RA-22-0043, CFR 50.54(q) Evaluation

CFR 50.54(q) Evaluation

ML22039A230
Person / Time
Site:	Harris
Issue date:	02/08/2022
From:	Vandenberg R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-22-0043
Download: ML22039A230 (15)

Text

Document Control Desk Serial: RA-22-0043 Enclosure

ENCLOSURE

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1

DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF -63

10 CFR 50.54(Q) REVIEW FORM FOR AD-EP-HNP -0106, REVISION 3

(13 PAGES PLUS COVER)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

ATTACHMENT 2 Page 1 of 13

<< 10 CFR 50.54(q) Review Form >>

Section I: 10 CFR 50.54(q) Review Number: (EREG #): 2382514 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP 02401818

MNS ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title AD-EP-HNP-0106 3 HNP SITE SPECIFIC OSC SUPPORT

Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments, or continue additional pages as necessary): Continue to Section III.

AD-EP-HNP-0106, HNP Site Specific OSC Support, is being revised to incorporate references for the Duke Energy Common Emergency Plan. In addition, the elimination of the Control Room (CR) Operations Bridge position is being included in this procedure change, based upon AD-EP-ALL-0105, Activation and Operation of the Technical Support Center, Revision 7, issuance that removed the CR Operations Bridge from the TSC.

A table of changes is provided below for reference. Changes 1-2 and changes 7-10 are considered to be editorial changes in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.

Change 3 corrects a description of facilities that require habitability surveys (EOF is removed since it is no longer located near HNP). Changes 4-6 update titles and descriptions of emergency response organization (ERO) personnel roles, based upon the elimination of the CR Operations Bridge position in the TSC.

1. Section Current (Existing) Text Proposed (Change) Text Reference 1 Throughout Old revision number and table of New revision number and updated table contents of contents as a result of procedure changes 2 Revision PRR 2304710 incorporates the installation 5.2.2.1 - Deleted EOF.

Summary of the last EC 266216 Child #10 (EC 5.2.3.2 - Deleted "CR OPS Bridge and" due 293273) which to ERO position being deleted with the completes the migration of RM-80s to the Common ERO EPlan rollout.

DICSP, finalizes the abandonment of 41 5.2.3.3 - Replaced "CR OPS Bridge" to Shift nonessential plant radiation monitors, and Communicator due to ERO position being removes the RM-11s and associated RM-deleted with the Common ERO EPlan 11 consoles. Section 5.2.3 Step 2: Deleted rollout. Replaced He with Shift RM-11 as an alternate to the DICSP. Communicator.

5.2.3.4 - Replaced "The CR OPS Bridge will normally direct the Control Room RP technician to coordinate" with "The Control Room RP Technician will coordinate".

5.2.3.5 - Deleted "The CR OPS Bridge must be informed when this occurs and".

5.2.3.8.a - Deleted "generally the CRS and the CR OPS Bridge".

5.2.3.8.b - Replaced CR OPS Bridge with EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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"Control Room RP Technician".

7.2 - Removed PLP-201, Emergency Plan.

Created Section 7.3, Miscellaneous Documents. Added references: EP-ALL-EPLAN, Duke Energy Common Emergency Plan and EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex.

3 5.2.2.1 Perform habitability surveys in each facility Perform habitability surveys in each facility (TSC, OSC, Control Room, EOF and (TSC, OSC, Control Room, and Security)

Security) and RWCR (if occupied) after and RWCR (if occupied) after activation and activation and at appropriate intervals at appropriate intervals thereafter.

thereafter.

4 5.2.3, steps 2.Once the OSC is manned, at least one 2.Once the OSC is manned, at least one 2-4 RP technician will stay with the Control RP technician will stay with the Control Room staff at all times. The primary Room staff at all times. The primary purpose of this RP technician is to provide purpose of this RP technician is to provide guidance to the CR OPS Bridge and EC-guidance to the EC-MCR on changing MCR on changing radiological conditions radiological conditions and protective and protective measures that must be measures that must be taken for people taken for people being sent into the plant. being sent into the plant. The RP technician The RP technician should establish should establish radiological conditions radiological conditions using the using the radiological monitoring system radiological monitoring system (DICSP) (DICSP) terminal and brief operators on terminal and brief Operators on those those conditions.

