RA-19-0221, 10 CFR 50.54(q) Evaluation

10 CFR 50.54(q) Evaluation

ML19135A356
Person / Time
Site:	Harris
Issue date:	05/15/2019
From:	Mccabe B Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0221
Download: ML19135A356 (15)

Text

(DUKE Brian C. McCabe Support Services Manager ENERGYQI Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562-9300 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

May 15, 2019 Serial: RA-19-0221 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

10 CFR 50.54(q) Evaluation Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is submitting the 10 CFR 50.54(q) Screening Evaluation Form and the 10 CFR 50.54(q)

Effectiveness Evaluation Form for a revision to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Plan. PLP-201, "Emergency Plan," Revision 70, was issued on April 24, 2019.

This submittal contains no regulatory commitments. Please refer any questions regarding this submittal to Sarah McDaniel at (919) 362-2002.

Sincerely, Brian C. McCabe

Enclosure:

10 CFR 50.54(q) Screening Evaluation Form and 10 CFR 50.54(q) Effectiveness Evaluation Form for PLP-201, Revision 70 cc: J. Zeiler, NRC Senior Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP NRC Regional Administrator, Region II

Brian C. McCabe Support Services Manager Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562-9300 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

May , 2019 Serial: RA-19-0221 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

10 CFR 50.54(q) Evaluation Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is submitting the 10 CFR 50.54(q) Screening Evaluation Form and the 10 CFR 50.54(q)

Effectiveness Evaluation Form for a revision to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Plan. PLP-201, Emergency Plan, Revision 70, was issued on April 24, 2019.

This submittal contains no regulatory commitments. Please refer any questions regarding this submittal to Sarah McDaniel at (919) 362-2002.

Sincerely, Brian C. McCabe

Enclosure:

10 CFR 50.54(q) Screening Evaluation Form and 10 CFR 50.54(q) Effectiveness Evaluation Form for PLP-201, Revision 70 cc: J. Zeiler, NRC Senior Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP NRC Regional Administrator, Region II

Document Control Desk Serial: RA-19-0221 Enclosure ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF-63 10 CFR 50.54(Q) SCREENING EVALUATION FORM AND 10 CFR 50.54(Q) EFFECTIVENESS EVALUATION FORM FOR PLP-201, REVISION 70 (12 PAGES PLUS COVER)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 ATTACHMENT 4

<< 10 CFR 50.54(q) Screening Evaluation Form >>

Screening and Evaluation Number Applicable Sites BNP EREG #: 2266594 CNS CR3 HNP MNS ONS 5AD #: 2266575 RNP GO Document and Revision PLP-201 Revision 70 EMERGENCY PLAN (PRR 2245928)

1. Procedure Current (Existing) Text Proposed (Change) Text Supporting Section Reference Rationale (Justification) for Change

1. 1.3 Manager-Emergency Manager-Site Support Editorial Change 5.1.1 Preparedness Services (Position Title) 5.1.2 5.2.2 5.2.4 Annex A

2. 2.4.1.C 2.4.1. E Plant Operations Director Operations Supervisor - Editorial Change OSC (Position Title)

3. 2.4.3.D.7 N/A Added: Moved the function Perform chemical of assigning chemistry technician sampling and analysis assignments from the OSC Chemistry Supervisor to the Operations Supervisor.

4. 2.4.3.D.8 N/A Added: Alignment with fleet Record and review procedure with the chemical sampling and combination of analysis Chemistry Supervisor and Operations Supervisor

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

5. Old 2.4.3.H Deleted: N/A Alignment with fleet Chemistry Supervisor and procedure with the responsibilities. combination of Chemistry Supervisor and Operations Supervisor

6. Figure 2.2-1 Deleted: N/A Alignment with fleet Chemistry Supervisor procedure with the (OSC) combination of Chemistry Supervisor and Operations Supervisor

7. Figure 2.2-1 Total Responders Full Total Responders Full Alignment with fleet Staff: 36 Staff: 35 procedure with the combination of Chemistry Supervisor and Operations Supervisor

8. Figure 2.4-3 Deleted: Chemistry Moved both Chem Techs Alignment with fleet Supervisor under Operations procedure with the Supervisor combination of Chemistry Supervisor and Operations Supervisor

9. Figure 2.4-3 "Bold Boxes Indicate Duplicated cell as legend Editorial Minimum Staff Positions" to indicate Minimum Staff (Formatting)

Position.

10. 5.3.2 A formal written evaluation A formal written evaluation This considers the of the exercise will be of the exercise will be Fleet support prepared by the prepared by the resources often Emergency Planning Emergency Planning used for critique report writing Coordinator following the Coordinator or designee critique. following the critique.

