Text

Emergency Plan Amendment Request
	ML22019A236
Person / Time
Site:	Davis Besse
Issue date:	01/19/2022
From:	Tony Brown; Energy Harbor Nuclear Corp
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-20-289
	Download: ML22019A236 (442)
	v • d • e

m energy

~ harbor Energy Harbor Nuclear Corp.

Davis-Besse Nuclear Power Station 5501 N State Route 2 Oak Harbor, Ohio 43449 Terry J. Brown 419-321-7676 Site Vice President, Davis-Besse Nuclear January 19, 2022 L-20-289 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Emergency Plan Amendment Request Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. (EHNC) hereby requests an amendment to the Davis-Besse Nuclear Power Station (DBNPS) Emergency Plan (EP).

The proposed changes are being submitted to the Nuclear Regulatory Commission (NRC) for approval, prior to implementation, pursuant to 10 CFR50.54(q)(4).

The proposed changes to the DBNPS EP would reduce the number of on-shift staff positions, extend augmented Emergency Response Organization (ERO) response times, and re-align augmented ERO response positions. EHNC has reviewed the proposed changes against the planning standards in 10 CFR 50.4 7(b) and requirements of 10 CFR 50, Appendix E and concludes that the standards and requirements will continue to be met.

An evaluation of the proposed amendment is enclosed. The EHNC staff discussed the proposed DBNPS EP changes with the staffs of the State of Ohio, Ottawa County, and Lucas County (offsite response organizations). The offsite response organizations indicated that the proposed DBNPS EP changes were understood and were satisfied that the proposed changes do not impact their respective radiological emergency preparedness plans.

EHNC is requesting Nuclear Regulatory Commission (NRC) staff approval of the proposed amendment by January 31, 2023. Once approved, the amendment shall be implemented within six months.

Davis-Besse Nuclear Power Station L-20-289 Page 2 of 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager -

Fleet Licensing, at 330-696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 19, 2022.

Enclosure:

Evaluation of the Proposed Emergency Plan Changes cc:

NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Evaluation of Proposed License Amendment Page 1 of 35

Subject:

Emergency Plan Amendment Application Table of Contents 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 DBNPS Emergency Plan Background 2.2 Reason for Proposed Changes 2.3 Description of the Proposed Changes

3.0 TECHNICAL EVALUATION

3.1 Technical Justification 3.2 Functional Analysis 3.3 Conclusions

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Attachments:

1. DBNPS Emergency Plan Affected Pages (Mark-up)

2. DBNPS Emergency Plan Affected Pages (Clean Copy)

3. DBNPS Emergency Plan Emergency Response Organization Change Summary

4. DBNPS Emergency Plan Table B-1 Comparative Chart

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 2 of 35 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the renewed Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS).

The proposed amendment revises the DBNPS Emergency Plan (EP). Energy Harbor Nuclear Corp. (EHNC) completed a staffing analysis of on-shift responsibilities resulting from the impacts associated with the proposed changes. The analysis supports that incorporating the proposed changes listed below will maintain the sites ability to protect public health and safety:

Standardize position titles and responsibilities to align with fleet initiatives,

Redefine augmented response timeframes as being initiated from event classification rather than Emergency Response Organization (ERO) notification,

Extend augmented ERO response times from 30 minutes to 60 minutes and, in some cases, extend 60 minute response times to 90 minutes,

Revise Table 5.1 to reflect NRC Revised Table B-1 content for performance of EP functions at DBNPS,

Separate command and control functions between the Technical Support Center (TSC) and Emergency Operating Facility (EOF) to streamline augmented ERO staffing and reduce turnover of responsibilities during initial stages of the event,

Remove references to the Corporate Assistance Center (CAC) and the Radiological Testing Laboratory (RTL),

Revise figures delineating positions associated with facility activation are included in the proposed DBNPS EP,

Allows for the transfer of classification, state/local notification, dose assessment, Protective Action Recommendation (PAR), and emergency exposure functions from the Control Room (CR) in advance of 60 minutes when minimum staff positions are met as defined in the proposed emergency plan.

Additionally, a functional analysis of the augmented ERO positions based on extended response times and completion of major tasks was completed, as outlined in NUREG-0654/FEMA-REP-1, Revision 1, and NRC Revised Table B-1, issued June 2018 (ML18022A325).

The changes in staff augmentation times and removal of on-shift Radwaste Operator (RWO) and maintenance positions are considered a reduction in DBNPS EP effectiveness as defined in 10 CFR 50.54(q)(1)(iv). In accordance with 10 CFR 50.54(q)(4), changes to a licensees emergency plan that reduce the effectiveness of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval and are to be submitted as a License Amendment Request (LAR) in accordance with 10 CFR 50.90.

Following emergence from bankruptcy and the assignment of plant properties, the

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 3 of 35 Davis-Besse property parcels and mineral rights which comprise the Exclusion Area and the Site Area Boundary are no longer wholly owned by either Energy Harbor Corp. or its subsidiary Energy Harbor Nuclear Generation LLC. This issue has been entered into the corrective action program and is being addressed through legal negotiations between Energy Harbor Corp. and FirstEnergy Corp. The current status of these parcels does not impact the ability to effectively implement the emergency plan and does not impact this submittal.

2.0 DETAILED DESCRIPTION 2.1 DBNPS Emergency Plan Background The last DBNPS EP that was reviewed and approved by the NRC in staffing was Revision 4. This revision was approved by NRC Safety Evaluation Report (SER) dated June 27, 1983. As approved by NRC, the DBNPS EP contained the following categories of augmented response timeframes:

30-minute normal working hour response

60-minute off-hour response

Standard 60-minute response

1-2 hour response The response time requirements applied to key positions met the intent of the guidance of NUREG-0654, Revision 1. These time goals were shown in DBNPS EP Table 5-1, Manpower, Location and Response Considerations for Emergencies.

Table 5.3, Shift Manning, was added in response to NRC letter dated March 23, 1982, Appendix B, Preparedness Improvement Items, Item 2, which recommended that the personnel call out list be prioritized to assure that expertise required in Table B-1 of NUREG-0654 could be identified. The site response dated April 20, 1982, to the NRC letter identified that Revision 4 of the DBNPS EP would include a revision of Administrative Memo No. 37, to identify personnel meeting Table B-1 functions.

In Revision 4, DBNPS maintained three on-site Emergency Response Facility (ERFs),

which augmented the on-shift staff with activation of the TSC, Operations Support Center (OSC), and Emergency Control Center (ECC) at the alert or higher classification.

Additional corporate support was available from the Toledo Edison Company (TED)

Corporate Emergency Response Organization (CERO) located at the emergency support center in Toledo, Ohio. Provision of information to the news media was the responsibility of the corporate organization. In Revision 8, the facility responsible for provision of public information was changed to the Joint Public Information Center (JPIC) housed at the ECC.

In Revision 25, the ECC was renamed the Emergency Operations Facility (EOF) and the

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 4 of 35 CERO was renamed the Corporate Assistance Center (CAC). In Revision 26, the JPIC was renamed the Joint Information Center (JIC).

During an emergency, the shift manager initially assumes the responsibility as Emergency Director (ED). Emergency response by on-shift staff is directed by the ED from the CR until relieved by an augmenting staff with the activation of ERFs.

DBNPS has maintained the four standard levels of emergency classification as described in NUREG-0654, Revision 1. The current EP includes activation of the TSC, OSC, and EOF at an alert or higher classification, as well as notification of the CAC.

2.2 Reason for Proposed Changes The proposed changes that reduce on-shift staffing, extend augmentation response times, and streamline augmented positions are needed to address concerns regarding limitations on the number of personnel available to respond to the site in 30 and 60 minutes. Some personnel live far enough away from the plant that they may be precluded from being assigned as responders to the augmented ERO. The alignment of on-shift and augmented ERO positions and the extending of augmentation times increase the population of eligible plant personnel available to fill ERO positions and add valuable expertise. The proposed changes will not be applied as permission to delay response to an event.

Changes to on-shift staffing are related to the removal of references to positions not performing EP functions or those positions whose function is governed by other programs such as chemistry, fire, and security. The diverse and redundant nature of the emergency core cooling system (ECCS) precludes the need for maintenance activities as part of the initial response to an event. As a result, the proposed change removes the performance of maintenance functions on shift. Details associated with ECCS are addressed in Section 3.2.5 of this request. The proposed change revises response for augmentation of the electrical and mechanical maintenance positions at 60 minutes from two to one each and extends augmentation of an Instrument and Controls (I&C) maintenance position to 90 minutes while removing the requirement for augmentation of a second, I&C maintenance position in accordance with NUREG-0654, Revision 1.

The proposed change adds the definition of facility activation as it relates to ERFs readiness to accept emergency response functions and standardizes the criteria to better align with NRC guidance. The proposed change defines activation criteria to clearly identify the positions that must be filled in the TSC, OSC, and EOF so that transfer of command and control functions (classification, notification, protective action recommendations, dose assessment, emergency exposure authorization) from the CR can be completed and on-shift personnel can be relieved of these duties. For the OSC activated corresponds to the position required to transfer oversight of in-plant teams from the control room. The term staffed is applied to the JIC, which does not have responsibility for any command and control actions. This change allows for the transfer of command and control functions from the CR in advance of 60 minutes once minimum

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 5 of 35 staff positions are filled.

The NRC Safety Evaluation Report (SER) that approved DBNPS EP, Revision 4, dated June 27, 1983, noted that augmented response times were based on the time of ERO notification. The proposed change revises this standard such that the response will be based on the time of event classification. Elimination of 30-minute normal working hour augmented response timeframes and the transition of response times from the point of ERO notification to event declaration results in a net extension of day-shift augmented response of up to 30 minutes. For off-hours augmentation, maintaining the 60-minute response time along with the transition of the augmentation start time from the point of ERO notification to event classification results in a net reduction of off-hours augmented response of up to 15 minutes.

References to the CAC, a company facility that receives support from other company facilities throughout the service districts, was eliminated to better align site emergency response processes with regulatory guidance documents. Inclusion of a corporate support organization in Revision 4 of the DBNPS EP was based on company support capability and not associated with a specific commitment or performance deficiency.

The corporate organization does not have responsibility for performance of any activity associated with implementation of the DBNPS EP and will be referenced in site procedures as applicable.

The proposed changes were evaluated in accordance with 10 CFR 50, Appendix E.IV.A.9. The evaluation did not reveal any conflicting duties for on-shift personnel because of the proposed changes and the EP continues to meet the requirements of NUREG-0654 Table B-1 guidance. Details on the impact of the proposed changes are discussed in Section 3.2.

The changes in on-shift staffing and augmentation response times are considered a reduction in emergency plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv). In accordance with 10 CFR 50.54(q)(4), changes to a licensee's emergency plan that reduce the effectiveness of the plan shall be submitted for NRC approval as an amendment application in accordance with 10 CFR 50.90.

A table summarizing current emergency response position and functions compared to the proposed changes is included as Attachment 3. The changes identified in the table do not reflect a re-design of the ERO but only necessary reassignment of responsibilities based on the result of the functional analysis.

Conclusion Maintaining an appropriate number of on-shift personnel, crediting additional on-shift staff positions, technological advances available for on-shift responders, extending augmentation response times to 60 and 90 minutes and alignment of ERO positions to EP functions are practical and prudent alternate methods of ensuring effective and timely emergency response augmentation.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 6 of 35 Details associated with changes to the on-shift ERO, revised augmented ERO and revised key responsibilities and tasks as identified in NUREG-0654, Revision 1, are included in Section 3.2.

2.3 Description of the Proposed Changes Brief descriptions of the associated emergency plan proposed changes are provided below. The justification for each change is discussed in Section 3.2. The specific wording changes are provided in Attachments 1 and 2 as marked-up and clean copy emergency plan pages, respectively.

a. Section 1.0, Definitions, added definition of Facility Activation. Revised Shift Manager Office definition to remove reference to Emergency Assistant Plant Manager position and removed reference to Radiological Testing Laboratory as this is encompassed within the TSC.

b. Table 1-1, Acronyms, revised to remove reference to Radiological Testing Laboratory, Corporate Assistance Center, and include references to Emergency Coordinator, Emergency Response Facility and Field Monitoring Teams (previously named Radiation Monitoring Teams) in accordance with the other proposed changes.

c. Section 2.4, Regulatory Requirements, revised to include reference to NRC Revised Table B-1.

d. Section 2.6, Emergency Plan Interrelationships, revised to remove references to chemistry procedures as these are implemented by licensing processes outside of the emergency plan.

e. Table 2-1, Functional Relationships of Response Organizations, revised to reflect proposed changes related to performance of command and control functions.

f. Section 3.2, Emergency Organizations, revised to reflect new position titles and removed references to the Emergency Plant Manager and Emergency Assistant Plant Manager position in accordance with the proposed changes.

g. Section 4.0, Emergency Conditions, revised to reflect position title changes throughout the section in accordance with the proposed changes.

h. Section 5.0, Organizational Control of Emergencies, revised to reflect staffing of Onsite and Near Site Emergency Response Facilities at the Alert or higher classification and removed references to the Corporate Assistance Center.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 7 of 35

i. Section 5.1.2, On-Shift Operations Group, eliminated reference to On-Shift Chemistry, removed reference to Figure 5.1, On-Shift Emergency Organization, which is replaced by the updated Table 5.1, and eliminated on-shift maintenance staffing in accordance with the proposed change.

j. Section 5.1.3, Normal Plant Shift Staffing, removed references to on-shift staffing governed by licensing processes outside of the emergency plan in accordance with NRC Revised Table B-1 formatting. Changed references from Emergency Director to Emergency Coordinator. Removed certain functions associated with the Unit Supervisor and Shift Engineer (Shift Technical Advisor) positions.

k. Section 5.2, DBNPS Emergency Management, revised to reflect title changes, elimination of detail included in revised organizational figures, and re-assignment of command and control functions in accordance with the proposed changes.

l. Section 5.3.1, Shift Manager, revised to reflect position title changes in accordance with the proposed change.

m. Section 5.3.2, Unit Supervisor, revised to reflect position title changes in accordance with the proposed change.

n. Section 5.3.4, Shift Security Supervisor, revised to reflect position title changes in accordance with the proposed change.

o. Section 5.3.5, On-Shift Maintenance Support, revised to delete this reference to on-shift maintenance in accordance with the proposed change.

p. Section 5.4.1, Overview, revised to reflect assignment of command and control functions in accordance with the proposed change.

q. Section 5.4.2, Direction and Coordination, revised to reflect augmented response times in accordance with the proposed change.

r. Section 5.4.3, Control Room, revised position titles in accordance with the proposed change.

s. Section 5.4.4, Technical Support Center (TSC) Organization, revised to reflect removal of the Emergency Assistant Plant Manager position, facility position title changes, and re-alignment of TSC positions in accordance with the proposed change. Titles and functions added to the TSC include the TSC Manager, ENS Communicator, Operations Communicator, Maintenance Coordinator, Electrical and Mechanical Engineer. Titles and functions deleted from the TSC include the Emergency Facilities Services Manager and Owner Control Area Security Supervisor.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 8 of 35

t. Section 5.4.5, Operations Support Center (OSC) Organization, revised to reflect position title changes and re-alignment of OSC positions in accordance with the proposed change. Titles and functions deleted from the OSC include the Assistant OSC Manager, Rad Data Technician, and OSC Systems Engineers.

u. Section 5.5.1, Overview, revised to remove references to specific areas within the EOF in accordance with the proposed change.

v. Section 5.5.2, Emergency Operations Facility (EOF) Organization, revised to reflect re-alignment of facility positions and titles, as well as command and control functions in accordance with the proposed change. The functions added to the EOF include the Emergency Director, EOF Manager, State/local Communicator, Operations Communicator, Offsite Agency Liaison, State EOC Liaison, and HPN Communicator. Titles and functions deleted from the EOF include the Radiation Testing Lab (RTL) Coordinator, Emergency Director Advisor, Emergency Planning Advisor, Emergency Facilities Services Manager, and County and State Technical Liaisons.

w. Section 5.6, Joint Information Center, revised to reflect new facility title and position changes in accordance with the proposed changes.

x. Section 5.7, Corporate Assistance Center (CAC), deleted section to align emergency response facility descriptions in accordance with proposed change.

y. Section 5.8, Supporting Emergency Organizations, was renumbered to Section 5.7.

z. Section 5.8.1, Letters of Agreement, was renumbered to Section 5.7.1.

aa. Section 5.8.2 Medical Emergency Response Organization, was renumbered to Section 5.7.2 and removed references to first aid staffing that is governed by licensing process outside the emergency plan.

bb. Section 5.8.3, Government Agency Support, was renumbered to Section 5.7.3 and revised to reflect new titles in accordance with the proposed change.

cc. Section 5.8.4, Other Support Organizations, was renumbered to Section 5.7.4.

dd. Table 5-1, Manpower, Location and Response Considerations for Emergencies, revised to incorporate both on-shift and augmented staff, based on regulatory guidance documents, in accordance with the proposed change.

ee. Figure 5-1, On Shift Emergency Organization, revised to reflect on-shift organization in accordance with the proposed change.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 9 of 35 ff. Figure 5-2, Emergency Response Organization, revised to reflect Technical Support Center (TSC) Organization in accordance with the proposed change.

Remaining parts of former Figure 5-2 replaced as Figures 5-3, 5-4, and Figure 5-5.

gg. Figure 5-3, Operational Support Center (OSC) Organization, revised diagram to reflect augmentation times in accordance with the proposed change.

hh. Figure 5-4, Emergency Operations Facility (EOF) Organization, revised diagram to reflect augmentation times in accordance with the proposed change.

ii. Figure 5-5, Joint Information Center (JIC) Organization, revised diagram to reflect staffing times in accordance with the proposed change.

jj. Section 6.1, Activation of the Emergency Response Organization, revised position titles and deleted references to positions removed in accordance with the proposed change. Deleted notification requirements as well as removes an introductory statement regarding mobilization of onsite and offsite EROs and the Corporate Assistance Center (CAC).

kk. Section 6.1.1, Shift Manager/Control Room Operations, revised to reflect title changes in accordance with the proposed change.

ll. Section 6.1.2, Emergency Director, revised to reflect title change to Emergency Coordinator, and indicate that all of the ERO will be activated at an Alert or higher classification. Activation of the ERO and CAC for a Site Area or General Emergency classification has been deleted.

mm. Section 6.2.2, Assessment Actions for Alert, revised to reflect title changes and activation of TSC, OSC, EOF, as well as staffing of JIC, and dispatch of field monitoring teams at the Alert or higher classification.

nn. Section 6.2.3, Assessment Actions for a Site Area Emergency, revised to reflection position title changes in accordance with the proposed change.

oo. Section 6.3, Mitigative Actions, revised to reflect position title changes and elimination of chemistry individual.

pp. Section 6.4, Protective Actions, revised to reflect position title changes, deletion of Assembly Area Coordinator functions and assembly activities addressed under site security response procedures, and removal of the reference to the Radiological Testing Laboratory, which resides in the Davis-Besse Administration Building as cited elsewhere in the emergency plan.

qq. Section 6.5, Aid to Affected Personnel, revised to reflect changes in position titles and changes in command and control functions.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 10 of 35 rr. Figure 6-1, Summary of Typical Emergency Measures, revised to reflect position title, facility activation changes, and removal of references to the CAC in accordance with the proposed change.

ss. Section 7.1.1, Control Room, revised to reflect removal of the Emergency Assistant Plant Manager position in accordance with the proposed change.

tt. Section 7.1.2, Operations Support Center (OSC), revised to include facility activation criteria in accordance with the proposed change.

uu. Section 7.2, Davis-Besse Administration Building (DBAB) Facilities, revised to remove reference to the Radiological Testing Laboratory (RTL), as this is encompassed in the TSC, and remove reference to the Site Emergency Operations Center (SEOC).

vv. Section 7.2.1, Technical Support Center (TSC), revised to include facility activation criteria in accordance with the proposed change.

ww. Section 7.2.2, Radiological Testing Laboratory (RTL), removed reference to the specific title as the area is within the TSC.

xx. Section 7.3.1, Emergency Operations Facility (EOF), revised to include facility activation criteria in accordance with the proposed change.

yy. Section 7.3.2, Alternate TSC, revised to remove facility activation criteria.

zz. Section 7.4.1, Joint Information Center (JIC), revised to add facility staffing criteria.

aaa. Section 7.4.2, Corporate Emergency Facilities, removed references to the Corporate Assistance Center (CAC) in accordance with the proposed change.

bbb. Section 7.5.1, Ottawa County Emergency Operations Center, revised to reflect position title changes.

ccc. Section 7.5.2, Lucas County Emergency Operations Center, revised to reflect position title changes.

ddd. Section 7.5.3, State of Ohio Emergency Operations Center, revised to reflect position title changes.

eee. Section 7.6.2, Emergency Communications Systems, removed reference to the Dose Assessment Center (DAC), which is maintained within the EOF, was changed to reference the EOF.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 11 of 35 fff. Section 7.9.10, Laboratory Facilities, removed section related to chemistry sampling capability as this function is governed by processes outside the emergency plan.

ggg. Section 7.9.10, Facilities and Equipment for Offsite Monitoring, renumbered section, from 7.9.11 to 7.9.10. Revised Radiation Monitoring Team to Field Monitoring Team to align with fleet standard in accordance with the proposed change. Also revised this section to remove specific references to FMT vehicle type, number, and availability.

hhh. Figure 7-1, Emergency Facilities by General Location, revised to reflect removal of Corporate Assistance Center (CAC) and Radiological Testing Laboratory (RTL) in accordance with the proposed change.

iii. Section 8.1.2.c.5.b), Radiological Monitoring Drills, revised to include the change in title for Field Monitoring Teams in accordance with the proposed change.

jjj. Table 8-1, Periodic Training of Emergency Response Personnel, revised to reflect changes to ERO positions. Removed training and frequency requirements for Post-Accident Sampling personnel, First Aid Teams, Security Force, Fire Brigade, and Fleet Emergency Response Support Personnel assigned duties in the Corporate Assistance Center (CAC).

kkk. Section 9.0, Reentry and Recovery, revised positions title changes in accordance with the proposed change and removed reporting requirement to state and local agencies.

lll. Figure 9-1, Recovery Organization Framework, revised to reflect position title changes.

3.0 TECHNICAL EVALUATION

3.1 Technical Justification This section describes technical changes in plant systems, dose assessment, procedures and training that have been completed to better support on-shift functions and ease operator burden. An on-shift analysis utilizing NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, methodology was completed and determined that the proposed changes did not result in conflicting duties for on-shift personnel.

3.1.1 Plant Computer System

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 12 of 35 In the 1980s, the plant computer systems installed in the DBNPS CR included a combination of the plant computer, the Plant Process Computer System (PPCS), the Safety Parameter Display System (SPDS), the Data Acquisition and Display System (DADS), which was a plant computer system that accessed SPDS and miscellaneous applications such as core monitoring software, and meteorological data system. The systems were not integrated, and it was necessary for operators to utilize multiple computers and displays during routine and emergency operations.

Since the 1980s, new computer systems have been installed and existing systems have been upgraded and integrated. These design changes included the installation of an Integrated Control System (ICS), Digital Electro-Hydraulic Control System (DEHC),

Control Rod Drive System (CRDS), and Radiation Data digital networked recorders.

The design changes also included an upgrade of the plant computer and SPDS with an Integrated Plant Computer System (IPCS) that allowed the addition of the systems described above. The system integration added additional displays, and the user interfaces were modified to increase the number of plant parameters that could be accessed through the IPCS. In addition to the listed computer systems, a site Plant Information (PI) system was installed to allow archiving and trending of plant data accessible to control room operators and all site personnel via the business network.

The IPCS is an integrated system that gathers the required plant data, stores, and processes that data, generates visual displays for the operator and other personnel who need plant status information, and provides records of transient events. The basic components of IPCS are the Data Acquisition System (DAS), the central processor units, and the Satellite Display Station (SDS) workstations.

The SDS workstations consist of a display and keyboard. The display generates a variety of graphic real-time displays that are available on command from the keyboard.

The displays can show critical plant parameters such as water levels, temperatures, pressures, flows, and status of pumps, valves, and other equipment. More significantly, they provide the plant operator with a central display of critical symptoms of the plant conditions, which assists the operator in entering and following the Emergency Operating Procedures (EOPs) and achieving the required actions.

In summary, the benefits of the new and upgraded computer systems include:

Improved plant monitoring capability.

Improved graphical displays.

Real time read-only plant data available on personal computers.

Real time in-plant monitoring of conditions and trends.

3.1.2 Dose Assessment The plant computer system has specific screens designed to easily obtain the necessary information for performing offsite dose calculations. These screens include process radiation monitors for the effluent release points (station vent and main steam lines), effluent flow rates, and containment accident range radiation monitors (dose

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 13 of 35 rates), used to determine release concentrations. Separate screens exist for obtaining meteorological data. The plant computer also has dedicated, easily accessed screens dedicated to information to assess core damage. These are included in the Safety Parameters Display System (SPDS) screens of the plant computer system.

The Unified RASCAL Interface (URI) Dose Assessment software is maintained on the plant computer network to provide the ability to perform emergency offsite dose calculations on any of the computers that contain the plant computer data. Dose assessment is initially performed by CR personnel until the EOF is staffed, at which time dose assessment responsibilities are transferred to the EOF. Both the shift manager and shift engineer (STA) are trained and can perform the duty initially, although all licensed operators receive training. Once the EOF is activated, the dose assessment staff performs plant monitoring and calculates offsite releases.

3.1.2.1 Previous on-shift dose assessment Prior to 2002, calculations were performed using software contained in DADS, which was a plant computer system that accessed SPDS data. A sub-program within the system performed offsite dose calculations. The user could access plant effluent and radiation monitor information via the plant computer for calculations. Procedures were maintained for manual calculations of dose projections as well as the use of nomograms for a rapid estimate of the release.

In 2002, DBNPS began using an internally developed software referred to as PCDose for dose assessment. PCDose utilized Excel 97 software that was installed on the SPDS computer for access and control and was available in the control room and EOF.

PCDose received inputs from DBNPS instrumentation via the Plant Process Computer System (PPCS) and SPDS. Inputs included specific radiation elements, flow and pressure transmitters, and meteorological instruments used to estimate a radioactive plume from various DBNPS release paths. Updates for these input parameters were retrieved in real time at a specified time interval. The PCDose software provided calculations for Total Effective Dose Equivalent (TEDE), thyroid dose rates, and total dose throughout the DBNPS 10-mile Emergency Planning Zone (EPZ) for all effluent release pathways. PCDose performed calculations using a straight-line gaussian distribution and allowed dose projections to be performed from field team data. The software provided a graphical depiction of the plume overlaid onto a sub-area map and had a sub-routine that used meteorological data along with dose projections to aid in the determination of PARs. In the event that the software was not available, procedures were maintained for manual calculations of dose projections, as well as the use of nomograms for a rapid estimate of the release.

Between July 2014 and November 2019, DBNPS utilized the Meteorological Information and Dose Assessment System (MIDAS) software to perform dose assessment calculations. The MIDAS software package was installed and operated on designated

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 14 of 35 processors located in the CR and EOF. Inputs for meteorological data, plant effluent radiation monitor data, and other plant status indicators were automatically transmitted into the software from the plant computer. The software was menu driven and provided an option for a rapid dose (Quick Dose) for CR personnel. The software also included an upgrade that provided an ability to simultaneously assess multiple release paths.

MIDAS performed dose calculations employing both straight-line gaussian distribution as well as puff-modeling of the release. MIDAS also provided a graphical representation of the projected plume path, which aided the field monitoring function. Procedures were maintained for manual calculations of dose projections in the event that the dose assessment software was not available.

3.1.2.2 Current on-shift dose assessment The current URI dose assessment software was implemented in November of 2019.

The software is maintained on the plant computer network to provide the ability to perform emergency offsite dose calculations on any of the computers that contain the plant computer data. The URI dose assessment software has two modes of operation:

a rapid mode (used for on-shift dose assessment) and a detailed mode (used for augmented ERO dose assessment). In rapid mode, the URI input options and reports are streamlined to allow the on-shift personnel to perform calculations quickly with minimal impact for on-shift operations. The URI input options are expanded to allow for more precise condition entry and options expanded for conditions that take longer to develop. The detailed mode reports contain more assessment information that is used by the augmented ERO. The software also provides sum assessment mode and combines results from previously completed individual rapid or detailed assessments, to create one summation assessment of all selected releases, in the event of a multiple-pathway release.

URI is the fleet standard dose assessment program. The URI program is tailored to DBNPSs plant configuration, in which the unit-specific inputs establish the source term and conditions to be used in the assessment in a similar format across all URI programs. The URI modelling uses RASCAL modelling. The URI-generated assessment reports are the same format across all URI programs. URI uses a pathway approach, where pathways leading from the source of radioactivity to the environment are determined. Various factors can be applied to each pathway to establish the source term and assessment methodologies available. URI can perform assessments on individual pathways or sum multiple individual pathway assessments into a combined assessment.

URI can perform assessments to either 10 or 50 miles. URI employs both the straight-line gaussian distribution and as well as puff-release approach in its calculations.

URI performs calculations that uses data from effluent radiation monitors and flowrates, effluent and reactor coolant system sample results, reactor coolant system leakage, and field monitoring team data. While the plant specific data is not automatically transferred into the software, the data is easily retrieved by the dose assessment staff and entered into the URI software for calculations. In the event that the software is not available, manual hand calculations remain available to estimate releases.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 15 of 35 3.1.3 Procedure Improvements 3.1.3.1 Emergency Operating Procedures (EOPs)

EOPs have been improved through internal operating experience and through industry initiatives that have driven standards developed by the Pressurized Water Reactor Owners Group (PWROG). EOPs now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. The EOPs interface well with technology such as the SPDS and plant computer.

Additionally, the EOP maintenance program has been revised to incorporate requirements for documenting and maintaining the currency of the bases and deviation documents for the EOPs. Overall, the improvements made to EOPs and the EOP maintenance process reduce the operators reliance on the on-shift emergency response organization during the initial phase of the event.

3.1.3.2 Emergency Action Levels (EALs)

In 2017, DBNPS updated the classification methodology to NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6. EALs now incorporate guidance that has simplified the classification process, including the use of an overview matrix of EAL initiating conditions and threshold values that streamlines the process of evaluating EALs against plant conditions. The streamlined process allows the on-shift operators to focus on event mitigating actions without the aid of the emergency response organization during the initial phase of any event.

3.1.4 Training Improvements 3.1.4.1 Operations Training Operations training is administered through the application of the Systematic Approach to Training (SAT) to ensure that training is conducted to the industry-accepted standards required to achieve and maintain accreditation by the National Academy of Nuclear Training.

A dynamic reference plant simulator is used during Operations training to provide hands-on experience and practice in the operation of the nuclear control room during normal, abnormal, and emergency plant conditions in accordance with ACAD 07-002, Guidelines for Simulator Training. Out of the box simulator performance evaluations are an integral component to the requalification training cycle. The EHNC fleet training procedures describe the conduct of crew-specific simulator training. Evaluation scenarios are designed to be realistic and provide an opportunity for performance evaluation during a wide range of plant operating conditions including emergency conditions that require implementation of the stations EOPs. The simulator training scenarios can vary in both length and complexity with some scenarios running 90-105 minutes. The proficiency of the control room team is evaluated in the areas of transient

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 16 of 35 and accident analysis and control, severe accident management, the site emergency plan, and teamwork and communications in accordance with ACAD 07-001, Guidelines for the Continuing Training of Licensed Personnel.

3.1.4.2 Shift Technical Advisor Training Shift Technical Advisor (STA) training was developed to train the STA as an advisor to the control room team in accordance with the guidelines of NUREG-0737, Clarification of TMI Action Plan Requirements. In 2014, INPO revised training guidelines as detailed in ACAD 14-002, Guidelines for Training and Qualifications of Shift Technical Advisors.

The DBNPS STA training and qualification program adheres to the requirements of ACAD 14-002. The STA performs independent assessments of plant parameters, provides recommendations on appropriate corrective actions to restore plant parameters to acceptable values, and assesses whether core damage has occurred or appears imminent. The STA also advises the shift manager as to level of emergency classification and actions necessary to terminate or mitigate the consequences of the given situation.

3.1.5 Improvement Summary Improvements to equipment, procedures, and training that have occurred since initial approval of the DBNPS EP have resulted in a significant increase in the knowledge and capabilities of on-shift personnel. Based on these improvements, it is concluded that there would be no significant degradation or loss of any functional capability as a result of the proposed changes in on-shift staff, augmentation times, facility activation criteria or re-alignment of augmented positions.

3.2 Functional Analysis This analysis evaluates the impact of extending the augmentation times through the ability of the on-shift staff to perform the major tasks for the major functional areas of the DBNPS EP. The analysis demonstrates that no degradation or loss of function would occur as a result of the proposed changes.

The following is the result of the functional analysis performed for the areas as described in NUREG-0654, Revision 1, Table B-1 as well as the NRC Revised Table B-1 issued in June 2018 (ML18022A352). In general, the analysis is organized to provide details for each functional area for (a) DBNPS Plan Revision 4, (b) the current DBNPS EP and (c) the proposed DBNPS EP.

3.2.1 Plant Operations and Assessment of Operational Aspects NUREG-0654, Revision 1 assumes the on-shift staff will perform plant operations and assessment of operational aspects functions throughout the emergency. NRC Revised Table B-1 replaced plant operations and assessment of operational aspects functions with command and control and emergency classifications functions. The revision placed

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 17 of 35 greater focus on performance of emergency preparedness functions performed by plant operations personnel.

In the proposed change, staffing levels associated with plant operations are revised to reflect only those with positions performing emergency preparedness functions of classification, notification, protective actions/dose assessment, core damage assessment and oversight of on-shift ERO in order to better align the plan with NRC Revised Table B-1.

3.2.2 Emergency Direction and Control (Command and Control, Emergency Classification)

NUREG-0654, Revision 1 guidance indicates that the shift supervisor or STA assumes this function as a collateral duty, where responsibility for overall direction of facility response may be transferred when ERFs are fully staffed. NRC Revised Table B-1 identifies a position responsible for overall command and control of the ERO, EAL approval, PAR approval, and authorization of personnel dose extensions, as well as a position responsible for evaluation of plant conditions and classification recommendations as an ancillary duty.

a. In Revision 4 of the DBNPS EP, the shift supervisor would assume the duties of interim Emergency Duty Officer (EDO) and would be responsible for emergency response efforts until relieved by a designated EDO. The EP also identified an off-hour augmented EDO on-call, with a 60-minute response time, who reported to the ECC. In Revision 10, the on-call EDO position was renamed the Emergency Assistant Plant Manager (EAPM). This position maintained the 60-minute off-hour response time and reported to the CR to relieve the interim EDO of event related responsibilities. Transfer of this function to the ED in the ECC was completed upon staffing of that position. The interim EDO position on-shift was renamed the Emergency Director (ED) in Revision 11.

b. The current revision of the DBNPS EP maintains the Revision 11 transition from the Shift Manager/ED to the EAPM upon arrival in the CR with subsequent transfer of command and control functions to the ED in the EOF. The EAPM 60-minute off hour response time as noted in Revision 11 is also maintained.

c. In the proposed EP, the EAPM ERO position would be eliminated, and emergency direction would transition from the CR Shift Manager/ED to the TSC Emergency Coordinator (EC) and EOF Emergency Director (ED) upon activation of these facilities within 60-minutes of an alert or higher classification. Additional support for the shift manager will be provided, if needed, by duty operations personnel and will be managed through operations department procedures. Command and control functions of classification, federal notification and emergency exposure authorization are transferred to the TSC EC while state/local notification, dose assessment, and PAR development functions transition to the ED in the EOF. The proposed revision to the DBNPS EP defines a facility as activated by its respective manager once

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 18 of 35 minimum required staffing has been achieved such that the facility is capable of performing its assigned functions. The time from emergency declaration of a classification of Alert or higher to the time the facility is activated is the augmentation time for emergency responders.

The DBNPS EP minimum staff positions to support activation of the facility within 60 minutes of an alert or higher classification is depicted in Figure 5-2 for the TSC, Figure 5-3 for the OSC, and Figure 5-4 for the EOF, and are listed below:

Emergency Coordinator (TSC)

Core Hydraulic Engineer (TSC)

ENS Communicator (TSC)

Radiation Protection Coordinator (TSC)

OSC Coordinator (OSC)

Emergency Director (EOF)

Dose Assessment Coordinator (EOF)

State/County Communicator (EOF)

The proposed change eliminates the 30-minute normal working hour response requirement and establishes 60-minute and 90-minute response times for the augmented ERO in accordance with NRC Revised Table B-1. As stated in proposed emergency plan Section 1.0, response times under the proposed change are measured from event declaration rather than ERO notification. This change will result in the ability to transition command and control functions of classification from the CR to the applicable ERF earlier than is required during off-hour events in the current DBNPS EP.

The proposed DBNPS EP change was evaluated in accordance with 10 CFR 50, Appendix E.IV.A.9. No conflicting duties for on-shift personnel were identified and therefore, the proposed change continues to meet NUREG-0654 Table B-1 guidance.

This change is acceptable in that it identifies minimum staffing positions in the TSC, OSC, and EOF that enable transfer of the command and control functions of classification in advance of the 60-minute facility activation requirement.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 19 of 35 3.2.3 Notification/Communication Function Major Functional Area In accordance with NUREG-0654, Revision 1, the notification/communication function included major tasks to notify licensee, state, local, and federal personnel and maintain communications. NRC Revised Table B-1 maintains the function as described in NUREG-0654, Revision 1.

Licensee Notification

a. Revision 4 of the DBNPS EP identified the shift supervisor, acting as interim EDO, as being responsible for notification of key emergency response personnel. In Revision 10, an automated system was implemented to facilitate the call-out process.

b. The current EP maintains the Revision 10 requirement for notification of the ERO by the on-shift ED at the alert or higher classification as well as use of the automated call-out process.

c. The proposed EP maintains the notification requirement of the ERO by the on-shift Emergency Coordinator (formerly the Emergency Director) for augmented ERO in that personnel are notified to respond to the TSC, OSC, EOF, and JIC at an alert or higher classification.

State, Local and Federal Notification

a. Revision 4 of the DBNPS Emergency Plan identified notification of state/local personnel as well as the NRC as a function initially completed by the on-shift shift supervisor. The notification function was augmented during off-hours with three 60-minute communicator positions. In EP Revision 9, the state and county communicator augmented positions were combined into a single position. This change was predicated on the implementation of a direct ringdown phone circuit between the EOCs and the ECC, which allowed a single communicator to perform this task.

b. The current DBNPS EP maintains the Revision 4 on-shift organization for the state, local, and federal notification functions, as well as the Revision 9 off-hours augmented response.

c. The proposed revision to the EP maintains an on-shift resource for performance of the state, local, and federal notification function, eliminates the 30-minute augmented response position, and provides for augmented staffing by two (2) responders at 60 minutes. This change supports the transition of the federal notification function to the TSC and the state and local notification function to the EOF at 60 minutes.

The staffing analysis demonstrated that the on-shift communicator is able to perform the notification task for an additional 30 minutes without conflicts. This change is consistent with NRC Revised Table B-1.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 20 of 35 3.2.4 Radiological Accident Assessment and Support of Operational Accident Assessment Function (Dose Assessment/Projections, Field Monitoring Teams, Radiation Protection)

In accordance with NUREG-0654, Revision 1, the radiological accident assessment and operational accident assessment functional area includes EOF Director, Offsite dose assessment, Offsite surveys, Onsite (out-of-plant) surveys, In-plant surveys, and Chemistry/Radiochemistry major tasks. NRC Revised Table B-1 revised the functions associated with radiological accident assessment to address radiological aspects only.

Emergency Operations Facility (EOF) Director Major Task Revision 4 of the DBNPS EP identified the ECC as the initial response facility. Accident assessment, evaluation, and recovery functions were initially performed by the CR shift supervisor. In accordance with NUREG-0654, Revision 1, the EC role transferred from the shift supervisor to the EDO when the on-duty EDO activated the ECC. Details regarding direction and control of emergencies are discussed in Section 3.2 of this request.

Offsite Dose Assessment Major Task

a. Revision 4 of the DBNPS EP did not address on-shift response for performance of the offsite dose assessment function. The performance of the function was the responsibility of one individual with Senior Health Physics (HP) expertise within a 30-minute response time. Performance of on-shift dose assessment transitioned from the RP technician to the STA in Revision 8 of the EP. Revision 10 identified the dose assessment coordinator in the ECC as the 60-minute off-hours augmented responder responsible for this function.

b. The current DBNPS EP maintains the Revision 10 requirement for the completion of on-shift dose assessment by the STA on-shift, as well as off-hours augmentation by the dose assessment coordinator within 60-minutes of ERO notification.

c. In the proposed change, responsibility for initial performance of dose assessment by the STA is maintained. The off-hour augmentation time for the dose assessment coordinator is maintained.

The proposed change will not result in extension of the performance of the dose assessment function by on-shift personnel. Performance of the core damage and dose assessment functions is supported by improvements made to plant computer systems as discussed in Section 3.1.1 as well as improvements in the dose assessment software noted in Section 3.1.2.2. These improvements result in minimal user interface and the streamlining of data such that performance of these two activities by a single position improves the efficiency for performance of these tasks.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 21 of 35 Offsite Surveys Major Task

a. In Revision 4 of the DBNPS EP, offsite radiological monitoring was initiated at a Site Area Emergency (SAE) or higher classification. Each radiation monitoring team (RMT) was normally comprised of two qualified individuals as part of the 60-minute off-hour augmented response. Revision 12 modified the offsite monitoring process to require dispatch of teams at the alert or higher classification and the DBNPS EP was revised to reflect the purchase of three four-wheel drive vehicles that would be available for use by RMTs within about 30 minutes of an event. The addition of this equipment was noted in the 1987 NRC Routine EP Inspection Report. The addition of the equipment was not related to a licensing commitment or an inspection finding nor was it provided as a corrective action to a performance deficiency.

b. The current EP maintains three radiological monitoring teams at 60 minutes off hour augmentation upon declaration of an alert or higher as well as details on RMT vehicle type and number.

c. In the proposed EP, the dispatch of RMTs (RMTs renamed to Field Monitoring Teams [FMTs]) continues to occur at declaration of an alert or higher classification.

The proposed EP reduces the number of RMTs from three to two. The response time for the initial team remains at 60 minutes, the response time for the second team is extended from 60 minutes to 90 minutes.

Initial FMT response primarily involves environmental radiation and contamination assessments, plume tracking, and using dose assessment instrumentation. Actions include, driving to and from field positions, reading dose rate instrumentation and communicating results to the TSC and EOF. The first FMT, augmented at 60 minutes, can effectively track any potential plume, and cover the necessary area to identify whether a plume exists during the early stages of an event. The second team, augmented at 90 minutes, will support continued plume tracking capability as well as sampling activities.

