us know if you think any of the language is problematic. Hopefully this can also help with your pleading.

Note that this draft has not been reviewed by the BCs (Joe and Vic) but if there are any

significant changes as a result of their review I will let you know.

Tanny From: Mikula, Olivia <Olivia Mikula@nrc gov>

Sent: Wednesday, May 20, 2020 3:58 PM To: Sa ntos, Cayetano <Cayetano Santos@nrc gov>; Ghosh, Amitava <Amitava Ghosh@nrc.gov>;

Patel, Pravin <Pravin Patel@orc gov>; Ezell, Julie <Julie Ezell@nrc gov>; Colaccino, Joseph

<Joseph Colaccioo@nrc gov>

Cc: Hall, Victor <Yictor.Ha li@nrc gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Hey Tanny, l(b)(5)

_!(b__ ___ __,._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ hank you for always being so

)(5) thoughtful.

Olivia From: Sant os, Cayeta no <Cayetano Santos@nrc gov>

Sent: Wednesday, May 20, 2020 2:12 PM To: Ghosh, Amitava <Amitava Ghosh@nrc gov>; Mikula, Olivia <Olivia Mikuia@nrc gov>; Pa tel, Pravin <Prayin.Patei@nrc.gov>; Ezell, Julie <Juije.Ezell@nrc.gov>; Colaccino, Joseph

<Joseph Colaccino@orc gov>

Cc: Hall, Victor <Victor Hall@nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Amit/Pravin/Joe, I provided my comments to the audit report on the SP site. Please take a look and let me know if you would like to discuss my comments/suggestions. Could you also let me know when you think you will be able to get back to me? It would help in my giving an estimate to Olivia, Olivia, Given the situation would OGC want to review the audit report before it's issued? I don't think OGC typically provides an NLO on audit reports.

Tanny From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Wednesday, May 20, 2020 1:39 PM To: Mikula, Olivia <Oiivia.Mikuja@nrc.gov>; Patel, Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie

<Juiie.Eze ii @nrc gov>; Colaccino, Joseph <Joseph Co!accioo@nrc.gov>

Cc: Santos, Cayetano <Cayetano Santos@nrc gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Good afternoon Olivia.

We have completed the Audit Summary Report and Tanny has received it today.

I am copying Tanny as he probably is the best person to give an estimate.

Thanks, Amit Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regulatory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -07021 M 301-415-3268 Amjtava Ghosh(ti)nrc ~ov From: Mikula, Olivia <Olivia Mikula@nrc.gov>

Sent: Wednesday, May 20, 2020 1:34 PM To: Pate l, Pravin <Prayjn.Patel@nrc.gov>; Ghosh, Am itava <Am jtaya Ghosh@nrc gov>; Ezell, Julie

<Julie.Eze ll @nrc.gov>; Colaccino, Joseph <Joseph Colaccino@nrc.gov>

Subject:

Attorney Client Privi lege: LAR 20-001 Good afternoon, As I mentioned earlier in the weekJ(b)(5)

(b)(5)

Thanks, Olivia

From: Santos. Cayetano To: Ghosh. Amitava;. Patel. Pravin: Colaccjno. Joseph Cc: Hall, Victor; Mikula, Qlivia; Ezel!. Julie

Subject:

RE: Attorney Client Privilege: LAR 20-001 7-page attachment is being Dat e: Thursday, May 21, 2020 8:49:00 AM withheld under FOIA Ex.

Attachments: Audit report and memo LAR 20-001.aocx 5/Attorney Client Privilege All Please see attached. It's the latest file and includes the transmittal memo. I included some proposed responses to OGC comments and Amit's comment below. Pravin/Amit/Joe, I left one OGG comment for you to address.

Tanny From: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Sent: Thursday, May 21, 2020 8:38 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nre.gov>; Colaeeino, Joseph <Joseph.Colaecino@ nre.gov>

Cc: Hall, Victor <Victor.Hall@nrc.gov>; Mikula, Ol ivia <Olivia.Miku la@nrc.gov>; Ezell, Julie

<Ju lie.Eze ll@nre.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Good morning all.

There is a typo. I have a suggestion:

" ... documents were difficult to read and interpret." I am suggesting to add "and interpret" to make it clear.

But no big deal.

Than ks a lot.

Amit J;r'~u-i! ~ho.J,h Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -07021M 301-415-3268 Amjtava.Ghosh@.nrc,iQY From: Patel, Pravin <Pravin.Patel@nrc.gov>

Se nt: Thursday, May 21, 2020 6:53 AM To: Santos, Cayet ano <Cayetano Santos@orc.iNv>; Colaccino, Joseph <Joseph.Colaccjno@nrc.gov>

Cc: Hall, Victor <Victor Hall @nrc.gov>; Mikula, Olivia <Olivia Mikula@nrc.gov>; Ghosh, Am itava

<Am itava.G hosh@nrc.gov>; Ezell, Julie <Julie.Ezell@orc.gov>

Subject:

RE : Attorney Cl ient Privilege: LAR 20-001

Tanny, One typo. File is good.
Thanks, Pravin From: Sa ntos, Cayeta no <Cayeta no.Santos@nrc gov>

Sent: Wednesday, May 20, 2020 5:49 PM To: Colaccino, Joseph <Joseph Colaccjno@nrc.gov>

Cc: Hall, Victor <Yictor.Ha ll @nrc gov>; Mikula, Olivia <Olivia. Mikula@nrc gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc.gov>; Patel, Pravi n <Pravin.Patel@nrc.gov>; Ezell, Julie <Julje.Ezell @nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Joe/Pravin/Amit Please see attached. I made some proposed revisions to try and address Joe's comments. (changes are in redline strikeout)

Let me know what you think Tanny From: Colaccino, Joseph <Joseph.Colaccino@ nrc.gov>

Sent: Wednesday, May 20, 2020 4:52 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Hall, Victor <Victor.Ha ll @nrc.gov>; Mikula, Olivia <Olivia. Mikul a@nrc.gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc.gov>; Patel, Pravi n <Pravin.Patel@nrc.gov>; Ezell, Julie <Julie.Eze ll @nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001

Tanny, The only issue I have with the draft as transmitted to Olivia and Julie is that the settlement figures are not explicitly identified in the table or discussed in the text. We may want to state somewhere that these figures were data that was extracted from the data in the other referenced documents for better readability by the staff as certain data files in the referenced documents were unreadable.