11. 2.4.2-2.4.5 show shown Editorial

12. 3.5.3

References:

Editorial to align with 3.8 3.9 new numbering 3.8.2 3.9.2 sequence as part of 3.9.1 3.10.1 the previous changes

13. 5.0 PNSC ORC Editorial title change of the meeting group.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

Part II. Activity Previously Reviewed? Yes No Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part III Justification: Attachment 4, Part V.

Bounding document attached (optional)

Part III. Editorial Change Yes No Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effectiveness Attachment 4, Evaluation is not Part IV and required. Enter address non Justification:

justification and editorial The following changes are editorial: 1, 2, and 9 complete changes Attachment 4, Part V.

Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

(NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use.

(Requires final approval of Screen and Evaluation by EP CFAM.)

Part IV. Emergency Planning Element and Function Screen (cont.)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3) 6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.

6b Systems are established for prompt communication to emergency response personnel.

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response.

8b Adequate equipment is maintained to support emergency response.

9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

10 10 CFR 50.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

10d KI is available for implementation as a protective action recommendation in those jurisdictions that chose to provide KI to the public.

11 10 CFR 50.47(b)(11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR 50.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

Part IV. Emergency Planning Element and Function Screen (cont.)

14 10 CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

15 10 CFR 50.47(b)(15) Emergency Response Training 15a Training is provided to emergency responders.

16 10 CFR 50.47(b)(16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below.

Justification:

• Changes 1, 2, 9, 11, 12, and 13 are editorial in nature and do not require an evaluation per AD-EP-ALL-0602.

• Change 10 adds the word designee to the statement. This considers the fleet support resources that are often used to develop critique reports. Adding this statement provides depth in implementation. This change does not impact a planning standard, therefore, screens out.

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

The remaining changes are grouped as follows for evaluation purposes:

• Changes 3-8 move Chemistry Supervisor responsibilities to the Operations Supervisor which impacts PS 1, Function 1b, and PS 2, Function 2b.

Part V. Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Jamey Sharlow Signed electronically in CAS 04/23/19 Reviewer Name (Print): Reviewer Signature: Date:

Eric White Signed electronically in CAS 04/23/19 Approver (EP Manager Name (Print): Approver Signature: Date:

Brian McCabe Signed electronically in CAS 04/23/19 Approver (EP CFAM, as required) Name (Print) Approver Signature: Date:

David Thompson Signed electronically in CAS 04/23/19 QA RECORD

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 ATTACHMENT 5 Page 1 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Screening and Evaluation Number Applicable Sites BNP EREG #: 2266594 CNS CR3 HNP MNS 5AD #: 2266575 ONS RNP GO Document and Revision PLP-201 Revision 70 EMERGENCY PLAN (PRR 2245928)

Part I. Description of Proposed Change:

1. Procedure Current (Existing) Text Proposed (Change) Text Supporting Section Rationale Reference (Justification) for Change

3. 2.4.3.D.7 N/A Added: Moved the function Perform chemical of assigning chemistry technician sampling and analysis assignments from the OSC Chemistry Supervisor to the Operations Supervisor.

4. 2.4.3.D.8 N/A Added: Alignment with fleet Record and review procedure with the chemical sampling and combination of analysis Chemistry Supervisor and Operations Supervisor

5. Old 2.4.3.H Deleted: N/A Alignment with fleet Chemistry Supervisor and procedure with the responsibilities. combination of Chemistry Supervisor and Operations Supervisor

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 2 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

6. Figure 2.2-1 Deleted: N/A Alignment with fleet Chemistry Supervisor procedure with the (OSC) combination of Chemistry Supervisor and Operations Supervisor

7. Figure 2.2-1 Total Responders Full Total Responders Full Alignment with fleet Staff: 36 Staff: 35 procedure with the combination of Chemistry Supervisor and Operations Supervisor

8. Figure 2.4-3 Deleted: Chemistry Moved both Chem Techs Alignment with fleet Supervisor under Operations procedure with the Supervisor combination of Chemistry Supervisor and Operations Supervisor

• Changes 3-8 move Chemistry Supervisor responsibilities to the Operations Supervisor which impacts PS 1, Function 1b, and PS 2, Function 2b. These functions are described in section IV of this form.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 3 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >> , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Licensing Basis

• PLP-201, Harris Nuclear Plant Emergency Plan (Revision 3)

Current Emergency Plans Harris Nuclear Plant - PLP-201, Emergency Plan, Revision 69 The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

Changes are grouped as follows for evaluation purposes:

• Changes 3-8 move Chemistry Supervisor responsibilities to the Operations Supervisor which impacts PS 1, Function 1b, and PS 2, Function 2b.