The proposed change also removes references to FMT vehicle numbers, type, and availability. The site will continue to ensure vehicles with appropriate capability are maintained in a state of readiness for immediate response during an event. Details regarding management of FMT vehicles will be maintained in site procedures.

Oversight and direction of FMTs is provided by the FMT Coordinator in the EOF.

This position maintains responsibility for radiological safety of the FMTs. Dispatch of FMTs at 60 and 90 minutes from the alert classification continues to support timely performance of the offsite survey function.

Onsite (out-of-plant) and In-Plant Surveys Major Tasks

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 22 of 35

a. Revision 4 of the DBNPS EP provided for performance of onsite (out-of-plant) and in-plant surveys as an ancillary duty of an on-shift operator. Both the onsite (out-of-plant) and in-plant surveys were augmented during off-hours by four RP technicians responding at 60 minutes. In Revision 10 responsibility for performance of this task was the on-shift RP technician and the number of augmented RP technicians responsible for onsite (out-of-plant) and in-plant surveys was reduced from two to one. This change aligned the site augmented response for this function with NUREG-0654, Revision 1, Table B-1 staffing.

b. The current DBNPS EP maintains the Revision 10 requirement for performance of onsite and in-plant surveys on shift as well as augmentation at 60 minutes by an RP technician.

c. The proposed change maintains the performance of onsite (out-of-plant) and in-plant surveys as a function of the on-shift RP technician, maintains augmentation at 60 minutes by an RP technician, and adds augmentation by an additional RP technician at 90 minutes in accordance with NRC Revised Table B-1.

As previously stated in Section 3.1.1, improvements in plant computer systems have resulted in improved availability of plant data and trending capabilities. This benefit has been extended to data associated with area radiation and plant effluent monitoring. Radiological monitors installed throughout the plant provide detection, measurement, and indication of area radiation, airborne radioactivity concentrations, and process radioactivity concentrations. The area radiation monitoring system provides detection, measurement, and indication of radiation health hazards. In general, area radiation monitors are placed in areas where radiation levels could feasibly increase due to postulated occurrences. Fixed and movable air monitors comprised of particulate, iodine, and gaseous measuring channels provide both audible alarm and visual indications when pre-determined set points are exceeded for airborne radioactivity. The effluent monitoring system monitors liquid and gaseous effluents during actual or potential releases. Additionally, the proposed change recognizes that the onsite area at the site is small enough to allow for monitoring by a single individual and does not require the use of a vehicle to perform this task.

On-shift RP technicians can quickly determine radiological conditions utilizing the plant radiation monitoring systems. System data is displayed on plant desktop computers and this data can be used to brief on-shift operators and response teams to area conditions. This data can also be used to determine areas that may require follow-up RP surveys. Improved availability of live time radiological conditions in the plant allows the RP technicians to provide required information to the shift manager/EC in less time than performance of discrete area surveys while providing the same or better radiological protection capability for site personnel. The result of improved use of technology is the reduction in on-shift burden for RP technicians such that extension of augmented response times does not adversely impact performance of the functions.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 23 of 35 Chemistry/Radiochemistry Major Task

a. Revision 4 of the DBNPS EP identified performance of the chemistry/radiochemistry function as the responsibility of the Chemistry & Health Physics (C&HP) tester on-shift and an augmenting technician responding at 60 minutes during off hours. In Revision 11, the chemistry function was separated from the RP function. The response was also revised to include a chemistry technician on shift and an augmenting technician responding at 60 minutes during off hours as well as one additional chemistry responder within 1-2 hours of event notification.

b. The current EP maintains the Revision 11 requirement for one on shift and one augmented chemistry technician.

c. The proposed EP revision eliminates the requirement for performance of the chemistry/radiochemistry function on shift as well as augmented staffing for performance of this function.

Performance of chemistry/radiochemistry functions are being removed from the DBNPS EP and will be governed by processes outside the emergency plan. This change is also aligned with NRC Revised Table B-1.

3.2.5 Plant System Engineering, Repair and Corrective Actions Function (Engineering, Repair Team Activities)

In accordance with NUREG-0654, Revision 1, the plant system engineering, repair and corrective actions functional area includes technical support and repair and corrective actions major tasks. NUREG-0654 Table B-1 notes that mechanical maintenance/radwaste operator and electrical maintenance/instrument and control technician expertise may be provided by shift personnel assigned other functions. NRC Revised Table B-1 identifies the engineering function as an evaluation of on-shift reactor conditions and the repair team activities as an activity performed by augmented resources for restoration of ECCS equipment as needed.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 24 of 35 Technical Support Major Task

a. Revision 4 of the DBNPS EP identified the STA as the on-shift position responsible for performing the assessment of the emergency including reactor core status. The core thermal hydraulics function was augmented at 60 minutes from the time of ERO notification. Additional technical support was augmented at 1-2 hours by the nuclear engineering manager, plant I&C system engineer, and the plant nuclear system engineer. In Revision 10, the 60-minute augmented response was revised to include the TSC engineer manager and the core thermal hydraulic engineer. Response by I&C system, electrical, and mechanical engineers occurred at 1-2 hours after ERO notification.

b. The current EP maintains the Revision 10 requirement for performance of the core thermal hydraulics function by the on-shift STA position as well as the 60-minute and 1-2 hour off-hours augmented responses.

c. The proposed change maintains the on-shift and 60-minute off hours augmented response position responsible for core thermal hydraulics tasks, revises response times for the electrical and mechanical engineers from 1-2 hours to 60 minutes, extends the response time for the engineering coordinator, formerly the TSC engineering manager, to 90 minutes, and removes the reference to the I&C engineer.

Evaluation of the on-shift activities associated with the proposed changes in accordance with 10 CFR 50 Appendix E.IV.A.9, showed that on-shift personnel were able to complete required tasks without conflicts.

Repair and Corrective Actions Major Task

a. In Revision 4 of the DBNPS EP, plant stabilizing functions were completed by on-shift operations personnel. Staff to address repair and corrective actions was augmented through off-hours activation with the addition of one electrician and one I&C technician responding at 30-45 minutes. In addition, one electrical maintenance, one mechanical maintenance, and one radwaste operator responded at 60 minutes.

In Revision 10, the on-shift maintenance resources maintained a 24-hour per day shift rotation consisting of a maintenance foreman, two mechanics, two electricians, and two I&C technicians. The revision aligned the emergency plan with changes in site staffing and was not related to an emergency plan performance deficiency.

b. The current EP eliminated the maintenance foreman position and maintained the on-shift staffing of one mechanic, one electrician, and one I&C technician. The on-shift staff is augmented within 60 minutes with the addition of one mechanic, one electrician, and one I&C technician for a total of two per position.

c. The proposed changes to the DBNPS EP have been revised to reflect mechanical and electrical maintenance personnel arriving within 60 minutes of an alert or higher

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 25 of 35 classification to perform the initial troubleshooting and corrective actions work in the plant. The OSC coordinator position, also arriving within 60 minutes, will direct repair and assessment personnel until the respective discipline supervisors arrive. In addition, the proposed changes to the DBNPS EP will reflect the mechanical maintenance coordinator, electrical maintenance coordinator, I&C coordinator, and I&C personnel positions in the OSC arriving within 90 minutes of an alert or higher classification to provide supervisory oversight for their respective disciplines.

Appendix 3D of the DBNPS Updated Safety Analysis Report (USAR) states that the design of DBNPS meets the intent of 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants, as published on February 20, 1971, and as amended on July 7, 1971. This includes conformance with General Design Criteria (GDC) 35, Emergency Core Cooling, which states:

A system to provide abundant emergency core cooling shall be provided.

The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

To support the objective of the single failure criteria, the DBNPS ECCS, as described in the DBNPS USAR, incorporates a diverse and redundant system design. The DBNPS ECCS consists of a core flooding tank on each of the two RCS cold legs, two redundant high pressure injection pumps, two redundant low pressure injection pumps each with an associated decay heat removal cooler, and one borated water storage tank. The ECCS trains are separated electrically and mechanically to ensure no single failure on any one train would preclude the other train from fulfilling the required safety function.

Normal operating status and deviations from this status are controlled by the DBNPS technical specifications.

System performance is tracked and trended by the site and demonstrates a high degree of reliability. System health requirements are maintained in accordance with NRC performance indicators for system availability and the tracking of functional failures, which are an integral part of the Reactor Oversight Process (ROP).

Additionally, reliability is driven by maintenance rule performance criteria.

Crediting the robust ECCS capability and protection against single point failures provides the basis for removal of maintenance personnel from on-shift, maintaining

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 26 of 35 augmentation response times for mechanical and electrical maintenance technicians and extending response time for I&C maintenance to 90 minutes. As a result, the proposed changes will not result in a reduction in response capability.

3.2.6 Protective Actions (In-Plant) Function (See Radiological Assessment)

In accordance with NUREG-0654, Revision 1, the protective actions functional area includes the radiation protection major task, specifically access control; RP coverage for repair and corrective actions, search and rescue, first aid, and firefighting; personnel monitoring; and dosimetry. NUREG-0654 Table B-1 notes that HP technician expertise may be provided by shift personnel assigned other functions. NRC Revised Table B-1 combines this function with the radiation protection function.

a. Revision 4 of the DBNPS EP provided for performance of the protective action function as an ancillary duty of two on-shift operators and was augmented during off-hours by four HP technicians within 60 minutes. In Revision 10, responsibility for performance of this task transitioned from two on-shift technicians to one technician and was augmented during off-hours by three technicians within 60 minutes and four additional technicians between 1 and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

b. The current DBNPS EP maintains one on-shift RP technician, one RP technician augmented at 60 minutes, and three RP technicians augmented between 1 and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. The proposed revision adds an RP resource to the on-shift staff for performance of protective action functions, provides for two RP technicians augmented at 60 minutes and an additional two RP technicians augmented at 90 minutes in accordance with NRC Revised Table B-1. These positions will continue to perform activities related to:

Access/Control dosimetry

Job coverage for repair and corrective actions

Personnel monitoring The performance of access control and dosimetry activities is primarily completed through the use of Self-Reading Dosimetry (SRD), which is obtained prior to entry into Radiologically Controlled Areas (RCA). The SRD also unlocks turnstiles to gain access to the RCA. Radiation Work Permits (RWPs) establish the necessary preset warnings and alarms associated with the SRD that assures that the teams dispatched to the in-plant areas to perform any function during a declared emergency will be afforded ample warning prior to exceeding their allowed dose or dose rate. Use of the SRD and RWP process eliminates the need for access control and dosimetry oversight by an RP technician for the initial response actions to an event.

Improvements in plant computer systems, as discussed in Section 3.1.1 and Section

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 27 of 35 3.2.4, allow information on plant radiological conditions to be made readily available to RP technicians. Plant area radiation monitors and ventilation data can be monitored from the plant access control point and allow the protective action RP technician to monitor changes in plant status and provide updates to plant personnel in a timely manner. This improvement in technology enables the on-shift staff to assess plant conditions quickly and efficiently, and with fewer distractions.

Performance of habitability activities are associated with the emergency response facilities after they are staffed by augmented personnel. As augmentation of emergency response staffing and RP technicians occurs simultaneously for each facility under the proposed change, performance of this function is not adversely impacted.

Implemented improvements in technology in the areas of dosimetry, access control and plant monitoring capability at DBNPS have reduced burden for on-shift RP resources and so serves as the basis for extension of response times for augmented resources. The proposed changes to RP response times are aligned with NRC Revised Table B-1 guidance.

3.2.7 Firefighting Function (Not Applicable)

In accordance with NUREG-0654, Revision 1, the firefighting functional area is addressed by use of a fire brigade and managed in accordance with site technical specifications. NRC Revised Table B-1 does not address the firefighting function as this is performed under the site fire protection plan.

a. In Revision 4, of the DBNPS EP, firefighting response was provided by on-shift personnel and augmented by the offsite local fire department.

b. The current EP maintains the firefighting function requirement through the use of on-shift operations personnel who make up the station fire brigade, as well as offsite support as needed.

c. The proposed EP removes the reference to firefighting from Table 5.1.

The proposed change will better align with NRC Revised Table B-1 formatting. The firefighting function will continue to be maintained as a part of the DBNPS fire protection plan. The firefighting function will no longer be described in the DBNPS EP.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 28 of 35 3.2.8 Rescue Operations and First-Aid Function (Not Applicable)

NUREG-0654, Revision 1, Table B-1 notes that this function may be provided by shift personnel assigned other functions. NRC Revised Table B-1 does not address rescue operations and first-aid as these tasks are outside the purview of the emergency plan.

a. In the DBNPS EP, Revision 4, Rescue Operations and First-Aid were provided as an ancillary duty by two on-shift personnel. The function was augmented by offsite local support organizations.

b. The current EP utilizes one non-licensed operator (NLO) to fulfill rescue operations and first-aid as an ancillary duty.

c. The proposed EP removes the reference to rescue operations and first-aid from Table 5.1.

The proposed change will better align with NRC Revised Table B-1 formatting. The rescue operations and first-aid function will continue to be performed as an ancillary duty by the site fire brigade in accordance with the DBNPS fire protection procedures. Rescue operations and first-aid functions will no longer be described in the DBNPS EP.

3.2.9 Site Access Control and Personnel Accountability Function (Not Applicable)

In NUREG-0654, Revision 1, the site access control and personnel accountability functional area is addressed by security personnel in accordance with the site security plan. NRC Revised Table B-1 does not address site access control as this function is under the purview of the site security plan.

a. In DBNPS Emergency Plan, Revision 4, site access control and accountability is identified as a function of the security personnel on-shift and is detailed in the security plan. In Revision 29, two security positions were added to Table 5-1 in support of this function.

b. The current EP maintains the Revision 29 requirements for on-shift staffing for this major functional area.

c. The proposed EP removes the reference to site access control and personnel accountability functions.

The proposed change will better align with NRC Revised Table B-1 formatting. The access control and accountability functions will continue to be implemented as part of the DBNPS physical security plan.

3.3 Conclusions

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 29 of 35 The proposed changes continue to support the functional areas of the DBNPS EP, continue to ensure the protection of the health and safety of the public and site personnel, and will not present a significant burden to the on-shift personnel.

The elimination of references to on-shift maintenance functions, given the diverse and redundant capabilities of plant systems, does not adversely affect the sites ability to respond to an event.

Removal of references to during normal work hours and extending augmented response times for certain positions from 60 minutes to 90 minutes, based on improved in-plant and effluent monitoring capability, does not adversely impact the sites ability to respond to an event or delay performance of maintenance or radiation protection functions.

Additionally, extension of RP technician augmented response times does not adversely affect performance of radiological assessment nor protective action functions associated with event response. DBNPS has incorporated new technologies in access control, dosimetry, and in-plant monitoring capability to ensure that the emergency response functions identified in the DBNPS EP will continue to be performed. The proposed changes do not result in a reduced ERO capability to effectively respond to an emergency.

Although the ERO staffing augmentation response time is being extended, resulting in an increased ERF activation time, the emergency response functions identified in the DBNPS EP will continue to be performed by the on-shift staff until relieved by augmented ERO responders and will not result in a reduction of the capability of the ERO to effectively respond to the emergency. Therefore, the proposed increase in augmentation response continues to ensure the DBNPS EP will meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

4.0 REGULATORY EVALUATION

EHNC proposes to revise the DBNPS EP to extend augmentation times for certain ERO positions and reduce the number of augmented RP positions to align with NRC Revised Table B-1, realign command and control functions between the EOF and TSC, and reassign augmented ERO positions to meet new command and control structure requirements. The proposed amendment would revise plan Sections 1, 2, 3, 4, 5, 6, 7, 8, and 9.

4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations 50.47(b)(1) and (2):

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 30 of 35 (b) The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:

(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.

(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 existing DBNPS EP meets the requirements listed above. This proposed amendment application includes, but is not limited to, the reduction of on-shift staffing; standardization of terms, position title and responsibilities; establishment of minimum staffing criteria for the OSC, TSC, and EOF; activation of the TSC, OSC, and EOF within 60 minutes of the declaration of an alert or higher classification; and extension of staff augmentation response times from 30 minutes to 60 minutes and, in some cases, extend 60-minute response times to 90 minutes. The proposed DBNPS EP will continue to meet 10 CFR 50.47(b).

Relevant portions of Title 10 Code of Federal Regulations 50.54(q) are as follows:

(q) EPPs (1)(iv) Reduction in effectiveness means a change in a Plan that results in reducing the licensees capability to perform an Emergency Planning function in the event of a radiological emergency.

(3) A holder of a license under this part, or a combined license under part 52 of this chapter after the Commission makes the finding under § 52.103(g) of this chapter, shall follow and maintain the effectiveness of a Plan that meets the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

(4) The changes to a licensee's Plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012, shall submit an application for an amendment to its license. In addition to the filing

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 31 of 35 requirements of §§ 50.90 and 50.91, the request must include all EPP pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's Plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

The existing DBNPS EP meets the planning standards of 10 CFR 50.47(b) and 10 CFR 50, Appendix E as required by 10 CFR 50.54(q)(2). This amendment application proposes to extend augmentation times of some ERO positions and reduce the number of augmented RP positions. These proposed changes are considered a reduction in effectiveness as defined in 10 CFR 50.54(q)(1)(iv) and requires NRC approval based on 10 CFR 50.54(q)(4). Therefore, Energy Harbor Nuclear Corp. is submitting this amendment application pursuant to 10 CFR 50.90.

The DBNPS EP will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the EP such that it meets the requirements of 10 CFR 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

Relevant portions of Title 10 Code of Federal Regulations Part 50 Appendix E.IV are as follows:

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:

A.9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned EPP implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the EPP.

The existing DBNPS EP includes a description of the organization, including definition of authorities, responsibilities, and duties of individuals. The current DBNPS EP is in compliance with the 10 CFR 50 Appendix E.IV.A.9. This amendment application proposes extension of augmentation times for some ERO positions, reduction in the number of augmented RP positions, realignment of command and control functions between the EOF and TSC, and reassignment of augmented ERO positions to meet new command and control structure requirements. A staffing analysis has been performed to demonstrate continued compliance with 10 CFR 50, Appendix E.IV.A.9.

The staffing analysis supports acceptability of this increase in staff augmentation times.

The proposed changes to the DBNPS EP will continue to describe the authorities, responsibilities, and duties of these individuals. Therefore, with the changes proposed

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 32 of 35 in the amendment application, the requirements of 10 CFR 50 Appendix E continue to be met.

NUREG-0654/FEMA-REP-1, Revision 1,Section II.B.5 states, in part:

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.

NUREG-0654, Revision 1 states general guidance concerning the onsite emergency organization to allow licensees some flexibility in the number of on-shift staff required by emergency plans for response to emergency events. NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30-minute and 60-minute responders. The augmented ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing them to focus on plant operations. NUREG-0654 also provides the guidance that augmentation time be measured from the declaration of the emergency. The current DBNPS EP staffing in Table 5.1 meets the intent of NRC Revised NUREG-0654 Table B-1. This amendment application proposes to extend the augmentation time for some ERO positions and reduces the number of augmented RP positions. The proposed changes have been evaluated in a staffing analysis performed to meet 10 CFR 50, Appendix E.IV.A.9 requirements. The proposed changes to the DBNPS Plan meet the intent of NUREG-0654, Table B-1. This change is in alignment with NUREG-0654, Revision 1,Section II.B.5.

4.2 Precedent The proposed DBNPS EP changes are similar to changes approved for other licensees, including South Texas Project (ML18159A212), Sequoyah (ML18159A461), Diablo Canyon (ML19196A309) and Browns Ferry (ML20085G896). Furthermore, the proposed DBNPS EP changes evaluated and documented in this submittal continue to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E.

4.3 No Significant Hazards Consideration Analysis

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 33 of 35 Energy Harbor Nuclear Corp. (EHNC) proposes to revise the Davis-Besse Nuclear Power Station (DBNPS) Emergency Plan (EP) to extend augmentation times for certain Emergency Response Organization (ERO) positions.

EHNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, and has determined that the operation of DBNPS in accordance with the proposed amendment presents no significant hazards. The EHNC evaluation against each of the criteria in 10 CFR 50.92 follows.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

This proposed amendment includes, but is not limited to, the reduction of on-shift staffing; standardization of terms, position titles and responsibilities; establishment of minimum staffing criteria for the operations support center (OSC), technical support center (TSC), and emergency operations facility (EOF); activation of the TSC, OSC, and EOF within 60 minutes of the declaration of an alert or higher classification; and extension of staff augmentation response times from 30 minutes to 60 minutes and, in some cases, extend 60 minute response times to 90 minutes. The proposed changes have no effect on normal plant operation or on any accident initiator or precursors and does not impact the function of plant structures, systems, or components (SCCs). The proposed changes do not alter or prevent the ability of the ERO to perform their intended functions to mitigate the consequences of an accident or event. As a result, the proposed changes are determined to not adversely affect the ability to meet the requirements of 10 CFR 50, Appendix E, and the emergency planning standards as described in 10 CFR 50.47(b).

Therefore, the proposed DBNPS EP changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not impact the accident analyses. The changes do not involve a physical alteration of the plant, a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the changes do not alter assumptions made in the safety analysis. The proposed changes do not alter or prevent the ability of the ERO to perform its intended function to mitigate the consequences of an accident or event.

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 34 of 35 Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (such as, fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with the DBNPS EP staffing and does not impact operation of the plant or its response to transients or accidents. The change does not affect the technical specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by these proposed changes. Safety analysis acceptance criteria are not affected by the proposed change. The functional analysis and the shift staffing analysis concluded that extension of augmentation times for certain ERO positions, and reduction of on-shift positions would not significantly affect the ability to perform the required emergency plan tasks. Therefore, the proposed changes are determined to not adversely affect the ability to meet the requirements of 10 CFR 50, Appendix E, and the emergency planning standards as described in 10 CFR 50.47(b). Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EHNC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions EHNC has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria. The proposed DBNPS EP changes continue to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

Based on the above evaluation, EHNC has determined that operation of the facility in accordance with the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that they do not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change recordkeeping, reporting, or administrative procedures or requirements. However, the proposed amendment does not involve (i) a

Evaluation of Proposed License Amendment Davis-Besse Nuclear Power Station Page 35 of 35 significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980.

2. NRC Letter to NEI, Alternative Guidance for Licensee Emergency Response Organizations, dated June 12, 2018 (ML18022A352).

3. NRC Regulatory Issue Summary RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ML16124A002).

Attachment 1 DBNPS Emergency Plan Affected Pages (Mark-up)

(194 pages follow)

DBNPS Emergency Plan Revision XX DAVIS-BESSE NUCLEAR POWER STATION EMERGENCY PLAN

DBNPS Emergency Plan Revision XX FOREWORD In accordance with the conditions of the Nuclear Regulatory Commission operating license for the Davis-Besse Nuclear Power Station, the management of the Company recognizes its responsibility and authority to operate and maintain the Davis-Besse Nuclear Power Station in such a manner as to provide for the safety of the public. The importance of Emergency Preparedness and Response in contributing to this safety as well as contributing to Station reliability is also recognized.

In accordance with this philosophy, this Emergency Plan has been prepared. It establishes the procedures and practices for management control over unplanned or emergency events that may occur at the Davis-Besse Nuclear Power Station.

Revision 35 of the Emergency Plan meets the requirements of 10 CFR 50.54(q). Changes made in Revision 35 of the Emergency Plan do not decrease its effectiveness.

The issuance and control of this Emergency Plan and activities associated with Emergency Response at the Davis-Besse Nuclear Power Station are the responsibility of the Site Vice President, DB Nuclear. Additions, deletions, or modifications to the Emergency Plan shall be approved by the Manager, Regulatory Compliance and Emergency Response, the Director, Site Performance Improvement, and the General Plant Manager. It is intended that this Emergency Plan and the Emergency Plan Procedures be fully compatible with the applicable requirements for quality assurance set forth in the Nuclear Assurance Program Manual.

The Manager, Regulatory Compliance and Emergency Response is hereby assigned the responsibility for emergency preparedness operations with authority as established in this Emergency Plan and outlined above. Day-to-day maintenance and implementation of the Emergency Response Program is the responsibility of the Manager, Regulatory Compliance and Emergency Response and the Emergency Response Section.

Manager, Regulatory Compliance and Date Emergency Response Director, Site Performance Improvement Date General Plant Manager Date Site Vice President - DB Nuclear Date

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DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes Revision 35 addresses routine updates to the DBNPS Emergency Plan and incorporates changes supporting changes to the station telephone communications, the company name, and removed reference to Company Nuclear Review Board (CNRB) in the Recovery Section of the plan.

Title change throughout Changed title of Emergency Response Manager to Manager, Regulatory Compliance Emergency Plan and Emergency Response Forward page Removed FENOC from the third paragraph Page xi Removed reference to FirstEnergy Corporation Section 2.2 Changed FENOC to Fleet Section 5.6 Removed the sentence The Emergency Public Information staff is activated by call tree notification, and operates the Joint Information Center (JIC).

Table 5-1 Moved NRC Liaison under Emergency Operations Facility from a 1-2 hours to a 60/60 time requirement in the Alert, Site Area Emergency, General Emergency column.

Table 5-1 Moved State/County Communicator under Emergency Operations Facility from a 1-2 hours to a 60/60 time requirement in the Alert, Site Area Emergency, General Emergency column.

Section 6.1 Removed the form number (Form 361) from the form name NRC Event Notification Worksheet.

Section 6.4.1.b Removed as described below. At other site locations (i.e., Davis-Besse Training Center, Davis-Besse Administration Building and Annex, Warehouse),

Section 7.6.1.a.1 Revised A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides six in/out bound offsite communications paths to A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides in/out bound offsite communications paths Section 7.6.1.a.1, first Deleted first bullet 2 paths connect to the FirstEnergy company communications bullet system

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DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes (Cont)

Section 7.6.1.a.1, Revised 3 priority circuits travel to Toledo where then connect to the commercial second bullet telephone system to 2 priority circuits connect directly into the administration building PBX from the commercial telephone system Section 7.6.1.a.1, third Revised 1 priority circuit connects directly into the local commercial telephone bullet system to 1 priority circuit connects directly into the plant office building PBX from the commercial telephone system Section 7.6.1.b.1 Revised Voice over IP service from the Akron Ohio West Akron Campus to Voice over IP service delivered via Point to Point circuits Section 7.6.1.g Removed sentence The system is composed of a minimum of 26 phone lines Table 7-1, section A Added or Equivalent under Type of Detector for Neutron Figure 7-1 Revised Toledo Edison Plaza to 300 Madison Building LLC; revised FirstEnergy Corp. Facility to Corporate Facility; and removed reference to the Site Emergency Operations Center Section 8.3.2 Revised FENOC to Fleet Section 9.2 Deleted Following a SITE AREA or GENERAL EMERGENCY, the Company Nuclear Review Board (CNRB) will participate in the recovery planning effort to assure that all nuclear safety aspects of the recovery are satisfied. The CNRB will report their findings to the Recovery Director, who shall take the actions that he deems appropriate for safe recovery operations.

Section 9.2.3.a.3 Deleted Coordinate with the CNRB to ensure adequate review of engineering activities and proper review and approval of the recovery plan and implementing procedures. And renumbered subsequent steps.

Page A-2 Removed procedures: NOP-LP-5400, FENOC MIDAS Dose Assessment Software; NOP-LP-5402, Davis-Besse MIDAS Dose Assessment Software; NOP-LP-5412, DBNPS MIDAS Multiple Accident Dose Assessment Software; and added procedures: NOP-LP-5020, Unified Rascal Interface (URI) Dose Assessment Software General Administration; NOP-LP-5022, Davis-Besse Unified Rascal Interface (URI) Dose Assessment Software, and NOP-LP-5024, Unified Rascal Interface (URI) Dose Assessment Software

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DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes (Cont)

Page A-2 Removed reference to RA-EP-02550, Offsite Personnel & Vehicle Monitoring &

Decontamination Page A-2 Removed FENOC from the title FENOC Field Monitoring Teams Radiation Monitoring Teams Field Surveys Page A-2, items 8 and 9 Revised 7.2 to 7.3 Page A-2, item 21 Revised 6.4.2 to 6.4.3 Page A-2, item 23 Revised 6.4.3 to 6.4 Page A-3, item 2, off- Added 6.5.3 normal Page A-3 Removed FENOC from the title FENOC Siren Testing And Maintenance Procedure Page A-4, item 1. Removed 4.3.3 and 5.5; and added 5.6 Public information Page A-4 Removed FENOC from the title Fleet Support of Emergency Plans at FENOC Nuclear Plants Appendix B Removed reference to FirstEnergy Corporation

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DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 1.0 DEFINITIONS ..........................................................................................................1-1 2.0 SCOPE AND APPLICABILITY ..............................................................................2-1 2.1 Site Description................................................................................................2-1 2.2 Population Distribution ....................................................................................2-2 2.3 Emergency Planning Zones ............................................................................2-3 2.4 Regulatory Requirements ................................................................................2-3 2.5 Objectives of Emergency Response.................................................................2-4 2.6 Emergency Plan Interrelationships ..................................................................2-4 2.7 Emergency Plan Procedures, Station Procedures and Fleet Business Practice ....................................................................................2-5 2.8 Participating Governmental Agencies .............................................................2-6 3.0

SUMMARY

OF THE EMERGENCY PLAN...........................................................3-1 3.1 Emergency Plan Steps .....................................................................................3-1 3.2 Emergency Organizations ................................................................................3-1 3.2.1 State of Ohio .......................................................................................3-2 3.2.2 Ottawa County, Ohio ..........................................................................3-2 3.2.3 Lucas County, Ohio ............................................................................3-3 3.2.4 Erie County, Ohio ...............................................................................3-3 3.2.5 Sandusky County, Ohio ......................................................................3-3 3.2.6 State of Michigan ................................................................................3-3 3.2.7 Federal Agencies.................................................................................3-4 3.3 Emergency Categories .....................................................................................3-4

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DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 4.0 EMERGENCY CONDITIONS .................................................................................4-1 4.1 Emergency Classification Levels (ECLs) .......................................................4-1 4.1.1 GENERAL EMERGENCY ................................................................4-1 4.1.2 SITE AREA EMERGENCY ..............................................................4-1 4.1.3 ALERT ...............................................................................................4-1 4.1.4 UNUSUAL EVENT ...........................................................................4-1 4.1.5 RECOVERY .......................................................................................4-2 4.2 EMERGENCY CLASSIFICATION4-2 4.3 INITIATING CONDITION (ICs) ...................................................................4-2 4.3.1 Recognition Category Codes ..............................................................4-2 4.3.2 Emergency Classification Level (ECL) Codes ...................................4-2 4.4 EMERGENCY ACTION LEVELS (EALs) and Fission Product Barriers (FPBs)................................................................4-3 4.4.1 Barrier Abbreviation Codes ...............................................................4-3 4.4.2 Fission Product Barriers (FPBs) Recognition Categories Codes ........4-3 4.4.3 Operation Mode Applicability ...........................................................4-4 4.4.4 Treatment of Multiple Events and Classification Level Upgrading ...4-4 4.4.5 Emergency Classification Level Downgrading ..................................4-5 4.4.6 Classifying Transient Events ..............................................................4-5 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES .........................................5-1 5.1 DBNPS Organization .......................................................................................5-1 5.1.1 Plant Management and Administrative Organization .........................5-1 5.1.2 Onshift Operations Group ...................................................................5-2 5.1.3 Normal Plant Shift Staffing ................................................................5-2 vi

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 5.2 DBNPS Emergency Management....................................................................5-4 5.2.1 Emergency Director ............................................................................5-4 5.2.2 Emergency Offsite Manager ...............................................................5-5 5.2.3 Emergency Plant Manager ..................................................................5-5 5.2.4 Company Spokesperson ......................................................................5-6 5.2.5 Emergency Director Advisor ..............................................................5-6 5.3 Onshift Emergency Response Organization ....................................................5-6 5.3.1 Shift Manager .....................................................................................5-6 5.3.2 Unit Supervisor ..................................................................................5-7 5.3.3 Shift Engineer (Shift Technical Advisor) ...........................................5-7 5.3.4 Security Shift Supervisor ....................................................................5-7 5.3.5 Onshift Maintenance Support .............................................................5-7 5.4 Onsite Emergency Response Organization ......................................................5-8 5.4.1 Overview.............................................................................................5-8 5.4.2 Direction and Coordination ................................................................5-9 5.4.3 Control Room .....................................................................................5-9 5.4.4 Technical Support Center (TSC) Organization...................................5-9 5.4.5 Operations Support Center (OSC) Organization ..............................5-12 5.5 Near Site Emergency Response Facility ........................................................5-15 5.5.1 Overview ...........................................................................................5-15 5.5.2 Emergency Operations Facility (EOF) Organization........................5-16 5.6 Joint Information Center (JIC) .......................................................................5-18 5.7 Corporate Assistance Center (CAC) ..............................................................5-18 vii

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 5.78 Supporting Emergency Organizations ...........................................................5-19 5.87.1 Letters of Agreement ........................................................................5-19 5.87.2 Medical Emergency Response Organization ...................................5-19 5.87.3 Government Agency Support ...........................................................5-22 5.87.4 Other Support Organizations ............................................................5-28 6.0 EMERGENCY MEASURES ....................................................................................6-1 6.1 Activation of the Emergency Response Organizations....................................6-1 6.1.1 Shift Manager/Control Room Operations ..........................................6-2 6.1.2 Emergency Director ............................................................................6-4 6.1.3 Ottawa and Lucas County Sheriffs' Offices ........................................6-4 6.1.4 Ottawa County and Lucas County Emergency Management Agency Directors ..........................................................6-4 6.1.5 Ohio Emergency Management Agency (OEMA)...............................6-4 6.1.6 Federal Agencies (Other than NRC) ...................................................6-5 6.1.7 Ohio Department of Health.................................................................6-5 6.2 Assessment Actions .........................................................................................6-6 6.2.1 Assessment Actions for an UNUSUAL EVENT................................6-6 6.2.2 Assessment Actions for an ALERT ....................................................6-6 6.2.3 Assessment Actions for a SITE AREA EMERGENCY.....................6-7 6.2.4 Assessment Actions for a GENERAL EMERGENCY ......................6-7 6.3 Mitigative Actions ...........................................................................................6-8 6.4 Protective Actions ............................................................................................6-8 6.4.1 Plant Site Protective Actions ..............................................................6-8 viii

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 6.4.2 Offsite Protective Actions .................................................................6-10 6.4.3 Use of Onsite Protective Equipment and Supplies ...........................6-11 6.4.4 Contamination Control Measures .....................................................6-11 6.4.5 Ingestion Pathway Control Measures ...............................................6-11 6.5 Aid to Affected Personnel..............................................................................6-11 6.5.1 Emergency Personnel Exposure .......................................................6-11 6.5.2 Thyroid Blocking ..............................................................................6-12 6.5.3 Decontamination and First Aid .........................................................6-13 6.5.4 Medical Transportation .....................................................................6-14 6.5.5 Medical Treatment ............................................................................6-14 7.0 EMERGENCY FACILITIES AND EQUIPMENT ..................................................7-1 7.1 DBNPS In-Plant Emergency Facilities ............................................................7-1 7.2 Davis-Besse Administration Building (DBAB) Facilities ...............................7-2 7.3 Near Site Emergency Response Facility..........................................................7-5 7.4 Other Company Emergency Facilities .............................................................7-5 7.5 County and State Emergency Operations Centers ...........................................7-6 7.6 Communications Systems ................................................................................7-7 7.7 Alarms ........................................................................................................... 7-9 7.8 Prompt Notification System...........................................................................7-10 7.9 Assessment Facilities .....................................................................................7-11 7.10 Protective Facilities and Equipment ..............................................................7-17 7.11 First Aid and Medical Facilities .....................................................................7-18 7.12 Damage Control Equipment ..........................................................................7-18 ix

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 8.0 MAINTENANCE OF EMERGENCY PREPAREDNESS .......................................8-1 8.1 Organizational Preparedness............................................................................8-1 8.1.1 Training...............................................................................................8-1 8.1.2 Drills and Exercises ............................................................................8-3 8.1.3 Manager, Regulatory Compliance and Emergency Response ...........8-6 8.1.4 Ottawa County EMA and Lucas County EMA Directors....................................................................................8-7 8.2 Educational Information for the Public............................................................8-8 8.3 Review and Update of the Emergency Plan and Emergency Plan...................8-8 Procedures 8.4 Maintenance and Inventory of Emergency Equipment and Supplies ..............8-9 9.0 REENTRY AND RECOVERY .................................................................................9-1 9.1 Reentry ............................................................................................................9-1 9.2 Recovery ..........................................................................................................9-2 x

DBNPS Emergency Plan Revision XX APPENDICES Appendix Title A Emergency Plan Procedure and Related Document Index and Cross-Reference B Department of Energy Radiological Assistance Program (DOE O 153.1) for Davis-Besse Nuclear Power Station C Letters of Agreement D Supporting Documents (Under Separate Cover)

E DBRM-EMER-1500 A, Davis-Besse Nuclear Power Station Emergency Action Level Basis Document F. Davis-Besse Nuclear Power Station (DBNPS) ERO On-Shift Staffing Analysis Report xi

DBNPS Emergency Plan Revision XX LIST OF TABLES Plan Tables Title Page 1-1 Acronyms ............................................................................................................. 1-11 1-2 Communications Test Frequencies....................................................................... 1-15 2-1 Functional Interrelationships of Response Organizations .................................... 2-7 3-1 Emergency Categories and the Degree of Participation by Various Groups .......................................................................... 3-5 4-1 Operating Mode Applicability.............................................................................. 4-4 5-1 Manpower, Location, and Response Considerations for Emergencies ......................................................................................................... 5-31 6-1 PAGs for the Early Phase of a Nuclear Incident .................................................. 6-15 6-2 Recommended Protective Actions ....................................................................... 6-16 6-3 Representative Shielding Factors from Gamma Cloud Source ............................ 6-17 6-4 Selected Shielding Factors for Airborne Radionuclides....................................... 6-18 6-5 Representative Shielding Factors for Surface Deposited Radionuclides ....................................................................................................... 6-19 6-6 Guidelines for Protection Against Ingestion of Contamination ........................... 6-20 7-1 Radiation Monitoring Instruments and Equipment .............................................. 7-19 8-1 Periodic Training of Emergency Response Personnel ........................................ 8-10 xii

DBNPS Emergency Plan Revision XX LIST OF FIGURES Plan Figures Title Page 2-1 DBNPS General Site Location ............................................................................. 2-8 2-2 DBNPS Site Annual Wind Distributions at the 10 Meter Level .......................... 2-9 2-3 DBNPS 10-Mile Emergency Planning Zone ........................................................ 2-10 2-4 DBNPS 50-Mile Emergency Planning Zone ........................................................ 2-11 5-1 Onshift Emergency Organization ......................................................................... 5-33 5-2 Emergency Response Organization...................................................................... 5-34 6-1 Summary of Typical Emergency Measures ......................................................... 6-22 6-2 Emergency Notification ....................................................................................... 6-26 6-3 Offsite Emergency Evacuation Routes ................................................................. 6-28 7-1 Emergency Facilities by General Location .......................................................... 7-21 9-1 Recovery Organization Framework ..................................................................... 9-7 xiii

1-1 DBNPS Emergency Plan Revision XX 1.0 DEFINITIONS Listed below are terms and their definitions as used in the Emergency Plan. Defined terms associated with the Emergency Action Levels in Appendix E are shown in ALL UPPER CASE LETTERS.

1.1 Affected Person Individual who has been physically injured and/or Radiologically exposed to a degree requiring special attention, as a result of an accident (e.g., first aid, or decontamination).

1.2 ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

1.3 Alternate Technical Support Center (ATSC) - An area within the Lindsey Emergency Response Facility, which has the capability to display and transmit plant status information to individuals who are knowledgeable of, and responsible for engineering and management support of reactor operations in the event of an emergency situation.

1.4 Assembly A process during which personnel report to predetermined locations for the purposes of communication and crowd control. Assembly can occur within the protected area, the OWNER CONTROLLED AREA, or at an offsite location.

1.5 Assessment Actions Those actions taken during or after the accident to obtain and process information necessary to make decisions to implement specific emergency measures.

1.6 Assessment Facility A facility utilized for evaluation of instrumentation data, and other information, to assess the scope and severity of an emergency condition.

1.7 Available Personnel Personnel who have not been assigned specific responsibilities or duties during an emergency situation.

1.8 Company Licensee as described in the Davis-Besse Nuclear Power Station NRC Operating License No. NPF-3.

1.9 Compensatory Indications Plant Process Computer, SPDS, and PI Data (Process Book).

1.10 CONFINEMENT BOUNDARY The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the DBNPS Dry Fuel Storage Facility, CONFINEMENT BOUNDARY is defined as the Dry Shielded Canister (DSC).

1-2 DBNPS Emergency Plan Revision XX 1.11 CONTAINMENT CLOSURE The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

1.12 Contaminated Area An area where removable contamination exists at levels in excess of 1000 dpm/100cm2 beta gamma or 20 dpm/100cm2 alpha.

1.13 Control Room The Davis-Besse Nuclear Power Station Control Room, located in the Auxiliary Building on elevation 623', is the area from which the reactor and its auxiliary systems are controlled.

1.14 Controlled Release Any release of radioactive material from Davis-Besse Nuclear Power Station to the environment, which is planned, deliberate, monitored and regulated.

1.15 Design Basis Accident The maximum credible accident values that can be anticipated given specific physical parameters and which provides the basis for the design of a component or system.

1.16 Dose Projection The calculated estimate of a radiation dose to individuals at a given distance from a potential or actual release (usually offsite), determined from the quantity and type of radioactive material released, and the meteorological transport and dispersion parameters.

1.17 Drill A supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation.

1.18 EMERGENCY ACTION LEVEL (EAL)

A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.

1.19 EMERGENCY CLASSIFICATION LEVEL (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert (A)

Site Area Emergency (SAE)

General Emergency (GE) 1.20 Emergency Operations Facility (EOF)

An area located at 1240 South Main Street, Lindsey, Ohio, which is equipped to facilitate the control and coordination of emergency activities and assessments.

1-3 DBNPS Emergency Plan Revision XX 1.21 Emergency Core Cooling System Engineered safety features system comprised of the Low Pressure Injection, High Pressure Injection, and Core Flood Systems.

1.22 Emergency Operations Center An offsite location used by State, County and other government agencies and organizations to perform radiological assessment and to coordinate offsite activities.

1.23 Emergency Plan The document, which describes the Company philosophy and organization for implementing of regulations dealing with a response to a radiological accident at the Davis-Besse Nuclear Power Station.

1.24 Emergency Plan Procedures Those procedures which implement the Emergency Plan and are maintained by the Emergency Response Section. They include the Emergency Plan Implementing, Off-Normal Occurrence, and Administrative Procedures.