Everything else is fine.

Thanks, Joseph Colaccino

Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEA)

Acting Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEB)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Commission 301-415-7102

!(b)(6)  !(Mobile)

From: Sant os, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 4:11 PM To: Mikula, Ol ivia <Oljvja.Mjkrula@nrc gov>; Ghosh, Amitava <Amjtava Ghosh@nrc.gov>; Patel, Pravin <Pravio Patel@nrc gov>; Ezell, Julie <Julie Ezell@orc gov>; Colaccino, Joseph

<Joseph.Colaccjno@nrc.gov>

Cc: Hall, Victor <Yietor.Ha ll@nre gov>

Subject:

RE : Attorney Cl ient Privilege: LAR 20-001 Olivia/Julie, Attached is the draft audit report. Please let us know if you think any of the language is problematic. Hopefully this can also help with your pleading.

Note that this draft has not been reviewed by the BCs (Joe and Vic) but if there are any significant changes as a result of their review I will let you know.

Tanny From: Mikula, Olivia <Olivia.M jkula@nre gov>

Sent: Wednesday, May 20, 2020 3:58 PM To: Sa ntos, Cayetano <Cayetano.Santos@nre.gov>; Ghosh, Amitava <Am jtava.Ghosh@nre.gov>;

Patel, Pravin <Pravio Patel@nre gov>; Ezell, Julie <Julie Ezell@nre gov>; Colaccino, Joseph

<Joseph .Colaeeioo@ore.gov>

Cc: Hall, Victor <Yietor.Ha ll@nre.gov>

Subject:

RE: Attorney Cl ient Privilege: LAR 20-001 Hey Tanny, (b)(5)

(b)(5)

-...---,-.,.,......,,----------------- hank you for always being so Olivia From: Santos, Cayetano <Cayetano,Santos@nre.gov>

Sent: Wednesday, May 20, 2020 2:12 PM To: Ghosh, Amitava <Amjtava.Ghosh@nre.gov>; Mikula, Olivia <Olivia,Mjkula@nre.gov>; Patel, Pravin <Pravio,Patel@nrc.gov>; Ezell, Julie <Julje.Ezell@nre.gov>; Colaccino, Josep h

<Joseph .Colaeeioo@o re. gov>

Cc: Hall, Victor <Victor Hall @nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Amit/Pravin/Joe, I provided my comments to the audit report on the SP site. Please take a look and let me know if you would like to discuss my comments/suggestions. Could you also let me know when you think you will be able to get back to me? It would help in my giving an estimate to Olivia,

Olivia, Given the situation would OGC want to review the audit report before it's issued? I don't think OGC typically provides an NLO on audit reports.

Tanny From: Ghosh, Amitava <Amitava Ghosh@nrc gov>

Sent: Wednesday, May 20, 2020 1:39 PM To: Mikula, Ol ivia <Olivia.Mikula@nrc Ov>; Patel, Pravin <Pravin Patel@nrc OV>; Ezell, Juli,e

<Julie.Eze ll @nrc gov>; Colaccino, Joseph <Joseph Colaccjno@orc.ov>

Cc: Santos, Cayetano <Cayetano Santos@nrc.gov>

Subject:

RE: Attorney Cl ient Privilege: LAR 20-001 Good afternoon Olivia.

We have completed the Audit Summary Report and Tanny has received it today.

I am copying Tanny as he probably is the best person to give an estimate.

Thanks, Amit Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -07021M 301 -415-3268 Amitava.Ghosh@nrc ~ov From: Mikula, Olivia <Olivia M ikula@nrc,ov>

Sent: Wednesday, May 20, 2020 1:34 PM To: Pate l, Pravin <Pravin Patel@nrc gov>; Ghosh, Am itava <Amitaya Ghosh@nrc gov>; Ezell, Julie

<Julie.Ezel l@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

Attorney Client Privi lege : LAR 20-001 Good afternoon ,

As I mentioned earlier in the week,l(b)(5)

(b)(5)

Thanks, Olivia

From: Santos. Cayetano 7-page attachment is being To: Ghosh. Amitava;. Patel. Pravin: Colaccjno. Joseph withheld in its entirety Cc: Hall, Victor; Mikula, Qlivia; Ezel!. Julie; Martin, Jody under FOIA Ex. 5/Attorney

Subject:

RE: Attorney Client Privilege: LAR 20-001 Client Privilege Date: Thursday, May 21, 2020 11:46:00 AM Attachments: Audit report and memo LAR 20-001 Rey Ldocx

All, Attached is the latest version of the audit report. There were some additional comments from Jody Martin. This version includes Jody's comments and some proposed revisions to address them.

Please let me know if you have any more comments/concerns.

Thanks Tanny From: Ghosh, Amitava <Am itava.Ghosh@nrc.gov>

Sent: Thursday, May 21, 2020 8:38 AM To: Patel, Pravin <Pravin.Patel@nrc.gov>; Sant os, Cayeta no <Cayet ano.Santos@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@ nre.gov>

Cc: Hall, Vict or <Victor. Hall@nrc.gov>; Mikula, Ol ivia <Olivia.Mikula@nrc.gov>; Ezell, Julie

<Ju lie. Eze l l@nre.gov>

Subject:

RE: Att orney Client Privilege: LAR 20-001 Good morning all.

There is a typo. I have a suggestion:

" ... documents were difficult to read and interpret." I am suggesting to add "and interpret" to make it clear.

But no big deal.

Thanks a lot.