conditions. 3.The Shift Communicator is responsible for 3.The CR OPS Bridge is responsible for ensuring accountability of all members on ensuring accountability of all members on the shift. If any shift members are the shift. If any shift members are dispatched from the Control Room, the Shift dispatched from the Control Room, the Communicator must be informed. The Shift CROPS Bridge must be informed. He will Communicator will confer with the Control confer with the Control Room RP Room RP technician to ensure radiological technician to ensure radiological protective protective measures are being met. The measures are being met. The OSC should OSC should be used for guidance, be used for guidance, direction, and for direction, and for development of radiation development of radiation work permits. work permits.

4.The CR OPS Bridge will normally direct 4.The Control Room RP Technician will the Control Room RP technician to coordinate with the OSC RP Supervisor to coordinate with the OSC RP Supervisor to ensure proper guidance is given to ensure proper guidance is given to operators being sent out in the plant.

operators being sent out in the plant.

5 5.2.3, step 5. Members of the Control Room must take 5. Members of the Control Room must take 5 care when assigning people who are care when assigning people who are already dispatched to perform additional already dispatched to perform additional duties prior to returning. The CR OPS duties prior to returning. The RP technician Bridge must be informed when this occurs in the MCR should provide concurrence that and the RP technician in the MCR should the previous radiological guidance is still provide concurrence that the previous adequate.

radiological guidance is still adequate.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

6 5.2.3, step 8. Guidance during a fire emergency 8. Guidance during a fire emergency 8 includes the following recommendations: a. includes the following recommendations:

The Control Room, generally the CRS and a. The Control Room will use the input of the CR OPS Bridge, will use the input of the RP technician in the Control Room to the RP technician in the Control Room to provide information and protection to the provide information and protection to the incident commander.

incident commander.

b. The incident commander should work b. The incident commander should work with the CR OPS Bridge when the fire is with the Control Room RP Technician when out to ensure personnel exposure is the fire is out to ensure personnel exposure considered (i.e., activities such as cleanup, is considered (i.e., activities such as re-flash watch). cleanup, re-flash watch).

7 7.2.3 PLP-201, Emergency Plan Delete

8 7.3 n/a Miscellaneous Documents (NEW SECTION) 9 7.3.1 n/a ADD: EP-ALL-EPLAN, Duke Energy Common Emergency Plan 10 7.3.2 n/a ADD: EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex

Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:

List all emergency plan sections that were reviewed for this activity by number and title.

IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.

Licensing Basis

• EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0, Section B, Emergency Response Organization

• EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex Revision 0, Section B, Emergency Response Organization

Current Emergency Plan

• EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 1, Section B, Emergency Response Organization

• EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex Revision 1, Section B, Emergency Response Organization

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section IV: Ability to Maintain the Emergency Plan.

Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.

1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Yes Level (EAL), associated EAL note or basis, including underlying calculation or basis? No, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.

3. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No

4. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No

5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No

6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No

If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.

Section IV conclusion:

If questions 1 -6 in Section IV marked NO, then complete Section V.

If any question 1-6 of Section IV marked yes, then continue at Section VI.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section V: Maintaining the Emergency Plan Conclusion.

The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.

2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emerge ncy plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

Conclusion:

Section VI: Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?

Yes 10 CFR 50.54(q) Evaluation is not required.

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

If PARTIALLY, identify bounding source document and list changes bounded by the approved

Partially 10 CFR 50.90 or Alert and Notification System Design Report below.

Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.

No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section VIII.

Partially Some Activities/Changes are editorial/typographical.

If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.

If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.

Justification: Changes 1-2 update the revision number of AD-EP-HNP-0106, update table of contents, and update the summary of changes included in this revision. Changes 7-10 incorporate references for the Duke Energy Common Emergency Plan. These changes are considered to be editorial changes in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)

Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate 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 on shift 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 RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of the declared 5a 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 public within the plume exposure pathway.

The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 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 RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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10 10 CFR 50.47(b) (10) Protective Response RS 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 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.

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.

Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.

If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.

Change 3 corrects a description of facilities that require habitability surveys (EOF is removed since it is no longer located near HNP). The proposed change does not cause a change to or impact the ability to maintain the emergency plan. Therefore, the proposed change continues to maintain requirements and effectiveness found in the Emergency Plan and can be made without a reduction in effectiveness.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.