1.25 Emergency Planning Zones Two zones established around a nuclear power station in which predetermined protective action plans are needed. One zone, with a radius of 10 miles for a Plume Exposure Pathway; and the other, with a radius of 50 miles for an Ingestion Exposure Pathway. In these zones, predetermined Protective Action plans are needed.

1.26 EPA PROTECTIVE ACTION GUIDELINES Environment Protection Agency Protective Action Guidelines. The EPA PAGs are expressed in terms of dose commitment: 1 Rem TEDE or 5 Rem CDE Thyroid. Actual or projected offsite exposures in excess of the EPA PAGs requires DBNPS to recommend protective actions for the general public to offsite planning agencies.

1.27 Essential Personnel Those assigned specific emergency response duties as identified in the Emergency Plan.

1.28 Exclusion Area The area surrounding the plant in which the licensee has the authority to determine all activities including the exclusion or removal of persons and property. At the Davis-Besse Nuclear Power Station this area corresponds to the site boundary, a distance varying from 720 meters (approximately 1/2 mile) to approximately 1 mile.

1.29 Exercise An event that tests the integrated capability and a major portion of the basic elements within the Emergency Plan.

1.30 EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an EXPLOSION. Such events may require a post-event inspection to determine if the attributes of an EXPLOSION are present.

1-4 DBNPS Emergency Plan Revision XX 1.31 FACILITY ACTIVATION An Emergency response Facility (ERF) is activated when the minimum staff per Figures 5-2, 5-3 and 5-4 is available and the facility is ready to assume its assigned Emergency Plan functions.

1.311.32 FAULTED The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

1.321.33 FIRE Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred, but is not required if large quantities of smoke and heat are observed.

1.331.34 FISSION PRODUCT BARRIER THRESHOLD A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

1.341.35 FLOODING A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

1.351.36 Full Participation When used in conjunction with emergency preparedness exercises for a particular site means appropriate offsite local and State authorities and licensee personnel physically and actively take part in testing their integrated capability to adequately assess and respond to an accident at a commercial nuclear power plant. Full Participation includes testing major observable portions of the onsite and offsite emergency plans and mobilization of State, local and licensee personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario. (10CFR50, Appendix E, IV.F.2.a) 1.361.37 Functional A system, subsystem, train, component or device, though degraded in condition or configuration is Functional if it is capable of maintaining respective system parameters within acceptable design limits.

1.371.38 GENERAL EMERGENCY Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that result in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

1.381.39 High Radiation Area Any area, accessible to individuals, in which radiation levels could result in an individual receiving in excess of 0.1 rem in one hour at 30 cm from the radiation source or from any surface the radiation penetrates.

1-5 DBNPS Emergency Plan Revision XX 1.391.40 HOSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station.

1.401.41 HOSTILE ACTION An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

1.411.42 HOSTILE FORCE One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

1.421.43 IMMINENT The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

1.431.44 IMPEDE(D)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

1.45 INDEPENDENT FUEL STORAGE INSTALLATION (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

1.46 Ingestion Exposure Pathway The means by which contaminated water or foodstuffs can expose the Population At Risk to radiation. The time of potential exposure could range from hours to months. The principal exposure sources from this pathway are:

Ingestion of contaminated drinking supplies, such as water or milk, Ingestion of contaminated food, such as fresh vegetables or aquatic foodstuffs.

1.47 INITIATING CONDITION (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

1.48 International Great Lakes Datum A place of reference datum set up for use on the Great Lakes. This datum refers to the mean water level at Father Point, Quebec as established in 1955. In 1985, the reference datum was revised upward by 0.57 feet.

1-6 DBNPS Emergency Plan Revision XX 1.49 Joint Information Center A location for coordinating news statements and providing joint briefings to the news media during an emergency. It provides a central point for information to be disseminated to the public by the utility, and federal, state and local officials.

1.50 Loss A state of inoperability in which Functional and Operable status cannot be maintained.

1.51 Low Population Zone The unrestricted area outside the OWNER CONTROLLED AREA, encompassed within a radius of 2 miles (approximately 3200 meters) from the site.

1.52 MAINTAIN Take appropriate action to hold the value of an identified parameter within specified limits.

1.53 Mitigative Actions Emergency measures taken to mitigate or terminate a potential or uncontrolled release of radioactive material or to minimize the consequences of such a release (e.g., shutting down equipment, fighting fire, repair, or damage control).

1.54 Modes of Discharge Discharge of radioactivity to the ground surface, surface water, atmosphere, or any combination thereof.

1.55 News Statement A detailed statement in printed format intended for public knowledge containing an announcement, supporting information, and usually some background information.

1.56 Non-essential Personnel Personnel who are not pre-assigned specific emergency response duties.

1.57 Normal Levels The highest reading in the past twenty-four hours excluding the current peak value.

1.58 Nuclear Group The functional area of the Company which operates and maintains all nuclear generating facilities owned by or licensed to the Company.

1.59 Offsite Any area outside the OWNER CONTROLLED AREA.

1.60 Onsite The area within the OWNER CONTROLLED AREA.

1.61 Operable/Operability A system, subsystem, train, component or device shall be Operable or have Operability when it is capable of performing its specified function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electric power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s), are also capable of performing their related support function(s).

1-7 DBNPS Emergency Plan Revision XX 1.62 Operations Support Center A location within the PROTECTED AREA where emergency response teams are assembled, briefed and coordinated during an emergency.

1.63 OWNER CONTROLLED AREA (OCA)

The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.

1.64 Partial Participation When used in conjunction with emergency preparedness exercises for a particular site means appropriate offsite authorities shall actively take part in the exercise sufficient to test direction and control functions, i.e., a) protective action decision making related to emergency action levels, and b) communication capabilities among affected State and local authorities and the licensee. (10CFR50, Appendix E, IV.F.2.c) 1.65 Personnel Dosimetry Devices designed to be worn or carried by an individual for the purpose of measuring the radiation dose received [e.g., pocket dosimeters, electronic alarming dosimeters (EADs),

thermoluminescent dosimeters (TLDs), etc.].

1.66 Plant Computer System - A computer system that monitors plant performance and displays this information to the plant operator.

1.67 Plume Exposure Pathway The means by which a radioactive cloud (plume) can expose the Population At Risk to radiation. The time of potential exposure could range from hours to days. The principal exposure sources for this pathway are:

Whole body external exposure to gamma radiation from the radioactive plume and from deposited material, Inhalation exposure from the passing radioactive plume.

1.68 Population At Risk Those persons for whom Protective Actions are being or would be taken.

1.69 Projected Exposure Time The estimated period of time that the population in the area surrounding Davis-Besse Nuclear Power Station may be exposed to radiation as a result of an uncontrolled airborne release. Projected Exposure Time starts when the airborne release is estimated to cross the OWNER CONTROLLED AREA, and ends when the radiation levels offsite are expected to return to normal.

1.70 PROJECTILE An object directed toward a nuclear power plant that could cause concern for its continued operability, reliability, or personnel safety.

1.71 PROTECTED AREA An area that normally encompasses all controlled areas within the security protected area fence.

1-8 DBNPS Emergency Plan Revision XX 1.72 Protective Actions Those emergency measures taken after an uncontrolled release has occurred, for the purpose of preventing or minimizing radiological dose to persons that would likely be exposed if the actions were not taken.

1.73 Public Information Hotline A telephone number provided to the public which is available to answer specific questions regarding an emergency. Public Information Hotlines are maintained by the Davis-Besse Nuclear Power Station, the State of Ohio, and both Ottawa and Lucas Counties.

1.74 Radiation Area (RA)

Any area accessible to individuals in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at 30 cm from the radiation source or from any surface the radiation penetrates.

1.75 Radiation Work Permit A document which gives radiation protection requirements, authorization to enter the radiologically controlled area, and permission to receive radiation dose.

1.76 Radiologically Controlled Area (RCA)

Any area to which access is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

1.77 Radiological Testing Laboratory A facility near the Technical Support Center in the Davis-Besse Administration Building which serves as a staging location for Radiation Monitoring Teams, and where a limited amount of radiological counting and analysis of low-level environmental samples may be performed.

1.781.77 RCS INTACT The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

1.791.78 Recovery Actions Those actions taken after an emergency to restore the station as nearly as possible to pre-emergency conditions.

1.801.79 REFUELING PATHWAY The reactor refueling canal, spent fuel pool and fuel transfer canal comprise the REFUELING PATHWAY.

1.811.80 Release A radiological release (airborne or liquid) to the outside environment attributable to the emergency event.

1.821.81 RESTORE Take the appropriate action required to return the value of an identified parameter to the applicable limits.

1-9 DBNPS Emergency Plan Revision XX 1.831.82 RUPTURED The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

1.83 Safety Parameter Display System (SPDS) - A computer system that acquires and displays plant data. This system provides data to Operator Aids and the Emergency Response Data System (ERDS).

1.84 SAFETY SYSTEM A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures 1.85 SECURITY CONDITION Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

1.86 Shift Managers Office A facility that is located within the Control Room envelope. and is used by the Emergency Assistant Plant Manager during emergency conditions to observe and provide guidance to the Shift Manager for direction and control of in-plant activities.

1.87 SITE AREA EMERGENCY Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that result in intentional damage or malicious acts: 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

1.88 SITE BOUNDARY Area as depicted in UFSAR Figure 1.2-12 Site Plan. The SITE BOUNDARY is defined at a minimum exclusion distance of 0.75 miles. This is the nearest distance from potential release points at which protective actions would be required for members of the public.

1.89 State The State of Ohio.

1.90 Technical Support Center (TSC)

An area within the OWNER CONTROLLED AREA, which has the capability to display and transmit plant status information to individuals who are knowledgeable of, and responsible for engineering and management support of reactor operations in the event of

1-10 DBNPS Emergency Plan Revision XX an emergency situation.

1.91 Uncontrolled Release Any release of radioactivity from Davis-Besse Nuclear Power Station to the surrounding environment which can be described by any one or combination of the following terms:

unplanned, unintentional, and unregulated.

1.92 UNISOLABLE An open or breached system line that cannot be isolated, remotely or locally.

1.93 UNPLANNED A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

1.94 UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

1.95 VALID An indication, report, or condition, is considered to be VALID when it is verified by: 1) an instrument channel check, 2) indications on related or redundant indicators, or 3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

1.96 VISIBLE DAMAGE Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

1.97 Vital Equipment Any equipment, system, device and material, the failure, destruction or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.

Equipment or systems which would be required to function to protect the public health and safety following such failure, destruction or release are also considered to be vital.

1-11 DBNPS Emergency Plan Revision XX TABLE 1-1 ACRONYMS AC Alternating Current AFW Auxiliary Feed Water ATSC Alternate Technical Support Center ALARA As Low As is Reasonably Achievable APRM Average Power Range Meter ARM Area Radiation Monitor ATWS Anticipated Transient Without Scram B&W Babcock and Wilcox BWR Boiling Water Reactor BWST Borated Water Storage Tank CA Controls Area (in control room)

CAC Corporate Assistance Center CAM Continuous Air Monitor CANS Computerized Automated Notification System CAS Central Alarm Station CCW Component Cooling Water CDE Committed Dose Equivalent CE Combustion Engineering CFR Code of Federal Regulations CNRB Company Nuclear Review Board CRA Control Rod Assembly CRM Containment Radiation Monitor CSF Critical Safety Function CSFST Critical Safety Function Status Tree CTMT/CNMT Containment CTRM Control Room cpm counts per minute DBAB Davis-Besse Administration Building DBABA Davis-Besse Administration Building Annex DBNPS Davis-Besse Nuclear Power Station DBTC Davis-Besse Training Center DC Direct Current DFSF Dry Fuel Storage Facility DHR Decay Heat Removal DOE Department of Energy DOT Department of Transportation DPM Decades Per Minute dpm disintegrations per minute E&C Electrical and Controls EAL Emergency Action Level EAS Emergency Alert System EC Emergency Coordinator ECCS Emergency Core Cooling System ECL Emergency Classification Level ED Emergency Director

1-12 DBNPS Emergency Plan Revision XX TABLE 1-1 ACRONYMS EEC Energy Education Center EMA Emergency Management Agency ENS Emergency Notification System (NRC "red phone")

EOC Emergency Operations Center EOF Emergency Operations Facility EOP Emergency Operating Procedure EPA Environmental Protection Agency EPG Emergency Procedure Guideline EPIP Emergency Plan Implementing Procedure EPRI Electric Power Research Institute EPZ Emergency Planning Zone ERF Emergency Response Facility ERG Emergency Response Guideline ERO Emergency Response Organization ESF Engineered Safety Feature ESW Emergency Service Water FAA Federal Aviation Administration FBI Federal Bureau of Investigation FE FirstEnergy Corporation FEMA Federal Emergency Management Agency FENOC FirstEnergy Nuclear Operating Company FMT Field Monitoring Team FSAR Final Safety Analysis Report GE General Emergency HPI High Pressure Injection HPCI High Pressure Coolant Injection HPSI High Pressure Safety Injection HPN Health Physics Network IC Initiating Condition I&C Instrument and Control IGLD International Great Lakes Datum IPEEE Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI Independent Spent Fuel Storage Installation ITS Improved Technical Specifications JIC Joint Information Center Keff Effective Neutron Multiplication Factor LCEMA Lucas County Emergency Management Agency LCO Limiting Conditions for Operation LDE Lens Dose Equivalent LER Licensee Event Report LOCA Loss of Coolant Accident LPI Low Pressure Injection LPSI Low Pressure Safety Injection LPZ Low Population Zone LWR Light Water Reactor MFW Main Feed Water (pump) mR milliRoentgen MSIV Main Steam Isolation Valve

1-13 DBNPS Emergency Plan Revision XX TABLE 1-1 ACRONYMS MSL Main Steam Line MSSV Main Steam Safety Valve MU Makeup MU-HPI Makeup High Pressure Injection MW Megawatt MWe Megawatt electric MWt Megawatt thermal NEI Nuclear Energy Institute NESP National Environmental Studies Project NOAA National Oceanographic and Atmospheric Administration NORAD North American Aerospace Defense Command NOUE Notification Of Unusual Event NPP Nuclear Power Plant NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUMARC Nuclear Management and Resources Council OBE Operating Basis Earthquake OCA Owner Controlled Area OCEMA Ottawa County Emergency Management Agency ODCM/ODAM Offsite Dose Calculation (Assessment) Manual OEMA Ohio Emergency Management Agency ORO Offsite Response Organization OSHP Ohio State Highway Patrol OSC Operations Support Center OTSG/SG Steam Generator PA Protected Area PAF Primary Access Facility PAG Protective Action Guide PASS Post Accident Sampling System (see ARCSS)

PNS Prompt Notification System (siren system)

POAH Point of Adding Heat PORV Power Operated Relief Valve PRA/PSA Probabilistic Risk Assessment / Probabilistic Safety Assessment PWR Pressurized Water Reactor PSIG Pounds per Square Inch Gauge R Roentgen RCA Radiologically Controlled Area RCC Reactor Control Console RCDT Reactor Coolant Drain Tank RCIC Reactor Core Isolation Cooling RCS Reactor Coolant System REM Roentgen Equivalent Man REMP Radiological Environmental Monitoring Program RETS Radiological Effluent Technical Specifications RMT Radiation Monitoring Team RP Radiation Protection

1-14 DBNPS Emergency Plan Revision XX TABLE 1-1 ACRONYMS RPS Reactor Protection System RPV Reactor Pressure Vessel RO Reactor Operator RTL Radiological Testing Lab RVLIS Reactor Vessel Level Indicating System RWCU Reactor Water Cleanup RWP Radiation Work Permit SAM Severe Accident Management SAS Secondary Alarm Station SBGTS Stand-By Gas Treatment System SBO Station Blackout SCBA Self-Contained Breathing Apparatus SDE Shallow Dose Equivalent SG Steam Generator SI Safety Injection SPDS Safety Parameter Display System SRO Senior Reactor Operator SSE Safe Shutdown Earthquake STA Shift Technical Advisor TEDE Total Effective Dose Equivalent TOAF Top of Active Fuel TRM Technical Requirements Manual TSC Technical Support Center VPF Visitor Processing Facility UE Unusual Event USAR Updated Safety Analysis Report VDC Volts DC WE Westinghouse Electric WOG Westinghouse Owners Group

1-15 DBNPS Emergency Plan Revision XX TABLE 1-2 COMMUNICATIONS TEST FREQUENCIES Monthly - At least once per calendar month Quarterly - At least once per 92 days Semi-annual - At least once per 6 months Annual - At least once per 12 months

2-1 DBNPS Emergency Plan Revision XX 2.0 SCOPE AND APPLICABILITY The Davis-Besse Nuclear Power Station Emergency Plan has been developed to provide a description of the station's response during emergencies. The description includes organizational control, equipment, supplies, facilities, and protective actions that may be used in mitigating the consequences of an emergency. Emergency Preparedness exists to provide direction for emergencies varying in severity from relatively minor ones with no health and safety implications to events presenting an actual or potential offsite radiological hazard.

This Emergency Plan is a detailed expansion of the Updated Safety Analysis Report, Section 13.3.

It is intended to satisfy the requirements of Title 10 Code of Federal Regulations, Section 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.

Furthermore, this document satisfies the requirements of NUREG 0654/FEMA REP. 1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

This Emergency Plan is not the primary working document to be used during an emergency. The purpose of the Emergency Plan is to describe the program established at DBNPS to satisfy regulatory requirements and to safeguard the public and plant personnel in the event of an emergency.

2.1 Site Description The DBNPS is located on the southwestern shore of Lake Erie in Ottawa County, Ohio, approximately six (6) miles northeast of Oak Harbor, Ohio.

DBNPS employs a pressurized light water reactor steam supply system furnished by the Babcock & Wilcox Co. (now Framatome) to generate approximately 930 MWe. The reactor design core power is 2817 MWt.

The Station encompasses 954 acres, of which more than 700 acres is marsh land. A portion of the marsh land is leased to the U.S. Government as a natural wildlife refuge. The land area surrounding the site is generally agricultural, with no major industry in the vicinity of the site.

The topography in the vicinity of DBNPS is flat, with marsh areas bordering the lake and the upland area rising to only 10-15 feet above the lake low water datum level. The site itself varies in elevation from marsh bottom, below Lake Level, to approximately six feet above the lake low water datum level.

The site has been built up from 6 to 14 feet above the existing grade elevation to an elevation of 584 feet International Great Lakes Datum (IGLD). This provides flood protection from the maximum credible water level conditions of Lake Erie. The three sides of the station with exposure to the lake are provided with a dike to an elevation of 591 feet IGLD to protect the facility from wave effects during maximum credible water level conditions.

2-2 DBNPS Emergency Plan Revision XX The Station structures are located approximately in the center of the site, 3000 feet from the shoreline. This provides a minimum exclusion distance of 2400 feet from any point of the site boundary.

Ohio Route 2 approaches the site from the city of Port Clinton, Ohio, to the southeast, and forms the west boundary of the site. At the north boundary of the site, Ohio Route 2 turns west and proceeds towards Oregon and Toledo, Ohio. Four (4) all-weather roads provide access to the site from Ohio Route 2. Figure 2-1 shows the general site location.

Site meteorological data for 2007 indicates that the prevailing winds at 10 meters above ground level are from the south/southwest. The average wind velocity at this level is 9.42 miles per hour (4.21 meters per second). Figure 2-2 shows the average wind distribution.

The primary source of potable water in the area is Lake Erie. The nearest offsite public potable water intake serves Camp Perry, the Erie Industrial Park, and surrounding residences; and is located approximately 2.8 miles from the site. Another potable water intake, which serves residents of Carroll Township, including Davis-Besse, is located approximately four miles west-northwest of the site. The Ottawa County Regional Water Systems potable water intake is eight miles east of the site. This system serves Port Clinton, Oak Harbor and the eastern end of Ottawa County. The Toledo and Oregon intakes are 13 miles west of the site. Most of the residents in the vicinity of the site not serviced by the municipal water suppliers, either have their water trucked in, or utilize well water which is periodically tested for potability by local authorities. DBNPS personnel periodically test local water sources for radioactivity.

2.2 Population Distribution NOTE: The following information regarding population distribution is for historical purposes only. For current population estimates refer to Davis-Besse Nuclear Power Station Development of Evacuation Time Estimates, Final Report Revision 2, which has been prepared in accordance with NUREG 0654/FEMA Rev.-1, Appendix 4.

The near-site population is distributed from the southeast to the west northwest. The total permanent population in the 10-mile area surrounding DBNPS, based on 2010 Census information is 20,403 people. Approximately 89% of these people live 5 to 10 miles from the site. The population varies seasonally due to tourism in the area and the summer home residents. Figures indicating the permanent and seasonal population distribution projections in the 0 to 2 mile, 2 to 10 mile, and 10 to 50 mile radii are included in Davis-Besse Nuclear Power Station Development of Evacuation Time Estimates, Final Report Revision 2, which has been prepared in accordance with NUREG 0654/FEMA Rev.-1, Appendix 4.

The EPZ permanent resident population is reviewed annually. If at any time during the decennial period the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5- mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the currently NRC approved or updated ETE, Fleet updates the ETE analysis to reflect the impact of that population increase. The updated ETE analysis is submitted to the NRC under 10 CFR 50.4 no later than 365 days after Fleet determines the criteria for updating the ETE have been met and at least 180 days before

2-3 DBNPS Emergency Plan Revision XX using it to form protective action recommendations and providing it to state and local governmental authorities for use in developing offsite protective action strategies.

The nearest population center of 25,000 or more is Toledo, Ohio, 20 miles west-northwest of the site. Other population centers within a 50-mile radius in excess of 25,000 include Bowling Green (33 miles), Findlay (45 miles), Lorain (46 miles), and Sandusky (20 miles) in Ohio; Allen Park (40 miles),

Dearborn (40 miles),

Detroit (40 miles), Inkster (40 miles),

Lincoln Park (40 miles), Monroe (26 miles), Southgate (40 miles), Westland (40 miles),

and Wyandotte (41 miles), in Michigan; and Windsor (50 miles) in Ontario, Canada.

2.3 Emergency Planning Zones In defining the Emergency Planning Zones (EPZs) for the DBNPS, factors such as organizational capabilities, method of implementing the emergency plan, and the availability of onsite and offsite emergency facilities and equipment have been taken into consideration.

Two primary zones have been identified for development of emergency planning and implementation of the Plan. One zone has a 10-mile radius. This EPZ is referred to as the Plume Exposure Planning Zone. Within this zone, evacuation or sheltering may be recommended for the general public. The principal concern in the 10-mile EPZ is direct exposure from a passing plume and/or inhalation of radionuclides from the plume. This 10-mile EPZ is comprised of part of Ottawa County and part of Lucas County.

The second zone, the Ingestion Exposure Planning Zone, extends to a 50-mile radius. The principal concern in the 50-mile EPZ, or Ingestion Pathway EPZ, is long-term exposure from ingested material. Within the Ingestion Pathway EPZ, close monitoring of water, crops, dairy cows and farm animals may be necessary. It may also be necessary to segregate and/or remove contaminated items from the food chain (e.g., milk, fresh vegetables, etc.). This 50-mile EPZ is comprised of all of Ottawa, Lucas, Wood, Sandusky, Erie, Seneca, Huron, Lorain, Fulton, Henry, Crawford, Hancock, and Wyandot Counties in Ohio; and all of Monroe, Lenawee, Washtenaw and Wayne Counties in Michigan. Essex County and part of Kent County within the province of Ontario, Canada are also contained within this 50-mile Emergency Planning Zone.

Figures 2-3 and 2-4 show the 10-mile and 50-mile EPZs.

2.4 Regulatory Requirements 2.4.1 The Code of Federal Regulations contains requirements for emergency planning in the following sections:

a. 10 CFR 50.34 Contents of applications; technical information.

b. 10 CFR 50.33 Contents of applications; general information.

c. 10 CFR 50.47 Emergency Plans.

d. 10 CFR 50.54 Conditions of Licensee.

e. 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.

2-4 DBNPS Emergency Plan Revision XX 2.4.2 Supplemental guidance has been provided by the Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA) in NUREG-0654/FEMA-REP-1, REV. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants and in NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 6, and NRC Revised Table B-1, dated June 2018 (ML18022A352).

These documents describe methods acceptable for compliance with regulations regarding nuclear power plant emergency plans.

2.5 Objectives of Emergency Response 2.5.1 The objective of the Emergency Response Section is to provide for public protection in the event of an emergency at DBNPS by establishing a well-trained and technically competent emergency organization, and to provide that organization with the necessary facilities, equipment, supplies and communication links.

2.5.2 Objectives of the Emergency Plan

a. To outline the most effective course of action required to safeguard the public and station personnel in an emergency.

b. To establish an emergency organization.

c. To assign responsibilities for directing the response to an emergency condition or radiological incident.

d. To provide for procedures that will limit the consequences of the incident.

e. To provide for procedures that will terminate or mitigate the radiological consequences of an emergency, both onsite and offsite.

f. To control onsite and offsite surveillance activities.

g. To establish procedures to identify and classify the emergency condition.

h. To stipulate the necessity for public protection actions.

i. To establish procedures to implement any protective actions deemed appropriate.

j. To provide for the training of all emergency response personnel.

k. To describe emergency facilities and their use.

l. To describe emergency communication systems and their use.

2.6 Emergency Plan Interrelationships Interrelationships of this plan with procedures, other plans, and emergency arrangements are summarized as follows:

2.6.1 Detailed actions to be taken by individuals in response to onsite emergency conditions are described in the Emergency Plan Implementing Procedures. These procedures provide the mechanisms for response as outlined in this plan.

2-5 DBNPS Emergency Plan Revision XX 2.6.2 The DBNPS Physical Security Plan and Procedures and this plan are coordinated to ensure that appropriate emergency actions can be taken. For example, the Physical Security Plan and Procedures contain provisions for emergency response personnel and vehicle access when required by the Emergency Plan Procedures.

2.6.3 Davis-Besse site contractors/vendors that develop emergency procedures for their personnel are tasked with coordinating their procedures and this plan.

2.6.4 The DBNPS Radiation Protection Administrative Procedures and Radiation Protection Nuclear Operating Procedures define administrative controls and procedures such as radiological control limits and precautions, use of personnel monitoring devices, use of protective clothing and equipment, personnel decontamination, etc. Additionally, Chemistry Procedures and Radiation Protection Procedures provide instructions for conducting surveys, analyzing samples, operating health physics/radiation protection equipment, etc. Information and details provided in these documents have either been incorporated into the Plan and/or Emergency Plan Procedures or have been appropriately referenced.

2.6.5 The DBNPS has established Off Normal Occurrence Procedures, which discuss generic emergencies such as floods, icing, and severe weather conditions. The methods and equipment developed for such emergencies are available for use in responding to emergencies covered by this plan.

2.6.6 Formal agreements have been negotiated to define the coordination and interface with offsite organizations and agencies having related radiological emergency planning responsibilities. Continuing liaison with the offsite organizations ensures compatibility and proper interfacing with this plan. Refer to Table 2-1, "Functional Interrelationships of Response Organizations", for functional interrelationships of emergency response organizations.

2.6.7 Other offsite organizations, not within the immediate area, may also be requested to offer technical assistance (i.e., Institute of Nuclear Power Operations, Framatome, Bechtel, etc.).

2.7 Emergency Plan Procedures, Station Procedures and Fleet Business Practice Detailed Emergency Plan Procedures direct the implementation of this Emergency Plan.

Detailed Station procedures prescribe appropriate courses of action necessary to place the plant in a safe condition and limit the consequences for each classification of incident and/or emergency. Other Emergency Plan Procedures and a Fleet business practice detail maintenance of the Emergency Preparedness Program, Off Normal Occurrence Procedures (i.e. floods, tornadoes, etc.), Fleet emergency response support, and Public Relations. An index of these procedures and Fleet business practices are attached as Appendix A to this plan.

2-6 DBNPS Emergency Plan Revision XX 2.8 Participating Governmental Agencies Participating governmental agencies whose emergency plans are interrelated with this plan for action include the following:

2.8.1 State of Ohio, The Ohio Radiological Emergency Preparedness Plan, which includes the Ohio Radiological Emergency Preparedness (REP) Operations Manual and Ohio Emergency Operations Plan, Emergency Support Function #10, Hazardous Materials, Tab B - REP Incident Response Plan.

2.8.2 Ottawa County, The Ottawa County Radiological Emergency Response Plan 2.8.3 Lucas County, The Lucas County Radiological Emergency Response Plan 2.8.4 Erie County, Radiological Emergency Response Procedures Document 2.8.5 Sandusky County, Radiological Emergency Response Procedures Document 2.8.6 U.S. Department of Energy, Chicago Operations Office, Argonne, IL., Emergency Planning and Preparedness and Response Program 2.8.7 U.S. Nuclear Regulatory Commission, Region III, Lisle, IL 2.8.8 State of Michigan, Michigan Emergency Preparedness Plan 2.8.9 Federal Emergency Management Agency (FEMA) Plan, Region V.

The development of the State and County Plans and the DBNPS Emergency Plan have been closely coordinated. In addition, specific State requirements for reporting of emergencies, providing information and data, recommending protective actions, etc., have been integrated directly into the Emergency Plan Procedures.

2-7 DBNPS Emergency Plan Revision XX Table 2-1 FUNCTIONAL INTERRELATIONSHIPS OF RESPONSE ORGANIZATIONS DAVIS-BESSE RESPONSE FUNCTION RESPONSE ORGANIZATION(S)

Plant Operation Control R Control Room / Technical Support Center Engineering Assessment R Technical Support Center Meteorological Data A Emergency Operations Facility Protective Response A R A Emergency Operations Facility Command & Control of Emergency Response R A Control Room / TSC / Emergency Operations Facility Warning R A A Control Room Notification & Communication A R A A Control Room / TSC / EOF Public Information R A A Joint Information Center Accident Assessment A R Technical Support Center Public Health & Sanitation A R A Emergency Operations Facility Social Services R A A Emergency Operations Facility Fire & Rescue R Control Room Emergency Medical Services A R Control Room Traffic Control R A Nuclear Security Law Enforcement R A A Nuclear Security Transportation R Emergency Operations Facility Radiological Exposure Control A R A Technical Support Center / Emergency Operations Facility LEGEND: R=Task Responsibility A=Task Assistance LOCAL STATE FEDERAL ENGINEERING SUPPORT Ottawa County EMA Ohio EMA US NRC Region III Framatome Ottawa County Sheriff Ohio Department of US DOE Bechtel Power Corp.

Ottawa County Health Department Transportation US EPA Ottawa County Engineer Ohio EPA FEMA OTHER SUPPORT Carroll Township Fire & EMS Ohio State Highway Patrol US Coast Guard American Nuclear Insurers Lucas County EMA Ohio National Guard National Weather Nuclear Mutual Limited Lucas County Sheriff Ohio Department of Health Service Lucas County Health Department Ohio Department of Federal Radiological Lucas County Engineer Natural Resources Monitoring and H.B.Magruder Hospital Assessment Center ProMedica Memorial Hospital Mercy St.Charles Hospital

2-8 DBNPS Emergency Plan Revision XX Figure 2-1 DBNPS General Site Location

2-9 DBNPS Emergency Plan Revision XX Figure 2-2 DBNPS Site Annual Wind Distributions At the 10 Meter Level

2-10 DBNPS Emergency Plan Revision XX Figure 2-3 DBNPS 10-Mile Emergency Planning Zone

2-11 DBNPS Emergency Plan Revision XX Figure 2-4 DBNPS 50-Mile Emergency Planning Zone DETROIT LAKE ST CLAIR WINDSOR ANN ARBOR 50 N

40 30 MONROE 20 LAKE ERIE MICHIGAN CANADA 10 OHIO Davis Besse OREGON UNITED STATES TOLEDO OAK HARBOR PORT CLINTON VERMILLION LORAIN SANDUSKY HURON BOWLING GREEN ELYRIA FREMONT BELLEVUE NORWALK FOSTORIA TIFFIN WILLARD FINDLAY

3-1 DBNPS Emergency Plan Revision XX 3.0

SUMMARY

OF THE EMERGENCY PLAN The DBNPS Emergency Plan has been established in accordance with the requirements of 10 CFR 50.47 and Appendix E to 10 CFR 50, supplemented by the guidance issued by the Nuclear Regulatory Commission in NUREG-0654/ FEMA-REP-1 and other documents.

The Emergency Plan will be put into effect whenever a radiological emergency or other potentially hazardous situation is identified. The details of the Emergency Plan Procedures are not included herein, but a description of the scope of the procedures demonstrates that appropriate actions can be taken by DBNPS and other support agencies to protect station personnel and the general public during emergencies.

The Emergency Plan establishes the concepts, evaluation and assessment criteria, and protective actions that are necessary in order to mitigate the consequences of radiological emergencies. The plan provides for the necessary prearrangements, directions, and organization needed to safeguard station personnel, and the property and safety of the general public.

3.1 Emergency Plan Steps In general, the Emergency Plan encompasses the following basic steps:

a) Recognition of the emergency b) Classification of the emergency c) Required notifications and activation of the responding organization(s) d) Ongoing assessment of the situation e) Periodic dissemination of updated information f) Determination and initiation of protective actions g) Determination and initiation of mitigative actions h) Aid to affected persons i) Reentry and Recovery During response to an emergency, several of the steps may be performed concurrently.

3.2 Emergency Organizations This document establishes an organization capable of responding to the complete range of incidents covered herein.

Provisions are made for rapid mobilization of the response organization and for expanding the response organization if the situation dictates.

An individual with the authority and responsibility to initiate any emergency actions under the provisions of this Emergency Plan, including the release of information to the public/media, is onsite at all times. The Shift Manager assumes this authority by becoming the Emergency CoordinatorDirector upon initial classification of an emergency. If the Shift Manager cannot assume these duties, authority is delegated to the Unit Supervisor or Shift Engineer (Shift Technical Advisor) in that order. The Emergency Plant Manager or Emergency Assistant Plant Manager may assume the Emergency Director position upon arrival in the Control Room. The Emergency Plant Manager may also assume the Emergency Director duties from the Technical Support Center. The designated Emergency

3-2 DBNPS Emergency Plan Revision XX Director, upon arrival in the Emergency Operations Facility (EOF) or Technical Support Center (TSC), will assume this authority.

The operating shift crew is responsible for implementing emergency procedures in accordance with assigned response functions. Emergency response functions are also assigned to off-shift plant staff personnel who can be rapidly alerted and mobilized, to augment or relieve the operating shift personnel of emergency duties.

If required, additional support is provided by the Fleet Emergency Response Organization.

Fleet emergency response management and their staff may provide technical, administrative, and logistical support to the onsite Emergency Organization. They may authorize emergency expenditures, coordinate the efforts of offsite support organizations, and maintain the flow of information to the public.

In addition, this plan includes the use of offsite agencies and organizations that have signed letters of agreement with the DBNPS. Their designated response functions include implementation of offsite protective actions, transportation and treatment of personnel, control of access to the station, fire fighting support, radiological sampling and assessment, technical consultation, and testing. These offsite agencies and organizations include the following:

3.2.1 State of Ohio The Ohio Emergency Management Agency (OEMA), Department of Public Safety, State of Ohio, is the lead planning agency for developing state nuclear incident plans for licensed nuclear facilities contiguous to and within the State.

The specific tasks and responsibilities assigned to several departments and agencies of the State of Ohio are specified in the Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan.

The OEMA is notified at the declaration of an emergency via dedicated telephone from the Control Room or EOF. Once notified, the OEMA will implement its Nuclear Incident Accident Call List as specified in the State of Ohio plan.

3.2.2 Ottawa County, Ohio The lead agency for county-wide emergency planning is the Ottawa County Emergency Management Agency. Responsibilities for various county agencies and organizations are described in Section II, The Ottawa County Radiological Emergency Response Plan.

The Ottawa County EMA is notified at the declaration of an emergency via dedicated telephone in the Control Room or EOF. Once notified, Ottawa County will implement its emergency plan as appropriate.

3-3 DBNPS Emergency Plan Revision XX 3.2.3 Lucas County, Ohio The lead agency for county-wide emergency planning is the Lucas County Emergency Management Agency. Responsibilities for various municipal and county agencies and organizations are delineated in The Lucas County Radiological Emergency Response Plan.

The Lucas County EMA is notified at the declaration of an emergency via dedicated telephone in the Control Room or EOF. Once notified, Lucas County will implement its emergency plan as appropriate.

3.2.4 Erie County, Ohio The Erie County Emergency Management Agency acts as the lead agency within Erie County for evacuees from Ottawa County. Responsibilities for the individual agencies are contained in the Erie County Radiological Emergency Response Procedures Document.

The Erie County EMA is notified of an emergency by the Ottawa County EMA, and/or the Ottawa County Sheriff. Once notified, Erie County will implement its Standard Operating Procedures as appropriate.

3.2.5 Sandusky County, Ohio The Sandusky County Emergency Management Agency acts as the lead agency within Sandusky County for evacuees from Ottawa County. Responsibilities for the individual agencies are contained in the Sandusky County Radiological Emergency Response Procedures Document.

The Sandusky County EMA is notified of an emergency by the Ottawa County EMA, and/or the Ottawa County Sheriff. Once notified, Sandusky County will implement its Standard Operating Procedures as appropriate.

3.2.6 State of Michigan In Michigan, the Emergency Services Branch of the Department of State Police is the lead agency for the preparation, coordination, and implementation of the Michigan Emergency Preparedness Plan. As such, they are prepared to mitigate the effects of an incident at Davis-Besse, which may extend to the State of Michigan through the ingestion exposure pathway (50-mile EPZ).

The Ohio EMA will notify the State of Michigan should the need arise. Michigan, under conditions specified in a letter of agreement with the State of Ohio, will provide necessary emergency response within the State of Michigan.

3-4 DBNPS Emergency Plan Revision XX 3.2.7 Federal Agencies

a. U.S. Nuclear Regulatory Commission (NRC), Region III, Lisle, Illinois.

b. U.S. Department of Energy, Chicago Operations Office, Argonne, Illinois.

c. Federal Emergency Management Agency (FEMA), Region V, Main Office

- Chicago, Illinois.

3.3 Emergency Categories Emergencies are grouped into four categories. From least to most severe they are:

3.3.1 UNUSUAL EVENT 3.3.2 ALERT 3.3.3 SITE AREA EMERGENCY 3.3.4 GENERAL EMERGENCY Section 4.0, Emergency Conditions, contains a more detailed discussion of the categories of emergencies. Table 3-1, depicts participation by onsite and offsite organizations for each category of emergency.

TABLE 3-1 EMERGENCY CATEGORIES AND THE DEGREE OF PARTICIPATION BY VARIOUS GROUPS Participation Necessity By Various Organizations for Emergency Protective Actions Mitigative DBNPS Offsite Category Onsite Offsite Actions1 Onsite Fleet Support Agencies Unusual Possible None Possible Notification Notification Notification Event Status2 Status Status Alert Possible Possible Possible Action Standby Standby Status3 Status3 Site Area Required Possible Probable Action Action Action Emergency General Required Required Required Action Action Action Emergency

¹Action might include local fire support, ambulance service, medical assistance, or radiological assessment.

²Notification Status: Organization informed of situation onsite.

³Standby Status: Organization staffs preplanned centers, establishes communications, and assembles emergency teams, as required.

4-1 DBNPS Emergency Plan Revision XX 4.0 EMERGENCY CONDITIONS 4.1 Emergency Classification Levels (ECLs)

The Davis-Besse Nuclear Power Station Emergency Plan emergencies are divided into four Emergency Classification Levels (ECLs): GENERAL EMERGENCY, SITE AREA EMERGENCY, ALERT, and UNUSUAL EVENT.

The ECLs are arranged from most severe to least severe according to relative threat to the health and safety of the public and emergency workers. An ECL is determined to be met by identifying abnormal conditions and then comparing them to INITIATING CONDITIONS (ICs) through EMERGENCY ACTION LEVELS (EAL) and Fission Product Barrier (FPB) threshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached. Emergency Plan, Section 6.0, Emergency Measures, summarizes the emergency measures to be taken by both the Onsite and corporate emergency response organizations.

4.1.1 GENERAL EMERGENCY Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

4.1.2 SITE AREA EMERGENCY Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts: 1) toward site personnel or equipment that could lead to the likely failure of or, 2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

4.1.3 ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

4.1.4 UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

4-2 DBNPS Emergency Plan Revision XX 4.1.5 RECOVERY Recovery may be entered prior to returning to a normal organization and operation.

Recovery provides dedicated resources and organizational structure in support of restoration and communication activities following the termination of the emergency event. Recovery phase is discussed in Section 9.0 of the Emergency Plan.

4.2 EMERGENCY CLASSIFICATION The Davis-Besse Nuclear Power Station maintains the capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications that an EAL has been exceeded. The 15-minute criterion commences when plant instrumentation, plant alarms, computer displays, or incoming verbal reports that correspond to an EAL first become available to any plant operator.

4.3 INITIATING CONDITION (ICs)

The INITIATING CONDITION (IC), EMERGENCY ACTION LEVELS (EALs) and the Fission Product Barrier (FPB) matrix with their related basis information are located in Appendix E of the Emergency Plan. The ICs provide a general description of emergency conditions that are organized beneath the broader categories of the ECLs. The IC can be a continuous, measurable function that is outside Technical Specifications, or encompass events such as FIRES or system/equipment failures.

Each IC is given a unique identification code consisting of four characters. The first character (letter) identifies the recognition category, the second character (letter) identifies the ECL, the third character (number) identifies the subcategory, and the fourth character (number) identifies the numerical sequence within the subcategory.

4.3.1 Recognition Category Codes F designates Fission Product Barrier Degradation R designates Abnormal Rad Levels / Rad Effluent H designates Hazards and Other Conditions Affecting Plant Safety S designates System Malfunctions C designates Cold Shutdown / Refueling System Malfunction E designates Dry Fuel Storage Facility (DFSF) 4.3.2 Emergency Classification Level (ECL) Codes G designates GENERAL EMERGENCY S designates SITE AREA EMERGENCY A designates ALERT U designates UNUSUAL EVENT The specific details on Initiating Conditions and their use are found in RA-EP-01500, Emergency Classification. The basis for the Emergency Action Levels is contained in

4-3 DBNPS Emergency Plan Revision XX Appendix E, DBRM-EMER-1500 A, Davis-Besse Emergency Action Levels Basis Document.

4.4 EMERGENCY ACTION LEVELS (EALs) and Fission Product Barriers (FPBs)

EMERGENCY ACTION LEVELS (EALs) are predetermined, site specific, observable conditions within the ICs that place the state of the plant in a given ECL (Reference Emergency Plan, Appendix E).

EALs are individually identified by the IC identification code followed by the EAL number, such as RG1.1 for major effluent release or HU3.1 for tornado.