Amit J;/~ ~ ~ o,,y,t{

Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -070 21M 301-415-3268 Amitava Ghosh@nrc r;ov

From: Patel, Pravin <Pravin.Patel@nrc gov>

Sent: Thursday, May 21, 2020 6:53 AM To: Santos, Cayetano <Cayetano Santos@nrc.gov>; Colaccino, Joseph <Joseph.Co!accino@nrc.gov>

Cc: Hall, Victor <Victor.Ha ll @nrc.gov>; Mikula, Olivia <Olivia Mikula@nrc.gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc.gov>; Ezell, Julie <Julie Ezell@nrc.gov>

Subject:

RE : Attorney Cl ient Privilege: LAR 20-001

Tanny, One typo. File is good.
Thanks, Pravi n From: Sa ntos, Cayeta no <Cayetano Santos@nrc gov>

Sent: Wednesday, May 20, 2020 5:49 PM To: Colaccino, Joseph <Josepn Colaccino@nrc.gov>

Cc: Hall, Victor <Vjctor.Ha ll @nrc gov>; Mikula, Olivia <Olivia Mikula@nrc gov>; Ghosh, Am itava

<Am itava Ghosh@nrc gov>; Patel, Pravin <Pravjn.Pate\@nrc gov>; Ezell, Julie <Julie.Eze l\ @nrc gov>

Subje ct: RE: Attorney Cl ient Privilege: LAR 20-001 Joe/Pravin/Amit Please see attached. I made some proposed revisions to try and address Joe"s comments. (changes are in redline strikeout)

Let me know what you think Tanny From: Colaccino, Joseph <Joseph.Colaccino@ nrc.gov>

Sent: Wednesday, May 20, 2020 4:52 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Hall, Victor <Yictor.Ha ll @nrqwv>; Mikula, Olivia <O\jvja.Mjkula@nrc gov>; Ghosh, Am itava

<Am itava.Ghosh@nrc.gov>; Patel, Pravi n <Pravin.Patel@orc.gov>; Ezell, Julie <Ju\je.Eze ll @nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Tanny.

The only issue I have with the draft as transmitted to Olivia and Julie is that the sett lement figures are not explicitly identified in the table or discussed in the text. We may want to state somewhere that these figures were data that was extracted from the data in the other referenced documents for better readability by the staff as certain data files in the referenced documents were unreadable.

Everything else is fine.

Than ks, Joseph Colaccino Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEA)

Acting Chief, Structural, Civil, and Geotechnical Engineering Branch (ESEB)

Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Comm ission 301 -415-7102 l(b)(6)  !(Mobile)

From: Sa nt os, Cayetano <Cayetano Santos@nrc gov>

Sent: Wednesday, May 20, 2020 4:11 PM To: Mikula, Olivia <Oiivja,Mjku ia@nrc.gov>; Ghosh, Amitava <Amjtava.Ghosh@nrc.gov>; Patel, Pravin <Pravin Patei@nrc.gov>; Ezell, Julie <Julie Ezell@nrc,ov>; Colaccino, Joseph

<Joseph Colaccjno@nrc gov>

Cc: Hall, Victor <Victor Haii @nrc gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Olivia/Julie, Attached is the draft audit report. Please let us know if you think any of the language is problematic. Hopefully this can also help with your pleading.

Note that this draft has not been reviewed by the BCs (Joe and Vic) but if there are any significant changes as a result of their review I will let you know.

Tanny From: Mikula, Olivia <Olivia M ikula@nrc.gov>

Sent: Wednesday, May 20, 2020 3:58 PM To: Sa ntos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>;

Patel, Pravin <Pravin Patel@nrc gov>; Ezell, Julie <Julie Ezell@nrc.gov>; Colaccino, Joseph

<Joseph.Coiaccioo@orc.gov>

Cc: Hall, Victor <Victor.Ha ll@nrc.gov>

Subject:

RE: Attorney Cl ient Privilege: LAR 20-001 Hey Tanny, (b)(5)

(b)(5) Thank you for always being so Olivia From: Santos, Cayetano <Cayetano Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 2:12 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Mikula, Olivia <01ivia.Mikula@nrc.gov>; Patel, Pravin <Pravin.Patel@orc gov>; Ezell, Julie <Julie Ezell@nrc.gov>; Colaccino, Josep h

<Joseph Colaccioo@nrc gov>

Cc: Hall, Victor <Yictor.Ha ll@nrc.gov>

Subject:

RE : Attorney Cl ient Privilege: LAR 20-001 Amit/Pravin/Joe, I provided my comments to the audit report on the SP site. Please take a look and let me know if you would like to discuss my comments/suggestions. Could you also let me know when you think you will be able to get back to me? It would help in my giving an estimate to Olivia,

Olivia, Given the situation wou ld OGC want to review the audit report before it's issued? I don't think OGC typically provides an NLO on audit reports.

Tanny From: Ghosh, Am itava <Amitava Ghosh@nrc.gov>

Sent: Wednesday, May 20, 2020 1:39 PM To: Mikula, Ol ivia <Olivia Miku la@nrc gov>; Patel, Pravin <Pravin Patel@orc gov>; Ezell, Juli,e

<Julie Eze ll@nrc gov>; Colaccino, Joseph <Joseph Colaccjno@nrc.gov>

Cc: Santos, Cayetano <Cayetano Santos@ nrc gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Good afternoon Olivia.

We have completed the Audit Summary Report and Tanny has received it today.

I am copying Tanny as he probably is the best person to give an estimate.

Thanks, Amit

%ndUa.:j,/f Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 07021 Mail Stop O -07021M 301-415-3268 Amjtava.Ghosh@nrc eov

From: Mikula, Olivia <0livia.Mikula@nrc.gov>

Sent: Wednesday, M ay 20, 2020 1:34 PM To: Pate l, Pravin <Pravin.Patel@nrc.gov>; Ghosh, Am itava <Amitava.Ghosh@nrc.gov>; Ezell, Ju lie

<Julie.Ezel l@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Subject:

Attorney Client Privi lege: LAR 20-001 Good afternoon ,

As I mentioned earlier in the week .l(b)(5)

(b)(5)

Thanks, Olivia

From: Santos. Cayetano To: Mikula, Olivia; Ghosh. Amitava; pate!. Pravio; Ezen. Julie: "";Co~la~cc~io.=Jo~se~p='

n~ =-h- - - - - ~

Cc: Hall. Victor 4-page attachment to be

Subject:

RE: Attorney Client Privilege: LAR 20-001 withheld in its entirety under Date: Wednesday, May 20, 2020 4:10:00 PM FOIA Ex. 5/Attorney-Client Attachments: draft Audit summary LAR 20-001 dated s-20-20.docx Privilege Olivia/Julie, Attached is the draft audit report. Please let us know if you think any of the language is problematic. Hopefully this can also help with your pleading.