Proposed Changes 4-6:

Standards:

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

10CFR50.47(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.

Functions:

Function 1a, Responsibility for emergency response is assigned.

Function 2b, "The process for timely augmentation of on shift staff is established and maintained."

Appendix E to Part 50, Part 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.

Program Elements NUREG- 0654 Section II:

A.1.a: The organizations having an operational role specify their concept of operations and relationship to the total effort.

B.1.a: The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties. Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.

Proposed changes 4-6 remove the CR Operations Bridge from AD-EP-HNP-0106, based upon changes to AD-EP-ALL-0105, Revision 7, that removed the CR Operations Bridge position from the TSC. Removal of this position does not impact any responsibilities outlined in the current Emergency Plan or HNP Annex. The CR Operations Bridge assignments are redundant to other communication pathways currently in place that facilitate communications between the Control Room, TSC, and EOF. Timely augmentation of on-shift staff continues to be maintained upon removal of this position. The removal of the CR Operations Bridge does not impact major functional areas of the current Emergency Plan because it does not result in any major tasks outlined in the Emergency Plan to become unassigned.

The CR Operations Bridge is not a key position identified in the Emergency plan, thus removal of the position does not reassign responsibilities to the key positions outlined in the Emergency Plan or result in assigned duties to be performed concurrently by key positions. Removal of this position does not reduce the authority and responsibility of key positions outlined in the Emergency Plan to perform emergency assignments in accordance with the emergency plan, nor does it affect the timeliness and accuracy of the EROs performance of major functional areas or major tasks in accordance with the emergency plan. Upon removal of this position, the Emergency Plan continues to identify responsibilities assigned for emergency response and provide timely augmentation of on-shift staff. The Emergency Plan also continues to outline the Emergency Response Organization along with the authorities, responsibilities and duties of those positions that make up the organization.

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<< 10 CFR 50.54(q) Review Form >>

Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.

Proposed changes 4-6 remove the CR Operations Bridge from AD-EP-HNP-0106, based upon changes to AD-EP-ALL -0105, Revision 7, that removed the CR Operations Bridge position from the TSC. Removal of this position does not impact any responsibilities outlined in the current Emergency Plan or HNP Annex.

The Control Room Operations Bridge assignments are redundant to other communication pathways currently in place that facilitate communications between the Control Room, TSC, and EOF. Timely augmentation of on-shift staff continues to be maintained upon removal of this position. The removal of this position does not impact major functional areas of the current Emergency Plan because it does not result in any major tasks outlined in the Emergency Plan to become unassigned.

The CR Operations Bridge is not a key position identified in the Emergency Plan, thus removal of the position does not reassign responsibilities to the key positions outlined in the Emergency Plan or result in assigned duties to be performed concurrently by key positions. Removal of this position does not reduce the authority and responsibility of key positions outlined in the Emergency Plan to perform emergency assignments in accordance with the emergency plan, nor does it affect the timeliness and accuracy of the EROs performance of major functional areas or major tasks in accordance with the emergency plan. Upon removal of this position, the Emergency Plan continues to identify responsibilities assigned for emergency response and provide timely augmentation of onshift -

staff. The Emergency Plan also continues to outline the Emergency Response Organization along with the authorities, responsibilities and duties of those positions that make up the organization

The proposed changes do not reduce the effectiveness of the Emergency Plan. These changes continue 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 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 Shearon Harris Nuclear Plant Emergency Plan as written and approved.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 8

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<< 10 CFR 50.54(q) Review Form >>

Section XII: 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 reduction in Yes effectiveness)? No

3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create CAS assignment EP03, and then continue on to Section XIV and implement change(s).

Complete CAS assignment EP03 - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.

Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?

Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.

If YES, 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:___________________________________. Complete Section XIV.

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<< 10 CFR 50.54(q) Review Form >>

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. 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.Section XIV as applicable.

Preparer Name (Print): Preparer Signature: Date:

Sarah McDaniel See CAS See CAS Reviewer Name (Print): Reviewer Signature: Date:

Chuck Yarley See CAS See CAS Approver Name (Print): Approver Signature: Date:

Jamey Sharlow See CAS See CAS Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A

QA RECORD