Fission Product Barriers (FPBs) are given unique character identification codes and are further subdivided into Loss and Potential loss categories. Meeting or exceeding one or more FPB can result in various ECLs. The first two letters simply identify the particular barrier by abbreviation. The letter in the FPB identification code associates it with a particular FPB recognition category. The FPB identification codes are developed as follows:

4.4.1 Barrier Abbreviation Codes FC designates FUEL CLAD RC designates REACTOR COOLANT CT designates CONTAINMENT 4.4.2 Fission Product Barriers (FPBs) Recognition Categories Codes A designates RCS or SG Tube Leakage B designates Inadequate Heat Removal C designates CT Radiation / RCS Activity D designates CT Integrity or Bypass E designates ED Judgment Fission Product Barrier Thresholds are listed within each Fission Product Barrier Category and are identified by a sequential number.

FPBs are treated the same as EALs in that they exist only as long as the condition(s) for loss or potential loss exist, as opposed to ECLs which once declared, remain in place until termination or recovery.

For EALs that contain time imbedded criterion, the Emergency CoordinatorDirector should not wait until the applicable time period has elapsed but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

4-4 DBNPS Emergency Plan Revision XX 4.4.3 Operating Mode Applicability For purposes of event classification, the following operating mode applicability definitions establish the conditions when the EAL or FPB thresholds represent a threat:

TABLE 4-1 Operating Mode Applicability Reactivity % Rated Average Coolant Mode Condition, Keff Thermal Power* Temperature

1) Power Operation 0.99 > 5% N/A

2) Startup 0.99 5% N/A

3) Hot Standby < 0.99 N/A 280° F

4) Hot Shutdown < 0.99 N/A 280° F > Tavg > 200° F

5) Cold Shutdown < 0.99 N/A 200° F

6) Refueling One or more vessel head closure bolts less than fully tensioned.

D) Defueled All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage).

Excluding decay heat.

The Operating Mode Applicability table is based on the Technical Specifications definition of Operational Mode. ICs are based on the operating mode that exists at the time the event occurred, prior to any protective system or operator action initiated in response.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the FPB threshold values are applicable only to events that initiate in Hot Shutdown or higher.

If there is a change in operating mode following an event declaration, any subsequent events involving EALs outside of the current declaration escalation path will be evaluated on the mode of the plant at the time the subsequent events occur.

4.4.4 Treatment of Multiple Events and Classification Level Upgrading When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. For example, two ALERTS remain in the ALERT category; or, an ALERT and a SITE AREA EMERGENCY is a SITE AREA EMERGENCY.

Although the majority of the EALs provide very specific thresholds, the Emergency

4-5 DBNPS Emergency Plan Revision XX CoordinatorDirector must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the Emergency CoordinatorDirector, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded. While this is particularly prudent at the higher emergency classification levels (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels. Figure 6-1 illustrates the scheme for upgrading emergency classification based on current conditions.

4.4.5 Emergency Classification Level Downgrading Another important aspect of usable EAL guidance is the consideration of what to do when the risk posed by an emergency is clearly decreasing. A combination approach involving recovery from a GENERAL EMERGENCY and some SITE AREA EMERGENCIES and termination from UNUSUAL EVENTS, ALERTS, and certain SITE AREA EMERGENCIES causing no long term plant damage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications but may have merit under certain circumstances. Figure 6-1 illustrates the options for downgrading or termination of events based on current plant conditions. Recovery phase is discussed in Section 9.2.

4.4.6 Classifying Transient Events For some events, the condition may be corrected before a declaration has been made.

The key consideration in this situation is to determine whether or not further plant damage occurred while the mitigative actions were being taken. In some situations, this can be readily determined, in other situations, further analyses (e.g., coolant radiochemistry sampling) may be necessary. Classify the event as indicated and terminate the emergency once assessment shows that there were no consequences from the event and other termination criteria are met.

Existing guidance for classifying transient events addresses the period of time of event recognition and classification (15 minutes). However, in cases when EAL declaration criteria may be met momentarily during the normal expected response of the plant, declaration requirements should not be considered to be met when the conditions are a part of the designed plant response, or result from appropriate operator actions.

There may be cases in which a plant condition that exceeded an EAL was not recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review), and the condition no longer exists. In these cases, an emergency should not be declared.

Reporting requirements of 10 CFR 50.72 are applicable and the guidance of NUREG-1022, Event Reporting Guidelines, 10 CFR 50.72 and 50.73, should be applied.

5-1 DBNPS Emergency Plan Revision XX 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES In planning for emergencies the availability of the normally present operating staff, augmented by support from other utility personnel and offsite support agencies, is considered. The initial phase of an emergency at DBNPS will involve a relatively small number of individuals. Augmented resourcesThese individuals will be capable of: (1) determining that an emergency exists, (2) providing initial classification and assessment, (3) promptly notifying other groups and individuals in the emergency organization, and (4) performing actions immediately necessary to protect site personnel and the public. The follow-on phases of an emergency situation may require an increasing augmentation of the emergency organization. In the case of an ALERT or higher SITE AREA EMERGENCY or a GENERAL EMERGENCY, this will result in the mobilization of the Emergency Response Organization (ERO)all personnel resources of the Company, under the direction of a Senior Company Officer.

This section of the Emergency Plan addresses the assignment of personnel and the establishment of responsibilities and authority for the:

5.1 DBNPS Organization 5.2 DBNPS Emergency Management 5.3 Onshift Emergency Response Organization 5.4 Onsite Emergency Response Organization 5.5 Near Site Emergency Response Organization 5.6 Joint Information Center (JIC) 5.7 Corporate Assistance Center (CAC) 5.78 Supporting Emergency Organizations 5.1 DBNPS Organization Daily operating and engineering activities at DBNPS are under the control of the Vice President - Nuclear.

DBNPS has engineering service contracts with the Nuclear Steam Supply System (NSSS) supplier and the Architect-Engineer. Organizational structure and communication arrangements exist to assure that these services are available and can be obtained in a timely manner.

5.1.1 Plant Management and Administrative Organization The General Plant Manager directs and supervises all operating, administrative, technical and maintenance activities in connection with the continuous, efficient and safe operation of the DBNPS.

To support the General Plant Manager, an administrative organization has been established. Responsibilities have been assigned for the various aspects of station operation.

5-2 DBNPS Emergency Plan Revision XX 5.1.2 Onshift Operations Group The Normal Onshift Operations Group at the Davis-Besse Nuclear Power Station maintains the capability at all times to perform the emergency detection, classification, and notification functions required in the early phases of an incident.

These capabilities are augmented, as required, by the Onsite Emergency Response Organization and the Fleet Emergency Response Organization.

The Onshift Operations Group conforms with ANSI N18.1 and includes both management and operating personnel. Figure 5-1, Onshift Emergency Organization, shows the functional levels. The Onshift Maintenance Support Organization maintains a 24-hour shift rotation. The shift includes persons from the Mechanical, Electrical, and Instrument and Control Maintenance Sections.

These personnel form the initial nucleus staff of the OSC. Other cContinuous duty, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s-per-day organizations include Plant Operations, Chemistry, Radiation Protection and Security. Additional Maintenance personnel and the various Engineering organizations are onsite during normal work hours, Monday through Friday, excluding holidays.

5.1.3 Normal Plant Shift Staffing The plants operating staff meets or exceeds the requirements of Technical Specification 5.2.2 and Technical Requirements Manual 10.2.1. Table 5-1 MANPOWER, LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES, A. ONSHIFT MINIMUM STAFFING REQUIREMENTS describes the minimum on shift staffing utilized to support the emergency plan.

In addition, the plant is continuously manned with a minimum shift complement consisting of the following:

1 Chemistry Tester 1 Radiation Protection Technician 5 Fire Brigade Members (may have other assignments)

Nuclear Security Force

safeguards information An established duty roster system provides access to plant management 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day.

Table 5-1 specifies minimum shift requirements as prescribed by NUREG-0654, Revised Table B-1.

The Shift Manager directs the onshift personnel operating the station and verifies that their work is performed according to approved procedures. Ultimate authority for directing all phases of plant operations always lies with the Shift Manager. The Shift Manager becomes the Emergency CoordinatorDirector upon classification of an emergency at DBNPS.

A Unit Supervisor, who is assigned to each shift during power modes, assists the Shift Manager by following his directives in supervising employees engaged in controlling the operations of the Nuclear Steam Supply System, Turbine Generator, and other station equipment. During an emergency, the Unit Supervisor may also direct employees to function as emergency maintenance personnel or to assist fire

5-3 DBNPS Emergency Plan Revision XX brigade team members. The Unit Supervisor assumes the role of Shift Manager, including Emergency CoordinatorDirector duties, should the Shift Manager become incapacitated.

A Shift Engineer (Shift Technical Advisor) is normally assigned to the shift to relieve the Shift Manager of administrative responsibilities, such as coordination of maintenance schedules, establishment of short term objectives for plant operation and review of documentation. In addition, the Shift Engineer (Shift Technical Advisor) also provides the additional technical and analytical capability needed in the Control Room, during all operating modes except refueling and cold shutdown, to support the diagnosis of off-normal events. If available, tThe Shift Engineer (Shift Technical Advisor) serves as the technical assistant to the Shift Manager in analyzing and mitigating such events, and may perform dose assessment calculations during emergencies. The Shift Engineer (Shift Technical Advisor) may serve as the Emergency CoordinatorDirector if both the Shift Manager and the Unit Supervisor are incapacitated. Under certain circumstances, the Shift Engineer (Shift Technical Advisor) position may be filled by an onshift Senior Reactor Operator assigned another function, such as Shift Manager.

The Security Shift Supervisor is responsible for coordinating the functions of the station security forces, and the operation and testing of security-related equipment.

A Security Shift Supervisor will be onsite at all times.

5-4 DBNPS Emergency Plan Revision XX 5.2 DBNPS Emergency Management In the event of a declared ALERT or higher level emergency, the TSC, OSCOnsite and EOFNear Site Emergency Response Organization (ERO) shall be activated. The individuals responsible for managing the emergency are the TSC Emergency CoordinatorDirector, EOF Emergency DirectorOffsite Manager, Emergency Plant Manager and the Company Spokesperson.

5.2.1 Emergency Coordinator (EC) and Emergency Director (ED)

a. The SM/Emergency CoordinatorDirector is the senior individual on-shiftin the onsite ERO responsible for the coordination of the initialoverall response to any emergency at the DBNPS. During such an emergency, the Emergency CoordinatorDirector will coordinate and direct the emergency response from the Control Room until relieved of EC duties by the Emergency Coordinator in the Technical Support Center (TSC) and the Emergency Director (ED) in the , or the Emergency Operations Facility (EOF).

The following are non-delegable responsibilities of the SM/Emergency CoordinatorDirector:

1. Emergency Classification

2. Offsite Protective Action Recommendation

3. State/local and Federal Notification

4. Emergency dose authorizations in excess of 10 CFR 20 limits

5. Onsite administration of Potassium Iodide (KI)

3. Compliance with station procedures

4. Safety and well being of station personnel

5. Ordering a station general evacuation Responsibilities that the SM/Emergency CoordinatorDirector transfers to the TSC Emergency Coordinator may delegate to the Emergency Plant Manager only are:

1. 1. Emergency Classification

2. NRC Notifications

3. Emergency dose authorizations in excess of 10 CFR 20 limits, and

42. Onsite administration of Potassium Iodide (KI).

b. Responsibilities that the SM/Emergency Coordinator transfers to the EOF Emergency Director are:

1. State/local Notifications 2, Protective Action Recommendations

3. Dose Assessment

c. Transfer of command and control functions from the CR to the TSC and EOF are depicted in the diagram below.

5-5 DBNPS Emergency Plan Revision XX CONTROL ROOM TSC EOF SM/Emergency Emergency Emergency Coordinator Coordinator Director Classification Classification Notifications Notifications (State/local) (State/local)

(Federal) Notifications (Federal)

PARs PARs Emergency Exposure Emergency Exposure Controls Controls Transition of Command and Control Functions

b. Reporting directly to the Emergency Director are:

1. Emergency Offsite Manager

2. Emergency Plant Manager

3. Company Spokesperson

4. Emergency Director Advisor

c. In the absence of the Emergency Director, one of the following positions will assume the duties and responsibilities of the Emergency Director:

1. Emergency Plant Manager

2. Emergency Assistant Plant Manager

3. Shift Manager

4. Unit Supervisor

5. Shift Engineer (Shift Technical Advisor)

During the initial phase of the emergency, the Shift Manager will be the Emergency Director until relieved by the designated Emergency Director or the Emergency Plant Manager. The Emergency Plant Manager may assume the Emergency Director duties from the TSC, in the absence of the designated Emergency Director. In the absence of the Emergency Plant Manager and the Emergency Director, the Shift Manager may be relieved by the Emergency Assistant Plant Manager upon arrival in the Control Room. However, to relieve the Shift Manager of the Emergency Director's duties, the Emergency Assistant Plant Manager must be in the Control Room.

5-6 DBNPS Emergency Plan Revision XX 5.2.2 Emergency Offsite Manager The Emergency Offsite Manager reports directly to the Emergency Director. The Emergency Offsite Manager's primary responsibility is the overall operation of the EOF including:

a. Coordination of radiological dose assessment activities and protective action recommendations.

b. Control and coordination of communication and interface with corporate, offsite and regulatory agencies.

c. Tracking parameters associated with EALs for radiological releases.

d. Making recommendations to the Emergency Director concerning appropriate offsite protective actions, and/or changes to the emergency classification level.

e. Interfacing with the Emergency Plant Manager, Company Spokesperson, and regulatory and governmental officials.

5.2.23 TSC Emergency CoordinatorPlant Manager The TSC Emergency CoordinatorPlant Manager is the senior individual responsible for the coordination and conduct of all activities associated with plant operations, plant assessment, emergency classification associated with plant parameters, and onsite actions taken to mitigate the emergency situation. The TSC Emergency CoordinatorPlant Manager reports to and advises the Emergency Director on plant status and provides recommendations for emergency reclassification based upon technical information and indications recorded in the TSC. The Emergency Director may delegate the responsibilities of authorizing the use of Potassium Iodide onsite, and emergency doses in excess of 10 CFR 20 dose limits, to the Emergency Plant Manager. Once tasked with these responsibilities, the Emergency Plant Manager cannot delegate them.

The Emergency Plant Manager reports directly to the Emergency Director and interfaces with the Emergency Offsite Manager.

5.2.34 Company Spokesperson The Company Spokesperson is responsible for the overall operation of the Joint Information Center (JIC), conferring with the Emergency Director concerning plant status, reviewing news statements with the Emergency Director, conferring with the JIC Manager concerning media response status, and acting as company spokesperson during media briefings.

The Company Spokesperson is normally located at the JIC during an emergency.

5-7 DBNPS Emergency Plan Revision XX 5.2.5 Emergency Director Advisor The Emergency Director Advisor is responsible for accompanying the Emergency Director during performance of emergency duties; and maintaining an awareness of the present emergency situation, while anticipating possible changes. Personal knowledge of the Emergency Plan and associated procedures enable the Emergency Director Advisor to respond to specific questions, as well as brief the Emergency Director on possible courses of action and required procedural responses.

5.3 Onshift Emergency Response Organization Onshift Emergency Response Organization personnel are adequately trained to recognize, classify, notify, and take appropriate action to terminate or mitigate any emergency situation at the Davis-Besse Station, and shall do so until relieved by the Onsite Emergency Response Organization. The Onshift Emergency Response Organization is depicted in Figure 5-1. Key positions within the Onshift Emergency Response Organization are briefly outlined below.

5.3.1 Shift Manager The Shift Manager is responsible for assuming the role of the Emergency CoordinatorDirector. The Shift Manager supervises the following activities:

a. The timely assessment of plant status.

b. Recognition and appropriate classification of the given situation.

c. Augmentation of the Onshift Emergency Response Organization, as appropriate.

d. Initial notification of offsite agencies.

e. Termination or mitigation of the emergency situation.

f. Protective action recommendations for the general public and Station personnel.

g. Authorization of emergency radiation doses.

5.3.2 Unit Supervisor During power operations, the Unit Supervisor is responsible for assisting the Shift Manager in the supervision of Operations personnel.

The Unit Supervisor will immediately assume the duties and authorities of the Shift Manager, including Emergency CoordinatorDirector duties, if the Shift Manager becomes incapacitated.

5.3.3 Shift Engineer (Shift Technical Advisor)

During an emergency, the Shift Engineer (Shift Technical Advisor), if available, is primarily responsible for the assessment of reactor thermal dynamics. The Shift Engineer (Shift Technical Advisor) is trained to advise the Shift Manager as to level of emergency classification, and actions necessary to terminate or mitigate the consequences of the given situation.

5-8 DBNPS Emergency Plan Revision XX The Shift Engineer (Shift Technical Advisor) will assume the role of Emergency Director if the Shift Manager and the Unit Supervisor become incapacitated. The Shift Engineer (Shift Technical Advisor) is normally assigned to the onshift operating crew during operational modes 1, 2, 3, and 4. Under certain circumstances, this position may be filled by an onshift SRO assigned another function.

5.3.4 Security Shift Supervisor The Security Shift Supervisor is responsible for the activities of the Nuclear Security Force in controlling access to the Protected Area, assisting during medical emergencies and conducting accountability, if necessary.

The Security Shift Supervisor reports directly to the EmergencyTSC Security Manager and interfaces with the OSC Manager and the OSC RHP Coordinator.

5.3.5 Onshift Maintenance Support During normal power operations, the Onshift Maintenance personnel report to the Shift Engineer. Upon declaration of an emergency, the Onshift Maintenance personnel report directly to the Shift Manager and implement the functions of the OSC until the facility is fully activated by the Onsite Emergency Response Organization. During the initial stages of an emergency, the Onshift Maintenance personnel are responsible for performing Mechanical Maintenance, Electrical Maintenance, and Instrument and Controls Maintenance support functions.

5.4 Onsite Emergency Response Organization 5.4.1 Overview During an emergency, an Onsite Emergency Response Organization will be activated. The assignment of responsibilities in the Onsite Emergency Response Organization is ultimately the responsibility of the Vice President, Nuclear.

However, the Manager, Regulatory Compliance and Emergency Response is responsible for establishing and maintaining a predefined Onsite Emergency Response Organization. Alternate assignments to various positions are specified to provide for timely, automatic, and unambiguous manning to satisfy emergency response requirements.

In general, the Onsite Emergency Response Organization will be housed in three onsite facilities. These facilities are briefly described below:

a. Control Room Control Room staff will control the operation of the power plant during both normal and emergency operations.

b. Technical Support Center (TSC)

TSC staff will assess plant conditions and provide management and technical assistance to the Control Room, as required, to mitigate the

5-9 DBNPS Emergency Plan Revision XX effects of the emergency event. The TSC staff will analyze and track parameters relating to the technical EALs and will be responsible for event classification as needed.advise the Emergency Director of the need to reclassify the emergency.

In the event that the onsite TSC is not accessible TSC personnel will utilize the Alternate TSC at the Lindsey Emergency Response Facility.

c. Operations Support Center (OSC)

OSC staff will provide emergency maintenance and radiation monitoring support, as requested by the Control Room; and provide emergency support, as required, for onsite material acquisition, fire fighting, and first aid.

5.4.2 Direction and Coordination Procedurally, the Onsite and Near Site Emergency Response Organization is activated when an emergency is classified at the ALERT level or higher. The response times for the various emergency positions within the organization are specified in Table 5-1 and include 60-minute response by positions providing support to the onshift staff and 90-minute response by positions providing relief to onshift personnel of emergency response functions. The primary function of the Onsite and Near Site Emergency Response Organization is to relieve the Control Room staff of those duties and responsibilities not directly related to the operation of the primary and secondary plant systems.

5.4.3 Control Room In the Control Room, the Onsite Emergency Response Organization is the same as the Onshift Emergency Response Organization. At the ALERT level or greater, additional operators will be assigned to assist in the OSC, under the direction of the OSC CoordinatorManager.

5.4.4 Technical Support Center (TSC) Organization The TSC Organization is composed of individuals housed in two separate and distinct facilities: the Technical Support Center, in the Davis-Besse Administration Building.; or Shift Manager's office, which is in the Control Room envelope.

Personnel and activities in thisese facilityies are directed by the TSC Emergency CoordinatorPlant Manager.

The following individuals report directly to the Emergency CoordinatorPlant Manager:

a. TSC Manager The TSC Manager is responsible for facility operation including communications between the Control Room and EOF as well as oversight of administrative activities. Reporting to the TSC Manager is the

5-10 DBNPS Emergency Plan Revision XX Engineering Coordinator, TSC Operations Coordinator, RP Coordinator and Maintenance Coordinator.

a.b. TSC Operations CoordinatorEmergency Assistant Plant Manager The TSC Operations Coordinator Emergency Assistant Plant Manager is the senior Company representative within the Control Room. The Emergency Assistant Plant Manager is responsible for coordination and interface between the TSC emergency organization and the plant. The TSC Operations CoordinatorEmergency Assistant Plant Manager advises the Emergency CoordinatorPlant Manager on plant status and trends, and their potential impact on protective action recommendations and emergency classification.

The TSC Operations CoordinatorEmergency Assistant Plant Manager interfaces with the Emergency CoordinatorPlant Manager, TSC Engineering CoordinatorManager, TSC Emergency Radiation Protection CoordinatorManager, and the OSC CoordinatorManager.

Reporting to the TSC Operations Coordinator is the ENS Communicator and the Operations Communicator.Emergency Assistant Plant Manager is the Shift Manager and the Operations staff, in the Control Room.

cb. ENS Communicator (TSC)

The ENS Communicator is responsible for completion of NRC notifications in accordance with 10 CFR 50.72 and 73.

d. Operations Communicator The Operations Communicator in the TSC serves as a liaison between operations personnel in the Control Room and EOF and is responsible for alerting the Operations Coordinator of vital data relayed in other ERFs.

e. TSCEmergency Radiation Protection CoordinatorManager The TSCEmergency Radiation Protection CoordinatorManager is located in the TSC and is responsible for ensuring radiological assessment and surveys are conducted and for provision of onsite RP personnel for FMTs.within the Protected Area. The TSCEmergency Radiation Protection CoordinatorManager coordinates plant protective action and health physics support for emergency activities, and interprets data to provide health physics and chemistry input to engineering assessments and ensures access is restricted to controlled areas where radiological hazards exist. The Emergency Radiation Protection Manager interfaces with the Dose Assessment Coordinator to provide data on plant radiological status and trends. In addition, the TSCEmergency Radiation Protection CoordinatorManager provides recommendations to the TSC Emergency CoordinatorPlant Manager for emergency personnel doses, and the issuance of Potassium Iodide to plant personnel.

5-11 DBNPS Emergency Plan Revision XX The TSCEmergency Radiation Protection CoordinatorManager interfaces with the TSC Engineering CoordinatorManager, the Emergency Security CoordinatorManager, the OSC CoordinatorManager, the OSC RHP Coordinator and, the EOF Dose Assessment Coordinator and staff.

fc. Technical Support Center (TSC) Engineering CoordinatorManager The TSC Engineering CoordinatorManager is responsible for the coordination and supervision of TSC engineering activities associated with development of emergency procedures to terminate or mitigate the emergency situation. The TSC Engineering CoordinatorManager ensures that the Technical Support Center is operated with attention to such detail as timely updating, accurate record-keeping, and complete documentation of the event for historical purposes. The TSC Engineering CoordinatorManager advises the TSC Emergency CoordinatorPlant Manager on information pertinent to emergency classification, from the technical standpoint.

The TSC Engineering CoordinatorManager interfaces with the TSC Operations CoordinatorEmergency Assistant Plant Manager, OSC CoordinatorManager and the TSCEmergency Radiation Protection CoordinatorManager.

Reporting to the TSC Engineering CoordinatorManager are the TSC Core Hydraulic Engineer, Mechanical Engineer and Electrical EngineerEngineering Lead, and the TSC Operations Lead.

gd. TSC Core Hydraulic Engineering Lead The TSC Core Hydraulic Engineering Lead is staffed as appropriate, and is responsible for performance of the core damage assessment function in the coordinating the TSC Engineers.

The TSC Core Hydraulic Engineering Lead reports to the TSC Engineering CoordinatorManager and interfaces with the TSC Operations CoordinatorLead, the TSC Mechanical and Electrical Engineers and the Emergency Radiation Protection CoordinatorManager.

h. Electrical Engineer The Electrical Engineer is responsible for troubleshooting and development of restoration procedures for electrical systems.

i. Mechanical Engineer The Mechanical Engineer is responsible for troubleshooting and development of restoration procedures for mechanical systems.

5-12 DBNPS Emergency Plan Revision XX Reporting to the TSC Engineering Lead are engineers with expertise in the following disciplines:

1. Core/Thermal Hydraulics

2. Electrical

3. Mechanical

4. Instrument and Control

e. TSC Operations Lead The TSC Operations Lead is staffed as appropriate, and is responsible for coordinating and supervising the TSC Operations Engineering group. The TSC Operations Lead coordinates engineering tasks assigned to the TSC and Operations Engineering staff.

The TSC Operations Lead reports to the TSC Engineering Manager, and interfaces with the TSC Engineering Lead and the Emergency Radiation Protection Manager.

Reporting to the TSC Operations Lead are personnel with expertise in various aspects of plant operations and computer technology.

j. Maintenance Coordinator The Maintenance Coordinator directs and coordinates the activities of mechanical, electrical and instrumentation personnel in the performance of emergency corrective actions and/or damage control activities.

kf. Emergency Security CoordinatorManager The Emergency Security CoordinatorManager is responsible for the overall direction of the Emergency Security Organization in controlling access to the site, assisting in medical emergencies, and assembly and accountability.

The Emergency Security CoordinatorManager reports to the TSC Emergency Plant Manager and interfaces with the Emergency Radiation Protection CoordinatorManager, and the OSC CoordinatorManager.

g. Emergency Facilities Services Manager

1. The Emergency Facilities Services Manager reports to the Emergency Offsite Manager in the Emergency Operations Facility and is responsible for coordinating with emergency response facility management to ensure the sufficient availability of personnel to support the operations of the DBAB and EOF. This personnel pool includes:

a) Communicators b) Logkeepers c) Status Board Keepers d) Clerical e) Maintenance

5-13 DBNPS Emergency Plan Revision XX f) Laborers

2. The Emergency Facilities Services Manager is also responsible for the procurement of the following equipment in support of DBAB and EOF operations during an emergency:

a) Food and sleeping supplies.

b) Road maintenance, (e.g., snow removal).

c) Phone service.

d) Onsite transportation.

e) Support as requested by the TSC Engineering Manager.

3. The Emergency Facilities Services Manager is also responsible for the operation of DBAB systems such as the emergency ventilation system, the potable water system and the emergency power systems. during emergencies.

h. Owner Controlled Area Security Supervisor The Owner Controlled Area Security Supervisor is responsible for controlling access to the emergency facilities, and ensuring that all ERO personnel in the DBAB have received emergency dosimetry. The Owner Controlled Area Security Supervisor also directs the action of the security force when controlling access to the Owner Controlled Area (OCA).

The Owner Controlled Area Security Supervisor reports to the Emergency Security Manager.

5.4.5 Operations Support Center (OSC) Organization

a. OSC CoordinatorManager The OSC CoordinatorManager is responsible for the briefing and supervision of OSC personnel and ensures adequate personnel and material/equipment support is provided for personnel dispatched into the plant.their associated activities. The OSC Manager will assess the manpower requirements and technical skill level required by the given emergency situation, and provide for augmentation as appropriate. At a minimum, the OSC Manager will provide personnel to staff the following OSC teams:

1. Emergency Repair

2. Search and Rescue

3. First Aid

4. Fire Brigade The OSC CoordinatorManager reports to and interfaces directly with the Emergency Plant Manager and interfaces with the Emergency Assistant Plant Manager and the Emergency Maintenance Coordinators and Radiation Protection CoordinatorManager. Reporting to the OSC

5-14 DBNPS Emergency Plan Revision XX CoordinatorManager are the OSC Maintenance Coordinators Assistant OSC Manager and the OSC Radiation ProtectionHP Coordinator.

b. Assistant OSC Manager The Assistant OSC Manager reports to and assists the OSC Manager as directed. He is responsible for the OSC personnel pool, and assumes the duties and responsibilities of the OSC Manager in his absence.

bc. Mechanical Maintenance Coordinator in the OSC is responsible for oversight of mechanical maintenance troubleshooting and corrective actions work in the plant.

c. Electrical Maintenance Coordinator in the OSC is responsible for oversight of electrical maintenance troubleshooting and corrective actions work in the plant.

d. I&C Coordinator in the OSC is responsible for oversight of I&C troubleshooting and corrective actions work int the plant.

e. The OSC HPRadiation Protection Coordinator The OSC HPRadiation Protection Coordinator dispatches RP and Chemistry technicians within the protected area to survey, sample, and analyze various systems and/or areas to determine the emergency radiological conditions. The OSC HPRadiation Protection Coordinator also provides radiological support for emergency repair teams., the fire brigade, and first aid teams.

The OSC HPRadiation Protection Coordinator reports to the OSC CoordinatorManager, and informs and is advised by the TSCEmergency RP CoordinatorManager.

Reporting to the OSC HPRadiation Protection Coordinator are all RP personneland Chemistry testers not specifically assigned other responsibilities within the emergency organization.

d. Rad Data Technician The Rad Data Technician is an RP technician who obtains area radiation data from the Control Room back panels and transmits it by fax, or verbally by telephone, to the OSC RP Coordinator and Emergency RP Manager.

5-15 DBNPS Emergency Plan Revision XX fe. OSC Pool Personnel The OSC Pool Personnel will be comprised of Maintenance, RP, Chemistry, and Operations personnel who are not assigned other roles and responsibilities within the emergency response organization. OSC personnel will be trained to staff one or more of the following OSC emergency teams:

1. Emergency Repair

2. Search and Rescue

3. First Aid

4. Fire Brigade Members of the OSC Personnel Pool report to the Maintenance and HP Coordinators in the OSCAssistant OSC Manager.

f. OSC Systems Engineers A minimum of three OSC Systems Engineers will be called out to support OSC activities. The disciplines represented will include primary systems, secondary systems, and electrical and controls.

The OSC Systems Engineers will report to the OSC Manager, and interface with the various emergency repair teams, and the TSC engineers.

5-16 DBNPS Emergency Plan Revision XX 5.5 Near Site Emergency Response Organization 5.5.1 Overview During an emergency, a Near Site Emergency Response Organization will be activated at an Alert or higher emergency classification. The assignment of responsibilities in the Near Site Emergency Response Organization is ultimately the responsibility of the Vice President, Nuclear. However, the Manager, Regulatory Compliance and Emergency Response is responsible for establishing and maintaining a predefined Near Site Emergency Response Organization.

Alternate assignments to various positions are specified to provide for timely, automatic, and unambiguous manning to satisfy emergency response requirements.

In general, the Near Site Emergency Response Organization will be housed at the Lindsey Emergency Response Facility. The Lindsey Emergency Response Facility houses the following three facilities:

a. Emergency Operations Facility (EOF)

EOF staff will assess conditions in the Owner Controlled Area and the Plume Exposure Pathway Emergency Planning Zone and provide protective action recommendation to the Emergency Director. The EOF will provided communications between Davis-Besse to external organizations/agencies.

1. Dose Assessment Center The Dose Assessment Center is located at Lindsey Emergency Response Facility and is responsible for evaluation of conditions in the Owner Controlled Area and the Plume Exposure Pathway Emergency Planning Zone, and making recommendations to the EOF.

2. Radiological Testing Lab (RTL)

The RTL is located onsite in the DBAB and is the primary assembly point for Radiation Monitor Team personnel who evaluate habitability conditions in the Owner Controlled Area and perform radiological surveys in the Plume Exposure Pathway Emergency Planning Zone. Collected field survey information is communicated to the Dose Assessment Center.

b. Alternate Technical Support Center (TSC)

In the event that the onsite TSC is not accessible TSC personnel will utilize the Lindsey Emergency Response Facility and perform those tasks as described in Section 5.4.4.

c. Mustering Point for the Operations Support Center (OSC)

In the event that the station is not accessible, OSC personnel will muster at the Lindsey Emergency Response Facility and standby to support the plant mitigation strategy.

5-17 DBNPS Emergency Plan Revision XX 5.5.2 Emergency Operations Facility (EOF) Organization

a. The Emergency Director (ED) is responsible for and has the authority to direct any and all emergency response activities for the site.

Reporting to the Under the direction of the Emergency DirectorOffsite Manager, in the following positions staff the EOF is the EOF Manager.

b. EOF Manager The EOF Manager reports to the Emergency Director. The EOF Managers primary responsibility is the overall operation of the EOF including:

1. Coordination of radiological dose assessment activities and protective action recommendations.

2. Control and coordination of communication and interface with corporate, offsite and regulatory agencies

3. Making recommendations to the Emergency Director concerning appropriate offsite protective actions

4. Interfacing with the TSC Emergency Coordinator, Company Spokesperson and regulatory and government officials.

Reporting to the EOF Manager is the State/local Communicator, Operations Communicator, Offsite Agency Liaison, State EOC Liaison, and Dose Assessment Coordinator.

c. State/local Communicator The State/local Communicator is responsible for completion of initial and follow up notifications to state, local and county officials of changes in classification, release status and PARs as required.

d. Operations Communicator The Operations Communicator in the EOF serves as a liaison between operations personnel in the Control Room, TSC and EOF and is responsible for alerting the Emergency Director of vital data relayed in other ERFs.

ea. Offsite AgencyNRC Liaison The Offsite AgencyNRC Liaison is responsible for providing responses to questions from offsite agencies.establishing and maintaining communications with the Nuclear Regulatory Commission (NRC): The NRC Liaison will be present at meetings between the Emergency Response Organization and the NRC.

5-18 DBNPS Emergency Plan Revision XX

f. State EOC Liaison(s) report to applicable offsite agency EOCs to coordinate communication of technical information.

b. EOF Operations Advisor The EOF Operations Advisor is responsible for gathering, interpreting, and advising the Emergency Offsite Manager with respect to current or potential plant situations; and for providing key plant parameters to the dose assessment group to support their evaluation efforts.

gc. Dose Assessment Coordinator The Dose Assessment Coordinator has the overall responsibility for evaluation and computation of projected dose rates and doses, for areas outside of the Protected Area.

The Dose Assessment Coordinator interfaces with the EOF ManagerOperations Advisor and the TSCEmergency RP CoordinatorManager.

The following individuals report directly to the Dose Assessment Coordinator:

1. Dose Assessorment Staff The Dose Assessorment Staff is responsible for evaluating plant and meteorological parameters associated with a potential or ongoing radiological release and performs dose assessments and projections using this information. A quantitative evaluation of the collected data is performed by the Dose Assessment Staff and the results are provided to the Dose Assessment Coordinator for review. The Dose Assessorment Staff interfaces with the RFMT Coordinator and Dose Assessment CoordinatorRad Data Technician.

2. RadiationField Monitoring Team (RFMT) Coordinator The RFMT Coordinator is responsible for coordinationng and direction of the activities of the RFMTs for purposes of plume tracking as well as ensuring radiological safety for FMT Members.while they are in the field. Under the direction of the Dose Assessment Coordinator, the RMT Coordinator assesses current and projected meteorological conditions and positions the RMTs to track the radiological release. Data gathered in the field by the RMTs is provided to the Dose Assessment Staff for evaluation. The RMT Coordinator coordinates radiological surveys of the owner-controlled area, contiguous to the DBAB, but outside of the Protected Area.

The RFMT Coordinator interfaces with the Dose AssessorRTL Coordinator and the Dose Assessment CoordinatorStaff.

5-19 DBNPS Emergency Plan Revision XX Reporting to the RFMT Coordinator are the Radiation Monitoring Teams.

3. Radiation Testing Lab (RTL) Coordinator The RTL Coordinator is located in the RTL and is responsible for:

a) Set up of contamination survey equipment at points of entry and exit to the DBAB emergency complex.

b) Routine habitability surveys of the DBAB.

c) Decontamination of individuals and equipment within the DBAB.

d) Preliminary analyses of environmental samples gathered by the RMTs.

34. RadiationField Monitoring Team (RFMT)

Each RadiationField Monitoring Team is comprised of two individuals who have been trained in radiological and environmental sampling techniques.

The RFMT members are responsible for taking air, water and soil samples, performing radiation surveys, and using associated survey equipment.

hd. HPN Communicator The HPN Communicator is responsible for provision of onsite and offsite radiological information to the NRC via the Health Physics Network.

Emergency Planning Advisor The Emergency Planning Advisor is responsible for the coordination of the Emergency Operations Facility (EOF) physical operating requirements.

The Emergency Planning Advisor assesses facility readiness, supervises offsite communication, and provides for around-the-clock staffing during extended emergency situations.

The Emergency Planning Advisor interfaces with the Emergency Facility Services Manager for the procurement of personnel and equipment.

Reporting to the Emergency Planning Advisor are the EOF Communications Staff and the Log and Status Board Keepers (EOF).

The EOF communications staff is comprised, at a minimum, of two communicators who are responsible for communications with the Ottawa County Emergency Operations Center, the Lucas County Emergency Operations Center, the State of Ohio, and the Corporate Assistance Center (CAC). The EOF Communications staff may be augmented by additional personnel to assist in communications, Nuclear Network transmissions, and operations of support equipment.

5-20 DBNPS Emergency Plan Revision XX

e. County and State Technical Liaisons A technical liaison is dispatched to each of the Ottawa County, Lucas County, and the State Emergency Operations Centers, at the declaration of a Site Area Emergency. The technical liaisons provide interpretation of events that occur at the station. They report to the Emergency Offsite Manager and will communicate with station personnel to obtain information, as necessary, and report offsite activities.

5.6 Joint Information Center (JIC)

Coordination of the JIC is the responsibility of the JIC Manager, who reports to the Company Spokesperson. The JIC organization is outlined below.

a. Company Spokesperson The Company Spokesperson is responsible for establishing corporate credibility and is designated by Senior Management.

b. JIC Manager The JIC Manager is responsible for the staffing and overall operation of the JIC and oversee the conduct of the briefings with off-site agencies

c. Information Coordinator The Information Coordinator is responsible for notifying the JIC staff of the emergency situation, coordinating the activities of the staff, directing rumor control activities and ensuring the distribution of news announcement.

d. Media Monitor/Rumor Control The Media Monitor/Rumor Control position is responsible for monitoring local radio and TV broadcasts to ensure accuracy of information reported and for coordinating rumor information.

e. Technical Advisor The Technical Advisor is responsible for maintaining frequent contact with the EOF to obtain up-to-the-minute information on plant status.

f. Nuclear Communications Coordinator The Nuclear Communications Coordinator is responsible for ensuring a continuous flow of essential information for developing news announcements regarding plant conditions.

g Media Relations Coordinator The media Relations Coordinator works with the news media to meet special requests such as arranging interviews of company officials and directing media

5-21 DBNPS Emergency Plan Revision XX photographers and camera crews to designated locations to obtain requested photos and film footage.

h. Logistics Coordinator The Logistics Coordinator Serves as the primary source for locating, acquiring and ensuring the timely acquisition and set-up of equipment to be used at the JIC to carry out the emergency response.

5.7 Corporate Assistance Center (CAC)

The CAC has been established to ensure that the full capabilities and resources of the Company can be effectively utilized to respond to any postulated emergency condition at Davis-Besse. The CAC is staffed by designated personnel who coordinate and provide various technical, logistical, and liaison support services to the Emergency Director. This support could include public relations, engineering, technical assistance, security services, and procurement.

Notification and activation of the CAC will depend upon the classification of the emergency event. At the ALERT level, key CAC members are notified and provide support as necessary. At SITE AREA EMERGENCY and GENERAL EMERGENCY levels, the CAC is activated.

Coordination of the CAC is the responsibility of a Senior ERO Position member located at an unaffected FirstEnergy facility. The Senior ERO Position member oversees the operation of the CAC and ensures that CAC activities are carried out in a manner that supports the requests made by the Emergency Director.

5-22 DBNPS Emergency Plan Revision XX 5.78 Supporting Emergency Organizations 5.78.1 Letters of Agreement Since an emergency may require augmenting the onsite ERO, it may become necessary to request and utilize assistance furnished by local personnel, organizations, and activities.

Since it is essential that support from local law enforcement agencies, fire departments, hospitals, and ambulance services be available on relatively short notice, letters of agreement have been signed with many of these personnel, organizations, agencies and support groups.

Letters of agreement are contained in Appendix C.

a. Medical Support Organizations and Personnel The following medical support organizations and personnel have signed letters of agreement to furnish necessary services upon request:

1. H. B. Magruder Hospital

2. Mercy St. Charles Hospital

3. Carroll Township Emergency Medical Services

4. ProMedica Memorial Hospital

b. Fire-Fighting Organizations The Carroll Township Fire Department will provide fire fighting assistance, as requested by Davis-Besse Nuclear Power Station.

When local fire support is required within the Protected Area, local fire department personnel will function in conjunction with, and under the direction of, the DBNPS Fire Brigade.

5.78.2 Medical Emergency Response Organization

a. Medical support for the DBNPS is a three-tiered system consisting of:

1. First Aid and evaluation at the station.

2. Emergency treatment at H. B. Magruder Hospital, Port Clinton, Ohio; Mercy St. Charles Hospital, Oregon, Ohio; or ProMedica Memorial Hospital, Fremont, Ohio (noncontaminated injuries may receive routine medical treatment at other area hospitals).

3. Consultative or direct medical and radiological assistance is provided by the radiological emergency assistance provider.

b. Emergency Medical Responsibilities

1. General Plant Manager:

The General Plant Manager is notified in all cases of serious personnel injury or illness.

2. First Aid Teams:

5-23 DBNPS Emergency Plan Revision XX First Aid Teams consisting of station personnel have been established along with a continuous training program. These teams provide first aid for both radiation and nonradiation injuries in a manner outlined below:

a) Injuries Involving Radiological Complications:

1) Injured personnel, whose injuries are known or suspected to have been complicated by excessive internal or external exposure to radioactive materials or ionizing radiation, shall be given first aid and shall be medically evacuated to the hospital for further treatment if their injuries warrant. Decontamination and treatment of excessive dose will be rendered on a second priority basis.

2) First Aid Team members will work with Radiation Protection personnel to ensure radioactive contamination is removed or contained as much as possible prior to the patients medical treatment if the injuries allow.

b) Non-Radiological Injuries:

1) Any injury requiring medical assistance at DBNPS shall be given first aid by the First Aid Team.

2) A minor injury is an injury that can be treated by the First Aid Team.

3) Major injuries are injuries that require offsite assistance, in addition to treatment by the First Aid Team.

3. Radiation Protection Personnel:

a) Shall respond to injuries involving radioactive contamination and shall control radiological aspects of the scene as much as possible.

b) Shall remove or contain the injured persons contamination as much as possible prior to medical treatment or transportation if injuries allow.

c) Shall accompany the potentially contaminated injured person(s) to the hospital and render assistance to the attending physicians as required.

d) Shall provide the attending physicians with prompt evaluations of the internal and/or external doses incurred by injured personnel. The services of the radiological emergency assistance provider are available for assistance in this matter.