Note that this draft has not been reviewed by the BCs (Joe and Vic) but if there are any significant changes as a result of their review I will let you know.

Tanny From: Mikula, Olivia <Olivia.Mikula@nrc.gov>

Sent: Wednesday, May 20, 2020 3:58 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>; Ghosh, Amitava <Amitava.Ghosh@nrc.gov>;

Patel, Pravin <Pravin.Patel@nrc.gov>; Ezell, Julie <Ju lie.Ezell@nrc.gov>; Colaccino, Joseph

<Joseph.Colaccino@nre.gov>

Cc: Hall, Victor <Victor.Hall@nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Hey Tanny, (b)(5)

(b)(5) hank you or always being so Olivia From: Sant os, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 2:12 PM To: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>; Mikula, Olivia <Olivia.Miku la@nrc.gov>; Patel, Pravin <Pravi n.Patel@nrc.gov>; Ezell, Julie <Julie.Ezell@nrc.gov>; Colaccino, Josep h

<Joseph .Colaccioo@ore.gov>

Cc: Hall, Victor <Vjctor.Ha ll @nrc.gov>

Subject:

RE : Attorney Client Privilege: LAR 20-001 Amit/Pravin/Joe, I provided my comments to the audit report on the SP site. Please take a look and let me know if you would like to discuss my comments/suggestions. Could you also let me know when you think you will be able to get back to me? It would help in my giving an estimate to Olivia, Olivia,

Given the situation wou ld OGC want to review the audit report before it's issued? I don't think OGC typically provides an NLO on audit reports.

Tanny From: Ghosh, Am itava <Amitava.G hosh@nrc.gov>

Sent: Wednesday, May 20, 2020 1:39 PM To: Mikula, Ol ivia <Olivia Mikula@nrc.gov>; Patel, Pravin <Pravi n Patel@orc gov>; Ezell, Julie

<Julie.Eze ll @nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc gov>

Cc: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

RE: Attorney Client Privilege: LAR 20-001 Good afternoon Olivia.

We have completed the Audit Summary Report and Tanny has received it today.

I am copying Tanny as he probably is the best person to give an estimate.

Thanks, Amit

,ybi,/ ~ J/h Amitava Ghosh, PhD Geotechnical Engineer U.S. Nuclear Regu latory Commission NRR/OEX/ESEA OWFN 070 21 Mail Stop O -07021M 301-415-3268 Amitava Ghosh@nrc i:ov From: Mikula, Olivia <Olivia.Mikula@nrc.gov>

Sent: Wednesday, May 20, 2020 1:34 PM To: Pate l, Pravin <Prayin.Patel@nrc.gov>; Ghosh, Am itava <Am itaya.Ghosh@nrc gov>; Ezell, Julie

<Julie Eze ll @nrq;ov>; Colaccino, Joseph <Joseph.Co!accino@nrc gov>

Subject:

Att orney Client Privi lege: LAR 20-001 Good afternoon, As I mentioned earlier in the week,l(b)(5)

(b)(5)

Thanks, Olivia

From: Mikula, Oljyja 4-page attachment to be To: Santos. Cayetano Cc: Ezell, Julie withheld in its entirety under

Subject:

FW: Audit report FOIA Ex. 5/Attorney-Client Dat e: Thursday, May 21, 2020 10:34: 19 AM Privilege Attachments: draft Audit summary LAR 20-001 dated s-20-20 OGC cmts.docx Hey Tanny, Please take a look at this version of the audit report - Jody had a couple of small things to add. Sorry to keep sending you different versions (last one - I promise). I really appreciate your coordination.

Best, Olivia From: Martin, Jody <Jody.Ma rtin@nrc.gov>

Sent: Thursday, May 21, 2020 10:29 AM To: M ikula, Ol ivia <Olivia. M iku la@nrc.gov>

Cc: Ezell, Julie <Ju lie.Ezell@nrc.gov>

Subject:

RE: Audit report Thanks Olivia, (b)(5)

(b)(5) and had a cou le more.

(b)(5)

Best, Jody Jody C. Martin Deputy Assistant General Counsel for New Reactor Programs Office of the General Cou nsel U.S. Nuclea r Regulatory Commission 301-287-9201 Jody.Martin@nrc.gov From: M ikula, Olivia <Olivia.M ikula@nrc.gov>

Sent: Thursday, May 21, 2020 9:34 AM To: Martin, Jody <Jody.Martio@nrc.gov>

Cc: Ezell, Julie <Ju lie.Ezell@orc.gov>

Subject:

Audit report

Hey Jody, Just FYI - This is the audit re ort with comments from Julie and I. Let me know if ou have any major concerns. (b)(5)

Best, Ol ivia

From: schoedeL Antho DY J To: Arafeh. Yasmeen N: Santos. Cayetano Cc: Humphrey. Mark PbilliPs

Subject:

[External_Sender) RE: RE: RE: LAR-20-001 Dat e: Wednesday, May 20, 2020 1:27:47 PM Attachments: imaaeoo1.ona Tanny/Yasmeen:

I've filled in the blanks below. For the Settlement Monitoring Figures, please note that t his fi le was compiled at the request of NRC as an action from our first Webex audit meeting. NRC asked to see plots overlaying the measured-to-pred icted settlements. So we put these together in a single file for posting to ERR to support our second Webex audit meeting. As such, t his fi le does not have its own document number/rev/date. It is simply plotting the data from SV0-0500-XCR-800031 and APP-G9-XCR-002 onto common plots at NRC request.

