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2 predominantly in North America and western Europe . Drawing upon these analyses , ided expert testimony in legal and regulatory proceedings , and have served I have prov on committees advising US government agencies . My CV is provided here as Attachment A . co Scope of My Review 5 . In preparation of this Declaration, I reviewed the NRC ' s Federal Register notice for the proposed license amendment, the Final Safety Analysis Report for the Shearon Harris Nuclear Power Plant, the Final Environmental Statement related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2 (NURE& 0972 , October 1983 ) , and CP &L ' s application for the proposed license amendment. I also reviewed various correspondence and technical documents relating to the propose license amendment and to risks of spent fuel storage , which are _ identified below . 6 . The information that has been provided by the NRC and CP & L to date does not contain all of the detail that I would need to provide a complete , final statement about the hazards associated with the proposed license amendment . I would expect to review the full body of detailed evidence and present my final evaluation in the context of a hearing . However , even the limited information provided so far is adequate to permit me to identify serious safety concerns which preclude the NRC from making a "no significant hazards" determination . These issues should be addressed through the systematic , public process that a prior licensing hearing can provide . D . The " No Significant Hazards " Standard 7 . The NRC has stated its standard for determining that a . license amendment request involves no significant hazards consideration . 2 The standard is met if operation of the facility in accordance with the proposed amendment would not : ( 1 ) involve a significant increase in the probability or consequences of an accident previously evaluated ; or (2 ) create the possibility of a new or different kind of accident from any accident previously evaluated ; or (3 ) involve a significant reduction in a margin of safety . 8 . In my professional opinion, based on the preliminary evidence provided by the NRC and CP & L , operation of the Shearon Harris plant in accordance with the license amendment proposed by CP & L will violate all three of the conditions set forth in the preceding paragraph . Therefore , the NRC staff should reverse its position and should determine that CP & L ' s license amendment request does not involve no significant hazards consideration . E . The License Amendment in Context - Spent Fuel Management at Harris 9 . Before discussing my concerns about the safety implications of the proposed license amendment, I provide here some background information about spent fuel management at the Hams plant and CP &L ' s proposal to increase the spent fuel storage capacity at Harris . Unless specified otherwise, the information presented here is drawn from CP &L ' s license amendment application or from CP &L ' s Final Safety Analysis Report (FSAR) for the Harris plant . 2 Ibid .