Changes 3-8 This change is supported by on-shift staffing analyses and promotes efficiency gains. All functions performed by chemistry personnel are directed by operations procedures. Using the Operations supervisor to directly request these actions, vs going through the Chemistry Supervisor improves the timeliness of response. The Operations supervisor has the capacity to perform this function as part of their ongoing activities. During normal and emergency operations, operations procedures direct when to take chemistry samples. When procedures direct to take a chemistry sample, operations contacts chemistry to perform samples and report results to control room. This process will only modify by location when OSC is activated. The OSC Operations Supervisor will be in contact with control room during declared emergencies and as samples are required by procedure, the OSC Operations Supervisor will direct chemistry to perform samples and report results to OSC. The OSC Operations Supervisor is trained to direct and control in-plant operations as directed by procedure. The OSC Operations Supervisor is aware of plant conditions and will continue to dispatch missions including requesting chemistry samples using OSC resources ensuring radiological and personnel safety. Chemistry samples will continue to be assessed in TSC for upgrades in classification and core damage assessments. Responsibilities for chemistry sampling continue to be defined and timely augmentation of chemistry sampling supervision is available. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, the Harris Emergency Plan will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E, Section IV.A Organization.

The changes evaluated above continue to meet NRC requirements as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 4 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

10CFR50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

10CFR50 Appendix E.IV.A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

The associated EP Function is Function 1b, "The response organization has the staff to respond and to augment staff on a continuing basis (i.e., 24/7 support) in accordance with the emergency plan."

Program Element NUREG-0654 Section II.A A.1.e. Each organization shall provide for 24-hour emergency response, including 24-hour per day manning of communication links.

A.4 Each principal organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.

10CFR50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

The associated EP Function is Function 2b, "The process for timely augmentation of onshift staff is established and maintained."

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 5 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Program Elements NUREG-0654 Section II.B B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Changes are grouped as follows for evaluation purposes:

• Changes 3-8 move Chemistry Supervisor responsibilities to the Operations Supervisor which impacts PS 1, Function 1b, and PS 2, Function 2b.

Changes 3-8 move Chemistry Supervisor responsibilities to the Operations Supervisor in the OSC. This change is due to staffing analysis and efficiency gains. During normal and emergency operations, operations procedures direct when to take chemistry samples. When procedures direct to take a chemistry sample, operations contacts chemistry to perform samples and report results to control room. This process will only modify by location when OSC is activated, and on shift activities are not impacted by this change. The OSC Operations Supervisor will be in contact with control room during declared emergencies and as samples are required by procedure, the OSC Operations Supervisor will direct chemistry to perform samples and report results to OSC. The OSC Operations Supervisor is trained to direct and control in-plant operations as directed by procedure. Operations Supervisors come from the Operations Department with background as an Operator. These additional tasks are similar to daily operations interface they have with the chemistry technicians. The OSC Operations Supervisor is aware of plant conditions and will continue to dispatch missions including requesting chemistry samples using OSC resources ensuring radiological and personnel safety. Chemistry samples will continue to be assessed in TSC for upgrades in classification and core damage assessments. Responsibilities for chemistry sampling continue to be defined and timely augmentation of chemistry sampling supervision is available. During the March 2019 ERO Drill this new model was tested. There were no challenges to the OSC functions and or the ability to dispatch the appropriate resources for chemistry sampling analysis. The Chemistry supervisor position was evaluated and implemented during the 2016 Duke Energy standard ERO implementation. During the 2016 staffing comparison it was recognized that 4 additional positions were added to the full staffing figure 2.2-1, and total ERO members increased from 32 to 36. The Chemistry supervisor was one of the 4 additions to the full staffing figure, however, was not listed as a minimum staffing position to the OSC. Shifting the responsibilities of the chemistry supervisor to the Operations Supervisor does not add additional burden to the Operations Supervisor or the rest of the ERO.

The ERO continues to be staffed to augment initial response on a continuous basis. Thus, there is no reduction in effectiveness of the Emergency Planning Functions of Assignment of Responsibility and Onsite Emergency Organization.

The changes described provide assurance that the normal plant operating organization and ERO has the ability and capability to:

• respond to an emergency;

• perform functions in a timely manner;

• effectively identify and take measures to ensure protection of the public health and safety; and

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 6 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

• effectively use response equipment and emergency response procedures.

Thus, there is no reduction in effectiveness of the Harris Emergency Plan.

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes No reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.

Therefore, the activity cannot be implemented without prior NRC approval.

Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or Yes No rejected?

If No, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:__________________________________________________.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 5 Page 7 of 7

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4) (i.e., Emergency Action Levels and Emergency Action Level Bases). If CFAM approval is NOT required, then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Jamey Sharlow Signed electronically in CAS 04/23/19 Reviewer Name (Print): Reviewer Signature: Date:

Eric White Signed electronically in CAS 04/23/19 Approver (EP Manager) Name (Print): Approver Signature: Date:

Brian McCabe Signed electronically in CAS 04/23/19 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

David Thompson Signed electronically in CAS 04/23/19 If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.

If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.

• One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing.

• One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

QA RECORD