RA-20-0360, Emergency Plan Revised 10 CFR 50.54(q) Screen and Evaluation

Emergency Plan Revised 10 CFR 50.54(q) Screen and Evaluation

ML20315A054
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/10/2020
From:	James Smith Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0360 AD-EP-ALL-0602
Download: ML20315A054 (13)

Text

James M. Smith Manager, Nuclear Support Services

~ -, DUKE McGuire Nuclear Station

~ ENERGY Duke Energy MG01VP I 12700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.5477 James-Junior.Smith@duke-energy.com Date: November 10, 2020 10 CFR 50.54(q)

Serial No. RA-20-0360 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001

Subject:

Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Numbers. 50-369, 50-370 Renewed License Nos. NPF-9 and NPF-7 Emergency Plan Revised 10 CFR 50.54(q) Screen and Evaluation

REFERENCE:

RA-20-0003, McGuire Nuclear Station, Unit 1 and 2, Emergency Plan Revision 19-2 and Revision 19-3, dated January 9, 2020 RA-20-0119, McGuire Nuclear Station, Unit 1 and 2, Emergency Plan Revision 20-1, dated April 15, 2020 On January 9, 2020 Duke Energy Carolinas, LLC (Duke Energy) submitted RA-20-0003, McGuire Nuclear Station, Unit 1 and 2, Emergency Plan Revision 19-2 and Revision 19-3 and on April 15, 2020 Duke Energy Carolinas, LLC (Duke Energy) submitted RA-20-0119, Emergency Plan (EPLAN) Revision 20-1 in accordance with the requirements of 10 CFR 50.54( q). During the 2020 Emergency Preparedness Program Inspection the NRG issued a Level IV violation for failure to adhere to 10 CFR 50.54( q)(3) requirements when making changes to CSD-EP-MNS-0101-02, Wallchart, in EPLAN Revision 20-1. In response to the violation, McGuire revised the associated Screening Evaluation Form and generated an Effectiveness Evaluation Form associated with the changes to CSD-EP-MNS-0101-02 Rev. 000.

The revised Screening Evaluation Form and Effectiveness Evaluation Form are attached.

U.S. Nuclear Regulatory Commission RA-20-0360 Page 2 Questions regarding this submittal should be directed to Joseph Hussey, McGuire Regulatory Affairs, at (980) 875-5045.

Sincerely, James M. Smith Manager, Nuclear Support Services McGuire Nuclear Station Enclosed Attachment, Revised Screening Evaluation Form and new Effectiveness Evaluation Form associated with the changes made to CSD-EP-MNS-0101-02 Rev. 000, Wallchart.

U.S. Nuclear Regulatory Commission RA-20-0360 Page 3 cc:

(Two Copies)

Laura A. Dudes Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 (One Copy)

Director Office of Nuclear Material Safety and Safeguards Mail Stop 14 A12 Washington, D.C. 20555-0001 (w/o attachments)

G. Edward Miller Project Manager (McGuire)

U.S. Nuclear Regulatory Commission Mail Stop O-9-E3 11555 Rockville Pike Rockville, MD 20852 G.A. Hutto NRC Senior Resident Inspector McGuire Nuclear Station andy.hutto@nrc.gov

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

Rev. 7 ATTACHMENT 4 Page 1 of 4

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

Screening and Evaluation Number Applicable Sites EREG #: 02319149 [Original] and 02351390 [Revised] BNP NOTE: Revisions are noted by change bars in right margin except for CNS changes associated with form being revised from Revision 6 to HNP Revision 7.

MNS ONS SAD #:_02345532 RNP GO Document and Revision CSD-EP-MNS-0101-02 (EAL WALLCHART (BOTH HOT AND COLD)

Revision 001 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

Change Section or Step Change From Change to 1 Footer CSD-EP-MNS-0101-02 Rev 000 CSD-EP-MNS-0101-02 Rev 001 2 ICHS6 Applicability: Modes 1, 2, 3, 4, 5, 6, Applicability: Modes 1, 2, 3, 4, 5, 6 (EAL 6.1) NM , 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. Activity Previously Reviewed? Yes I No I 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 Ill Justification: Attachment 4, Part V.