5-24 DBNPS Emergency Plan Revision XX

4. Davis-Besse Security:

Shall notify the appropriate hospital as soon as it is suspected that a potentially contaminated injured person may be sent to H.B.

Magruder Hospital, Mercy St. Charles Hospital or ProMedica Memorial Hospital, so that they may prepare their Radiation Emergency Area.

5. Ambulance Service:

Carroll Township Emergency Medical Services (EMS),

located four (4) miles from DBNPS, has agreed to provide ambulance service to DBNPS. Backup ambulance service is provided in accordance with the Ottawa County Mutual Aid Agreement, which all EMS services in the county have signed.

All personnel involved with this service have received extensive first aid training and have been certified by the Ohio Department of Education as Emergency Medical Technicians (EMT). Periodic training is given to the members of the Carroll Township Emergency Medical Services (EMS) and Mid-County EMS at which time discussions are held on the handling of contaminated injured personnel and standard health physics practices.

6. Radiological Emergency Assistance Provider:

In the event of radiation/medical emergencies, the Radiological Emergency Assistance Provider will provide medical assistance.

The Radiological Emergency Assistance Provider has expertise and is equipped to conduct:

a) Medical and radiological triage b) Decontamination procedures and therapies for external contamination and internally deposited radionuclides c) Diagnostic and prognostic assessments of radiation induced injuries d) Radiation dose estimates by methods that include cytogenetic analysis, bioassay and invivo counting

c. Over-Exposure/Internal Contamination:

If it is known, or suspected, that an individual has been exposed in excess of the limits specified by 10 CFR 20.1201, an immediate investigation shall be conducted by Radiation Protection personnel, and such reports or notifications required by 10 CFR20 shall be submitted.

5-25 DBNPS Emergency Plan Revision XX If a dose falls outside the acceptable limits of 10 CFR 20.2202(a)(1),

the General Plant Manager shall immediately obtain medical consultation from the radiological emergency assistance provider. The radiological emergency assistance provider, in turn, will assure that the exposed individual(s) are promptly evaluated and appropriately treated.

5.78.3 Government Agency Support

a. Agreements with Government Agencies

1. Discussions have been held with appropriate government agencies which have emergency preparedness responsibilities. The responsibility for overall management of response to accidental off-site releases of radioactivity resulting from either a nuclear power plant, or a transportation accident, rests with the State of Ohio and local governments. Through the provisions of the Atomic Energy Development and Radiation Control Act, P.L. 1625 (1965), as amended, the following State agencies have prime responsibilities in matters of radiation hazards:

a) Ohio Department of Agriculture b) Ohio Department of Health c) Ohio Department of Highway Safety d) Ohio Department of Natural Resources e) Ohio Department of Public Safety f) Ohio Department of Transportation g) Ohio Emergency Management Agency (OEMA) h) Ohio Environmental Protection Agency

2. The Emergency Plans for DBNPS, State of Ohio, Ottawa County and Lucas County, have been formulated to provide timely notification and close coordination with these agencies.

3. In the event of a HOSTILE ACTION at the site (including attack by air, land or water using guns, explosives, projectiles, vehicles or other devices to deliver destructive force), the Federal Bureau of Investigation (FBI) will be the lead federal agency to coordinate response to the emergency, as described in the Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan, the Ottawa and Lucas County Radiological Emergency Response Plans, and existing letters of agreement.

4. In addition, arrangements have been made for timely notification of the NRC in an emergency. Emergency support will be provided by the NRC, Region III, Office of Inspection and Enforcement; and the Department of Energy, Chicago Operations Office, Radiological Assistance Program. Other arrangements include police protection, fire-fighting support, and ambulance support.

b. Criteria for Notification of Government Agencies

5-26 DBNPS Emergency Plan Revision XX

1. Federal regulations require timely notification of local and state emergency response agencies. Additionally, notifications are made to the NRC and the Onsite Emergency Response Organization and other key company personnel.

Upon declaration of an emergency, and periodically throughout the emergency, notifications are made to the following:

a) Station Personnel b) Onsite Emergency Response Personnel and other Key Company Personnel c) Ottawa County Sheriff's Office or the Ottawa County Emergency Management Agency (OCEMA) d) Lucas County Sheriff's Office or the Lucas County Emergency Management Agency (LCEMA) e) Ohio Emergency Management Agency or Ohio Highway Patrol f) NRC, Emergency Incident Response Center

2. In the event of personnel injury/illness, which require transportation to an offsite medical facility, the Ottawa County Sheriff's Office will be notified so that local authorities may prepare to answer public/media inquiries.

3. Section 6.0 discusses the radiological incident notification order.

4. Notification will take place as soon as the emergency is declared.

Notification will normally be in the order noted above. The Shift Manager/ Emergency CoordinatorDirector will ensure that the Ottawa and Lucas County Sheriff's Offices, and the State of Ohio, are notified within 15 minutes of the declaration. The NRC will be notified as soon thereafter as possible, but in no case more than one hour after declaration.

5. The Emergency Notification System (ENS) (red phone) will be used for notifying the NRC. In the event that the ENS is unavailable, the NRC commercial number will be used. If radiological concerns arise, the NRC Health Physics Network should be utilized.

c. Local Agencies

1. Ottawa County Sheriff's Office The Ottawa County Sheriff's Office is experienced in providing area control, communications assistance, and direct handling of the local population; including evacuation, should it become necessary. The Sheriff's Office provides 24-hour radio communication coverage with the Central Alarm Station at DBNPS. Until the OCEMA is activated, the Ottawa County

5-27 DBNPS Emergency Plan Revision XX Sheriff's Office is the lead Ottawa County agency contacted in the event of an emergency at DBNPS.

2. Lucas County Sheriff's Office The Lucas County Sheriff's Office is experienced in providing area control, communications assistance, and direct handling of the local population; including evacuation, should it become necessary. Until the LCEMA is activated, the Lucas County Sheriff's Office is the lead Lucas County agency contacted in the event of an emergency at the site.

3. In the event of a HOSTILE ACTION at the site (including attack by air, land or water using guns, explosives, projectiles, vehicles or other devices to deliver destructive force), local agencies will provide appropriate response to the emergency (including law enforcement, fire, and medical support) as described in the Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan, the Ottawa and Lucas County Radiological Emergency Response Plans, and existing letters of agreement.

d. State of Ohio Agencies As outlined in the State of Ohio Emergency Plan, the following State Departments/Agencies are prepared for and will respond to radiological incidents involving licensed nuclear facilities:

1. Department of Public Safety will:

a) Act as the lead-planning agency for developing the State of Ohio Nuclear Incident Plans for Licensed Nuclear Facilities.

b) Determine which State agencies should perform specific tasks within their capabilities and ensure assignment of responsibility.

c) Coordinate preparation of annexes by other State agencies having response capability/ responsibility.

d) Assist, if needed, in the preparation of plans by other state agencies and counties. Coordinate agreements in local plans between nuclear power utility operators and the county Radiological Emergency Response Plans for disasters as identified by the Ohio Emergency Management Agency.

e) Establish additional or alternate radiological field monitoring stations, as necessary for data acquisition.

f) Develop notification methods and procedures, which will include communication with the nuclear facility licensee.

g) Coordinate with adjacent states in matters pertaining to radiological emergency planning.

5-28 DBNPS Emergency Plan Revision XX h) Instruct National Guard units located in the vicinity of the nuclear power station to prepare plans to provide access control and other general assistance with local government officials and the licensee.

i) Be prepared to support the evacuation process, with the assistance of the National Guard, for residents near the nuclear site unable to transport themselves.

j) Make provisions for the alerting of boaters on Lake Erie inside the 10-mile EPZ. In coordination with the United States Coast Guard, Ohio Department of Natural Resources and Ohio Department of Transportation make provisions to close the portion of Lake Erie inside the 10 mile EPZ when directed by Ohio EMA.

2. State Department of Agriculture shall:

a) Plan and direct a statewide program for protection against radiological damage to animals, foodstuffs, and crops.

b) Coordinate with the U.S. Department of Agriculture in making estimates of crop and animal damage from radiation incidents.

c) Coordinate with the Department of Jobs and Family Services in matters pertaining to feeding and housing evacuees.

d) Control, through quarantine, isolation, or confiscation, crops and foodstuffs, on the stalk or harvested, that might be contaminated.

3. Ohio Environmental Protection Agency shall:

a) Assist the Ohio Department of Health in establishing protective actions based on projected radiation dose levels, which might result from a nuclear incident. Due consideration will be given to protective action guidelines established by the U.S. Environmental Protection Agency.

b) Provide assistance to the Ohio Department of Health and Ohio Emergency Management Agency in the development of radiological emergency response plans.

c) Cooperate with the Ohio Department of Health in recommending protective measures to mitigate the effects of a nuclear incident.

d) Review emergency contingency plans for all proposed and existing Licensed Nuclear Facilities with either the facility operators, or sponsors, and the U.S. Nuclear Regulatory Commission.

e) Ensure that an adequate supply of safe, potable water is maintained.

5-29 DBNPS Emergency Plan Revision XX

4. Ohio Department of Health shall:

a) Coordinate Department of Health planning for radiation emergencies at licensed nuclear facilities.

b) Provide guidance and support to other State agencies and local health services with regard to the assessment of radiological hazards and protective actions.

c) Formulate protective action guides to be used in the assessment of radiological hazards, which would be used as the basis for protective action decisions.

d) Act as the chief State agency in evaluating the extent of the hazard and recommending protective actions.

e) Make arrangements for emergency medical supplies and health service to the affected areas.

f) Develop plans for:

1) Relocation of hospitalized persons.

2) Utilization of hospitals and other medical facilities during radiation incidents.

3) Assuring environmental sanitation.

4) Stockpiling and distribution of Potassium Iodide (KI)

5. Ohio Department of Highway Safety shall:

a) Develop a system for implementing emergency traffic control measures within areas affected by radiological incidents.

b) The Ohio Highway Patrol shall:

1) Operate the National Warning System (NAWAS) for warning and emergency communication services insofar as it relates to the State Plan.

2) Obtain information about the radiological incident and resultant damage, and report it to the State Emergency Operations Center (EOC).

3) Provide a mobile radiological monitoring capability, consistent with the capabilities and limitations of the equipment, which is provided.

4) Operate, through the statewide Law Enforcement Emergency Radio Network, a notification system for State Highway Patrol Posts to disseminate nuclear incident information to local authorities as required.

6. Ohio Department of Natural Resources shall:

a) Maintain inventories of primary and secondary sources for water, and prescribe methods of use for such sources, in areas affected by radiological incidents.

5-30 DBNPS Emergency Plan Revision XX b) Cooperate with the Ohio Department of Job and Family Services in providing for the use of departmental land and facilities as evacuation centers or mass care areas.

c) Make provisions for the alerting of persons on state property (e.g., campers and vacationers) to possible radiological dangers, and provide for marine emergency access to the Lake Erie Islands, for possible evacuation in cooperation with the Ohio National Guard.

d) Make available the departments radio communications system for use in the state Emergency Operations Center, if needed.

7. Ohio Department of Transportation (ODOT):

ODOT supports the Ottawa County Engineers Office with traffic and access control assistance, impediment removal, and evacuation route maintenance.

The Division of Aviation will provide air transportation and aerial radiological monitoring in case of an incident at a licensed facility.

e. Federal Agencies

1. Department of Energy (DOE), Chicago Operations Office, Radiological Assistance Program (RAP)

Upon notification of a hazard to public health and safety, the DOE, Chicago Operations Office, will dispatch a Radiological Assistance Program (RAP) Team to the scene to advise and assist, as necessary, and to minimize the public radiation exposure. This advice and assistance will take the form of technical advice and environmental monitoring assistance, and will support the efforts of the Ohio Emergency Management Agency.

2. U.S. Environmental Protection Agency (USEPA)

Region V, USEPA, Chicago, will provide support to the DOE, Chicago Operations Office, upon request. This support consist of qualified radiation monitoring teams.

3. Nuclear Regulatory Commission, Region III, Office of Inspection and Enforcement.

The Office of Inspection and Enforcement Region III, NRC, will dispatch personnel to the scene in the event of an emergency, and will lend support in the areas of observation and accident evaluation.

4. U.S. Coast Guard (USCG)

Upon request, the USCG will broadcast an emergency notice to mariners. In addition, the Ninth District USCG stations will provide available resources (i.e., vessels, aircraft, and personnel) to begin notifying boaters on Lake Erie.

5-31 DBNPS Emergency Plan Revision XX 5.78.4 Other Support Organizations Assistance in response to an emergency is provided to DBNPS by several organizations which specialize in various areas of emergency response, or are structured to provide timely and effective mobilization of resources when the need exists. These organizations are:

a. Institute of Nuclear Power Operations (INPO)

1. One of the roles of INPO is to assist the affected utility in quickly applying resources throughout the nuclear industry to meet the needs of the emergency.

2. INPO, when notified of an emergency situation at a nuclear plant, will provide emergency response as requested. Such situations are equivalent to the ALERT, SITE AREA EMERGENCY and GENERAL EMERGENCY conditions as defined by NRC.

3. INPO is able to provide the following emergency support functions:

a) Assistance in locating sources of emergency manpower and equipment.

b) Analysis of the operational aspects of the incident.

c) Dissemination to member utilities, of information concerning the incident, that is applicable to their operations.

d) Organization of industry experts who could advise the utility on technical matters.

4. To support these functions, INPO maintains the following emergency support capabilities:

a) Twenty-four hour-a-day operation of an Emergency Response Center.

b) Designated INPO representative(s) who can be quickly dispatched to the utility emergency response organization to coordinate INPO support activities and information flow.

5. If requested by DBNPS, one or more suitably qualified members of the INPO technical staff will report to the Recovery Manager, and will assist his staff in coordinating INPO's response to the emergency as follows:

a) Staff a liaison to the appropriate utility manager.

b) Work with the INPO Duty Person, in Atlanta, to coordinate all requests for assistance, INPO response, and related communications.

5-32 DBNPS Emergency Plan Revision XX c) Assist the utility, as requested, in initiating and updating entries into industry information systems (such as NUCLEAR NETWORK).

d) Ensure that all information concerning the emergency, which is released by the INPO liaison, is properly and formally cleared through appropriate utility channels.

6. The president of INPO will direct an analysis of operational factors relating to the incident.

Onsite activities, when undertaken, will be coordinated with the onsite INPO Representative.

b. Davis-Besses Insurance Carriers

1. There are three occasions that require interfacing with the insurance carriers:

a) Nuclear Emergencies (Alert, Site Area Emergency, General Emergency).

b) Fire Protection impairment.

c) Accidents involving damage to insured property (e.g., fire, smoke, explosion, sprinkler leakage, damage to property by vehicles, lightning, windstorm, materials handling, losses.)

2. American Nuclear Insurers (ANI) will be notified in accordance with the Emergency Plan Implementing Procedures.

3. In the event of an extraordinary nuclear occurrence (as defined in the Price-Anderson Law), ANI has plans prepared to provide prompt emergency funding to affected members of the public.

4. The provisions of the Price-Anderson Law facilitate providing prompt assistance to members of the public who may be adversely affected in the event of a nuclear incident at an ANI indemnified facility. This arrangement is intended to alleviate the immediate financial burden which may be incurred by members of the public due, for example, to evacuation and relocation activities initiated as a consequence of the nuclear occurrence.

5. In providing emergency assistance to members of the public, representatives will be promptly dispatched to commence the distribution of emergency assistance funds.

Such emergency assistance enables members of the public to cope with and to otherwise defray the reasonable immediate expenses incurred by a nuclear occurrence.

5-33 DBNPS Emergency Plan Revision XX

6. Nuclear Electric Insurance Limited is the Stations property damage carrier and is notified of situations requiring their attention by appropriate Station procedures.

c. Nuclear Steam Supply System (NSSS) Vendor and Architect/Engineer Support The NSSS vendor for the Davis-Besse plant was the Babcock and Wilcox (B&W) Company. Babcock & Wilcox later became B&W Nuclear Technology (BWNT) and is currently known as Framatome. The Architect/ Engineer (A/E) for construction of the Davis-Besse plant was the Bechtel Power Corporation.

These two firms can be called on during emergency situations to provide the technical analysis and engineering support necessary to mitigate abnormal plant conditions.

d. Bordering Counties and Contiguous States Davis-Besse notifies Ottawa and Lucas Counties, and the Ohio Emergency Management Agency.

Ottawa County, in turn, notifies Sandusky County, Ohio; and Erie County, Ohio; of the emergency.

The Ohio Emergency Management Agency notifies the State of Michigan of emergencies at Davis-Besse.

5-34 DBNPS Emergency Plan Revision XX TABLE 5-1 MANPOWER, LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page 1 of 2 A. ONSHIFT MINIMUM STAFFING REQUIREMENTS Analysis Functional Area Major Tasks Emergency Positions Shift Staffing Shift Manager (SRO) 1

1. Plant Operations and Unit Supervisor (SRO) 1 Assessment of Control Room Staff Shift Engineer (STA) 1 Operational Aspects Reactor Operator 2 Non-Licensed Operator (EO3) 1

2. Emergency Direction and Command and Control Shift Manager 1(a)

Control Licensee CAS Operator 1(a)

3. Notification &

Local/ State NLO or above 1(a)

Communication Federal NLO or above 1(a)

Dose Assessment Shift Engineer (STA) 1(a)

In-plant Surveys RP Technician 1

4. Radiological Assessment Onsite Surveys RP Technician 1(a)

Chemistry Chemistry Technician 1 Technical Support - OPs Shift Engineer (STA) 1(a)

5. Plant System - Core Damage Shift Engineer (STA) 1(a)

Engineering, Repair, and Mechanical Repair 1(a)

Mitigative Actions Repair and Mitigative Actions Electrical Repair 1(a)

I&C Repair 1(a)

6. In-Plant PAs Radiation Protection RP Technician 2(a)

Fire Brigade Captain (RO/EO3) 1

7. Fire Fighting --

Fire Brigade Member 4

8. 1st Aid and Rescue -- NLO 1(a)

Security Shift Supervisor 1

9. Site Access Control and Security & Accountability CAS Operator 1 Accountability Security Personnel (b)

TOTAL: 15 Notes: Personnel assigned to the shift in excess of the minimum staffing listed above may be assigned to any of the emergency positions in functions 2 through 9 for which they are qualified. Appendix F, Davis-Besse Nuclear Power Station (DBNPS) ERO On-Shift Staffing Analysis Report, documents the minimum shifts ability to implement the emergency plan.

Operations personnel and Chemistry Technicians are qualified on survey instruments.

(a) May be filled by someone filling another position having functional qualifications.

(b) Per DBNPS Physical Security Plan.

5-35 DBNPS Emergency Plan Revision XX TABLE 5-1 MANPOWER, LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page 2 of 2 B. AUGMENTED EMERGENCY RESPONSE STAFFING REQUIREMENTS ALERT, SITE AREA EMERGENCY, UNUSUAL EVENT GENERAL EMERGENCY PERSONNEL TIME PERSONNEL TIME CONTROL ROOM CONTROL ROOM Emergency Assistant Plant Manager (1) Alerted Emergency Assistant Plant Manager (1) Normal Hours:

30 minutes Off Hours:

60 minutes OPERATIONS SUPPORT CENTER OPERATIONS SUPPORT CENTER OSC Manager (1) Alerted OSC Manager (1)

OSC RP Coordinator (1) OSC RP Coordinator (1) Normal Hours:

Mechanical Maintenance (2) 30 minutes Instrument & controls (2)

Electrical Maintenance (2)

Add Total Off Hours:

RP Technician (1) (2) 60 minutes Chemistry Technician (0) (1)

RP Technician (3) (5) 1-2 hours Chemistry Technician (1) (2)

TECHNICAL SUPPORT CENTER TECHNICAL SUPPORT CENTER As Required:

TSC Engineering Manager (1) Alerted TSC Engineering Manager (1) Normal Hours:

Core/Thermal Hydraulic Engineer (1) 30 minutes Off Hours:

60 minutes TSC I&C Engineer (1)

TSC Electrical Engineer (1) 1-2 hours TSC Mechanical Engineer (1)

EMERGENCY OPERATIONS FACILITY EMERGENCY OPERATIONS FACILITY As Required:

Emergency Director (1) Alerted Emergency Offsite Manager (1) Normal Hours:

Emergency Offsite Manager (1) Dose Assessment Coordinator (1) 60 minutes Emergency Planning Advisor (1) Off Hours:

NRC Liaison (1) 60 minutes State/County Communicator (1)

RMTs (3) 30-60 minutes Emergency Director (1) 1-2 hours NOTES: 1. All time requirements are based on optimum response conditions.

2. Figure 5-2, Emergency Response Organization, depicts functional levels beyond these augmented staffing requirements.

5-36 DBNPS Emergency Plan Revision XX TABLE 5-1 MANPOWER, LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Proposed Capability for Additions Major Functional Area Major Tasks Position Title/Expertise On-Shift 60 min 90 min Shift Manager (SRO) 1 ------ ------

Emergency Direction and Control Classification/Oversight TSC Emergency Coordinator (TSC) ------ 1 ------

Emergency Director (EOF) ------ 1 ------

Licensee, Local/State Federal Shift Communicator (State/local/Federal) 1 ------ ------

Notification/ Communication personnel and maintain State/local Communicator (EOF) ------ 1 ------

communication ENS Communicator (TSC) ------ 1 ------

Shift Technical Advisor (SRO/STA) 1* ------ ------

Offsite Dose Assessment Dose Assessment Coordinator (EOF) ------ 1 ------

FMT Lead ------ 1 1 Radiological Accident Offsite Surveys FMT Member ------ 1 1 Assessment In-plant/Onsite (out-of-plant) RP qualified individual 1 1 1 Protective Actions RP qualified individual 1 2 2 RP Oversight RP Coordinator (TSC) ------ 1 ------

Shift Technical Advisor (SRO/STA) 1 ------ ------

Core Hydraulic Engineer (TSC) ------ 1 ------

Plant System Engineering Technical Support Electrical Engineer (TSC) ------ 1 ------

Mechanical Engineer (TSC) ------ 1 ------

MM Coordinator (OSC) ------ ------ 1 EM Coordinator (OSC) ------ ------ 1 I&C Coordinator (OSC) ------ ------ 1 OSC Coordinator (OSC) ------ 1 ------

Repair and Corrective Repair and Corrective Actions HP Coordinator (OSC) ------ 1 ------

Mechanical Personnel (OSC) ------ 1 ------

Electrical Personnel (OSC) ------ 1 ------

Instrument & Control Personnel (OSC) ------ ------ 1 Total 5 18 9

May be performed by someone filling another position having functional qualifications.

5-37 DBNPS Emergency Plan Revision XX ONSHIFT EMERGENCY ORGANIZATION Page 1 of 1 Shift Manager Unit Shift Engineer Supervisor (Shift Technical Advisor)

Radiation Chemistry Operations Protection Personnel Shift Maintenance Security Personnel Shift Supervisor Nuclear Security Force FIGURE 5-1 FIGURE 5-1 ONSHIFT EMERGENCY ORGANIZATION Shift Manager Unit Shift Engineer Supervisor (Shift Technical Advisor)

Operations Radiation Personnel Protection

5-38 DBNPS Emergency Plan Revision XX ONSHIFT EMERGENCY ORGANIZATION Page 1 of 1 Shift Manager Unit Shift Engineer Supervisor (Shift Technical Advisor)

Radiation Chemistry Operations Protection Personnel Shift Maintenance Security Personnel Shift Supervisor Nuclear Security Force FIGURE 5-1

5-39 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 1 of 10 Emergency Director Emergency Director Advisor Emergency Plant Emergency Offsite Company Spokesperson Manager Manager see figure 5-2 page 2 see figure 5-2 page 8 see figure 5-2 page 10 Responsibilities: Responsibilities: Responsibilities:

-Plant Operations -Offsite Communications -Communications with the

-Engineering - Dose Assessment News Media Assessment

-Radiation Protection

-Repair Activities

-Station Security

5-40 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 2 of 10 Emergency Plant Manager Recovery Advisor Emergency Assistant TSC Emergency OSC Emergency Plant Manager Engineering Manager RP Manager Manager Security Manager see figure 5-2 page 3 see figure 5-2 page 4 see figure 5-2 page 5 see figure 5-2 page 6 see figure 5-2 page 7 Responsibilities: Responsibilities: Responsibilities: Responsibilities: Responsibilities:

- Plant Operations - Engineering Assessment - Radiological Evaluation - Emergency Repairs - Access Control

- Core Damage Assesment - Chemistry Evaluation - Search & Rescue - Station Security

- Damage Control

5-41 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 3 of 10 Emergency Assistant Plant Manager Control Room Communicator Shift Manager Shift Engineer (Shift Technical Advisor)

Operations Personnel

5-42 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 4 of 10 TSC Engineering Manager TSC Engineering* TSC Operations*

Lead Lead Core/Thermal TSC TSC TSC TSC Operations TSC Computer Hydraulic Engineer Mechanical Electrical I&C Engineers Technician Engineer Engineer Engineer (4)

Optional position that may be staffed at the discretion of the TSC Engineering Manager.

5-43 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 5 of 10 Emergency RP Manager OSC RP Coordinator RP Chemistry Technicans Technicans

5-44 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 6 of 10 OSC Manager OSC System Engineers OSC RP Assistant Coordinator OSC Manager RP & Chemistry RP Briefer/ OSC Pool OSC Team Operations Personnel Debriefer Personnel Briefer/debriefer Personnel

5-45 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 7 of 10 Emergency Security Manager Security OCA Shift Supervisor Security Supervisor Nuclear Security Force

5-46 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 8 of 10 Emergency Offsite Manager EOF Operations Advisor Dose Assessment Emergency Emergency NRC Technical Liaison -

Coordinator Facility Services Planning Liaison EOF Communicator Manager Advisor Technical Liaison -

see figure 5-2 page 9 Assembly Area Log & State of Ohio Coordinator Status Board Keepers (EOF)

Technical Liaison -

Maintenance Services State / County Ottawa County Personnel Communicator Resource Technical Liaison -

Coordinator Lucas County Warehouse Pool Personnel

5-47 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 9 of 10 Dose Assessment Coordinator RTL RMT Dose Coordinator Coordinator Assessors (2)

DBAB Field RMTs RMTs

5-48 DBNPS Emergency Plan Revision XX FIGURE 5-2 Emergency Response Organization Page 10 of 10 Company Spokesperson JIC Public Affairs Manager Duty Officer Security JIC News Statement Writer Coordinator JIC PR Communicator Communicator Audio/Visual Technical Coordinator Briefer Public Inquiry Media Hotline Operator Assistant (1) (2)

5-49 DBNPS Emergency Plan Revision XX FIGURE 5-2 Technical Support Center (TSC) Organization

5-50 DBNPS Emergency Plan Revision XX FIGURE 5-32

5-51 DBNPS Emergency Plan Revision XX FIGURE 5-42 Emergency Operations Facility (EOF) Organization

5-52 DBNPS Emergency Plan Revision XX FIGURE 5-52 Joint Information Center (JIC) Organization

6-1 DBNPS Emergency Plan Revision XX 6.0 EMERGENCY MEASURES This section identifies the specific measures that are taken for each class of emergency defined in Section 4.0, "Emergency Conditions", of this Plan. The logic presented in this section is the basis for detailed Emergency Plan Procedures which define the emergency actions to be taken for each emergency category. Emergency measures begin with the following:

a. The recognition and declaration of an emergency.

b. Notification of the applicable agencies for each emergency classification.

c. Mobilization of the appropriate portions of the emergency response organization.

Emergency measures can be classified as falling into one of the following categories:

a. Assessment Actions

b. Mitigative Actions

c. Protective Actions Figure 6-1 is a summary of typical emergency measures, which may be appropriate for each classification of emergency. Figure 6-2 indicates the groups and organizations that will be notified at each emergency classification.

6.1 Activation of the Emergency Response Organizations If conditions at Davis-Besse meet or exceed a predetermined value or condition specified as an EAL in the emergency classification procedure, the provisions of this plan, and those of the specific procedures shall be implemented.

Specific emergency action levels for each emergency category are defined in Section 4.0. The Shift Manager, acting as Emergency CoordinatorDirector, will implement this plan by initially classifying the emergency and ensuring that required notifications are made.

When an emergency classification level is declared or upgraded, initial notifications are promptly made to offsite response organizations. Notification and mobilization of federal, state and local agency response personnel is performed in accordance with their applicable emergency plan and procedures.

State and Local Response Agencies State and local agencies receive within fifteen (15) minutes an initial notification message of an event declaration (initial or an escalation). General Emergency classifications also include Protective Action Recommendations (PARs) within that same 15 minutes. Any subsequent changes to PARs continue to be provided to the agencies within 15 minutes.

Nuclear Regulatory Commission (NRC)

The NRC is notified immediately after notification of the appropriate state and local agencies and not later than one (1) hour after the time of initial event declaration, escalation to a higher classification level, emergency termination or entry into recovery.

The NRC is notified using the dedicated Emergency Notification System (ENS) by an individual knowledgeable of the event. If the ENS is inoperative, the required notifications are made via

6-2 DBNPS Emergency Plan Revision XX commercial telephone service. An open, continuous communication line is maintained with the NRC Operations Center upon request. An NRC Event Notification Worksheet may be utilized to assist in communicating event and plant information to the NRC.

For hostile action events, the NRC is notified immediately following or concurrent with state and local notifications.

Other event notifications related to emergency response capabilities not associated with an emergency classification level are performed in accordance with 10 CFR 50.72.

Support Organizations

- Medical, rescue, and firefighting support services are notified for assistance as the situation dictates.

- The Institute of Nuclear Power Operations (INPO) is notified at an Alert or higher classification with requests for assistance as necessary.

- The American Nuclear Insurers (ANI) are notified at an Alert or higher classification with requests for assistance as necessary.

- Vendor and contractor support services are notified for assistance as the situation dictates.

Following the notifications made to the counties, state, and NRC; notifications will be made to the General Plant Manager, the Manager of Operations, and the Emergency Director, or their designated alternates. The Emergency Assistant Plant Manager, working closely with the Shift Manager, will continually assess the emergency to verify that the most appropriate classification is made.

Depending on the level of the emergency and its severity, portions or all of the onsite and offsite EROs and the CAC will be mobilized as detailed below:

6.1.1 Shift Manager/Control Room Operations

a. Should emergency conditions arise, it is expected that the Control Room Operator(s) and/or the Shift Manager will be made aware of the situation by alarms, instrument readings, reports, etc. The Control Room Operator(s) will ensure that the Shift Manager is immediately informed of the situation. The Shift Manager will direct the Control Room staff to inform the Emergency Director and Station Management immediately.

b. The Shift Manager, when informed of an emergency situation, is responsible for assessing the emergency (e.g., plant systems and reactor core status, radiological conditions, etc.) in the following manner:

1. Determine the immediate actions to be taken (e.g., use of Abnormal Procedures and the Emergency Operating Procedure) to ensure the safe and proper operation of the plant. The Shift Engineer, acting as Shift Technical Advisor (STA), will advise and assist the Shift Manager on matters pertaining to the safety and proper operation of the plant, with regards to nuclear safety.

2. If the situation requires implementation of the DBNPS Emergency Plan, the Emergency CoordinatorDirector will:

6-3 DBNPS Emergency Plan Revision XX a) Classify the emergency. Classification of emergencies is a non-delegable responsibility of the Emergency CoordinatorDirector.

b) Ensure that the appropriate alarm (Fire, Access Evacuation, or Initiate Emergency Procedures) is sounded.

c) Announce the location, type and classification of the emergency on the station public address system (twice).

d) Implement the applicable Emergency Plan Procedure.

e) Notify the following personnel and organizations of the emergency conditions:

1) Nuclear Security Supervision.

2) Station Management.

3) Ottawa County Sheriff/EMA (within 15 minutes).

4) Lucas County Sheriff/EMA (within 15 minutes).

5) Ohio State Highway Patrol/EMA (within 15 minutes).

6) Key Emergency Response Personnel.

7) NRC, Emergency Operations Center, Bethesda, Maryland (within one hour).

f) Provide periodic follow-up notifications.

g) Recommend protective actions for public protection, as needed.

Recommending public protective actions is a non-delegable responsibility of the Emergency CoordinatorDirector.

3. Due to the numerous responsibilities assigned to the Shift Manager at the onset of an emergency, he will perform the following actions in their listed priority.

a) Ensure the safe operation of the plant.

b) Ensure that immediate notification requirements are met.

c) Dispatch, in the event of radiological emergencies, Radiation Protection (RP) personnel to appropriate locations within the protected area.

d) Perform additional emergency actions as time and conditions permit.

6-4 DBNPS Emergency Plan Revision XX 6.1.2 Emergency CoordinatorDirector The designated Emergency CoordinatorDirector, upon being informed that an emergency exists and has been declared by the Emergency CoordinatorDirector on-shift will:

a. Review information, data, and methods used by the on-shift Emergency CoordinatorDirector (Shift Manager) in making the emergency classification. The Emergency CoordinatorDirector may NOT delegate the responsibility of classifying emergencies.

b. Determine, to what extent the Emergency Response Organization (ERO) will be activated, using the following guidelines:

1. For an UNUSUAL EVENT, key individuals in the ERO will be alerted or mobilized at the discretion of the Emergency CoordinatorDirector.

2. For an ALERT or higher classification, all of the ERO will be activated. Key individuals in the CAC will be alerted.

3. For a SITE AREA EMERGENCY or GENERAL EMERGENCY, the entire ERO, and the CAC will be activated.

c. Ensure that the Emergency Response Organizations have been activated as indicated above. (If not already performed by Control Room staff.)

d. Report to the TSC/EOF and relieve the Emergency Director.

de. The Emergency Director in the EOF is responsible for Eensuringe that the Periodic Update Form, as provided in the Emergency Plan Procedures, is completed and supplied to the state and county Emergency Management Agencies. Protective action recommendations, for the Plume Exposure EPZ, is a non-delegable responsibility of the Emergency Director.

ef. The Emergency Director in the EOF Eensures that dose rate calculations, in accordance with the Emergency Plan Procedures, are performed periodically. A total population dose estimation may also be performed.

6.1.3 Ottawa and Lucas County Sheriffs' Offices Dispatchers at the Sheriffs' Office for both counties, will notify key county officials and organizations, according to established procedures.

6.1.4 Ottawa County and Lucas County Emergency Management Agency Directors The County EMA Directors will ensure that their county EROs are activated when necessary, and will notify municipalities near DBNPS.

6.1.5 Ohio Emergency Management Agency (OEMA)

The OEMA will ensure that applicable state agencies and organizations are notified and will ensure the State Emergency Operations Center is activated when necessary. Additional state agencies are contacted depending on the severity of the emergency classifications. These notifications are made in accordance with the State of Ohio emergency plan.

6-5 DBNPS Emergency Plan Revision XX The OEMA will have Radiological Monitoring Teams and an accident assessment team respond to an emergency at DBNPS. The accident assessment team will set up an operations center at the local governmental Emergency Operations Center. Using estimates from utility and offsite monitoring teams; and local governmental official's input, the accident assessment team will perform independent accident assessment activities to determine:

a. Protective measures including evacuation.

b. Actions to control exposure to radioactivity.

c. What further sampling of milk, food chain, water and air will be required.

If deemed appropriate, the accident assessment team will request assistance from responding federal agencies in accordance with the State of Ohio emergency plan.

6.1.6 Federal Agencies (Other than NRC)

The NRC, as the cognizant federal agency, will request assistance from other federal agencies when and if deemed appropriate.

Station management may also request assistance and/or information from federal agencies (other than the Department of Energy Radiological Assistance Program) as appropriate to the circumstances.

State organizations and agencies may consult with their federal counterparts if appropriate.

If required, the Department of Energy Radiological Assistance Program teams can be expected to begin arriving at the site in 4 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following notification. The first teams to arrive will have some survey instruments and air samplers. A mobile environmental monitoring lab can be expected to arrive at the site in 6 to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Appendix B contains a reference to the Radiological Assistance Program with the DOE to provide radiological assistance.

6.1.7 Ohio Department of Health The Ohio Department of Health, Radiological Health Unit, maintains a communications link with the U.S. NRC, Region III Office, from which assistance and support may be requested.

6-6 DBNPS Emergency Plan Revision XX 6.2 Assessment Actions Effective coordination and direction of all elements of the emergency organization requires continuing accident assessment throughout an emergency situation. Each emergency class invokes similar assessment methods; however each classification imposes a different magnitude of assessment effort.

In the following sections, assessment actions taken for each emergency classification are outlined.

6.2.1 Assessment Actions for an UNUSUAL EVENT The declaration of an UNUSUAL EVENT arises when a specific Emergency Action Level for this classification has been met.

Recognition of the need to declare the event will result from alarms, instrument readings, severe weather warnings, a security threat to facility protection, operating experience, or any combination thereof.

Continuing assessment actions to be performed for this category of emergency will be in accordance with the Emergency Plan Procedures and consist of the normal monitoring of Control Room and plant instrumentation and status, until the situation is resolved. Tornado and severe weather assessment actions consist of keeping in contact with the system dispatcher and the appropriate public authorities. If a fire prompted the declaration of an UNUSUAL EVENT, the Fire Brigade Captain will go to the fire location, make continuing assessments, and report to the Shift Manager on whether offsite fire fighting support is required. If a security event is in progress, then the emergency organization will immediately implement procedures for security events or threats.

6.2.2 Assessment Actions for an ALERT Once an incident has been classified as an ALERT, assessment actions will be performed in accordance with the Emergency Plan Procedure for an ALERT. These actions include:

a. Increased surveillance of in-plant instrumentation.

b. If possible, the dispatching of shift personnel to the identified problem area to confirm and visually assess the problem.

c. Activation of the TSC, OSC and EOF as well as staffing of the JIC d The dispatching of Field Monitoring Teams (FMTs)personnel to monitor for possible releases, and to confirm the correct classification.

ed. If a radiological incident is occurring, surveillance of the in-plant instrumentation necessary to obtain meteorological and radiological data required for calculating or estimating projected doses. Dose assessment activity will continue until termination of the emergency, so that assessment updates may be provided to all concerned offsite agencies and to the Emergency CoordinatorDirector. Emergency Plan Procedures are provided to allow a rapid, consistent projection of dose.

fe. If a security event is in progress, then the emergency organization will immediately implement specific procedures for security events or threats.

6-7 DBNPS Emergency Plan Revision XX 6.2.3 Assessment Actions for a SITE AREA EMERGENCY Assessment actions for the SITE AREA EMERGENCY category are similar to the actions for an ALERT. However, due to the increased potential for a possible release, assessment activity of greater scope will occur. The personnel necessary for this assessment effort will be provided by mobilization of the onsite and offsite EROs.

These actions include:

a. An increased amount of plant instrumentation will be monitored. (In particular, indications of core status, e.g., incore thermocouple readings, etc.)

b. Radiation monitoring efforts will be greatly increased. Radiation Monitoring Teams will be available for immediate dispatch. Beta-gamma field measurements may be performed; air sampling, environmental thermoluminescent dosimeter (TLD) change out, and collection of environmental media for assessment of material transport and deposition will be performed as necessary.

c. Dose assessment activities will be performed more frequently, with an increased emphasis on dose projection for use as a factor in determining necessary protective actions. Radiological and meteorological instrumentation readings will be used to project the dose rate at predetermined distances from the station, and to the potential integrated dose.

In reporting the dose projections to the Emergency Director or to offsite agencies, the dose rate, dose, and basis for the time used for the dose estimate will always be provided. Confirmation of dose rates by RFMTs will be reflected in reports and/or revised dose estimate information provided to offsite agencies.

All dose projections will be performed in accordance with the Emergency Plan Procedures which incorporate recommendations found in EPA-400-R-92-001 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. Reports to offsite authorities will include the relationship of dose to these guidelines. Emergency Plan Procedures are provided for recording pertinent information.

d. If a security event is in progress, then the emergency organization will immediately implement specific procedures for security events or threats.

6.2.4 Assessment Actions for a GENERAL EMERGENCY Assessment actions for the GENERAL EMERGENCY category are the same as for the SITE AREA EMERGENCY, with some possible increase in the scope of dose assessment/projection activities. Additionally, since projected doses are likely to be much closer to EPA Protective Action Guidelines (PAGs), greater emphasis will be placed on the assessment of release duration. Judgments and assumptions used for dose assessment will be documented.

6-8 DBNPS Emergency Plan Revision XX 6.3 Mitigative Actions Detailed operating procedures are available for use during emergencies, as well as during normal operations. Specific Emergency Operating Procedures and Abnormal Procedures are provided to assist the operators in placing the plant in a safe condition, and taking necessary supplemental mitigative actions. In addition, operations personnel are trained in the operation of the plant systems and their associated procedures, and are therefore capable of taking appropriate mitigative actions based on their training, knowledge, and experience.

Selected DBNPS Staff personnel, including Operations, Radiation Protection, Chemistry, and Maintenance personnel are trained and assigned to emergency teams. These teams are capable of responding to situations as set forth in the Emergency Plan Procedures, to assess conditions and take appropriate mitigative actions. Maintenance personnel will provide the necessary expertise to effect damage control and repair activities.

Mitigative actions will normally be planned events that are taken to gain control of, or terminate the emergency situation. Planned radioactive releases, or mitigative actions that may result in a radioactive release will be evaluated by the Emergency CoordinatorDirector and staff as far in advance of the event as is possible. Such events and data pertaining to the release, will be reported to the appropriate offsite organizations and/or agencies. DBNPS recommendations to authorities regarding the Plume Exposure EPZ are the non-delegable responsibility of the Emergency CoordinatorDirector.

6.4 Protective Actions Protective actions are emergency measures taken during or after an emergency situation to minimize or eliminate the hazard to the health and safety of the general public and/or station personnel. Such actions taken onsite are the responsibility of Company management, while those taken offsite fall under the jurisdiction of the State of Ohio and other offsite response agencies. All visitors to the Protected Area will be either escorted by an employee or receive training on actions required by them during an emergency.

6.4.1 Plant Site Protective Actions During an emergency, sheltering or evacuation of personnel may be required to prevent or minimize exposure to radiation and radioactive materials. The following sub-sections present information on policies concerning such situations. Figure 6-3 illustrates the routes to be taken from the site if evacuation becomes necessary.

a. Plant Site (within the protected area):

All personnel within the site protected area at the time of the declaration of an emergency, will be notified of the emergency by audible or visual alarms and verbal announcement over the public address system (Gai-Tronics). Personnel may be instructed to report to the assembly area. Personnel will be trained as to the location of the assembly area and the suggested route. Visitors will assemble with their escorts or be escorted offsite. At the assembly area, members of the emergency organization will conduct personnel assembly and evacuation (if required).

Accountability within the protected area is coordinated by the OSC CoordinatorManager and Security. The goal for completion of personnel accountability is 30 minutes.