Thanks, Anthony J. Schoedel Manager (Acting)

Regulatory Compliance & Corporate Licensing Office: 1-412-374-6118 Cell: l(b)(6) I From: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Sent: Wednesday, May 20, 2020 11:52 AM To: Schoedel, Anthony J <schoedaj@westinghouse.com>

Cc: Humphrey, Mark Phi llips <MPHUMPHR @sout hernco.com>; Santos, Cayetano

<Cayetano.Sa ntos@nrc.gov>

Subject:

FW: RE: RE: LAR-20-001 Anthony, could you please help us fi ll in some of the blanks in Tanny's email below?

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 vnarafeh@southernco.com J

From: Santos, Cayetano <Cayetano.Santos@nrc gov>

Sent: Wednesday, May 20, 2020 10:31 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subject:

RE: RE: RE: LAR-20-001 EXTERNAL MAIL: Caution Opening Links or Files Yasmeen Thanks for the quick response. Another question for you. The list of documents provided in the ERR is below. Could you please confirm that the information is correct. There are a few question marks I couldn't find .

Westinghouse Revision Document Title Document No. No. Date SV3-1200-GNR-000014 Auxiliary Bui lding Wal l 11 Seismic Gap 0 06/12/2019 violation near Col Line J above Elev.

135'-3" (ESR 50019720)

SV0-0500-XCR-800031 Interi m Report No. 30. Settlement 0 04/29/2019 Monitor ing of Power Block Structures for t he Period from August 1, 2017 through December 31, 2018 APP-lOOO_GE F-250 Appe ndix F; Vogtle Specific Soil 0 11/4/2019 Settlement APP-G9-XCR-002 Settlement Re-ana lysis of the APlOOO 5 04/07/2014 Buildings w it h Considerat ion to Construction Sequence Vogtle Units 3 and 4 APP-G9-XCR-004 Settlement Ana lysis of the APlOOO 0 03/10/2015 Buildings w it h Consideration to Const ruct ion Sequence for Vogtle Unit 4

N/A Settlement Monitoring Figures (This N/A N/A fi le was created at req uest of NR during f irst Webex audit to pull data from SV0-0500-XCR-800031 and APP-G9-XCR-002 and overlay them on a single plot to show comparison between measured-to-predicted settlement)

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com >

Sent: Wednesday, M ay 20, 2020 11:25 AM To: Sa ntos, Cayetano <Cayetano Santos@nrc gov>

Subject:

[External_Sender] RE: RE: LAR-20-001

Tan ny, see below:

SNC:

Yasmeen Arafe h Mark Humphrey Amy Chamberlain Amjid Qureshi WEC:

Anthony Schoedel Sam uel Boa kye

Best, Yasmeen Arafeh Nuclear Development, Lice nsing Work: (205)992-7190 ynarafeh@southernco com From: Santos, Cayeta no <Cayetano.Santos@nrc.gov>

Sent: Wednesday, May 20, 2020 9:32 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subject:

RE : RE : LAR-20-001 EXTERNAL MAIL: Caution Opening Links or Files Yasmeen ,

I am working on the audit summary. Could you give me a list of all the people from SNC and Westinghouse that participated in our audit calls? I don't need to know who participated on each call but a complete list of everyone (and their organization) who participated in any of them Thanks Tanny This e- contain proprietary information of the sending organization. Any unauthorized or improper disclosure, cop i distribution, or use o ts of this e-mail and attached document(s) Is prohibited. The information con *

  • 1s e-mail and attached document(s) is intended on ersonal and private use of the recipient(s) nam . you have received this communication in error, please notify the sender 1mr *
  • b email and dele 1nal e-mail and attached document(s).

h,~~-:rrrmay contain proprietary Information of the sending organization. Any unauthorized or Improper disclosure, copying.

From: Santos, Cayetano Sent: Tue, 24 Mar 2020 20:33 :26 +0000 To: Arafeh, Yasmeen N.

Subject:

Clarification Call - LAR 20-001 Attachment same Attachments: Clarification questions related to Aud it of LAR 20 Final.pdf asonpg. 74 Yasmeen ,

Attached are some clarification questions staff would like to discuss regarding the audit for LAR 20-001. Please take a look and give me a call so we can try to schedule a clarification call. You can reach me on my cell at!(b)(6) I*

Tanny

From: Arafeh, Yasmeen N.

Se nt: Tue, 17 Mar 2020 15:07:30 +0000 To: Santos, Cayetano Cc: Ghosh, Amitava

Subject:

[External_Sender) RE: RE: FW: RE: RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting Hi Tanny, I apologize for the delay in my response. What we posted to the ERR is the latest data.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

._ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Sunday, March 15, 2020 8:14 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

RE: RE: FW: RE: RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting

Yasmeen, Amit can access the ERR now Thank you.

We noted that the settlement info ends in 2018. IS there more recent Information that could be provided?

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Thursday, March OS, 2020 4:09 PM To: Santos, Cayetano <Cayetano.Santos@nrc gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

[External_Sender] RE: FW: RE: RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting The link I sent should work for everyone I Please let me know if Amit also has issues logging in. Thanks I

Best,

Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, March 5, 2020 3:08 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Ghosh, Amltava <Amitava.Ghosh@nrc.gov>

Subject:

RE: FW: RE: RE: RE: RE : LAR-20-001 (LAR-229) Post Submittal Meeting EXTERNAL MAIL; ,Caution Opening links or Files Yasmeen Amit has also filled in the forms and changed his password. Can you send him the link as well so he can try to access it? Or will the same link that you sent me work for him also?

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Thursday, March 05, 2020 3:46 PM To: schoedaj@westinghouse.com Cc: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] FW: RE: RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting Hey An~ ony, do yo, have any 5"ggestlons fo, Tanny that co,ld help him access to the ERRl Is the~

omaln the correct one to use?

1 Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, March 5, 2020 2:43 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

RE: RE: RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting EXTERNAL MAil! Caution Opening Links or Files

I've tried that but I'm still not getting in.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Thursday, March OS, 2020 3:39 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: RE: LAR- 20-001 (LAR-229) Post Submittal Meeting 4

Tanny, I believe you ente1...(b-)(_l _ __,r our username in the username field as shown in the example in the link. . .