Bounding document attached (optional) I

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

Rev. 7 ATTACHMENT 4 Page 2 of 4

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

Part 111 . Editorial Change Is this activity an editorial or typographical change only, such as formatting, Yes 1 No or Partially I

paragraph numbering, spelling, or punctuation that does not change intent? 10 CFR 50.54(q) Continue to Effectiveness Attachment 4, Evaluation is not Part IV and Justification:

required . Enter address non The change(s) below are defined as editorial in accordance with justification and editorial AD-EP-ALL-0602 and do not change the intent of the steps as written. complete changes Attachment 4, Change 1 - Footer - Editorial for revision number update. 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.

4 10 CFR 50.47(b)(4) Emergency Classification System 4a 5

A standard scheme of emergency classification and action levels is in use.

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

10 CFR 50.47(b)(5) Notification Methods and Procedures I

Sa Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

Sb Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway.

Sc 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.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 7 ATTACHMENT 4 Page 3 of 4

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

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

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).

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.

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.

10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

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

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.

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

Rev. 7 ATTACHMENT 4 Page 4 of 4

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

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

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:

Change 2 to be evaluated.

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

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): Barry Kimray Preparer Signature: See CAS Date:

See CAS Reviewer Name (Print): Jeffery White Reviewer Signature: See CAS Date:

See CAS Approver (Manager, Nuclear Support Services) Approver Signature: See CAS Date:

Name (Print): James Smith See CAS Approver (EP CFAM, as required) Name (Print) Approver Signature: N/A Date: N/A David Thompson If the proposed activity is a change to the E-Plan, then initiate PRRs. PRR Number(s):

N/A If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG EREG Due Date:

General Assignments.

02351390-04

• One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10/29/20 10 CFR 50.54(q), to Licensing.

• One for Licensing to submit the 10 CFR 50.54(q) information to the NRC in accordance EREG Due Date:

with 10 CFR 50.4(b )(5)(ii) within 30 days after the change is put in effect. 02351390-05 11/12/20 QA RECORD

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 7 ATTACHMENT 5 Page 1 of 6

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

Screening and Evaluation Number Applicable Sites BNP EREG #: 02319149 [Original] and 02351390 [Revised)

CNS NOTE: Evaluation is added as the revision. HNP MNS ONS SAD#: 02319154

- RNP GO Document and Revision CSD-EP-MNS-0101-02 (EAL WALLCHART (BOTH HOT AND COLD)

Revision 001 Part I. Description of Proposed Change:

Change Section or Step Change From Change to 2 ICHS6 Applicability: Modes 1, 2, 3, 4, 5, 6, Applicability: Modes 1, 2, 3, 4, 5, 6 (EAL HS6.1) NM Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Licensing Basis McGuire Emergency Plan Change 2 (dated February 1981), additional information submitted April 3, 1981 and July 1, 1981, Revision 97-1 (dated April 1997), and Revision 11-3 (dated October, 2011)

Current Emergency Plan Revision 20-01 License Amendment Request (ML19058A632) and Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire)

The differences in the approved and the current revision of the Emergency Plan have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions .

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR Rev. 7 50.54(Q)

ATTACHMENT 5 Page 2 of 6

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

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):

Proposed Change 2 makes No Mode (NM) not applicable for IC HS6 (EAL HS6.1). No Mode was inadvertently added to IC HS6 (EAL HS6.1) mode applicability during the printing of the EAL WALLCHART (CSD-EP-MNS-0101-02). The proposed change returns the EAL Wallcharts mode applicability for IC HS6 (EAL HS6.1) to those listed in License Amendment Request (ML19058A632) and Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire) and the McGuire EAL Technical Basis Document (CSD-EP-MNS-0101-01). McGuire licensing bases and McGuire EAL Technical Basis Document have IC HS6 (EAL HS6.1) described as -

HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to the Auxiliary Shutdown Panels or Standby Shutdown Facility (SSF)

AND Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):

Reactivity (Modes 1, 2 and 3 only)

Core Cooling NCS heat removal As there is no fuel in the core in no mode, the three key safety functions for control of reactivity, core cooling and NCS (reactor coolant system) heat removal are not applicable in no mode should transfer of plant control from the Control Room be necessary. Based on the preceding -

• The proposed change continues to assure compliance with planning standard 10CFR50.47(b)(4): A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures as the proposed change aligns the mode applicability for IC HS6 (EAL HS6.1) to the approved license basis.

• The proposed change improves the timeliness of the planning standard function as it removes contradicting information for IC HS6 (EAL HS6.1) mode applicability between the McGuire EAL Technical Basis Document (CSD-EP-MNS-0101 -01) and EAL WALL CHART (CSD-EP-MNS-0101-02) allowing for quicker evaluation of the EAL.