6-9 DBNPS Emergency Plan Revision XX Results are forwarded to the Emergency CoordinatorDirector. Once established, accountability within the protected area will be maintained throughout the course of the event. Specific guidance for performing accountability can be found in the Emergency Plan Procedures. Search for and rescue of missing persons will be performed in accordance with Emergency Plan Procedures.

Sheltering at onsite locations will be ordered when the projected dose would be less than or equal to that received during evacuation. For essential personnel who must remain within the protected area following an evacuation (e.g., Operations and Security personnel), particular attention will be paid to their radiation dose for ALARA purposes.

If a localized emergency exists, evacuation of the affected facility or area can be performed. Access to this area should then be restricted. The Protected Area will be evacuated if a SITE AREA EMERGENCY has been declared or if, at the discretion of the Emergency CoordinatorDirector/Shift Manager, a personnel hazard exists.

Nonessential personnel shall be evacuated from the site if a GENERAL EMERGENCY has been declared, or if, at the discretion of the Emergency CoordinatorDirector/Shift Manager, site evacuation is warranted for personnel safety reasons. Access control will be established by Security to prohibit the entry of unauthorized personnel to the protected area.

Personal vehicles will be used for site evacuation. Nonessential personnel may be evacuated to the designated offsite assembly area, which will be located at an offsite county reception center. Personnel and vehicles will be monitored for contamination at the offsite reception center, if necessary, prior to release.

b. Plant Site (Outside the Protected Area):

All personnel onsite, but outside the protected area will be notified, at the declaration of an emergency, of conditions that may affect them. Personnel outside of the range of the Gai-Tronics system will be notified via bullhorn, ERO mobile device, or site public address system. Personnel may be instructed to report to the nearest assembly area. Key personnel have been delegated responsibility for receiving emergency information and disseminating such information to personnel in these areas. If assembly becomes necessary, Assembly Area Coordinators will perform these functions and report the results to the Emergency Director.

c. Hostile-Action Based Protective Actions Hostile-Action Based, or security related, emergencies offer different challenges to the site organization. Davis-Besse Nuclear Power Station has incorporated a range of protective actions for onsite personnel during a hostile action event, consistent with the possible threat (including land/water based, as well as airborne attacks). Generally, these protective actions may include considerations for:

Site evacuation via normal exits Site evacuation via alternate means Dispersal of plant operators and essential ERO members Take Cover (sheltering in place for personnel onsite)

6-10 DBNPS Emergency Plan Revision XX Arrangements for accounting for personnel after a hostile action have been made. When the site is secure, all personnel who were in the protected area when the hostile action occurred will be accounted for as promptly as possible while not interfering with critical safe reactor shutdown activities or known medical emergencies. The details of these protective actions are described in site implementing procedures.

6.4.2 Offsite Protective Actions:

Responsibility for implementing actions to protect personnel in offsite areas rests with State and local officials, and is described in detail in the The Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan (under a separate cover), and is implemented in conjunction with The Ottawa County Radiological Emergency Response Plan, and The Lucas County Radiological Emergency Response Plan (under separate covers).

At a General Emergency classification Davis-Besse, through the Emergency Director, shall make offsite protective action recommendations to state and local authorities, based on emergency conditions. The FENOC PAR determination process has been developed in accordance with NUREG-0654 Supplement 3 revision 1, and its PAR logic diagram. The process includes consideration of precautionary protective actions, wind persistence, rapidly progressing release scenarios, hostile-action based events, and termination of protective actions. It also includes considerations that embody Offsite Response Organizations input at the various decision points as identified in the guidance.

Offsite protective action recommendations will be made for affected predetermined subareas.

(Refer to the Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan for description of the Davis-Besse 10-mile emergency planning zone subareas.) The preferred offsite protective action recommendation (PAR) is evacuation. A sheltering PAR will be considered when known roadway impediments impact the ability to evacuate a large portion of the Emergency Planning Zone, during a controlled short duration release, and during a Hostile-Action based event. Dose to the public from any actual or potential radiological release are evaluated prior to the determination of these sheltering recommendations.

The means to warn or advise persons involved in taking protective actions is the responsibility of the Ottawa County EMA Director, Lucas County EMA Director, and the Ottawa and Lucas County emergency organizations. These counties are responsible for the preparation and dissemination of public information material related to implementation of protective actions for the general public. The Ottawa County Sheriff's Office will authorize the broadcast of appropriate Emergency Alert System messages to the public, when necessary. The general content of these messages is contained in the Ottawa County Plan, the Lucas County Plan, and the State of Ohio Plan.

6-11 DBNPS Emergency Plan Revision XX 6.4.3 Use of Onsite Protective Equipment and Supplies Table 6-1 summarizes typical protective action recommendations for the general public and emergency workers. Tables 6-2, 6-3, 6-4, and 6-5 provide guidelines for the expected local protection against direction and inhalation exposure afforded by structures. The following onsite locations have been designated for assembly and dispatch of emergency teams:

a. Operations Support Center

b. Radiological Testing LaboratoryAdmin Building.

The exact location, type, and quantity of emergency equipment and supplies is specified in the Emergency Plan Procedures.

6.4.4 Contamination Control Measures

a. Station Area:

Access to the owner-controlled area will be limited. Contamination control within the station shall be exercised in accordance with approved Radiation Protection procedures.

b. Offsite Areas:

It is the responsibility of the State Department of Agriculture, in conjunction with the Department of Health and the Ohio Environmental Protection Agency, to issue guidance and coordinate actions to control the use and transport of contaminated agricultural products.

6.4.5 Ingestion Pathway Control Measures The Ingestion Pathway EPZ (50-mile radius) has been established to address the additional concern for ingestion of contamination. There are two levels at which protective actions may be recommended by the State (i.e., preventive and emergency levels) for food and water contamination. Suggested action levels for ground, food, and water contamination are given in Table 6-6.

6.5 Aid to Affected Personnel 6.5.1 Emergency Personnel Exposure Under emergency conditions, it may not be possible to perform mitigative/protective actions, while maintaining exposure (i.e., radiation doses) below limits specified in 10CFR20. Saving a life, measures to circumvent substantial doses to population groups, or preservation of safety related equipment, may be sufficient cause for above normal doses.

The following are the exposure limits based on EPA-400-R-92-001 guidance for these emergency activities:

6-12 DBNPS Emergency Plan Revision XX

a. Mitigative/protective actions:

Limit doses to the following when protecting valuable property and lower doses are not practicable:

1. 10,000 mrem Total Effective Dose Equivalent (TEDE)

2. 30,000 mrem Lens Dose Equivalent (LDE)

3. 100,000 mrem:

Total Organ Dose Equivalent (TODE)

Shallow Dose Equivalent (SDE) to the skin of the whole body or to any extremity

b. Lifesaving actions:

Limit doses to the following when protecting large populations or performing life saving activities and lower doses are not practicable:

1. 25,000 mrem TEDE

2. 75,000 mrem LDE

3. 250,000 mrem Total Organ Dose Equivalent (TODE)

Shallow Dose Equivalent (SDE) to the skin of the whole body or to any extremity The Emergency CoordinatorDirector has the authority to permit the above exposures in excess of the 10 CFR 20 occupational dose limits. This responsibility may be delegated to the Emergency Plant Manager.

Personnel involved in any of the above actions must be volunteers, and cognizant of the effects of such doses.

Emergency worker dose records shall be maintained in accordance with Davis-Besse RP Procedures.

Although doses in excess of the normal legal limits may be authorized, the Emergency CoordinatorDirector will ensure that all doses are kept ALARA.

6.5.2 Thyroid Blocking A ready supply of suitable thyroid blocking agent is maintained and available for use by emergency workers. Guidance for administration of the blocking agent will be provided by medical advisors, and is specified in emergency plan procedures.

The Emergency CoordinatorDirector or, when designated, the Emergency Plant Manager shall authorize the use of the thyroid blocking agent, i.e., potassium iodide (KI).

6-13 DBNPS Emergency Plan Revision XX The State of Ohio has elected to distribute and stockpile potassium iodide (KI) for the general public. At a General Emergency the Ohio Department of Health in coordination with the local Health Departments may elect to recommend that the general public take potassium iodide.

6.5.3 Decontamination and First Aid Decontamination materials, including specialized equipment and supplies are available in station decontamination areas. Portable instruments for personnel monitoring and portal monitors are available at the RCA entrance. Decontamination showers and sinks, both of which drain to the radwaste system, are also located in the Decontamination Area.

Action levels for determining the need for decontamination of personnel and equipment are specified in the Davis-Besse RP Procedures.

Personnel found to be contaminated will be decontaminated by Radiation Protection personnel (or other qualified personnel, as specified in RP Procedures). It is preferred that personnel decontamination be performed by trained RP personnel.

Measures shall be taken to prevent the spread of contamination. Such measures may include isolating the affected areas, placing contaminated personnel in "clean" clothing before moving them, and decontaminating affected personnel, their clothing, and equipment prior to release.

Emergency first aid and medical treatment will be given to injured personnel who are contaminated. Station personnel trained in first aid are available onsite, on a 24-hour basis, and will assist injured personnel. Provisions have been made to ensure contaminated and injured personnel receive specialized medical treatment, if necessary. H. B. Magruder Hospital, ProMedica Memorial Hospital, and Mercy St. Charles Hospital have agreed to accept contaminated patients for emergency medical and surgical treatment. If affected personnel must be transported, measures will be taken to limit the spread of contamination.

Any contaminated patient moved to an offsite facility will be accompanied by a member of the RP staff. If during the same incident, more than one victim is involved, the first victim will be accompanied by a member of the RP staff who will remain at the receiving facility during transport of the remaining patients. If more than one offsite facility is involved, then a member of the RP staff shall be present at each offsite facility. If necessary, a physician may be requested to provide onsite medical assistance.

6-14 DBNPS Emergency Plan Revision XX 6.5.4 Medical Transportation Ambulance service for Davis-Besse is provided for by a letter of agreement with Carroll Township Emergency Medical Service.

6.5.5 Medical Treatment Arrangements for hospital and medical services for injured and/or contaminated/over-exposed personnel are provided for by letters of agreement with the. Magruder Hospital; ProMedica Memorial Hospital; Mercy St. Charles Hospital.

The services of the radiological emergency assistance provider assures personnel providing services are prepared and qualified to handle radiological emergencies.

6-15 DBNPS Emergency Plan Revision XX TABLE 6-1 PAGs for the Early Phase of a Nuclear Incident PAG Protective Action (Projected Dose) Comments Evacuation (or sheltering1) 1-5 rem2 Evacuation (or for some situations, sheltering1) should normally be initiated at 1 rem.

Administration of stable iodine 25 rem3 Requires approval of State medical officials

¹Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site-specific conditions.

²The sum of the effective dose equivalent resulting from exposure to external sources and the committed effective dose equivalent incurred from all significant inhalation pathways during the early phase. Committed dose equivalent to the thyroid and to the skin may be 5 and 50 times larger, respectively.

³Committed dose equivalent to the thyroid from radioiodine.

Guidance on Dose Limits for Workers Performing Emergency Services Dose Limit¹ Activity Condition (rem) 5 all 10 protecting valuable lower dose not practicable property 25 life saving or protection lower dose not practicable of large populations

>25 life saving or protection only on a voluntary basis to persons fully of large populations aware of the risks involved

¹Sum or external effective dose equivalent and committed effective dose equivalent to nonpregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value. These limits apply to all doses from an incident, except those received in unrestricted areas as members of the public during the intermediate phase of the incident.

Reference:

Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

(EPA-400-R-92-001) U.S. Environmental Protection Agency, Washington, D.C.,

May 1992.

6-16 DBNPS Emergency Plan Revision XX TABLE 6-2 RECOMMENDED PROTECTIVE ACTIONS Accident Phase Exposure Pathway Examples Of Actions To Be Recommended Emergency Phase Inhalation of gases, radio- Evacuation, shelter, access control, (0 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) iodine, or particulate respiratory protection, prophylaxis (thyroid protection)

Direct whole body dose Evacuation, shelter, access control Ingestion of milk Take cows off pasture, prevent cows from drinking surface water, discard contaminated milk, or divert to stored products such as cheese INTERMEDIATE Ingestion of fruits and Wash all produce, or impound produce, PHASE2 vegetables delay harvest until approved, substitute uncontaminated produce Ingestion of water Cut off contaminated supplies, substitute from other sources, filter, demineralize (4 to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) Whole body exposure and Relocation, decontamination, access inhalation control LONG TERM Ingestion of food and water Decontamination, condemnation, or PHASE3 contaminated from the soil destruction of food; deep plowing, either by resuspension or condemnation, or alternate use of land uptake through roots (2 to 14 days) Whole body exposure from Relocation, access control, deposition material or decontamination, fixing of contamination, inhalation of resuspended deep plowing material.

¹Emergency phase - Time period of major release and subsequent plume exposure.

²Intermediate phase - Time period of moderate continuous release with plume exposure and contamination of environment.

³Long Term Phase - Recovery period.

6-17 DBNPS Emergency Plan Revision XX TABLE 6-3 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE Shielding¹ Representative Range Structure or Location Factor Outside 1.0 --

Vehicles 1.0 --

Wood-frame house² 0.9 --

(no basement)

Basement of wood house 0.6 0.1 to 0.73 Masonry House (no basement) 0.6 0.4 to 0.73 Basement of masonry house 0.4 0.1 to 0.53 Large office or industrial 0.2 0.1 to 0.33,4 building 1

The ratio of the dose received inside the structure to the dose that would be received outside the structure.

2 A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.

3 This range is mainly due to different wall materials and different geometries.

4 The shielding factor depends on where the personnel are located within the building (e.g., the basement or an inside room).

Reference:

Aldrich, D.C., D.M. Ericson, Jr., and T. D. Johnson. Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures.

Sandia Laboratories Report SAND 77-1725 (February 1978).

6-18 DBNPS Emergency Plan Revision XX TABLE 6-4 SELECTED SHIELDING FACTORS FOR AIRBORNE RADIONUCLIDES Wood house, no basement 0.9 Wood house, basement 0.6 Brick house, no basement 0.6 Brick house, basement 0.4 Large office or industrial building 0.2 Outside 1.0

Reference:

Aldrich, D.C., D.M. Ericson, Jr., and T. D. Johnson. Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures. Sandia Laboratories Report SAND 77-1725 (February 1978).

6-19 DBNPS Emergency Plan Revision XX TABLE 6-5 REPRESENTATIVE SHIELDING FACTORS FOR SURFACE DEPOSITED RADIONUCLIDES Structure or Location Representative¹ Representative Shielding Factor Range 1 m above an infinite smooth surface 1.00 --

1 m above ordinary ground 0.70 0.47-0.85 1 m above center of 50-ft roadways, 0.55 0.4-0.6 50% decontaminated Cars on 50-ft road:

Road fully contaminated 0.50 0.4-0.7 Road 50% decontaminated 0.50 0.4-0.6 Road fully decontaminated 0.25 0.2-0.5 Trains 0.40 0.3-0.5 One and two-story wood-frame house 0.4² 0.2-0.5 (no basement)

One and two-story block and brick house 0.2² 0.04-0.40 (no basement)

House basement, one or two walls fully exposed 0.1² 0.03-0.15 One story, less than 2 ft of basement, walls 0.05² 0.03-0.07 exposed Two stories, less than 2 ft of basement, walls exposed 0.03² 0.02-0.05 Three- or four-story structures, 5000 to 10,000 ft² per floor First and second floors 0.05² 0.01-0.08 Basement 0.01² 0.001-0.07 Multistory structures, >10,000 sq. ft. per floor:

Upper floors Basement 0.01² 0.001-0.02 0.005² 0.001-0.015

¹The ratio of dose received inside the structure to the dose that would be received outside the structure.

²Away from doors and windows.

Reference:

Aldrich, D.C., D.M. Ericson, Jr., and T. D. Johnson. Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures. Sandia Laboratories Report SAND 77-1725 (February 1978).

6-20 DBNPS Emergency Plan Revision XX TABLE 6-6 Page 1 of 2 GUIDELINES FOR PROTECTION AGAINST INGESTION OF CONTAMINATION A. Response Levels for Preventive PAG A "Preventive PAG" is the projected dose commitment value at which responsible officials should take protective actions with minimal impact, to prevent or reduce the radioactive contamination of human food or animal feeds.

Sample Media I-131¹ Cs-134² Cs-137² Sr-90 Sr-89 Initial Activity Area Deposition (µCi/m2) 0.13 2.0 3.0 0.5 8.0 Forage Concentration³ (µCi/kg) 0.05 0.8 1.3 0.18 3.0 Peak Milk Activity (µCi/l) 0.015 0.15 0.24 0.009 0.14 Total Intake (µCi) 0.09 4.0 7.0 0.2 2.6

¹The cumulative intake of Iodine-133 via milk is about 2 percent of Iodine-131 assuming equivalent deposition.

²Intake of Cesium via the meat/person pathway for adults may exceed that of the milk pathway; therefore, such levels in milk should cause surveillance and protective actions for meat as appropriate. If both Cesium-134 and Cesium-137 are equally present, the response levels should be reduced by a factor of two.

³Fresh weight.

Reference:

Federal Radiation Council. Radiation Protection Guidance for Federal Agencies. Federal Register (May 22, 1965).

6-21 DBNPS Emergency Plan Revision XX TABLE 6-6 Page 2 of 2 GUIDELINES FOR PROTECTION AGAINST INGESTION OF CONTAMINATION B. Response Levels for Emergency PAG An "Emergency PAG" is the projected dose commitment value at which responsible officials should isolate food containing radioactivity, to prevent its introduction into commerce, and at which responsible officials should determine whether condemnation or another method of disposal is appropriate. At the Emergency PAG, higher impact actions are justified because of the projected health hazards.

Sample Media I-131 Cs-134² Cs-137 Sr-90 Sr-89 Infant3/Adult Infant4/Adult Infant4/Adult Infant4/Adult Infant4/Adult Initial Activity 1.3/18 20/40 30/50 5.0/20 80/1600 Area Deposition

(µCi/m2)

Forage 0.5/7.0 8.0/17 13/19 1.8/8.0 30/700 Concentration5

(µCi/kg)

Peak Milk 0.015/2.0 1.5/3.0 2.4/4.0 0.09/0.4 1.4/30 Activity (µCi/l)

Total Intake 0.9/10 40/70 70/80 2.0/7.0 26/400

(µCi) 1 The cumulative intake of Iodine-133 via milk is about 2 percent of Iodine-131 assuming equivalent deposition.

2 Intake of cesium via the meat/person pathway for adults may exceed that of the milk pathway; therefore, such levels in milk should cause surveillance and protective actions for meat as appropriate. If both Cesium-134 and Cesium-137 are equally present, the response levels should be reduced by a factor of 2.

3 Newborn infant, includes fetus (pregnant woman) as critical segment of population for Iodine-131.

4 "Infant" refers to child less than 1 year of age.

5 Fresh weight.

Reference:

Federal Radiation Council. Radiation Protection Guidance for Federal Agencies.

Federal Register (May 22, 1965).

6-22 DBNPS Emergency Plan Revision XX Figure 6-1 Page 1 of 4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS UNUSUAL ACTIONS EVENT Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical assistance, UNUSUAL EVENT. as requested Assess and respond as needed.

Augment on-shift personnel as needed.

Terminate with verbal summary to offsite authorities, or escalate to a higher classification if conditions warrant. Standby until termination.

6-23 DBNPS Emergency Plan Revision XX Figure 6-1 Page 2 of 4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS ACTIONS ALERT Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical assistance, as requested.

ALERT Activate EOCs and other response Assess and respond. centers as needed.

Activate OSC, TSC, EOF & Staff JIC. Alert key emergency personnel to standby status.

DispatchPlace RFMTs on standby.

Alert Radiation Monitoring Teams.

Activate communication networks.

Maintain ALERT status until Notify the CAC. termination, downgrade, or escalation of the emergency classification.

Provide periodic plant status updates.

Provide meteorological conditions to offsite authorities.

Make Senior Management and Technical personnel available to the County, State, and NRC for consultation.

Assemble Protected Area personnel Terminate with verbal summary to offsite authorities, or escalate to a higher classification if conditions warrant.

6-24 DBNPS Emergency Plan Revision XX Figure 6-1 Page 3 of 4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS SITE AREA ACTIONS EMERGENCY Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical assistance, as requested.

SITE AREA EMERGENCY Activate sirens and transmit an Assess and respond. EAS message.

Activate OSC, TSC, EOF, & Staff JIC Activate the State & County EOCs, and CAC. and other response centers.

Dispatch RFMTs. Alert personnel needed for evacuation of the public to standby status.

Activate communication networks.

Dispatch key personnel and RMTs Make Senior Management and to nearby locations.

Technical personnel available to the County, State, and NRC for Activate communication networks.

consultation.

Continuously assess data from D-B Provide periodic plant status updates. and RMTs with regard to changes to Protective actions already initiated for Provide meteorological conditions the public and mobilized evacuation to offsite authorities. resources.

Evacuate nonessential personnel Recommend placing milk animals from the Protected Area, and perform within 2 miles on stored feed and accountability. Assemble personnel assess the need to extend distance.

within the Owner Controlled Area Maintain SITE AREA EMERGENCY status Terminate, downgrade, or escalate until termination, downgrade, or escalation the emergency classification as of the emergency classification.

conditions change.

6-25 DBNPS Emergency Plan Revision XX Figure 6-1 Page 4 of 4

SUMMARY

OF TYPICAL EMERGENCY MEASURES ERO OFFSITE ACTIONS GENERAL ACTIONS EMERGENCY Promptly inform offsite authorities and Provide for fire, law enforcement or Emergency Response Organization of the medical assistance, as requested.

GENERAL EMERGENCY and Offsite Protective Action Recommendations Activate sirens and transmit an Assess and respond. EAS message.

Activate OSC, TSC, EOF, & Staff JIC Activate the State & County EOCs, and CAC. and other response centers.

Dispatch RFMTs. Recommend sheltering or evacuating within a 2 mile radius of the plant, and Activate communication networks. 5 miles downwind, and assess the need for extending these distances.

Make Senior Management and Technical personnel available to the Dispatch key personnel and RMTs.

County, State, and NRC for consultation.

Recommend placing milk animals within 2 miles on stored feed and Provide periodic plant status updates. assess the need to extend distance.

Provide meteorological conditions Continuously assess data from to offsite authorities. D-B and RMTs with regard to changes to protective actions already Provide dose estimates for actual initiated for the public.

releases (if appropriate).

Maintain GENERAL EMERGENCY status Evacuate nonessential personnel until termination, or downgrade from the site. of the emergency.

Terminate, or downgrade, the emergency classification as conditions change.

6-26 DBNPS Emergency Plan Revision XX Figure 6-2 Page 1 of 2 EMERGENCY NOTIFICATION:

UNUSUAL EVENT Davis-Besse Nuclear Power Station Ottawa County Lucas County State of Ohio DBNPS Emergency Corporate Organization Management US NRC

6-27 DBNPS Emergency Plan Revision XX Figure 6-2 Page 2 of 2 EMERGENCY NOTIFICATION:

ALERT, SITE AREA EMERGENCY, GENERAL EMERGENCY Davis-Besse Nuclear Power Station US DBNPS Emergency State of Ottawa Lucas NRC Organization Ohio County County Corporate State of Sandusky OSHP Management Michigan County Bowling Green US Coast Erie Guard County Federal Ohio National State Guard Parks OSHP FEMA Sandusky EAS/

Canada NOAA

6-28 DBNPS Emergency Plan Revision XX Figure 6-3 OFFSITE EMERGENCY EVACUATION ROUTES

7-1 DBNPS Emergency Plan Revision XX 7.0 EMERGENCY FACILITIES AND EQUIPMENT This section describes the equipment and facilities used at DBNPS to:

Assess the extent of accident hazards.

Mitigate the consequences of an accident.

Provide protection to station personnel.

Support accident mitigation operations.

Provide immediate care for injured personnel.

A diagram identifying the emergency facilities and their general location relative to each other, is included as Figure 7-1, "Emergency Facilities by General Location". Many of the DBNPS facilities and much of the equipment is normally used for routine plant operations. Other items are reserved for use only on an "as needed" basis.

7.1 DBNPS In-Plant Emergency Facilities 7.1.1 Control Room

a. The Control Room is the location from which the plant is operated. It contains the instrumentation, controls, and displays for:

1. Nuclear systems

2. Reactor coolant systems

3. Steam systems

4. Electrical systems

5. Safety systems (including engineered safety features)

6. Accident monitoring systems.

The operating shift is staffed in accordance with TS 5.2.2 and TRM 10.2.1 requirements. Control manipulations and the safe operation of the plant are directed by the Senior Reactor Operator licensed Shift Manager and Unit Supervisor, and are performed by licensed Reactor Operators.

b. During abnormal operating conditions, the complexity of Station responsibilities increases significantly and the Control Room transforms into an emergency response center. These responsibilities include the following:

1. Diagnosing the abnormal conditions.

2. Performing mitigative actions.

3. Mitigation of abnormal conditions.

4. Management of plant operations.

5. Management of emergency response.

6. Informing Federal, State, and local officials.

7. Recommendations for public protective measures to State and local officials.

8. Restoring the plant to a safe condition.

9. Recovering from the abnormal conditions.

7-2 DBNPS Emergency Plan Revision XX Initially, Control Room personnel will assume all of these responsibilities.

However, by activating other emergency response facilities, much of this responsibility is turned over to other personnel.

During emergencies, the Emergency Assistant Plant Manager uses the Shift Manager's Office, which is within the Control Room envelope, to observe and provide guidance to the Shift Manager for direction and control of in-plant activities.

7.1.2 Operations Support Center (OSC)

The OSC is located on the third floor of the Containment Access Facility. The OSC is the assembly and dispatch point for damage control and repair teams.

Activation of the OSC is required within 60 minutes of the declaration of an Alert or higher classification.

7.2 Davis-Besse Administration Building (DBAB) Facilities The DBAB contains the Emergency Response Facilities (ERFs) necessary to assist Control Room personnel in accident assessment and abnormal operating conditions. The ERF area of the DBAB has been designed to provide radiological habitability for approximately 30 days during a design basis accident, as described in Chapter 15 of the Davis-Besse Updated Safety Analysis Report.

Within this protected environment, the ERFs function to:

1. Help the Control Room staff determine the plant safety status.

2. Relieve the Control Room staff of peripheral duties and communications not directly related to reactor system manipulations.

3. Prevent congestion in the Control Room.

4. Provide assistance to the operators from technical personnel who have comprehensive plant data at their disposal.

5. Provide a coordinated emergency response by both technical and management personnel.

6. Provide reliable communications between onsite and offsite emergency response personnel.

7. Provide relevant plant data to the NRC for its analysis of abnormal plant operating conditions.

The DBAB Annex and the second floor of the DBAB provide general administrative office space for the Station. The ERFs are on the first floor and are either in the restricted (north end) or unrestricted areas (south end).

The restricted area consists of two mechanical equipment rooms, a computer equipment room, telephone equipment room, Technical Support Center (TSC), TSC Library, Radiological Testing Laboratory (RTL), badging area, kitchen, and two areas designated as private office space.

7-3 DBNPS Emergency Plan Revision XX The unrestricted area consists of the Energy Education Center (EEC), a Site Emergency Operations Center (SEOC) and several work/conference rooms. The DBAB is approximately 2100 feet from the Control Room. They are linked by a paved road which is completely contained within the site security boundary.

The water supply to the DBAB can store up to 4,000 gallons within the buildings, if necessary.

Electrical power for the DBAB is supplied by the grid through a power structure approximately 200 feet east of the building. Backup power is provided by a diesel generator and vital loads are protected by an uninterruptible power supply.

The electrical and mechanical systems within the DBAB are computer controlled and activated using the Central Control and Monitoring System (CCMS). This system maintains building temperature and ventilation, and provides security alarms, trouble alarms, and fire protection, as conditions may warrant. For fires, an alarm on the CCMS can automatically activate the dry main sprinkler system in the records management vault; or a wet main sprinkler system in any other area.

To minimize radiation exposure, two emergency ventilation air handling units are provided; one for the restricted area (north end) and one for the remaining areas (south end). By design, either unit can supply the restricted area, should the primary unit fail. Upon local activation, the units will switch to the recirculation mode employing high efficiency filters to minimize the introduction of airborne radiation sources into the emergency facilities.

7.2.1 Technical Support Center (TSC)

The TSC serves as the workplace for key ERO personnel who, during emergencies, assist the Control Room staff, perform accident assessment, and determine appropriate protective actions. The TSC provides for direct voice and data communication with the Control Room. The TSC also contains the Safety Parameters Display System (SPDS).

The SPDS computer was designed to provide sufficient Station information and data communication for operations personnel to evaluate and diagnose station conditions and activities so as to conduct emergency operations in an orderly manner. The SPDS provides data communication to the EOF, TSC, and Control Room. Because the SPDS aids in the detection and monitoring of plant transients and accidents, the SPDS is capable of functioning during and following most events expected to occur during the life of the station.

The TSC is in the restricted side of the DBAB.

The TSC contains workspace for up to 25 people, within a main work area and three conference areas.

Activation and operation of the TSC is required within 60 minutes of the declaration of an Alert or higher classificationcontained in the Emergency Plan Procedures.

7.2.2 Radiological Testing Laboratory (RTL)

The RTL is a facility near the TSC for equipping and dispatching Radiological Monitoring Teams; and for the receipt, counting, and disposition of potentially contaminated environmental samples. The RTL reports to the Dose Assessment Coordinator in the near site EOF.

7-4 DBNPS Emergency Plan Revision XX The RTL is on the ground floor of the DBAB.

7.2.23. Private Office Areas Two areas are available as private office space for the NRC Site Director and other key emergency response officials. These office areas are in the restricted area of the DBAB.

7.2.34 Equipment Rooms The telephone equipment room contains communications equipment necessary to connect the site telephone system into company and external phone systems.

Two mechanical equipment rooms contain redundant systems for electrical distribution, heating and ventilation, and compressed air. Both mechanical equipment rooms are in the restricted side of the DBAB.

7-5 DBNPS Emergency Plan Revision XX 7.3 Near Site Emergency Response Facility The near site emergency response facilities are located near Lindsey, Ohio at the corner of SR 20 and SR 590. The facility houses the Emergency Operations Facility, the Alternate TSC and a muster area for station personnel. The facility has access to station radio and public Address systems. The facility is equipped with an uninterruptable power system and an emergency diesel generator. The Near Site Emergency Response Facilities include the following:

7.3.1 Emergency Operations Facility (EOF)

The EOF provides a central location for the development of protective action recommendations by DBNPS and for representatives from offsite organizations. The EOF staff evaluates the magnitude and effects of actual or potential radioactive releases and provides management assistance in the decision-making process to protect the public health and safety. Recommendations are based on station conditions with radiological and meteorological data obtained, through the Safety Parameters Display System (SPDS) and the Meteorological data acquisition computer. The EOF utilizes various communication systems to establish and maintain communications with State, Federal, and local officials, and mobile RadiationField Monitoring Teams (RFMTs).

The EOF provides space for at least 22 people.

Activation and operation of the EOF is required within 60 minutes of the declaration of an Alert or higher classification.described in the Emergency Plan Procedures.

7.3.2 Alternate TSC The Alternate TSC provides a location for the TSC in the event that the onsite TSC is not available. The Alternate TSC is equipped with those drawings, procedures, computer system and communications to be able to support the onsite response.

Activation and oOperation of the Alternate TSC is described in the Emergency Plan Procedures.

7.3.3. Muster Area A Muster Area for approximately 75 individuals is available for the staging of personnel in the event that the station is not accessible.

7.4 Other Company Emergency Facilities 7.4.1 Joint Information Center (JIC)

The Joint Information Center (JIC) is the emergency facility for coordinating news statements and providing joint media briefings during an event at Davis-Besse. The Company, state, local and federal agencies represented at the JIC jointly prepare news information for release to the public via the news media. Equipment and work spaces for Public Information Officers and their staffs are provided to support timely communications on plant status and emergency response actions. JIC facilities include news briefing areas for electronic and print media representatives. JIC support is available for any plant

7-6 DBNPS Emergency Plan Revision XX emergency. However, facility staffingactivation is mandatory at (and above)an the Alert or higher emergency classification level. The JIC is located at a FirstEnergy Corporation facility outside the 10-mile EPZ.

7.4.2 Corporate Emergency Facilities Company facilities located throughout the service districts are available to provide support for the Corporate Assistance Center (CAC). Certain Company facilities have been designated to support coordination of CAC activities and centralized management of Company resources. The primary company facility identified for Fleet Emergency Response Support is the Corporate Assistance Center (CAC), located at the unaffected FirstEnergy nuclear station/plant..

7.5 County and State Emergency Operations Centers 7.5.1 Ottawa County Emergency Operations Center Potential or actual emergencies at Davis-Besse could impact those persons who reside in Ottawa County within the 10-mile Emergency Planning Zone. To aid in protecting these residents, Ottawa County has a dedicated Emergency Operating Center (EOC) which meets the minimum federal criteria for space, communications, warning systems, and supplies.

The EOC is in the basement of the Ottawa County Courthouse Annex, in Port Clinton, Ohio. Communications during an emergency at Davis-Besse are coordinated through this facility, and the Ottawa County Sheriffs Office.

Davis-Besse dispatches a technical liaison to the EOC to help to aid offsite officials in understanding the event.

7.5.2 Lucas County Emergency Operations Center Potential or actual emergencies at Davis-Besse could impact those persons who reside in the eastern portion of Lucas County within the 10-mile Emergency Planning Zone. To aid in protecting these residents, Lucas County has a dedicated Emergency Operating Center (EOC) which meets the minimum federal criteria for space, communications, warning systems, and supplies.

The EOC is located in the Lucas County Emergency Services Building, 2144 Monroe Street, Toledo, Ohio. Communications during an emergency at Davis-Besse are coordinated through this facility, and the Lucas County Sheriffs Office.

Davis-Besse dispatches a technical liaison to the EOC to help to aid offsite officials in understanding the event.

7.5.3 State of Ohio Emergency Operations Center The State Emergency Operations Center is operated by the Ohio Emergency Management Agency, in Worthington, Ohio. During an emergency, representatives from all State agencies assemble at the State EOC to manage the response efforts. A technical liaison will also be sent to the State EOC, to help coordinate communications and provide technical advice.

7-7 DBNPS Emergency Plan Revision XX A reliable communications system, utilizing the Fixed Monitor Station Network of the State Highway Patrol, ties all areas, and both the Ottawa and Lucas County Emergency Operations Centers into the State EOC.

7.6 Communications Systems 7.6.1 Normal Communications Systems A comprehensive communications network with backup capabilities has been provided to assure reliable communications among the various emergency facilities and agencies. The network is composed of the following systems:

a. Onsite Commercial telephone systems:

1. A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides in/out bound offsite communications paths.

2 priority circuits connect directly into the administration building PBX from the commercial telephone system.

1 priority circuit connects directly into the plant office building PBX from the commercial telephone system.

The PBX system is self-contained to the Davis-Besse Nuclear Power Station and has backup power.

2. In addition to the company PBX system, there are also a limited number of lines that bypass the PBX system and are connected directly into the local phone company.

b. Near site Commercial telephone systems:

1. Voice over IP service delivered via Point to Point circuits.

c. A public address system (Gai-tronics), which is totally separate from the telephone system, includes handset stations, loud speakers, and portable station jacks. It provides five normal plant channels, five maintenance channels, two switchyard maintenance channels, and four fuel handling channels. Access to the Gai-tronics system is available at the near site emergency response facilities.

d. A radio system capable of transmitting and receiving the following types of voice communications:

1. A two-way mobile channel is normally used by service dispatchers in various locations to mobile units.

2. A channel for direct radio communications with the Ottawa County Sheriff's dispatcher.

3. A channel used exclusively by Security.

4. A channel used by the Maintenance Department for normal day-to-day transmissions.

7-8 DBNPS Emergency Plan Revision XX

5. A channel is used by Operations personnel for normal day-to-day transmissions.

e. Radiation Monitoring Teams communicate on a five-channel trunked 800 megahertz radio system. Cellular telephones are also available if needed.

f. ERO mobile devices are carried by key emergency responders to provide 24-hour a day coverage. Emergency classifications are communicated to emergency responders and can be used to communicate with other key personnel.

g. A Computerized Automated Notification System (CANS) is available to facilitate the notification process. One telephone line is dedicated for system activation by the Control Room or Security, and the others are connected to the telephone network. The CANS is capable of sending notification messages to all ERO mobile devices and individually calling all emergency response personnel. The system communicates the emergency classification and logs personnel response times.

7.6.2 Emergency Communications Systems

a. The following phone systems are dedicated for emergency communications:

1. The Davis-Besse 4-Way Phone including the State and County EOCs, the Ohio Highway Patrol Office, the Lucas County and Ottawa County Sheriff's dispatcher offices, the Emergency Operations Facility, and the Control Room.

2. A diverse network of commercial telephones, on uninterruptable power has been installed to provide:

a. NRC Emergency Notification System (ENS) telephone ("red phone").

b. NRC Health Physics Network (HPN) telephones.

c. Emergency Response Data System (ERDS) data lines.

3. Media press lines.

b. DBNPS has also established two separate communication bridges between various ERFs to ensure reliable and timely exchange of information between the emergency organizations. These bridges consist of the following:

1. Technical Data Bridge Provides a technical data link for the following:

a) Control Room b) Technical Support Center c) Emergency Operations Facility d) Operations Support Center

2. Radiation Management Bridge

7-9 DBNPS Emergency Plan Revision XX Provides dedicated communications for radiological conditions and radiation protection management information among the following:

a) Control Room b) Technical Support Center c) Operations Support Center d) Dose Assessment Center Emergency Operations Facility 7.6.3 Maintenance of Emergency Telephone Numbers The communication system which has been provided assures reliable onsite and offsite communications in any emergency. DBNPS maintains an Emergency Plan Telephone Directory, which is kept current by the Manager, Regulatory Compliance and Emergency Response. This directory is reviewed quarterly and includes ERO personnel, the radiological emergency assistance provider, hospitals, local, state, and federal agencies, and others with special qualifications for emergency support.

7.7 Alarms There are three station alarms as follows:

7.7.1 FIRE - Rise and Fall Siren 7.7.2 ACCESS EVACUATION - Pulsed Tone Burst 7.7.3 INITIATE EMERGENCY PROCEDURES - Warbled Tone The alarms are activated from the Control Room. The FIRE, INITIATE EMERGENCY PROCEDURES, and ACCESS EVACUATION alarms sound in all plant areas (i.e., station office building, personnel shop facility, radiologically controlled area, fuel handling area, outdoor areas, primary access facility, etc.)

7-10 DBNPS Emergency Plan Revision XX 7.8 Prompt Notification System Early warning of, and instructions to the population-at-risk are done under the direction of the Ohio Emergency Management Agency (OEMA) in conjunction with local officials, the Ottawa County Emergency Management Agency, and the Lucas County Emergency Management Agency. Prompt notification by the DBNPS is the vital first link in this process.

Once local and state authorities have been notified, several methods to warn the population-at-risk can be utilized. The method used and the time required will depend upon the severity of the situation. The methods available are:

7.8.1 Prompt Notification System (PNS) - Fifty-four high powered rotating sirens have been installed to provide an acoustic alerting signal for the residents and transients within the 10-mile radius of the Davis-Besse Station. Each siren is equipped with an independent battery backup which will allow operation during the loss of normal AC electrical power. The sirens have been located to meet the design objectives of Appendix 3 in NUREG-0654/

FEMA-REP-1, REV. 1. Local authorities activate the warning sirens from the Ottawa County Sheriff's Office. The sounding of the Prompt Notification System alerts the public to tune to local radio stations for EAS messages.

The PNS sirens are tested from the Ottawa County Sheriffs Dispatch Center as follows:

A three-minute audible test is performed at least once per year A one-minute audible test is performed at least monthly A three-minute, one-minute or a silent test is performed weekly Back-up Alert and Notification Methods - Backup alert and notification for the Davis-Besse 10-mile EPZ is achieved through pre-planned route alerting. This method has been approved by the Federal Emergency Management Agency (FEMA). County emergency management agencies will be prepared to make special provisions such as back up route alerting for those areas with sirens out of service, in the event of an emergency. The route alerting system utilizes planned routes for each siren that is unable to be activated.

7.8.2 Emergency Alert System (EAS) - State and local authorities can broadcast information, instructions, and necessary bulletins to the general public over the EAS (e.g., from the local Sheriff's offices or their Emergency Operations Centers).

7.8.3 NOAA National Weather Service alert monitors can be pulsed, and automatically turned on to disseminate emergency information.

7.8.4 Central Dispatching - The Ottawa and Lucas County Sheriff's Offices have central dispatches, manned 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, to communicate with the police, fire, medical responders, and the OEMA.

7.8.5 Commercial Paging System - A paging system, backed up by the local telephone service, is used to permit immediate contact of local officials.

7.8.6 Emergency Vehicles - Vehicles with loudspeakers can be dispatched to various remote locations to broadcast warning messages.

7-11 DBNPS Emergency Plan Revision XX 7.8.7 House-To-House Notification - Local fire and police departments can perform house-to-house notification of residents in the affected areas around the plant.

Notification times have been included in the Evacuation Time Estimate. Information and appropriate advisories developed for the public, including transient areas, concerning the actions to be taken during an emergency, are available. Pertinent information can also be found in the local telephone directories.

Additional information regarding warning capability and information to transient areas around the plant can be found in The Ottawa County Plan for Response to Radiation Emergencies at Licensed Nuclear Facilities,Section II Part D; The Lucas County Radiological Emergency Response Plan,Section II Part E; and The Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan.

7.9 Assessment Facilities The systems and equipment described in the following sections ensure that the capability and resources are available to provide valid and continuing assessment throughout the course of an incident.

7.9.1 Radiation Monitoring System The onsite Radiation Monitoring System contributes to personnel radiological protection within the plant, in accordance with regulatory guidelines. The Radiation Monitoring System detects, alarms, and initiates emergency actions when radiation levels or radionuclide concentrations exceed predetermined levels. To perform these functions, area, liquid, and atmospheric monitoring subsystems are employed.

The data from these subsystems are displayed by readouts in the Control Room.

Additionally, certain monitors sound an alarm and are displayed on the Fire Detection System/Radiation Monitoring System (FDS/RMS) Console in the Control Room. A summary description of individual radiation monitor channels, described below, is provided in the Updated Safety Analysis Report (USAR) Table 11.4-1, Liquid Gas, and Airborne Radiation Monitors, and Table 12.1-3, Area Radiation Monitors.

In general the radiation monitoring equipment is designed in accordance with the following specifications:

a. Each monitoring station has adjustable, high level, low level, and power supply failure alarms.

b. Solid-state circuitry is used except for primary detectors.

c. The safety-related radiation monitors are powered from the essential instrument distribution panels. The non-essential radiation monitors are powered from the uninterruptible instrument distribution panels.

d. With the exception of the Kaman monitors, each radiation monitor is capable of being checked periodically with solenoid actuated check sources.

e. A pulse generator or current source is used for electrically checking each monitor or subsystem. Electrical input tests measure the functional operation of the monitoring system from the detector output through the readout devices.

f. The modules are designed so that an alarm and/or indication is initiated when failure occurs anywhere in the channel.