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh~thernco.com

  1. !. Southern Nuclear From: Santos, Cayetano <C.iyetano.Santos@nrc.gov>

Sent: Thursday, March 5, 2020 2:36 PM To: Arafeh, Yasmeen N. <YNARAF-EH@southernco.com>

Subject:

RE : RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting EXTERNAL MAIL: Caution Opening Links or Files I may be doing something wrong What domain do I enter?

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Thursday, March OS, 2020 3:29 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting HI Tanny, that's great I Try this link, and let me know If it works:

l(b)(4)

Best, Yasmeen Arafeh Nuclear Development, licensing Work: (205)992-7190 ynairafeh@southernco.com

  • Southern Nuclear

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, March 5, 2020 2:28 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

RE : RE: RE: LAR-20-001 {LAR-229) Post Submittal Meeting EXTERNAL MAJL;-Cautlon OpeningLinks_~tflles Yasmeen I received the email and filled out the forms. I think I have access now How do I see the documents that were uploaded? Do I have to wait until the forms are approved before I can access them?

Just want to know what the next step 1s.

Thanks Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Thursday, March 05, 2020 9:53 AM To: Santos, Cayetano <Cayetano.Sant os@nrc.gov>

Subject:

[External_Sender] RE: RE: LAR-20-001 (LAR-229) Post Submittal Meeting Hi Tanny!

4 You and Amitava should be receiving emails from l(b)( ) ~ ith a request to fill out export control forms to get username and password information to access the ERR. Please let me know if you do not receive this email soon. Pravin is currently the only one with active access to the ERR.

The following documents have been uploaded to the ERR:

1. APP-G9-XCR-002 includes the information from item 1 in your email below
2. SVO-OSOO-XCR-800031 includes the information from items 2 and 3 in your email below Please let me know if you have any questions. Thanks!
Best, Yasmeen Arafeh Nuclear Development, Licensing Wo.rk: {205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, March 2, 2020 2:14 PM

To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subject:

RE : RE : LAR-20-001 (LAR-229) Post Submitta l Meeting Yasmeen ,

Staff is looking for the following information as part of its audit. When can this be made available in the ERR?

1. original analysis and prediction of the total and differential settlements for each structure,
2. settlement measurements of each structure along with the trend analysis of the total and differential settlement with time , especially when substantial loads were added at different construction stages, and
3. construction sequence including time lag of construction among these structures.

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Wednesday, February 19, 2020 9:40 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Rankin, Jennivine <Jenmvine.Rankin@nrc.gov>

Subject:

[External_Sender] RE: LAR-20-001 (LAR-229) Post Submittal Meeting Hi Tanny, thank you for letting me know. Do you have any more details on what specifically NRC is looking for as far as settlement is concerned so we can make the appropriate documentation available?

In the meantime, we will work on providing access to you and the following staff:

Amltava Ghosh Amitava.Ghosh@nrc.gov Pravin Patel Pravin.Patel@nrc.gov

Best, Yasmeen Arafeh Nuclear Development, Licensing Wo,rk: {205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc gov>

Sent: Tuesday, February 18, 2020 12:20 PM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Cc: Rankin, Jennlvlne <Jenniv1ne.Rankin@nrc.gov>

Subject:

Re: LAR-20-001 (LAR-229) Post Submittal Meeting EXTERNAL MAIL: Caution Opening Links or Ales Yasmeen There won't be a need to discuss LAR 20-001 this week.

Is the settlement information that staff asked about during the last call going to be made available through the ERR?

Tanny On: 17 February 202011:16, "Arafeh, Yasmeen N." <YNARAFEH@southernco.com> wrote:

Hi Tanny! I am aware that this Thursday is the VRG, and so I'm wondering if we'd be able to hold a post-submittal meeting for LAR-20-001 this week, or if next Thursday would work better? Please let me know what you think.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work : (205)992-7190 ynarafeh@southernco .com

From: Arafeh, Yasmeen N.

Se nt: Thu, 9 Apr 2020 19:58:12 +0000 To: Santos, Cayetano Cc: Humphrey, Mark Phillips

Subject:

[External_Sender] RE: RE: RE: LAR-20-001 Clarification Call Follow Up Hi Tanny, APP-G9-XCR-004 has been uploaded to the ERR.

Additionally, we are working on putting the requested plots together, and we expect them to be completed and uploaded to the ERR by Monday 4/ 20.

Best, Yasmeen Arafeh Nuclear Development, Licensing Wo,rk: (205)992-7190 ynarafeh@southernco rom

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Thursday, April 9, 2020 12:17 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

RE: RE: RE: LAR-20-001 Clarification Call Follow Up

Yasmeen, Yesterday during our phone call Anthony posted a new document in the ERR that showed a couple of settlement graphs. The staff has taken a closer look at this document and noted that this document references APP-G9-XCR-004. Could APP-G9-XCR-004 also be added to the ERR?

Thanks Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 2:34 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco com>

Subject:

[External_Sender] RE: RE: LAR-20-001 Clarification Call Follow Up HI Tanny, yes, that is my understanding. Is this what Amit and Pravin are expecting?

Best, Yasmeen Arafeh Nuclear Development, Licensing Wo,rk: (205)992-7190 ynarafeh@southernco.com

._ Southern Nuclear Fro:m: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 202012:33 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco com>

Subject:

RE: RE: LAR-20-001 Clarification Call Follow Up tXTERNAL MAIL: Cautlon Opcnlng~jllnks or Files Sorry for all the emails. One more question: For tomorrow's meeting 1s the plan for WEC to "walk the staff through" the existing documents in the ERR to highlight specific text/tables/figures to address staffs questions?

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 12:52 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: LAR-20-001 Clarification Call Follow Up Tanny, I got a webex invitation for tomorrow from Luis Betancourt, so I am assuming you got it figured out?

I tried to forward it to my WEC team, but I got an error. Could you please have him invite Anthony and Sam as well?