• The proposed change sustains the effectiveness of the planning standard function as the proposed change aligns the mode applicability for IC HS6 (EAL HS6.1) to the approved license basis.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR Rev. 7 50.54(Q)

ATTACHMENT 5 Page 3 of 6

<< 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):

Planning Standard 10CFR50.47(b)(4): A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Appendix E to Part 50 10CFR50 Appendix E.IV.C. Activation of Emergency Organization

2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

Associated Planning Function The associated EP Function is Function 4a, "A standard scheme of emergency classification and action levels is in use."

NUREG-0654 Rev. 1 Program Element NUREG-0654 Section I1.D. Emergency Classification System

1. An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.

2. The initiating conditions shall include the example conditions found in Appendix I and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR Rev. 7 50.54(Q)

ATTACHMENT 5 Page 4 of 6

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

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

Proposed Change 2 makes No Mode (NM) not applicable for IC HS6 (EAL HS6.1). No Mode was inadvertently added to IC HS6 (EAL HS6.1) mode applicability during the printing of the EAL WALLCHART (CSD-EP-MNS-0101-02). The proposed change returns the EAL Wallcharts mode applicability for IC HS6 (EAL HS6.1) to those listed in License Amendment Request (ML19058A632) and Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire) and the McGuire EAL Technical Basis Document (CSD-EP-MNS-0101-01). McGuire licensing bases and McGuire EAL Technical Basis Document have IC HS6 (EAL HS6.1) described as -

HS6.1 Site Area Emergency An event has resulted in plant control being transferred from the Control Room to the Auxiliary Shutdown Panels or Standby Shutdown Facility (SSF)

AND Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):

o Reactivity (Modes 1, 2 and 3 only) o Core Cooling D NCS heat removal As there is no fuel in the core in no mode, the three key safety functions for control of reactivity, core cooling and NCS (reactor coolant system) heat removal are not applicable in no mode should transfer of plant control from the Control Room be necessary. Based on the preceding -

• The proposed change continues to assure compliance with planning standard 10CFR50.47(b)(4): A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures as the proposed change aligns the mode applicability for IC HS6 (EAL HS6.1) to the approved license basis.

• The proposed change improves the timeliness of the planning standard function as it removes contradicting information for IC HS6 (EAL HS6.1) mode applicability between the McGuire EAL Technical Basis Document (CSD-EP-MNS-0101-01) and EAL WALL CHART (CSD-EP-MNS-0101-02) allowing for quicker evaluation of the EAL.

• The proposed change sustains the effectiveness of the planning standard function and, thus, is not a reduction in effectiveness of McGuire's Emergency Plan as the proposed change aligns the mode applicability for IC HS6 (EAL HS6.1) to the approved license basis.

The proposed change does not reduce the effectiveness of Duke Energy McGuire Nuclear Station's Emergency Plan . This proposed change continues to provide assurance that the Emergency Response Organization 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

• Effectively use response equipment and emergency response procedures.

These proposed changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, as well as the requirements of the Duke Energy McGuire Nuclear Station's Emergency Plan as written and approved.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR Rev. 7 50.54(Q)

ATTACHMENT 5 Page 5 of 6

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

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. If Yes, then mark Part VII as not applicable (NIA).

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.

NOTE: If prior NRC approval required, then complete Part VII .

Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or rejected?

N/A IYes I No 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 Rev. 7 50.54(0)

ATTACHMENT 5 Page 6 of 6

<< 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): Barry Kimray Preparer Signature: See CAS Date:

See CAS Reviewer Name (Print): Jeffery White Reviewer Signature: See CAS Date:

See CAS Approver (Manager, Nuclear Support Approver Signature: See CAS Date:

Services) Name (Print): James Smith See CAS Approver (EP CFAM, as required) Name Approver Signature: N/A Date: N/A (Print) David Thompson If the proposed activity is a change to the E-Plan, then initiate PRRs. PRR Number(s):

N/A If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG Due Date:

EREG General Assignments. 02351390-04

• One for EP to provide the 10 CFR 50.54( q) summary of the analysis, or the completed 10/29/20 10 CFR 50.54(q), to Licensing .

• One for Licensing to submit the 10 CFR 50.54(q) information to the NRC in accordance EREG Due Date:

with 10 CFR 50.4(b)(5)(ii) within 30 days after the change is put in effect. 02351390-05 11/12/20 QA RECORD