7-12 DBNPS Emergency Plan Revision XX 7.9.2 Area Radiation Monitoring The Area Radiation Monitoring subsystem is comprised of area monitors located throughout the plant. Under normal operating conditions, the area monitors warn personnel of increasing radiation level, which may result in a radiation health hazard. There are a total of 40 area monitors consisting of two types, Geiger-Mueller detectors and Ionization Chamber detectors. The detectors are housed in weather-proof containers and equipped with a remote controlled check source. The local alarm and readout for each of these channels is separate from the detector and is also housed in a weatherproof container.

These detectors can also monitor the high level of radiation that would be characteristic of the post-accident atmosphere in the containment. The detectors are desensitized by a lead shield.

The Control Room readout modules are located in the radiation monitoring panel in the Control Room.

7.9.3 Atmospheric Radiation Monitoring Atmospheric Radiation Monitoring measures radioactive material contained in the air.

The atmospheric radiation monitoring subsystem is comprised of monitors of the fixed and movable type. Each fixed atmospheric monitor is comprised of a particulate measuring channel, iodine measuring channel, and a gaseous measuring channel. The air sample that passes through each of these channels is obtained by means of a sampler and a pump assembly. Samples are obtained by means of a sampling head placed in a ventilation duct.

Portable atmospheric monitors are available for use during maintenance operations. These monitors are capable of monitoring particulate, iodines, and noble gases. The installed and portable atmospheric monitors provide both an audible alarm and visual indications when pre-determined setpoints are exceded for airborne radioactivity.

7.9.4 Process Radiation Monitoring Process radiation monitoring measures radiation given off radioactive material contained in process fluids within systems.

The process radiation monitoring subsystem consists of monitors each of which consists of a sampler, scintillation detector, and Control Room ratemeter module. The monitors readout in the Control Room on the individual ratemeter and two common recorders.

7-13 DBNPS Emergency Plan Revision XX 7.9.5 Radiation Monitoring Instruments and Equipment Radiation Monitoring Instruments and Equipment includes those instruments and equipment which may be taken into the field (both on and offsite) to determine the presence of gaseous, particulate or airborne radioactive material. This includes general survey instruments. Portable radiation survey instruments and personnel dosimetry and equipment are shown in Table 7-1.

7.9.6 Fire Protection and Detection Devices Fire protection at Davis-Besse is provided by (1) the Fire Protection Water System, and (2) the Fire Detection System.

a. Fire Protection Water System The Fire Protection Water System is a full-loop, piped system that supplies water for (1) sprinklers, (2) deluge water spray, (3) fire hydrants, and (4) hose connections that are located such that they provide fire protection for all major areas of the plant and site.

A Fire Water Storage Tank provides a source of water via the Electric Driven Fire Pump. A jockey pump maintains system piping full and pressurized.

The Diesel Driven Fire Pump takes suction from the intake forebay. In the event that a fire occurs, and either an automatic or manual system is initiated, the Fire Protection Water System piping pressure will decrease and cause the electric (120 psig) and the diesel (100 psig) fire pumps to start at their respective pressure setpoint, to meet system flow requirements.

Sprinkler systems provide a coverage of 0.3 gpm per square foot of floor area, for any (including the most remote) 3,000 square foot area; and 0.2 gpm per square foot, for any 10,000 square foot of floor area under the turbine operating and intermediate floors, and in all areas to which oil may spread in the event of an oil line break. This protection is also provided below major steel grating floor whether or not sprinklers are installed above.

Fire hydrants are connected to the main fire yard loop around the periphery of the station. A distribution header loop is provided within the turbine building, with four branch feeders from the underground fire yard loop. Each section of the header loop and each branch line are provided with isolation valves. The headers supply readily accessible, mounted, fire hose stations located throughout the turbine and auxiliary buildings.

Hose cabinets are provided throughout the auxiliary building. Each hose cabinet contains 50-75 feet of 11/2 inch hose, with an adjustable fog nozzle, and a separate 21/2-inch hose connection for local fire department use. Fire extinguishers are provided throughout the building.

Hose reel units are provided in the turbine building. Each reel is provided with 50-75 feet of 11/2 inch fire hose, and an adjustable fog and stream hose nozzle.

7-14 DBNPS Emergency Plan Revision XX Adjacent to each hose reel is a separate 21/2-inch hose connection for local fire department use. Portable fire extinguishers are located throughout the building.

Fire suppression to the Administration Building, Warehouse, Training Center, Primary Access Facility, and Service Building #3 consists of sprinkler systems and hose stations.

b. Fire Detection System The fire detection system is comprised of detectors located throughout Davis-Besse, especially in those areas not protected by sprinkler systems.

1. Temperature Rise Detectors Temperature rise detectors monitor the protected area and will send a signal to a local control cabinet and Control Room alarm if the rise in temperature reaches a setpoint.

2. Smoke and Vapor Detectors Ionization type smoke detectors monitor the area, and when activated, send a signal to a local control cabinet and Control Room alarm.

The Fire Detection Panels receive their inputs from the various detectors, and in turn send an alarm to the Control Room.

An alarm initiates when any of the following conditions occur within the Fire Detection System:

a) Fire b) Trouble c) Ground Fault If any of the above occur, a line printer, fed by the Fire Detection System/Radiation Monitoring System (FDS/RMS), will print out the alarm in the Control Room.

Upon receipt of an alarm, the Control Room operator acknowledges the alarm on the FDS/RMS console printer, and identifies the specific cause of the alarm.

7.9.7 Seismic Monitoring System The Seismic Monitoring System records (on local recorders for each accelerometer and in a personal computer within the central system in the control room) vibrations in the earth due to a local earthquake. In addition, the system will record the vibrations on man-made structures caused by the earthquake. The data acquired will contribute to the assessment of damage and the determination of cause of damage. The data is useful in confirming the design and analysis of the structure. To aid decision making, alarm lights are provided at the system rack, in the cabinet area of the Control Room. These lights show the

7-15 DBNPS Emergency Plan Revision XX exceedance of Operating Basis Earthquake (OBE) or Safe Shutdown Earthquake (SSE) at the containment foundation.

The sensors and seismic triggers are installed remotely from the system rack, are networked together, and are connected by cables to the rack. (See the Technical Requirements Manual (TRM) for location of the sensors and triggers.)

The four low-level triaxial seismic triggers are networked together, so that any one accelerometer can also trigger the other devices, to turn on the system automatically during the buildup of the event vibrations. The one required seismic trigger (free-field) is set at approximately 0.010g (g=acceleration due to gravity). The recording system includes pre-event (i.e., pre-trigger) data in the event record. Recording continues without interruption for approximately 30 seconds after the last low-level trigger signal. Upon completion of the seismic event recording, data is retrievable from each accelerometer (through an analog-to-digital recorder and data storage memory) and a personal computer in the Control Room, which will provide time history response data and can be readily reviewed without need for conversion to hardcopy. A video display will provide quick, accurate determinations to be made based on the seismic event, and to determine if a plant shutdown is required.

In keeping with the purposes of the system, loss of site power will not prevent system operation. Backup power is supplied from the Station Battery, and also an internal battery in the network control center and each recorder.

In addition to the components associated with the system rack, there are three peak recording accelerometers as listed in the TRM, Table 8.3.3-1, which require no electrical power to operate. After a seismic event operators can remove the three tape strips from each recorder, develop the strips, and determine the peak values recorded at the associated location.

7.9.8 Onsite Meteorological Measurement Programs Data collection from the current onsite meteorological monitoring system began at DBNPS on August 4, 1974. The location of both meteorological towers is such that the meteorological data from the towers are representative of the DBNPS site. The system includes two levels of instrumentation on a 340-foot freestanding tower and one level of instrumentation on a 35-foot satellite tower. Both towers are located in the southwest corner of the site approximately 2800 feet from DBNPS.

Wind direction and speed are measured at the 250 and 340-foot levels on the freestanding tower and at 35 feet on the satellite tower. Differential temperature measurements (T) are made between 35 and 250 feet and between 35 and 340 feet on the free standing tower.

The Control Room, Emergency Operations Facility (EOF), and Technical Support Center (TSC) can obtain meteorological data through the data acquisition computer in the TSC.

The Control Room can display meteorological data with the PI Process Book. The EOF and TSC can display meteorological data on the Plant Computer System. All meteorological data are recorded on strip chart. Dual-channel strip chart recorders are used for recording wind speed and direction; one recorder for each tower level. Ambient temperature, dewpoint, delta T, and precipitation are recorded on one multipoint strip chart recorder; each parameter is recorded on an individual channel. The data recording and

7-16 DBNPS Emergency Plan Revision XX signal conditioning equipment is housed in an environmentally controlled out structure located near the base of the tower.

The meteorological instruments at DBNPS are calibrated at least semiannually. The instrumentation and records are checked on a nominal daily basis for proper functioning of equipment. All maintenance and calibrations are performed in accordance with written procedures.

Backup meteorological data (i.e., wind speed and direction) are available from the National Weather Service. Arrangements have also been made to obtain complete backup meteorological information from the Enrico Fermi Nuclear Power Station at Newport, Michigan. Backup hydrological data can be obtained from the Marblehead Coast Guard Station, and the Port Clinton Sewage treatment plant (lake level and precipitation respectively).

7.9.9 Control Room Instrumentation Control Room Instrumentation measures appropriate parameters that are indicative of the status of various plant systems and the reactor itself.

The Post Accident Monitoring System (PAMS) is also available to follow the course of an accident with wide range instrumentation. This system will provide to the plant operators, the essential safety status information necessary to allow them to return the plant to a maintained, safe, shutdown condition.

USAR Table 7.5-1 provides a listing and a description of Control Room instrumentation, including PAMS that would be used in performing continued assessment of plant conditions.

7.9.10 Laboratory Facilities The Davis-Besse laboratory facilities are equipped to provide the water chemistry and radiochemical analysis support required during normal plant operations. This equipment can also be utilized in the analysis of abnormal events to assist in the diagnosis of plant operation when conditions permit.

If an accident occurs which would make normal sampling and counting methods impractical, the following measures can be taken:

a. A Radiological Testing Laboratory (RTL) is located in the DBAB in the restricted area near the TSC. Its primary functions are to act as a staging area for Radiation Monitoring Teams and provide a handling area for environmental samples.

b. For reactor coolant system sampling, a shielded, high-pressure sampler is available for pressurized samples. These samples are obtained using the Post Accident Sampling System (PASS) which was designed specifically for this purpose.

c. For containment atmosphere sampling, the normal sampling procedure is used. If any channel of the RE 4597 series monitor is off scale or an independent sample and analysis is required, a grab sample can be obtained from the Emergency Grab Sample System.

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d. For station vent sampling, procedure guidance exists for sampling using either the normal or accident range station vent monitors. Provisions are included to replace and quantify radioactive particulate and iodine sampling media. Also if RE 4598 series Channel 1, 2 or 3 is off scale, a portable survey instrument on the sample line can be used and dose rate is then converted to µCi/cc.

7.9.1011 Facilities and Equipment for Offsite Monitoring A complete Radiological Environmental Monitoring Program (REMP) for effluent control has been established at the DBNPS. The program has been in effect since August 1972.

The REMP employs fixed radiation/radionuclide detection and measurement instruments at various locations within a 25 mile radius from DBNPS. Samples of vegetation, water, soil, milk, and produce are routinely collected and analyzed. The REMP is conducted under the guidance contained in the Davis-Besse Offsite Dose Calculation Manual (ODCM).

During emergencies at DBNPS, baseline data from the REMP will be used in assessing the radiological effects of any possible releases on the environment.

DBNPS maintainshas three, four-wheel drive vehicles, equipped to perform field monitoring during emergencies. These vehicles are available within about 30 minutes after declaration of an emergency. RadiationField Monitoring Teams (RFMTs), dispatched at an ALERT or higher, will conduct emergency field monitoring of radiation and airborne activity levels throughout the EPZ, under direction from the Dose Assessment Center, in the EOF. Monitoring results will be used to verify plume boundaries and to adjust dose projections for more correct protective action recommendations.

7.10 Protective Facilities and Equipment Personnel protective action at DBNPS is a function of the nature of the hazards, for instance, preparing for a hurricane is somewhat different from preparing for radiological hazards.

Preplanned responses to the basic hazards, such as high winds, flooding, earthquakes, and radiation exposures are an integral part of the DBNPS Emergency Plan and are therefore discussed separately. A fundamental concept in personnel protection is the immediate release and removal of all individuals not essential to the operation, safety, security, and damage control of the plant.

Obviously some hazards can occur before any protective action can be taken. When the situation permits, the appropriate alarms are sounded and all personnel on site either assume their assigned emergency responsibilities, or are assembled at the designated points for accountability prior to release from the site or reassignment to an emergency team.

Protected facilities include the DBNPS Control Room and the emergency facilities on the first floor of the Administration Building. These areas are located in seismically rated structures and have adequate shielding to permit safe occupation for extended periods of time without exceeding a dose limit. The ventilation systems in these facilities have redundant fans and chillers and are provided with appropriate alarms and interlocks. Provisions have also been made for the air to be recirculated through high efficiency particulate (HEPA), and activated charcoal filters when necessary.

Self contained breathing apparatus (SCBAs) are located in the Control Room to permit continued occupancy if ventilation systems fail. Air-purifying respirators are available in the Radiologically

7-18 DBNPS Emergency Plan Revision XX Controlled Area and would be provided to Control Room personnel as needed. Additional SCBAs, protective clothing, and respirators are available at, or near, each onsite ERF, and are listed in applicable Radiation Protection Procedures and Emergency Plan Procedures.

Parts for the respirators and SCBAs, as well as additional protective clothing are available through the FENOC Supply Chain.

7.11 First Aid and Medical Facilities First aid facilities at DBNPS are designed to support immediate care ranging from simple first aid to procedures requiring a physician. The most readily available first aid is provided by the small kits placed throughout the plant. These kits contain items typically needed to care for minor injuries.

More complete medical cabinets are located throughout the site and contain medical supplies needed to care for more serious injuries.

7.12 Damage Control Equipment The DBNPS is extensively equipped to conduct preventive and mitigative maintenance and repairs on mechanical, structural, electrical and instrumentation and control equipment found in the station.

Each maintenance crew is qualified and, when required, certified to perform the tasks associated with their craft in the working environment of a nuclear plant.

In addition to the equipment and materials required for normal maintenance, other items are available to handle extraordinary maintenance jobs that might arise in damage control. Refer to the appropriate system procedure or Emergency Plan Procedure for equipment lists.

7-19 DBNPS Emergency Plan Revision XX TABLE 7-1 Page 1 of 2 Radiation Monitoring Instruments and Equipment A. Portable Radiation Survey Instruments Type Range Detector Quantity Location High Range 0-1000 5 RTLDEBAB ERF Survey mrad/hr-103 rad/hr GM 3 RP Area Instruments Ion 0-50 R/hr Chamber 6 RTLDEBAB ERF Low Range Ion Survey 0-5 rem/hr Chamber 2 RP Area Instrument 0-5 x 105 cpm GM 4 RTLDEBAB ERF Alpha Survey Meter 0-5 x 105 cpm Scintillator 1 RP Area Neutron 0-5000 mrem/hr BF3 or 2 RP Area equivalent B. Portable Air Sampling Equipment Type Quantity Location Environmental Offsite Air Sample 10 Survey Stations Low 12 volt D.C. 4 RTLDEBAB ERF Volume Battery Power 4 RTLDEBAB ERF High Volume 1 RP Area Onsite Low Volume 2 RP Area

7-20 DBNPS Emergency Plan Revision XX TABLE 7-1 Page 2 of 2 Radiation Monitoring Instruments and Equipment (Continued)

C. Personnel Dosimetry and Equipment Range Self-Reading Dosimeters:

Pocket Ion 0-10 rem or 0-100 rem Chamber 0-1.5 rem or 0-5 rem 0 - 200 mrem or 0-500 mrem OR Electronic Alarming All ranges Dosimeters Dosimeter All ranges Charger Thermoluminescent All ranges Dosimetry (TLD)

Radiation Monitor 0-50 kcpm (Frisker)

Automatic Whole Body N/A Contamination Monitors

7-21 DBNPS Emergency Plan Revision XX Figure 7-1 EMERGENCY FACILITIES BY GENERAL LOCATION SUPPORT AGENCIES COMPANY (OFFSITE / GENERAL AREA) (OFFSITE) (ONSITE)

State of Ohio Joint Control Room Emergency Operations Information Center (CTRM)

Center (EOC) (JIC) Davis-Besse Ohio Emergency 623' Elevation Management Agency 300 Madison Building LLC Worthington, Ohio Toledo, Ohio Operations Support Center (OSC)

County Emergency Operations Center (EOC) Corporate Assistance Containment Access Ottawa County Lucas County Center (CAC) Facility (CAF)

Courthouse Annex Emergency Services Bldg Corporate Third Floor Port Clinton, Ohio Toledo, Ohio Facility Technical Support Emergency Center (TSC)

Nuclear Regulatory Institute of Nuclear Operating Facility Radiological Testing Commission (NRC) Power Operations (EOF) Laboratory (RTL)

Operations Center Emergency Response Lindsey Emergency Davis-Besse Response Facility Center (ERC) Lindsey, Ohio Administration Building Rockville, Maryland Atlanta, Georgia First Floor (North)

Incident Response Federal Emergency Center (IRC) Operations Center NRC Region III DOE, COO Lisle, Illinois Argon, Illinois Framatome Bechtel Power Corporation Lynchburg, Virginia Gaithersburg, Maryland

8-1 DBNPS Emergency Plan Revision XX 8.0 MAINTENANCE OF EMERGENCY PREPAREDNESS Efforts will be made to assure continuous emergency preparedness and operational readiness among Company personnel and the offsite response agencies and organizations. The Vice President - Nuclear has been assigned the overall responsibility for emergency preparedness as related to the DBNPS. This responsibility includes not only maintenance of the DBNPS Emergency Plan and Emergency Plan Procedures, but also its interrelationships with state, federal and county plans; agreement letters; corporate policy and plans; and other related plans, programs, and procedures. The Vice President - Nuclear is also responsible for training of personnel who implement the Plan and Procedures. To assist the Site Vice President - DB Nuclear in meeting these assigned responsibilities, the Manager, Regulatory Compliance and Emergency Response has been designated. The specific responsibilities of the Manager, Regulatory Compliance and Emergency Response are described in the following subsections; and in particular, subsection 8.1.3.

8.1 Organizational Preparedness 8.1.1 Training All personnel permitted access to the DBNPS protected area will take part in a formal training program under the direction of the Vice President - Nuclear. This training program provides for the indoctrination of Company employees and contractors. In addition it provides specialized training for licensed operators, chemistry personnel, radiation protection personnel, and personnel assigned specific responsibilities in the ERO.

The Vice President - Nuclear is responsible for ensuring that personnel in each department receive the appropriate training. The Nuclear Group Department Directors are responsible for identifying training required for each individual's job specialty.

Training in support of the Emergency Plan, includes the following:

a. All DBNPS staff personnel requiring unescorted access will receive training related to Emergency Response. This training will be completed initially, prior to being granted unescorted access, and annually to maintain unescorted access.

With regard to Emergency Response, the following objectives have been established:

1. State the purpose of the Emergency Plan, and associated procedures.

2. State the classifications of station emergencies.

3. Recognize the emergency alarms and state the proper response for each.

4. State the actions required during Emergency Plan implementation.

5. State the purpose and importance of accountability.

6. Identify the location of emergency facilities and assembly areas inside the Protected Area and Owner Controlled Area.

7. Discuss evacuation plans, including identification of evacuation routes.

8. State the company's policy concerning the release of information to the public and news media regarding an emergency.

9. State the function of the Prompt Notification System.

10. Identify the appropriate communication system to be used for reporting emergencies, locating an individual in the Plant, and conducting lengthy discussions.

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11. Identify and discuss operation of the radiation exposure control criteria for personnel during an emergency for the persons who have access to Radiation Restricted Areas.

b. Personnel assigned to the DBNPS ERO with specific Emergency Plan duties and responsibilities will receive specialized training for their respective assignments.

Table 8-1 delineates which personnel shall receive specialized training, the type of training, and the minimum required frequency for each type of training.

c. Training for offsite organizations and personnel involved in emergency response for DBNPS is the responsibility of the State of Ohio and Ottawa and Lucas County Emergency Management Agencies. Training programs for these agencies are controlled and conducted in accordance with existing radiological emergency plans and procedures. Davis-Besse coordinates with the State of Ohio, county emergency management agency directors, and local authorities to ensure consistency and continuity of the above-mentioned plans and procedures with the DBNPS Emergency Plan and Emergency Plan Procedures. Davis-Besse financially supports the State of Ohio and the county agencies to ensure continued program maintenance and training support of the Radiological Emergency Preparedness (REP) program.

d. The local fire departments will be invited to participate in a training program, which, as a minimum, will include the following topics:

1. Interface with the nuclear security force during emergencies.

2. Basic health physics indoctrination and training.

3. The DBNPS facility layout.

4. Onsite fire protection system equipment (permanent and portable).

5. Differences between onsite fire fighting equipment and fire company supplied equipment.

6. Communications systems.

7. Review of applicable parts of the DBNPS Emergency Plan and Emergency Plan Procedures.

8. The onsite emergency organization, with specific emphasis on the interface between the DBNPS Fire Brigade and local fire department personnel. (Included in this training will be the understanding that when local fire support is required within the protected area, local fire department personnel will function in conjunction with, and under the direction of, the DBNPS Fire Brigade.)

e. A review of the DBNPS EALs will be performed annually by the Emergency Response Section with state and local governmental agencies. This EAL review is directed toward offsite senior management personnel and may be performed through a mailing. This mailing includes an offer to receive training on the DBNPS EALs upon request.

f. A coordinated program shall be conducted annually to acquaint the news media with the Emergency Plan, information concerning radiation, and points of contact for release of public information in an emergency. Normally, this information will be presented through a mailing, which may include an invitation for a site/plant tour.

8-3 DBNPS Emergency Plan Revision XX 8.1.2 Drills and Exercises

a. Periodic drills and exercises will be conducted in order to test the overall state of emergency preparedness. The prime objective of this form of training is to determine the level of emergency preparedness of all participating personnel, organizations, and agencies. More specifically, each drill or exercise will be conducted to meet the following objectives:

1. Ensure that the participants are familiar with their duties and responsibilities.

2. Verify the adequacy of the DBNPS Emergency Plan and Emergency Plan Procedures.

3. Test communications networks and systems.

4. Check the availability of emergency supplies and equipment.

5. Verify the operability of emergency equipment.

The Manager, Regulatory Compliance and Emergency Response is responsible for the planning, scheduling, and coordination of all emergency preparedness related drills and exercises.

All drills and exercises are subject to the approval of the General Plant Manager.

In addition, the Site Vice President, DB Nuclear will approve the Biennial Exercise.

Each drill requirement will be performed within the specified time interval, with a maximum allowable extension not to exceed 25% of the drill interval. An exercise will be conducted once every other calendar year to demonstrate the overall effectiveness of the Davis-Besse Emergency Response Program. The scope and content of the biennial exercise will be consistent with established departmental procedures and regulatory requirements.

Instructions and coaching may be given to participants during a drill. Such actions are prohibited during a biennial exercise. Therefore, in order to take credit for specific drill objectives during an exercise, no instructions or coaching may occur.

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b. When a major drill or exercise is to be conducted, the Manager, Regulatory Compliance and Emergency Response will:

1. Assign personnel to prepare a scenario.

2. Coordinate efforts with other participating emergency personnel, organizations, and agencies.

3. Obtain the approval of the General Plant Manager (DB), and the Site Vice President-DB Nuclear (for the Biennial Exercise).

4. Schedule a date for drill execution and assign controllers.

5. Critique the results of the drill.

6. Assign personnel to correct any deficiencies.

7. Ensure that deficiencies are corrected.

8. Prepare and submit documentation to the Nuclear Records Management for record keeping of training conducted.

Scheduled drills and exercises will involve onsite as well as offsite emergency personnel, organizations, and agencies. These drills and exercises will be conducted simulating, as closely as possible, actual emergency conditions; and may be scheduled such that one or more drills or exercises are held simultaneously. Drill scenarios will be prepared that involve the participation of several emergency teams and all or specific parts of the onsite and offsite emergency organizations. This may include varying degrees of participation of state, county, and federal organizations and agencies, and local service support personnel and organizations. The Manager, Regulatory Compliance and Emergency Response will notify the offsite emergency response organizations and agencies at least thirty days in advance of the scheduled date of the drill or exercise. Collection and analysis of all sample media (e.g., water, vegetation, soil and air) should be included in the drills. Drills will involve on-the-spot correction of erroneous performance, and a demonstration of the proper performance by the controller, if necessary.

During the conduct of exercises, the controllers are restricted in their ability to correct erroneous performance, and may only intercede to assure safety of personnel, or prevent damage to equipment.

Recommendations for revisions to the DBNPS Emergency Plan, Emergency Plan Procedures, and/or the upgrading of emergency equipment and supplies, as a result of a drill or exercise, are forwarded to the Manager, Regulatory Compliance and Emergency Response by observers or participants. The Manager, Regulatory Compliance and Emergency Response will submit such procedure revisions for review in accordance with Emergency Plan Administrative Procedure. Approved changes will be incorporated into the Emergency Response Program under the direction of the Manager, Regulatory Compliance and Emergency Response .

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c. Records will be maintained on each drill/exercise listed below.

1. Medical Emergency Drill:

At least one drill per calendar year will be conducted.

The drill will involve the participation of some, if not all, of the local medical support personnel and organizations (e.g., local physicians, ambulance services, hospitals, etc.), and will involve cases of radiation overexposure and/or contaminated personnel and/or contaminated/injured personnel.

2. Fire Emergency Drill:

Fire drills will be conducted in accordance with DB-FP-00005, Fire Brigade.

3. Communications Links Test:

The communication links used for notification (e.g., DBNPS Control Room to Ottawa and Lucas County Sheriffs' Offices, OEMA, Ottawa County EMA and Lucas County EMA) will be tested at least monthly.

Communications between the Nuclear Regulatory Commission (i.e.,

NRC Headquarters) and the TSC, EOF and Control Room will be tested at least monthly.

The communications links used for contacting federal agencies (i.e.,

NRC and the DOE Radiological Assistance Program personnel) and the State of Michigan will be tested at least quarterly.

The communications links between emergency centers and Field Assessment Teams (i.e., DBNPS EOF to RMTs) will be tested at least annually. Table 1-2, Communication Test Frequencies, defines the above time periods.

4. Exercise and Drills:

Emergency Response exercises shall test the adequacy of timing, the content of implementing procedures and methods, test emergency equipment and communication networks, test the public notification system, and ensure that emergency organization personnel are familiar with their duties.

a) DBNPS shall conduct an exercise of its onsite emergency plan every two years. This biennial exercise will include full participation by Ottawa and Lucas counties, and either full or partial participation by the State of Ohio. Federal agencies may also elect to participate.

8-6 DBNPS Emergency Plan Revision XX b) In those years between biennial exercises, at least one drill involving a combination of some of the principal functional areas of the onsite emergency capabilities shall be conducted. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation. During these drills, activation of all of the emergency response facilities is not necessary. State and local agencies within the plume exposure pathway EPZ may participate in these drills at their request.

5. Radiological Monitoring Drills a) Radiological monitoring drills shall include, at least annually, collection and analysis of all samples (e.g., water, vegetation, soil, and air), and provisions for communications and record keeping.

b) RadiationField Monitoring Team (RFMT) drills will be conducted semiannually which involve simulated elevated airborne samples and direct radiation measurements in the offsite environment.

6. Health Physics Drills a) Semiannual Health Physics drills will be conducted which involve response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

b) An annual drill will be conducted which includes an analysis of actual in-plant liquid samples (Reactor Coolant System) with simulated elevated radiation levels.

7. One exercise/drill in a cycle will start between 6:00 p.m. and 4:00 a.m.

Drills should be conducted under various weather conditions. Some drills may be unannounced.

8. Staff Augmentation Drills Off-hours augmentation drills will be conducted semiannually to test and document the response times of the station emergency response staff personnel.

8.1.3 Manager, Regulatory Compliance and Emergency Response The Manager, Regulatory Compliance and Emergency Response shall ensure that:

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a. Information, data, and procedures detailed in the Emergency Plan Procedures are consistent with the DBNPS Emergency Plan.

b. Emergency Plan Procedures and other procedures are coordinated and interface properly (e.g., Administrative Procedures, Security Procedures, Radiation Protection Procedures, Training Procedures, etc.).

c. Coordination of the DBNPS Emergency Plan and Emergency Plan Procedures with the:

1. State Plans

2. County Plans

3. Davis-Besse Physical Security Plan

d. Adequate staffing of the ERO is maintained.

e. Emergency response related training documentation is sent to Nuclear Records Management.

f. Emergency related drills and exercises are coordinated as described in this Plan.

g. Periodic reviews and updates of the DBNPS Emergency Plan and Emergency Plan Procedures occur as described in this Plan.

h. Maintenance and inventory of emergency equipment and supplies is as described in this Plan.

i. Changes in the federal regulations and guidance that impact emergency preparedness activities are incorporated into the program as applicable.

8.1.4 Ottawa County EMA and Lucas County EMA Directors Emergency planning coordination among all Ottawa County and Lucas County agencies is the responsibility of the EMA Directors for each county. The Directors for these counties have the following responsibilities:

a. Ensure that a sufficient number of preparatory courses are scheduled in the areas of radiological monitoring and decontamination procedures. These courses will assist radiological monitors and local officials in fulfilling their assigned functions in an emergency.

b. In coordination with the American Red Cross, determine that a sufficient number of care centers will be available to house evacuees.

c. Ensure a complete evacuation education program is available for residents and transients within the risk area.

d. Work with state and local authorities to complete, test, and improve upon the Countywide Emergency Warning Plans, Emergency Communications Development Plans and Countywide Resource Manuals.

8-8 DBNPS Emergency Plan Revision XX 8.2 Educational Information for the Public For those members of the public residing within the 10-mile Emergency Planning Zone, DBNPS will provide written information on the following topics:

a) Educational information on radiation; b) Contact for additional information; c) Protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs; and d) Special needs of the handicapped.

Methods of providing this information may include direct mail, billing statement inserts, and/or telephone book inserts.

At least annually, in cooperation with the EMAs of Ottawa and Lucas Counties and the State of Ohio, DBNPS will update the information provided to members of the public within the 10-mile Emergency Planning Zone.

8.3 Review and Update of the Emergency Plan and Emergency Plan Procedures DBNPS maintains, as separate documents; this Emergency Plan, the Emergency Plan Implementing Procedures, Off-Normal Occurrence Procedures, the Emergency Plan Administrative Procedures, Fleet procedures to support station emergency plans, a Public Information Emergency Response Procedure, the Emergency Plan Telephone Directory, and the Evacuation Time Estimate (ETE). It is intended that this plan, although considered as part of the Davis-Besse Nuclear Power Station (DBNPS), Unit 1, Final Safety Analysis Report (FSAR), will be maintained as a separate document. This is more clearly defined in the Updated Safety Analysis Report (USAR), Section 13.3.

8.3.1 The DBNPS Emergency Plan, including appended letters of agreement and plans of offsite organizations and agencies will be reviewed annually and updated as required by the Emergency Response Section, under the direction of the Emergency Response Manager.

8.3.2 The DBNPS Emergency Plan will be reviewed annually by an independent group with no immediate responsibility for the emergency response program. This group is the Fleet Oversight organization. Results and recommendations from the review will be documented and sent to appropriate corporate and plant management, including the Company Nuclear Review Board (CNRB). The CNRB is responsible for auditing the Davis-Besse Nuclear Power Station Emergency Plan to verify compliance at least once every two years. The CNRB performs this function by reviewing the audits which are performed by the Fleet Oversight organization. The report on the adequacy of the interfaces between the DBNPS Emergency Plan and the state and local governments will be sent to the respective government agencies by the Emergency Response Section, and retained on file for at least five years.

Davis-Besse Oversight is responsible for auditing the DBNPS Emergency Plan at least annually to verify compliance with the companys internal rules and procedures, federal regulations, and operating license provisions. Personnel performing audits of the DBNPS Emergency Plan and/or Emergency Plan Procedures will take into account corporate policy, state policy and plans, county plans, and the various agreements and

8-9 DBNPS Emergency Plan Revision XX understandings with federal, state, county and local support groups, agencies and organizations. Davis-Besse Oversight is responsible for auditing the fire protection program at least once per 24 months per the FENOC Quality Assurance Program Manual.

Results of each annual and biennial review and update (if needed) of the Davis-Besse Nuclear Power Station Emergency Plan and Emergency Plan procedures will be reported to the Site Vice President - DB Nuclear.

8.3.3 The Manager, Regulatory Compliance and Emergency Response will provide an ongoing review of the Emergency Plan and Procedures.

a. The DBNPS Emergency Plan Procedures will be incorporated into the DBNPS procedures program. As such, procedures will be prepared, reviewed, approved, controlled, distributed, and revised in accordance with DBNPS administrative procedures. Document holders (e.g., DBNPS, state, county, and federal agencies, etc.,) will receive revisions to the Emergency Plan Procedures in a controlled manner, as they are issued. In addition, these Emergency Plan Procedures will provide guidance to document holders on how to make comments and recommendations concerning the Emergency Response Program to DBNPS.

Revisions to the DBNPS Emergency Plan will be similarly controlled.

b. The Manager, Regulatory Compliance and Emergency Response is responsible for coordinating the periodic review and audit of the DBNPS Emergency Plan and Emergency Plan Procedures. In addition, the Emergency Response Manager will, through letters, meetings, seminars, or other means available; ensure that appropriate elements of the emergency organization are informed of the DBNPS Emergency Plan and amendments thereto, and the Emergency Plan Procedures and revisions thereto.

8.4 Maintenance and Inventory of Emergency Equipment and Supplies The Manager, Regulatory Compliance and Emergency Response is responsible for planning and scheduling the quarterly inventory and inspection of designated emergency supplies and equipment.

Designated emergency equipment and supplies, and their storage locations, will be listed in the Emergency Plan Administrative Procedures.

Such equipment and supplies will be maintained in accordance with approved DBNPS procedures. Equipment, supplies, and parts having shelf lives shall be checked and replaced as necessary.

8-10 DBNPS Emergency Plan Revision XX TABLE 8-1 Sheet 1 of 3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL Personnel Category Involved Personnel Training and Frequency Operations Station personnel Operations CoordinatorEmergency Assistant Plant ManagementEmergen designated as Manager shall periodically receive training on DBNPS cy Assistant Plant Operations Emergency and Abnormal Operating Procedures and Manager CoordinatorEmergenc reactor thermal shock considerations equivalent to that y Assistant Plant received by SRO licensed individuals.

Manager Licensed Operators Shift Managers Reactor Operators and Senior Reactor Operators receive Unit Supervisors extensive on-the-job and formal training as scheduled Other licensed staff and conducted by the operator requalification training members program. This program shall include a comprehensive review of the DBNPS Emergency Plan and the Emergency Plan Procedures.

Personnel responsible Emergency Director, Training will include the Emergency Plan, Emergency for assessment of Emergency Plan Procedures, Technical Specifications (that are emergencies CoordinatorPlant referenced in the Emergency Action Levels), and other Manager, station programs, plans, and procedures. The listed EOFmergency Offsite individuals attend at least one meeting per year to Manager, Shift receive training on the Emergency Plan and Procedures.

Managers, Shift Detailed instructions with special attention given to the Technical Advisors use of either dose assessment or engineering assessment (STAs), Key techniques is provided based on the role they are Emergency Response expected to play during an emergency. Personnel shall Personnel participate in scheduled exercise and drills depending on availability.

Staff personnel designated by the General Plant Manager who may act as OSC and TSC Managers Other members of the Nuclear Group staff as designated by the Site Vice President - DB Nuclear.

Personnel responsible Maintenance Periodic training is provided to Station maintenance for repair and damage personnel in troubleshooting techniques as described in control Other personnel as the training program for the specific discipline.

designated by station management as Fire Fire Brigade and First Aid training occurs as described in Brigade and First Aid this table.

8-11 DBNPS Emergency Plan Revision XX TABLE 8-1 Sheet 2 of 3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL Personnel Category Involved Personnel Training and Frequency Radiological Station personnel On an annual basis, detailed instructions are provided on Monitoring Personnel designated as such topics as classification of emergencies, interfaces Radiation Monitoring and responsibilities of the radiological monitoring and Team Members assessment personnel, personnel protection during emergencies, location and use of emergency equipment, monitoring techniques, and communications.

Post Accident Chemistry personnel On an annual basis, detailed training shall be provided Sampling Personnel designated by the on the purpose and applications of the Post Accident Chemistry Supervisor Sampling System with both a detailed review of to perform PASS applicable system procedures and a walkdown of the samples system equipment.

First Aid Team(s) Station personnel as Each member of the First Aid Team(s) shall receive a designated by station standard accredited first aid course, including management cardiopulmonary resuscitation (CPR). Satisfactory completion of this course certifies them as members of the First Aid Team(s). Recertification training shall be provided at the frequency required by the certifying organization. Annually, a refresher course shall be made available for the team members which shall include a review of CPR, portions of the standard first aid course and handling of contaminated injured victims. In addition, after completing the standard first aid course, and during each of the annual refresher courses, each member shall be instructed on the availability of onsite medical treatment facilities, equipment, and supplies; communication systems; radiological hazards existing during personnel-related emergencies; and interfaces and responsibilities with local medical support personnel (e.g., local physicians, ambulance personnel, etc.).

Security Force Nuclear Security The listed individuals will receive training on at least an Management annual basis. The training program shall include the following subjects: a review of the applicable parts of the Emergency Plan, and Emergency Plan Procedures with emphasis on the classification of emergencies, communications, and specific areas of responsibility; personnel accountability; personnel and vehicle access control during emergencies; evacuation control; and interfaces with offsite support organizations and agencies.

8-12 DBNPS Emergency Plan Revision XX TABLE 8-1 Sheet 3 of 3 PERIODIC TRAINING OF EMERGENCY RESPONSE PERSONNEL Personnel Category Involved Personnel Training and Frequency Fire Brigade Fire Captains This training which is provided to each person involved, Designated shift is given by instructors trained in fire fighting. The personnel program shall include, but not be limited to, the types of fires and their particular hazards, equipment to be used Other station on each type of fire, the installed fire detection and personnel as protection systems, portable firefighting equipment and designated by station locations, respiratory protection devices, and radiological management as Fire hazards existing during fire emergencies. In addition, a Brigade Members review of fire fighting procedures and techniques shall be included in the training program. Practical demonstrations of firefighting shall also be given. Fire Brigade training frequency is defined by the Fire Protection Program.

Offsite Medical Medical Hospital and These personnel shall receive offsite medical training Training Ambulance Personnel in accordance with the responsibilities and details contained in current state and local government plans and procedures.

Fleet Emergency All Company These personnel shall receive training at least on an Response Support personnel assigned annual basis. The program shall include a Personnel duties and comprehensive review of Fleet procedures to support responsibilities in the station emergency plans with specific attention and Corporate Assistance instruction given to their support role, responsibilities Center (CAC) to and duties.

support the DBNPS Emergency Plan Emergency Response Manager, Regulatory Periodic classroom training and seminars on Emergency Personnel Compliance and Response shall be provided on an as-needed basis and at Emergency Response the discretion of the Manager, Regulatory Compliance and designated staff and Emergency Response to these individuals from qualified outside organizations and documentation of this training maintained by the Emergency Response Section.

9-1 DBNPS Emergency Plan Revision XX 9.0 REENTRY AND RECOVERY 9.1 Reentry During an emergency, immediate actions are directed toward limiting the consequences of the accident, so as to afford maximum protection to Station personnel and the general public. Once mitigative measures have been taken and effective control reestablished, the response efforts shift towards reentry and recovery. Reentry is made to perform certain essential actions which could not be performed coincident with the immediate response to the emergency.

Offsite Reentry is the responsibility of state and local authorities. It typically consists of environmental monitoring and assessment of the actions required to support return of the public to evacuated areas and residences. Additional details regarding plans and procedures for offsite reentry are found in The Ohio Radiological Emergency Preparedness Plan and the Ohio Emergency Operations Plan . DBNPS will provide support and assistance to offsite agencies as requested to facilitate these efforts.

Onsite reentry is made when the emergency situation is under control and more deliberate planning can be made for the activities to be performed. These activities may occur prior to termination of the emergency, or they may be conducted as part of the Recovery phase of the response. All reentry actions conducted prior to the termination of the emergency will be authorized by the Emergency CoordinatorPlant Manager, and coordinated by the Operations Support Center (OSC)

CoordinatorManager and the Emergency Radiation Protection (RP) CoordinatorManager. Reentry conducted during Recovery will be authorized by the Plant Recovery Manager. When preplanning these initial onsite reentries, the following items will typically be considered:

9.1.1 Review available radiation surveillance data to determine plant areas potentially affected by radiation and/or contamination.

9.1.2 Review radiation dose histories of personnel required to participate in the recovery operations.

9.1.3 Determine the need for additional personnel and the source of these additional personnel.

9.1.4 Review adequacy of radiation survey instrumentation and equipment (i.e., types, ranges, number, calibration).

9.1.5 Pre-plan survey team activities to include:

a. Areas to be surveyed

b. Anticipated radiation and contamination levels

c. Radiation survey equipment required

d. Shielding requirements and availability

e. Protective clothing and equipment required

f. Access control procedures (issuance of new RWPs) including exposure control limits and personnel dosimetry required

g. Decontamination requirement

h. Communications requirements

9-2 DBNPS Emergency Plan Revision XX 9.1.6 Review and revise security access lists to prevent unauthorized or unintentional entry into hazardous areas.

9.1.7 Reentry teams should be tasked with as many of the following as possible:

a. Determination of the initial required recovery operations.

b. Observation of hazards or potential hazards associated with the recovery operations.

c. Conducting comprehensive surveillance of plant facilities.

d. Isolating and posting of areas in the plant with appropriate warning signs and rope barriers, such as Radiation Areas, High Radiation Areas, High Airborne Activity Areas, and Contaminated Areas, etc.

e. Assessing the conditions of station equipment and areas.

In the period immediately following an accident, initial radiation monitoring functions involve only gross hazard evaluations, isolation of the hazard, and the definition of radiological problem areas. This immediate radiation surveillance activity is used to provide the basic information for recovery operations.

9.2 Recovery The Emergency Director and Emergency CoordinatorPlant Manager have the joint responsibility for determining when an emergency situation is stable and the Station is ready to enter the recovery phase. The Recovery Organization will develop and coordinate plans and schedules for recovery operations.