Anthony Schoedel schoedaj@westinghouse com Samuel Boakye boakyesv@westinghouse.com

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

>. Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 10:07 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco com>

Subject:

RE: RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up

.-----=~r-=- -~:,a-_;;;11,. +- -=--"I;:;.._ ~ .*T. !ifil!,*J-=

EXTERNA_L MAIL! Caution O__penlng ~Inks or:.f.lles Let's try for 12:30-2:00 on Wed 4/8.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 10:50 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up Tanny, WEC Is unavailable on Friday due to the holiday.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 9:48 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Subject:

RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up E)CTIR"iiAL MAIL( ciution Openirig [links'o r Files How about Friday 4/10 from 9-11 am? Especially since we still have to figure out how to do webex.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 10:47 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: RE: LAR- 20-001 Clarification Call Follow Up Tanny, I feel like I remember Jennie telling me that the NRC has the ability to organize both skype and webex meetings. I'm reaching out to her now to see, because we only have skype at SNC, and WEC cannot access skype.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 9:43 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

RE : RE: RE: RE: LAR*l0-001 Clarification Call Follow Up I'll check. But will you be able to organize a webex meeting? I don't think I've even participated in one of those.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Se nt: Tuesday, April 07, 202010:40 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco com>

Subject:

[External_Sender) RE: RE: RE: LAR-20-001 Clarification Call Follow Up Tanny, I believe we can work around the staffs availability for tomorrow. Please send me some times you think would work.

Bes.t, Yasmeen Arafeh Nuclear Development, Licensing Wo,rk: (205)992*7190 ynarafeh@southernco.com

._ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Se nt: Tuesday, April 7, 2020 9:35 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco com>

Subject:

RE : RE: RE: LAR-20-001 Clarification Call Follow Up Unfortunately I don't know how to organize a webex meeting. What time on Wed? I'll see if we can support.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 10:32 AM

To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] RE: RE: LAR-20-001 Clarification Call Follow Up Hi Tanny, good news, our team is also available tomorrow! Do you have the ability to organize a webex meeting? WEC cannot access skype meetings.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

._ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 8:48 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

RE: RE: LAR-20-001 Clarification Call Follow Up EXTERNAL_MAlij.,.t a_ut!on Openl"g1Llnks_or)llcs Right now T hursday and Friday this week don't look good. Would tomorrow (Wed) be too soon? If so then maybe we try 3-5 pm again next Monday, April 13 if we can't find anything else this week.

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 5:05 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subje ct: [External_Sender] RE: LAR-20-001 Clarification Call Follow Up Tanny, yes we are aligned. SNC had our initial internal meeting where we discussed a few different action items we'd need to take to determine what the path forward will need to be. As a result, I've provided the page numbers in the responses to aid Pravin and Amit in their reviews in the meantime.

If you'd like for me to go ahead and set up a webex call, please provide me a few different windows of availability for this week (or next) so that I can ltry to get somet hing on our calendars.

Best, Yasmeen Arafeh Nuclear Development, Licensing Wo,rk: (205)992-7190

ynarafeh@southernco.com

._ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, April 6, 2020 3:53 PM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco com>

Subject:

RE : LAR-20-001 Clarification Call Follow Up Thanks, Yasmeen. I will share with the staff. I think SNC was going to have some internal discussions to determine the best way to "walk the staff' through the data/tables in the reports.

(Basically, what Mike King proposed). I think a webex or skype call for the meeting to do this would be helpful. Is this your understanding?

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 4:46 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco com>

Subject:

[External_Sender] LAR-20-001 Clarification Call Follow Up HI Tanny, while we look Into our options on what we can provi de for more clarification, I wanted to send you a write up of our responses to the five audit questions. I have highlighted the responses t hat point to page numbers in the reports. Please let me know if this helps address some of the Staff's concerns, or if the Staff would like to walk through these pages with our team. I' d be happy to help set up a webex call .

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

._ Southern Nuclear

From: Patel, Pravin Se nt: Wed, 8 Apr 2020 12:58:32 +0000 To: Santos, Cayetano Cc: Ghosh, Amitava

Subject:

FW: Clarification questions Attachments: Clarification questions.doc><

As you requested before.

From: Patel, Pravin Sent: Tuesday, April 07, 2020 4 :17 PM To: Colaccino, Joseph <Joseph.Colaccino@nrc.gov>

Cc: Ghosh, Amitava <Amitava.Ghosh@nrc.gov>

Subject:

FW: Clarification questions Joe.

Amit and I have prepared simplified discussion points for the SNC WebEx meeting tomorrow. If you have questions we can discuss this before the internal alignment rneeting(11am). It is best that three of us agree before we send to PM

Thanks, Pravin From: Ghosh, Amltava <Amitava.Ghosh@nrc.gov>

Sent: Tuesday, April 07, 2020 4 :02 PM To: Patel, Pravin <Pravin.Patel@nrc.gov>

Subject:

Clarification questions

Pravin, Here is the revised text. Thanks a lot for all your help.

Amit

1. Provide clear visualization of settlement measurement at different points with time (currently ending at December 2018; but include 2019 measurements as stated in the LAR page 8).
2. Walk with the staff through the timeline of settlement measurements at critical oints versus prediction to COLA license (plant fuel load). (b)(4)

(b)(4)

(b){4) SNC need

3. Walk through with the staff and explain how to confirm in actual measurements that the Annex Buildin is settlin in the o osite direction of the Nuclear Island, (b)(4)

(b)(4)

From: Santos, Cayetano Sent: Mon, 6 Apr 2020 20:55:47 +0000 To: Patel, Pravin;Ghosh, Amitava;Colaccino, Joseph;Hall, Victor;King, Mike

Subject:

FW: LAR-20-001 Clarification Call Follow Up Attachments: LAR-20-001 Audit Question Responses.pdf Attachment same as on pgs. 108- 109

All, See attached. SNC is sharing the answers they provided during this afternoon's phone call to the clarification questions.

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 4:46 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] LAR-20-001 Clarification Call Follow Up Hi Tanny, while we look into our options on what we can provide for more clarification, I wanted to send you a w rite up of our responses to the five audit questions. I have highlighted the responses that point to page numbers in the reports. Please let me know if this helps address some of the Staffs concerns, or if the Staff would like to walk through these pages w it h our team. I'd be happy to help set up a w ebex call.

Best.

Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7 190 ynarafeh@southernco com

~ Southern Nuclear

Clarification questions related t o Audit of LAR 20-001

1. Are there any additional loaq.*1.1:M1.1..,..a.i;=a.a..i"""=..ua==...a.i;.=.1.t.Q"-i>tructures) to t he Nuclear Island, Turbine 4

Building, and Annex Buildin (b)( }

(b)(4)

2. It Is almost impossible to track the settlement history at a monitoring point in the black and white plots In the Settlement Monitoring Report (SV0-0500-XCR-800031), for example, Figures 9 and 11. Can the data from

?

3. When does th (b)(4) of the Rizzo Report (APP-G9-XCR-002)? .___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __.
4. In P :n nf thP Ri77n Donn rt l(b)(4) I (b)(4)

Do the measurements of settlement across these buildings show that the tilt towards the Nuclear Island is

"""lloihlP?

(b)(4)

5. The Rizzo Report is dated April 2014.l(b}(4)

(b)(4)

Clarification questions related to Audit of LAR 20-001 What are the actual settlement histories monitored at the Nuclear Island, the Turbine Building, and the Annex Building near the area of non-conformance?

(b)(4)

From: Santos, Cayetano Sent: Wed, 8 Apr 2020 15:46:08 +0000 To: Arafeh, Yasmeen N.

Cc: Humphrey, Mark Phillips

Subject:

RE: RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up Importance: High

Yasmeen, For today's call, the staff has tried to more clearly describe what we are looking for. See below:

Staff does not understand how the data provided in the ERR supports the specific gaps in LAR 20-001 . Our discussion this afternoon should focus on determining how the data presented supports the as built measurements as you have provided in your justification of LAR 20-001 . The data should provide a projection to support the proposed changes in LAR 20-001.

Tanny From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Se nt: Tuesday, April 07, 2020 10:50 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subje ct: [External_Sender) RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up Tanny, WEC Is unavailable on Friday due to the holiday.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 9:48 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Subject:

RE: RE: RE: RE: RE: LAR-20-001 Clarification Call Follow Up EXTERNAL MAILtOautlon Opentngiunks: orFlles How about Friday 4/10 from 9-11 am? Especially since we still have to figure out how to do webex.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 10:47 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: RE: LAR- 20-001 Clarification Call Follow Up Tanny, I feel like I remember Jennie telling me that the NRC has the ability to organize both skype and webex meetings. I'm reaching out to her now to see, because we only have skype at SNC, and WEC cannot access skype.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 9:43 AM To: Arafeh, Yasmeen N. <YNARAFEH@southemco.com>

Subject:

RE : RE: RE: RE: LAR-20-001 Clarification Call Follow Up

.-*~-*~~---~ . . . -:,, --..... --~-,~,=_ .

EXTERNAL'MAIU_Cautlon ..Openlngll.l_nks or f!les I'll check. But will you be able to organize a webex meeting? I don't think I've even participated in one of those.

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Tuesday, April 07, 2020 10:40 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] RE: RE: RE: LAR-20-001 Clarification Call Follow Up Tanny, I belleve we can work around the staff's availability for tomorrow. Please send me some times you think would work.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

~ Southern Nuclear

From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Se nt: Tuesday, April 7, 2020 9:35 AM To: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

RE: RE: RE: LAR-20-001 Clarification Call Follow Up Unfortunately I don't know how to organize a webex meeting. What time on Wed? I'll see if we can support.

Fro:m: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Se nt: Tuesday, April 07, 202010:32 AM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] RE: RE: LAR-20-001 aarification Call Follow Up Hi Tanny, good news, our team is also available tomorrow I Do you have the ability t o organize a webex meeting? WEC cannot access skype meetings.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynairafeh@southernco.com

~ Southern Nuclear Fro:m: Santos, Cayetano <Cayet ano.Santos@nrc.gov>

Sent: Tuesday, April 7, 2020 8:48 AM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

RE: RE: LAR-20-001 Clarification Call Follow Up Right now Thursday and Friday this week don't look good. Would tomorrow (Wed) be too soon? If so then maybe we try 3-5 pm again next Monday, April 13 if we can't find anything else this week.

Tanny

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 5:05 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender) RE: LAR-20-001 Clarification Call Follow Up Tanny, yes we are aligned. SNC had our initial internal meeting where we discussed a few different action items we'd need to take to determine what the path forward will need to be. As a result, I've provided the page numbers in the responses to aid Pravin and Amit in their reviews In the meantime.

If you'd like for me to go ahead and set up a web ex call, please provide me a few different windows of availability for this week (or next) so that I can try to get somet hing on our calendars.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work: (205)992-7190 ynarafeh@southernco.com

._ Southern Nuclear From: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Sent: Monday, April 6, 2020 3:53 PM To: Arafeh, Yasmeen N.<YNARAFEH@southernco.com>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

RE: LAR-20-001 Clarification Call Follow Up Thanks, Yasmeen. I will share with the staff. I think SNC was going to have some internal discussions to determine the best way to "walk the staff through the data/tables in the reports.

(Basically, what Mike King proposed). I think a webex or skype call for the meeting to do this would be helpful. Is this your understanding?

From: Arafeh, Yasmeen N. <YNARAFEH@southernco.com>

Sent: Monday, April 06, 2020 4 :46 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Subject:

[External_Sender] LAR-20-001 Clarification Call Follow Up Hi Tanny, while we look into our options on what we can provide for more clarification, I wanted to send you a write up of our responses to the five audi t questions. I have highlighted the responses t hat point to page numbers in the reports. Please let me know if this helps address some of the Staff's concerns, or

if the Staff would like to walk through these pages with our team . I' d be happy to help set up a webex cal l.

Best, Yasmeen Arafeh Nuclear Development, Licensing Work : (205)992-7190 ynarafeh@southernco com A Southern uclear
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