The Emergency CoordinatorPlant Manager, under the direction of the Emergency Director, will be responsible at the site for coordinating onsite recovery activities and the return to normal operations.

At the time that an emergency has been terminated, and Recovery has been initiated, the EOFmergency Offsite Manager will be responsible for providing notification to Federal agencies.all applicable agencies (federal, state, county, etc.).

9.2.1 Prior to terminating an emergency and entering the Recovery phase, the Emergency Director will coordinate with the Emergency CoordinatorPlant Manager and the EOF mergency Offsite Manager to ensure that the following criteria have been considered:

a. The conditions which caused the emergency have stabilized, are under control, and are unlikely to deteriorate further.

b. The plume is beyond the ten-mile Emergency Planning Zone, and/or plume tracking is no longer required. The only environmental assessment activities in progress may be those necessary to assess the extent of deposition resulting from passage of the plume.

9-3 DBNPS Emergency Plan Revision XX

c. In-plant radiation levels are acceptable, and are stable or decreasing.

d. Radioactive releases are under control and are no longer in excess of technical specification limits.

e. The potential for uncontrolled radioactive releases is acceptably low.

f. Containment pressure is within technical specifications.

g. The reactor is in a stable safe shutdown condition and long-term core cooling is available as required.

h. Any fire, flood, earthquake or similar emergency condition no longer exist.

i. All contaminated injured, personnel have been transported to a medical care facility.

j. All required notifications have been made.

k. Offsite conditions will not limit access of personnel and support resources to DBNPS.

l. Discussions have been held with all offsite and select regulatory agencies, and agreement has been reached to terminate the emergency.

9.2.2 The extent of recovery activities will dictate the precise framework of the Recovery Organization:

a. For events of a minor nature, the normal onshift organization should be adequate to perform necessary recovery actions (e.g., for UNUSUAL EVENT classifications).

b. For events involving significant damage to plant systems required to maintain operation of the plant, the onsite emergency organization, or portions thereof, should be adequate to coordinate the necessary recovery actions (e.g., for ALERT classifications).

c. For events involving damage to plant systems required to maintain safe shutdown of the reactor, a formal Recovery Organization will be established to manage the recovery actions (e.g., for SITE AREA or GENERAL EMERGENCY classifications).

Particular attention should be directed toward isolating components and systems as required to control or minimize the hazards. A systematic investigation will be conducted to determine the extent of any equipment damage. Recovery operations are considered to be terminated when the plant has returned to pre-accident levels of radiation and contamination or to conditions, which are acceptable and controllable for an extended period of time.

9-4 DBNPS Emergency Plan Revision XX Recovery operations that may result in the release of radioactive materials shall be evaluated by the Recovery Director. Such events and data pertaining to the release will be reported to the appropriate offsite emergency organizations and agencies.

In the final phase of the recovery operations, a restoration program will begin. The overall purpose of the restoration program is to prepare for resumption of full-power operations. This program will include a detailed incident analysis.

Determinations will be made as to the repair work required to perform needed modifications to plant equipment and/or operating procedures. Repair work and approved modifications will be carried out as authorized. Test programs to confirm fitness and acceptability to return to service will be developed and executed.

Since no emergency is considered to exist during this time period, normal limits of radiation dose will be applied during the restoration. Compliance with the limits are the responsibility of the Recovery Director.

A recovery plan, must be flexible enough to adapt to existing, rather than theoretical, conditions. It is not possible to anticipate in advance all of the conditions that may be encountered in an emergency situation. Therefore, the DBNPS plan addresses some general principles that will serve as a guide for developing a flexible plan of action.

Specific members of the Recovery Organization will be selected based upon the sequence of events that preceded the recovery activities.

9.2.3 The following is a basic framework for the formation of a formal Recovery Organization. The reporting chain for the organization is outlined in Figure 9-1.

This organization may be modified as necessary for any particular incident.

a. Recovery Director The Recovery Director is responsible for directing the activities of the Recovery Organization, including the following:

1. Ensure that sufficient personnel from DBNPS and other organizations are available to support recovery.

2. Direct the development of a recovery plan and implementing procedures, as required.

3. Coordinate the deactivations of emergency response facilities and personnel as appropriate.

4. Coordinate the integration of available state and federal assistance into recovery activities.

5. Coordinate with offsite authorities, and provide support as required for offsite recovery activities.

6. Review all information released by the Public Information Organization.

9-5 DBNPS Emergency Plan Revision XX

b. Outage Director:

1. Reports to the Recovery Director.

2. Coordinates the development and implementation of the recovery plans and procedures, under the direction of the Recovery Director.

3. Directs all onsite activities supporting of the recovery of DBNPS.

c. Radiation Protection Manager:

1. Reports to the Outage Director.

2. Develop plans and instructions to process and control liquid, gaseous and solid wastes in a manner consistent with the recovery organizational goals.

3. Coordinate cleanup and repair activities, in such a manner as to ensure that dose to the workers is maintained as low as is reasonably achievable.

4. Estimate the total population dose, as necessary.

5. Develop plans for plant radiation surveys, sampling, and shielding in support of waste system processing, plant repairs, and design modification activities.

6. Designate members of Reentry/Recovery Team(s) dealing with onsite radiological aspects of the response.

7. Organize and coordinate actions of the Reentry Team.

8. Ensure teams are adequately briefed and equipped with the required protective gear, and are familiar with the radiological conditions and precautions for the area to be reentered.

9. Provide an interface between the teams and the Recovery Management to ensure reentry actions are approved and executed in accordance with instructions, and provide the teams with the required support.

d. Technical and Engineering Manager:

1. Reports to the Outage Director.

2. Coordinate the development of plans and procedures in support of plant systems and operation activities.

3. Provide a central point for the collection, retention, retrieval and transmission of plant data.

4. Analyze problems, determine alternatives and develop plans in the recovery of system operations.

5. Designate members of Recovery Team(s) dealing with technical and engineering aspects of the plant.

e. Operations Manager:

1. Reports to the Outage Director.

2. Direct recovery activities conducted by Operations personnel.

3. Provide recommendations to the Outage Director regarding plant operations-related aspects of the recovery.

9-6 DBNPS Emergency Plan Revision XX

f. Maintenance Manager:

1. Reports to the Outage Director.

2. Coordinate maintenance activities conducted in support of recovery.

3. Designate members of the Reentry team, as appropriate to support maintenance.

g. Offsite Recovery Advisor:

1. Reports to the Recovery Director.

2. Provides liaison with offsite agencies and coordinating DBNPS assistance with offsite recovery and assessment efforts, as requested.

3. Coordinates any ingestion pathway sampling DBNPS elects to do to supplement that performed by the state.

4. Coordinates the collection of other offsite radiological data, as required, in support of DBNPS recovery activities.

h. Company Spokesperson:

1. Reports to the Recovery Director.

2. Functions as the official spokesperson for the Company on all matters relating to the accident or the recovery.

3. Coordinates with non-Company public information groups (e.g.,

Ottawa County, Lucas County, OEMA, NRC, FEMA, etc.).

4. Interfaces with the news media.

5. Coordinates media monitoring and public inquiry activities.

6. Coordinates with Company Corporate Communications, as may be applicable.

9.2.4 The Recovery Organization described herein represents the disciplines and areas of expertise that would typically be required to support recovery from a severe nuclear accident. The organization will be modified based upon the specific accident from which DBNPS is recovering.

9-7 DBNPS Emergency Plan Revision XX FIGURE 9-1 RECOVERY ORGANIZATION FRAMEWORK Recovery Director (Emergency Director)

Advisory Support Group Company Nuclear Review Board Offsite Recovery Advisor Outage Director Company Spokesperson (EOF Manager) (Emergency Coordinator) (Company Spokesperson)

Operations Manager Radiation Protection Manager (Operations Coordinator) (RP Coordinator)

Scheduling Manager Engineering Manager (Recovery Advisor) (Engineering Coordinator)

Materials Manager Maintenance Manager (Resource Coordinator) (OSC Coordinator)

A-1 DBNPS Emergency Plan Revision XX Appendix A EMERGENCY PLAN PROCEDURE AND RELATED DOCUMENT INDEX AND CROSS-REFERENCE

A-2 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 1 of 6 Procedure DBNPS Emergency Implementing Procedures Number Plan Section

1. Emergency Classification RA-EP-01500 4.1, 4.2

2. Unusual Event RA-EP-01600 4.1.4

3. Alert RA-EP-01700 4.1.3

4. Site Area Emergency RA-EP-01800 4.1.2

5. General Emergency RA-EP-01900 4.1.1

6. Emergency Management RA-EP-02010 5.1, 5.2, 5.3

7. Emergency Notifications RA-EP-02110 6.1.1, 7.6

8. EOF Activation and Response RA-EP-02220 5.5.2, 6.1.2, 7.0, 7.3 Dose Assessment Center Activation and RA-EP-02230 5.5.2, 7.3

Response

9. Unified Rascal Interface (URI) Dose NOP-LP-5020 6.2 Assessment Software General Administration

10. Davis-Besse Unified Rascal Interface (URI) NOP-LP-5022 6.2 Dose Assessment Software

11. Unified Rascal Interface (URI) Dose NOP-LP-5024 6.2 Assessment Software

12. Offsite Dose Assessment RA-EP-02240 6.2

13. Protective Action Guidelines RA-EP-02245 6.4

14. Field Monitoring Teams Radiation NOP-LP-5015 6.2, 5.5.2 Monitoring Teams Field Surveys

15. DBAB Radiation Monitoring Team RA-EP-02252 6.2, 5.5.2 Surveys

16. Radiological Controls in the DBAB RA-EP-02260 6.4.1, 6.4.2, 7.2

17. Facilities Support RA-EP-02270 7.0

18. TSC Activation and Response RA-EP-02310 5.4.4, 7.2

19. Emergency Technical Assessment RA-EP-02320 6.2

20. OSC Activation and Response RA-EP-02410 5.4.5, 6.4.3, 7.1.2

21. Search and Rescue RA-EP-02420 6.4.1

22. Emergency Security Activation and RA-EP-02510 5.3.4, 5.4.4, 6.4

Response

23. Assembly and Accountability RA-EP-02520 6.4.1

24. Evacuation RA-EP-02530 6.4.1

25. Emergency RP Organization Activation and RA-EP-02610 5.4.4, 5.4.5

Response

26. Emergency Exposure Control and RA-EP-02620 6.5.1, 6.5.2 Potassium Iodide Distribution

27. Station Radiological Surveys and Controls RA-EP-02640 5.4.5, 6.5 During Emergencies

28. Reentry RA-EP-02710 9.1

29. Recovery Organization RA-EP-02720 9.2

A-3 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 2 of 6 Procedure DBNPS Emergency Off Normal Occurrence Procedures Number Plan Section

1. Medical Emergencies RA-EP-02000 2.7, 5.8.2, 6.5.3

2. Preparation and Transport of Contaminated RA-EP-02800 2.7, 6.5.3 Injured Personnel

3. Emergency Helicopter Landing Zone RA-EP-02807 2.7

4. Tornado RA-EP-02810 2.6.5, 2.7, 7.10

5. Earthquake RA-EP-02820 2.6.5, 2.7, 7.10

6. Flooding RA-EP-02830 2.6.5, 2.7, 7.10

7. Explosion RA-EP-02840 2.6.5, 2.7, 7.10

8. Hazardous Chemical and Oil Spills RA-EP-02850 2.6.5, 2.7, 7.10

9. Radiological Incidents RA-EP-02861 2.6.5, 2.7, 7.10

10. Containment Evacuation RA-EP-02864 2.7, 6.4.1

11. Loss of Containment Integrity RA-EP-02865 2.7

12. Station Isolation RA-EP-02870 2.6.5, 2.7, 7.10

13. Internal Flooding RA-EP-02880 2.6.5, 2.7, 7.10

14. ERO Response to Security Events or Threats RA-EP-02890 2.6.5, 2.7, 6.4.1 Administrative Procedures

1. Emergency Plan Training Program RA-EP-00100 2.7, 8.1.1

2. Emergency Response Organization Training NOP-LP-5006 2.7, 8.1.1 Program

3. Emergency Response Drill And Exercise Program NOP-LP-5011 2.7, 8.1.2

4. Emergency Planning Activity Scheduling RA-EP-00300 2.7 System

5. Siren Testing And Maintenance Procedure NOP-LP-5005 2.7, 7.8

6. Maintenance of Emergency Plan Telephone RA-EP-00510 2.7, 7.6.3 Directory

7. Emergency Response Organization RA-EP-00520 2.7, 6.1

8. Computerized Automated Notification System RA-EP-00550 2.7, 7.6.1

9. Emergency Facilities and Equipment RA-EP-00600 2.7, 8.4 Maintenance Program

10. DBAB Emergency Response Facility RA-EP-00650 2.7, 8.4 Preventative Maintenance Program

11. Emergency Facilities Communications RA-EP-04000 2.7, 8.1.2 Monthly Test

12. Station Alarm Test RA-EP-04001 2.7, 8.1.2

13. Communication System Quarterly Test RA-EP-04002 2.7, 8.1.2

14. Computerized Automated Notification System RA-EP-04003 2.7, 8.1.2 Weekly Test

15. Emergency Facilities Communication RA-EP-04010 2.7, 8.1.2 Quarterly Test

A-4 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 3 of 6 Public Information Procedure

1. JIC Activation and Response RA-EP-02950 2.7, 5.6, 7.2, 8.3 Supporting Documents

1. Fleet Support of Emergency Plans at Nuclear NOBP-LP-5001 8.3, Table 8-1 Plants

A-5 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 4 of 6 NUREG DB Emerg. NUREG DB Emerg.

0654 to Plan Section 0654 to Plan Section A 1a 2.8, 5.8, Table 2.1 F 1d 7.6 A 1b 5.1 - 5.8 F 1e 6.1.2, 7.6.1 A 1c Table 2-1 F 1f 7.6 A 1d 5.2 F2 7.6.3, 7.8 A 1e 5.1.2, 5.1.3, Table 5.1 F3 8.1.2 A 2a N/A G1 8.2 A 2b N/A G2 8.2 A3 App. C G 3a 7.3.4 A4 5.0 G 3b 7.3.4 B1 5.3 G 4a 5.2.4 B2 5.2.1 G 4b 5.5, 7.3.4 B3 5.2.1, 5.3.1-5.3.3 G 4c 7.3.4 B4 5.2.1 G5 8.1.1 B5 5.0, Table 5-1 H1 7.2, 7.2.2 B6 Figure 6-2 H2 7.2 B7 Table 5-1, 5.6 H3 N/A B 7a 7.0 H4 Table 5-1, 7.6.1 B 7b 7.2 H 5a 7.9 B 7c 7.2 H 5b 7.9.6, 7.9.8 B 7d 7.2 H 5c 7.9.9 B8 5.8.4 H 5d 7.9.6 B9 5.7, App. C H 6a 7.9.8 C 1a 5.2.1, 6.1.6 H 6b 7.9.11 C 1b 5.8.3 H 6c 7.9.10 C 1c 7.6, 7.9 H7 7.9.11 C 2a N/A H8 7.9.6 C 2b 5.5.2 H9 7.10 C3 7.9.10-7.9.12 H 10 7.12, 8.1.3 C4 5.8, App. C H 11 6.4.2, 7.12 D1 N/A (NEI 99-01) H 12 7.9.10 D2 N/A (NEI 99-01) I1 4.0 D3 N/A D4 N/A I2 7.9 E1 6.1, 7.6.2 I 3a 4.0 E2 6.1 I 3b 4.0 E3 6.1 I4 4.0 E4 6.0 I5 7.2, 7.9.8 E5 N/A I6 7.9.8 E6 6.4` I7 7.9.11 E7 6.4 I8 7.9 F 1a 7.6 I9 7.9, Table 7-4 F 1b 7.6 I 10 7.9 F 1c 7.6 I 11 N/A

A-6 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 5 of 6 NUREG DB Emerg. NUREG DB Emerg.

0654 to Plan Section 0654 to Plan Section J 1a 6.4.1 K 6c 6.4.3 J 1b 6.4.1 K7 6.5.3 J1c 6.4.1 L1 5.8.2, 6.5.4, 6.5.5 J 1d 6.4.1 L2 6.5.3 J2 6.4.1 L3 N/A J3 6.4.1, 6.4.3, 6.5.3 L4 5.8.2, 6.5.4 J4 6.4.1, 6.5.3 M1 9.1, 9.2 J5 6.4.1 M2 9.2, Figure 9-1 J 6a 7.9 M3 9.2 J7 6.4.1 M4 9.2.3.c.3 J8 App. D N 1a 8.1.2 J9 N/A N 1b 8.1.2 J 10a App. D N 2a 8.1.2 J 10b App. D N 2b 8.1.2 J 10c 7.7 N 2c 8.1.2 J 10d N/A N 2d 8.1.2 J 10e N/A N 2 e(1) 8.1.2 J 10f N/A N 2e (2) 8.1.2 J 10g N/A N 3a 8.1.2 J 10h N/A N 3b 8.1.2 J 10i N/A N 3c 8.1.2 J 10j N/A N 3d 8.1.2 J 10k N/A N 3e 8.1.2 J 10l N/A N 3f 8.1.2 J 10m 6.4.1, Table 6-1 thru 6-6 N4 8.1.2 J 11 N/A N5 8.1.2 J 12 N/A 01 8.1.1 K 1a 6.5.3 0 1a 8.1.1 K 1b 6.5.1 0 1b N/A K 1c 6.5.1 02 8.1.1, 8.1.2 K 1d 6.5.3 03 8.1.1, Table 8-1 K 1e 6.5.3 0 4a 8.1.1 K 1f 6.5.4 0 4b 8.1.1 K 1g 6.5.5 0 4c 8.1.1 K2 5.2.1, 6.5.1 0 4d 8.1.1 K 3a 5.2.1 0 4e 8.1.1 K 3b 6.1 0 4f 8.1.1 K4 N/A 0 4g 8.1.1 K 5a 6.5.3 0 4h 8.1.1 K 5b 6.5.3 0 4i 8.1.1 K 6a 6.4.3 04j 8.1.1 K 6b 6.4.3 05 8.1.1

A-7 DBNPS Emergency Plan Revision XX Emergency Plan Procedure and Related Document Index and Cross-Reference Page 6 of 6 NUREG DB Emerg. NUREG DB Emerg.

0654 to Plan Section 0654 to Plan Section P1 Table 8-1 P6 App. A, 8.3, Table of Contents P2 8.1.3 P7 App. A P3 8.1.3, 8.3 P8 App. A P4 8.3 P9 8.3 P5 8.3 P 10 7.6.3

B-1 DBNPS Emergency Plan Revision XX Appendix B Department of Energy Emergency Radiological Assistance Program (DOE O 153.1) for Davis-Besse Nuclear Power Station (Reference to DOE O 153.1 is available Online at: www.directives.doe.gov)

C-1 DBNPS Emergency Plan Revision XX Appendix C LETTERS OF AGREEMENT Contents Carroll Township EMS & Fire Service, Inc.

H. B. Magruder Hospital Lucas County ProMedica Memorial Hospital Mercy St. Charles Hospital Institute of Nuclear Power Operations Ottawa County Commissioners Ohio Department of Public Safety Emergency Management Agency

C-2 DBNPS Emergency Plan Revision XX EMERGE CY RESf'ONSE AGREE E This Agreement made aod e-ntered into by and between FirstEnergy (be1*ein.after "Utility") and the Canon Townshlp Em ,rgoncy Med*cal nod F~ _ Service, Inc., in ooitlsideration ot the following.:

l. The Carroll I ownooip Emergency Medfoa! and Fire Service, hie.,

(hen:foafter .,..Serv'c-e Ino.,) agrees to use ,equipment available to irt to provide twentyafour (24) trour emergency amlbul.atlCe and fbe protection for actual merge.11cies, includiQg l ostik actfon eve ts at Da r.is Besse Po,ver Sia.ti~ <'l'r:iUs and tru *oing acti ities at First

erg , located 'i ithin the jurisdictional bo-uudaey of Carron TOi\'fl1ship~ Ottawa County, Ohio, all subject to t ' e actual. em.ergency needs o:f l e ;vho.le To ~'VllShip. When 1

neoes *!fy *to* provide such a0ctual ,i-Hnl"lrgency service,. Service, Inc., wilJ r-equ. st any mutual aid or a,sistarn<: , as may be necessary and that may be

.available from surro mding conm1unities,

2. TI e Utility hall provide Se1*vice, foe., with any supplle and additi.onal eg'Uipmtmt or .modi:fications to current equipment th.at may be necessa.ry 1, as determined based upo,n the murlt/1al agreement of the Utmty and Service, fuc., or Servi,ee, loo., to fulfiU its obligations hel'euuder or to meet the 1ieqwrement,s of the Nuclear Regnlatory ComIDissfon. that may apply to*

thi* Agreement~ if the, nee S~r,)' equripment is not provided to ervice, Inc., by Ulity. the.n the obllgations hereunder requited of Servfoe, me.,

are waived. and Service,, In:e., shaU not be req ui.ted in any fashion to fu]fiJ the obJigatioos hereof, nor sbadl Service., Inc., be liable for faiiling to W,fiU said o,b]IJ;,ra(io.os. Any equipment provided hy the UtiJity to Se1'vic~ luc.~

shaU h stor.ed and maintained at the discretion o:f S .*rvke, [uc ..

3. Further, the U *lity :agreces to ftSSlllme ail e:icp.enstS and costs. of providing 0

specializ,ed training for pt1rlicipating ~*so-nneI and supJ)Ort perso:nn.el as

C-3 DBNPS Emergency Plan Revision XX 1 rg noy Res o s.e Agreement Pagel d .* lgnared by Servke~Inc.. This training shal include an annuaJ revi w of necessary emerg,e:ncy t1anspo,rtaf on procednres1 eq1.dpment, :supplies, annual tr.aim g sesSJO and participation in. periodic emer:* <;mcy drills.

Servite, n ., iU submit invoices for reimbursement on a time and mated al basis whlch sl1aH be :pl'Omptly paid to Servke, Inc,, by ( e _ti] ity.

4, Carroll Tm,vnshlp Emerg ncy M dk I and Fire Servic-e~ fnc., agrees to make practice ntn$ and/or dnlls in conjunction with exercises of t e er:nerg n y plan as may be mntua1ly ~ d upo~ but

uc aig11 _ement shall not oo unreasonably w1t1hheJd.

5. It shall

e the resp ,~ibility of Th Utility to protect and safeg ru'd the perso, nel and equl.pm L'llt of Service, hie., and nuy mutua] aid ~J)O d rs, fi*om :rac iation. The Utility shaH be liable foi: pl'-operty damage to, e"rvice, In ., eq u"pmeut and any bodUy inj my to Service} Inc., personnel, includu:ig deathi that is ca sed by expoSl!lre o rodiatio during e p rforrmmc . of obli ruions under the *greement. The Uti ity aU be liable for non-:mdiati.on related i:njurles ,or damages to the extent cau ed by its own o gUg nee. The Utility shaU pron1rptly repair or repJac:e s~rvk*iej .

In. ,, eq_l!.tipment in order to avold. any intenuptio.n fn fire o,r ambuJance s.ervice to fhe conununity. How ver, m 11 , ent ,sba1l the Utility be required to replace *Or repa *r any property it1 excess of its pno:1"fair maJ:ke1 v~O¢, Further, The U1ility slk1ll not be l'abJ,.e for any coot of complete de ontaminatfon~, r~pafr ancllor repla ement of ar y piioperty or non radfation related b dily in.Juwy to the extent it ]s the result of the negligence of lh.e '

rvice, Inc ..

C-4 DBNPS Emergency Plan Revision XX Emergency R.es1XJ se greemen.t Page3

6. Further~ The Ut 'lily shall indemnify and hold S* r ic~

0. 1 Canoll ownship1 the Bowd o Carroll To m~hip Trustee~ imy ,other erthcy providm *.m 1turu aid ponse;,and any wid an persons associated with

~ny such. orgnwzations~ harm1es _, fro,m any and at 1iabiJ:ity for dmnages.,

x_pense*,.iaju_ries o fos:res: that may occur :in. :the lfillm =* o th obligation <t~thls Agr ement, e;ltcept for non,;.radiological emerg

cy ambulance E"ind fire p, otection serdces. The UtjUty afureMkl 'nde.nmHy and hold hannle~ agreement shall not be ap_pUcaMe to a y liabi Uy caused by th sole active negllge oe of Service) I c., or any other m.utua] aid responder'.

7. There shall be 1 o charg,e for the afo:_~- aid n*,o prot ctfon; however, the

tili _ ha] y the CmoJJ To ms ip merge.n y M dica.l and Fire

erv.ice, foe.~ 1 e rat, o $2 _0.00 pe I our, fol" time from caiU un.til t'he ambulunc is b ck in service, or emo *g. cy .ambulance calls h1 excess o:f twelv, O2) per year.

8.,

e.rvice~ fo _.1. agrees top ovid

a raging airea for enierg,ency equripm nt and pe1~omiel in the vent the UtiUty {Da,l s B ss *uclear PO\ver talion) i in olved in a s :curity re]ated event

9. 'Ibis Agreement shaU remain in effect until temuna ed in writi t1g by' it ru-party thirty (30) day,s prior io the effective dine.

C-5 DBNPS Emergency Plan Revision XX Euiergency Response Agreement Page4

.FirstEnergy Carroll Township Emergency Medical and Flre Servic Inc, By: - - Ne, a Ie,,.f' N~7! R41m~-t , 4. L. ie.~

Pom!hon: Si*-le. Via Davis B-es.se udear f~;,/e~i By: ~m..,,_,,.. ~C'4f STATEOFOIDO )

) . S:

COUNTYO:FOTfAWA)

Be it :11emembered that on *this before me ,a otar-y PnhHc in and for- said County, pe,rsonal]y came

~=-,..:...:~i.=...-.i....:__::::.....:..:-_,;:;y_~' _ ffll Officer of FimtEne:rgyji who acknow]ed,ged the ignmg ,of the abov _ greement ar an f toer -of Pint Energy, on 'behalf of First B ergy, and, by the authority ofitc. Board of Direotura, and that the Agreement is the v,olummy act a -d d ed of First Energy .m1d ~ .l ,, as such Office 1 and *th

voluntary act and deed of F'irsl ~n-e*rgy~ for th; purposes :stated therein.

IN TESTIMONY WHEREOF, I haVie h.er-et1oio .subscribed my n.am1e aud ~ffixed rn.y s.ea] t ,is * -~ day of *~ mbRX" , 20]4.

C-6 DBNPS Emergency Plan Revision XX Emergency Response Agreement Page 5 STATE OF OHIO )

) SS:

COUNTY OF OTTAWA)

Be it remembered that on this ___).__!::. day of before me a , otary Public in and for said County, personally came Joh.,-. f'x-~ufo . and . }(6-~ 0(;)w)</ Officers of Carroll Tovvnsbip Emergency Medical and Fire Service, Inc., who acknowledged the signing of the above Agreement as Officers of Service, Inc., on behalf of Service, Inc.,

and by the authority of its Board of Directors, and that the Agreemen1 is the voluntary act and deed of -"fo J...~ ffr0tf- . and k,-~7_ 6 o\,Jr=:- ,

as such Officers, and the voluntary act and deed of Service, Inc., for the~ urposes stated therein.

IN TESTIMONY WHEREOF, I have hereunto subscribed my name and affixed my seal this J J.!Y day of Ov~ 2014.

C-7 DBNPS Emergency Plan Revision XX MAGRU DER 615 FuUon Street Port Clinton . Ohio 43452 HOSPI TAL 419*734a3131 Ifs How We Care October 19, 2016 Mr. Jam.es Vetter Emergency Respon.sie Manager Davis- Besse NuoTear Power Stat ion SS01 State Ro ute 2, Maill Stop 3060 Oak lelarbo r, Ohio 43449-9760

Dear Mr. Vetter:

This is to reaffi,r m our commitment of November 14, 972 in that H. B. Magr1Jder Memo:rial Hospital wil accept cas,ua,lties arising from radiation accidents c1t t he Davi~ Besse Nuclear Powe r Statton.

It is understood that the .FirstEne rgy Compa ny is fina ncial:ty responsible for any modif1cations of the existing hospital! fa cil i.ty wh [ch may be required by regulations of the Nuclear Regulatory CQmmissfon, or others, for the treatment of patients &llpos.ed to radioactilve materia ls. This also incl'udes tra,ining of hospita l personnel as maybe required and forsped al equipment as may be n,ecessary.

it ,is f urther un de rstood that writte n procedures detailing the actions to be followed for the care of t hese patients wil l ibe implemented and t hat our personnel will continue to receive instructions rega,rding this plan of .action and will make periodic Mdry runs" as needed.

This a,g reement shall remai'n in effect unt il tenminated frqwriting by either party thirty (301 days prior to tihe effectlve date.

Sincerery,

~/!4/

J, iodd Alme ndinger Pres*ident & CEO JTAfpap

C-8 DBNPS Emergency Plan Revision XX Rev. 23 FebJ11.rary, 20 l 1 illaml !if Oll!!n'l,J' li'Nnlltlotim

"~~

~

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,Qmd1Cmlhdl!

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~R~Manqer V.'111-&.tblen,Power ~

SS-01NonhS-~2 O!lk Harbor, OK '43449*

De.M'r.V~l.!Cr, ne l.i.Rt Cowty ~ ,Ma,~ APIO)' r, 0*1111 lracl ..-er '.n tu. c.trty ro, ll!t ,CIOMflilton ,!1f 111de tmelf,Wict M ill (11.e COWII)'. As ~ (le lillC8I Cwilly ~ ~

rapolllle IO IRlil

~ iwo.111 lad 1nd a,cxdl!l!lll; tu* Ciwlf1 iCQOilSO to 81111100.

in.cfdm! Ill

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pidclltNi 10 (IMJ wlih llll ~ y a Difiwt-Bmo Niiekff iPOI.IW S4atioil, 11\d Wllllld l1i.ijileirm lhCil; pin lid ~ to be.,t oflls l\ll][ty: 11 tlKi Cftllt or. irdd~illi I -

,p ul. .

11le ~ lily i kl ptvCed lhil lleallti,DIil weltive orlbe ,ooJ!b: la! ~- ~ ~ me, ~LCllli ol lb letJICi'lk Ii'-* guiildina.

11"31ll8,l'IICIIIOOI 1blll' l'lll!Wn ,la cd'_b unt.D !~i ~ [~ mt~ I>)' ti1lw pan,, lilly (lO) ~ , pd.or io llw

,ef'lteti"dat.e.

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Hlli)'2 IS.-051Xl ' lv//ft.11&111.d~n flffl(~ 19) :ZIJ.m2 AIJir,t!M!(/Wll!Nllll,II~

C-9 DBNPS Emergency Plan Revision XX Board of Conmy LUCAS COUNTY Comntl.uion:ers Quo] Contrad111.

prgsjde11t Tin* Skeldon Wozniak Pete Gerken fmerp.ncy Managemeol Agency Mauhew S, Hq:rnlan, Director Ml', Jame~ Vetter Febrnary 6, 20 14 BmcJgcucy Response Manager Davis-B!.\sse Nucle11r Powet Station 550 I N. State Rou e 2 Ollk Harbo, Ohio 43449

Dear Mt. Veltei*.,

111c following 1tmhml old agroorncn1s nrc availnblc for Lucas County EMA in the even1 addi1ional resou1~es al'c needed to suppmt II resJKlllse to 1111 h1ciclent, in.c,1.ud ing hostiLHcl ion based, at the Davis.Dcsse NucJear Power Station.

TJ,e OhiQ Jntrast.a.to Mull1al Aid Coulpaot (JMAC) o The purpose of IMAC is to clevcJop lllld improve inlrnstafc 11mtu11I aid capt1 bilitfos for pl'Oviding services and resources ncross loc&I boundaries in response to and recovery from any disaster ~llting in a. form11I declaration of e111.ergCJ1cy.

E,ne~*g,eney Mauagenu:ut Assistance Comµact (81\1AC) o This con1poot was as1ablished by st111cs, for the st:aw. It is 11ot a federal program. *nie~ s*rc, however, systems in the EMAC program which allow fur close cao1.*dh:u1tion with fedcml ~'18rt11ers engaged in supporting affecled state$.

Ohio Law Enforcement Response Pinn (LERP) o Tho LBR P is a loo) for l'aw enf01'Ceme11t a.geelcies to ncquire .l11rg~ quAntfl les of Jaw enfmceme:nl F~tourcc.!I iu the event of II domes.tic lerrorist RI.tack, maj 01* dis.mer, or other emc.rgc11ey.

Obio Fire CJ1iers Association Emergeuc:y Response Plan o Developed by die Ohi.o Fhe Chief's Association 11s a phm to bring mutual aid to any ar-eu of01e state in need of 11.dditionaJ fire response rtlS0\1!'¢eS, Regards,.

MRUhcw Heynnan Dil'ector

C-10 DBNPS Emergency Plan Revision XX

~ PROMEDICA MEMORIAL HOSPITAL 0 1 r M issio n is to imp rove yo r health ond well -being.

November 28, 2017 Mr. James M . Vetter Manager - Emergency Prep.are-d.ne.s.s Davis-Besse Nuclear Power Station 5501 State Route 2, Mail Stop 3060 Oak Har:bor, Ohio43A49-9760

Dear Mr. Vetter,

This letter reaffirms our commitment ,of June 30, 1998 that ProMediica, Memortal Hospita,1 w illl accept rasualtles arising from radiation a,cddE!nts at the Davis-SI!~ Nudle-a,r Pa.wer Station.

t is understood that FlrstE?e~gy rs f inancially responsible for any modifications to, the existing ho* pit.al facility, wh ich may be re*CFfi1~d for regulations of the Nuclear Regulatory Comrnissiorn, or others, for the treatment of patient,; exposed to radioactille ma~e rials. This also includes tra ining of hospital pe rson nel as: may be requfred and for special equipment as may be necessa.ry.

It is further understood that wriitten 1p rocedu~ detailirng the acttorns to be followed for the care of these 1patlents, wmbe 1lmp'lemented and that our personnel will continue to r&eilVe*l1nstructfons, regard ng this 1plan of action and will mak,e perfodic Ndry runs: a,s needed.

This i.lgreement sha,11 remain irn effect until temi ini.ltett i:n wiritiing by e ithr Pi.lrtv thirty (30) days prior to the ,effective date.

Sincerely,

<yu_,t\M P m Jens.en-, Pre

C-11 DBNPS Emergency Plan Revision XX

~ ; MERCY July 2.9, 2015 Mr. James M . Vetter

~,ey Ctilo1>'1's Hosp11B Ma11ager - Emergency Response M.,rcy HaapaaJ al NilnOO Davis-Besse Nucle.ir Power Station 5501 N. State Route 2, Mall St op 3060 Oak Harbor OH 43449-9760

Dear M r. Vetter:

This Letter of Agreement reaffirms our commitment:, specified in our mutual agreement with First Energy, that Mercy St. Charles Hospital will acce pt casualt ies ari,sin!! from radiation accidents at the Dav1~ Besse Nuclear PowerSta*ti.o n.

It is ,understood that First Energy is financially responsfble for any modifications of the existing hospital facility w hich may be required by regulations or other guidance of the Nuclear Regulatory Commission (NRC) or the Federal Emergency Managemen t Agency (FEMAI for the treatment of patients exposed to radioactive materials. This also includes training of hospit,al personnel as may be required, and for speaia.l equipment as may be necessary.

It is further understood that written ,procedures detailing the actions to be followed for t he care oft:hese patients w ill be implemente d and t hat our personnel wll l ,c ontin ue to receive inst ructions regarding this plan of action and wTII m.ike perlodlc "dry runs* as needed.

This agreement shall remain in effect until terminate-din writing by either party th irty (30) days prior to the effective date.

Sincerefy, t~ AA ~

Craig Albers, RN Vice President. Patient Care/CNO Mercy St. Cha rles Hospital Agreed to:

Date Ma ger, Emergency Respo nMi Davis-Besse Nuclea r Power Station

C-12 DBNPS Emergency Plan Revision XX INPO ltaflitAM' IJI NtJGif1i rl':iJ we 0 ,lrllfllrHJt

&r/2 JOO 1flD aui'fflil F'ili'hii>'*

M,ml iill 3fJTl3JJ"5ffa' 710./J4~~ (J/)0 Sl FAX 110.f-l*N~

October 30, 2012 111.i * [ uer c:er te-: _ at e plant e er,g.ency _*!l:!li~lan.,ce 0igreement between INPO aru:il lb:;,metnber u.tillll. ili'e.truilctl in effect lithe e¥e1u ot' li!i emergenc-y at your utiility~ -0 will assist you macquiring the help iof o.flillM urganiz1.dions in the iruh.!lsb'y, as de!J;cribc-d m

ecli 1 l of tho mer anr;y Ilesrnure.s: MBirn.lnl1, IN!PO* (t3im00], imcHn di.c United 8 tes Nuclsae - try Riespom~ P1 -WOik. If1,cque~od! _PO wm pFovide Ute . Wb:Iw.tng ij!{ic:!i:s~m;c:

., c *ordriut te teclm~~- :iru.i maaion fl :ioan the **e ,l . d ufll{ .* to th uc~ear Irnd

str,y and gover,nm.ent age11,eies

- , oFdijruit.e [h-e proc:urell!u;mt .1md t:dtlpprng of cquipme:m and Hpplic,s

1 ~c~ 1* _p - J w~ tec]nuc l ~et111.n !i

*f a0,ili ate indw.1 vendor and comm . ial. suppU r ,su , -or .

oibtain niecrn]lica.l inrormat.iio.n and :tndustll.J' QJ)l'a'af.ng oxp1Mi ence rt,gaming pilant 1

c-ornponcnts 8lil:d sysl 1m

provide nn. ]NPO Hai.ii.on to fa.c:ihtate jm,,e_ faoc-This a:~ .~ -m-ent _nI :rem.1m .in e~ '~ t ir n ten in ;ed i 1 \ 1rlti . Should yo l ha mny t , pie-a

call . 'te e Men , , t {770) 644~ 8546 r e~ - 11 t t MengSW@inpo. g.

IT :cjm

C-13 DBNPS Emergency Plan Revision XX

. . O:tutw.~ County Emc1tgcrncy Mana cme111l Agency ,offic~ 4il?--7l+6i'90-0

'i *.*'

I 315 M3d n Street, Annex !Basement fl'Ol1 c .rillon, Ohio 4345.2:-19':3(!;

,cn.mly\ _de:

IIFll * ]mile.

.aoo-7&8-8803, iU9,.24'9*23(il AUlD PETE. ** EN, l[)Lf,C(lor lfpellersen@m.oll:nva.olu S'o,0t4*'fi *. il,i\VLV.oo..ottawa.oluJ1$/*0liLaMi'aiC O ,

l!lpt mber ,1\1, W:IA Mr. Jarifl~. flier, rs 1-c:1 Re* po11 M* niJJJ r

. -_ ~C' Nuc 1r Po.111ror tlolfl, 5501 tllOil"llh Sti;lte R(i1,J1;e 2 O'i! . t i t bo , OH 43~119 Dea r Mt . Vette *,

'11 Ou w C~1.m'l'y f~ rg

nc.y M r~ eme11 A<gei1cv h li);e I fldl agen -~ In om.100 o.rnnt*r fo Iii nd ne:

1

.aoo t(lo(]l'dinert g res;ponse to, e,re;i-Wld'e, emerg(! (!*~ wlltlln lh~ CQim:cy. AS s1,1 th, Ille Oct.aw.a Col/lnl','

Hnel'gerilty aoogeme-i:il A§emcv wou iii lead and toordiillate Couilil:i; l'e~onse to, a1n ineiilem at I e-i1/4lvls-ne . ucle21t Po,wer :St r ,-..

Oita

ta Cou tv has. d,evelO'pedi [Pl~* s .and ~ i!'.f.eli :s to deal wit h a -emergenc.y at D.avfs-Besse

UJ lear l'm\o1er SMtliltl, il"lclUd In lttoSllOO actfoo, and !f(J11i1 ld ~ nd- e dC!-11 s to th t ,o Jt5 1;11blllty In t e , ve, t of M n . i;:lent t the l}le1nf.

co ,iv 1le"1d~ t-o proteet !Jhe t1~ltl aa,dl 11~fa1e of title, pea le i~ ottaona Couniv ifuvuti;h U;e n _le .e uilil of ll~ re~_ponse p.fam ,a rJ su dellne:;.

111'1s. t1i r or 1e o, nl Is. not 11111 cl, r~d lmll 001 l:i w nsttu d H cr,M ns I ,b i"l.y on the p:1tt o

!he- C'IJ'l,Jnty qf OU1;1~, i;1J1d outs oll l!len~e~. ,or of the of* .~ J~, 1;1gents :r ~mJ;!l'ovee~ dler of.

This .'.l re: i'll'ltl'U. W I b F lew d , rtd, Ir ill 00 t'/, II d (li'I tin an.i'lual bas" ili -'.ICCOl\ihinit~ Wjll fJJIJ',fUG 4. If no re11ls.io~ ar nei;e$.S,i!JY, fliilc, ,i!Sf me nt will r,emttl J111 e t ~ lllil iS terrnln ted b';'

ell r part',' glvJ11g rnln:etv !90) d11','s. ii!d.ii::1!1<<!, w !'it e11 11-otic::~ , f termination t,o tlhe ,0,tihe, . IIY, EM EnGH<<:'I' s} *Co; mis.

~

Soo\liitn M. At11dt, Co :missrol'"li!:r

C-14 DBNPS Emergency Plan Revision XX December 2, 20 l:l Mr. Glenn McKee 1 First Eoe:rgy Nu~lear Operating C-0mp,my 1 341 White Pond Dri f:,.VAC B~l)

Akron, O hio 44320

Dear Mr. McKee:

lJ!I order for the State of Ohio to Jefnj,jll1 in oompiiance i,vith Federal regufationcs, th~ estahli:shed Memorandum of Understmdin:g (MOU) b 1:w,cen the Slate of Ohio and Firiit Energy Nuclear Operru:ing Company (FENOC) has bean reviev.-ed regarding the ooo-rdina:tio11 of off-site response to n.u:olear incidents for Beaver V a.lky Power Station (BVFS). Davis.-Bes&e

ucJear flower Stfflion (DBNPS) and eny N uclear Power Pbnt (PNPP). The ~ment is in aooordM.Cr: with the NHC!ear Regolato.ry Commis. ion (NRC) and Fe&!ral Emergency M8:llagement Agency (FEMA)' guidance as outlined in NUREG-0654/FBMA-REI1~1 ,

R.e,vi:skm t Enclosed you.w.ilJ fin.cl ~ c pr ofthe most recent ,d cwn i:.

The ptupose of this letter is to inform y,011 the agreement be~ the Slate of Ohio aoo lhe F . N w:iis reviewed and remain in e oct. The State fmtl1er ackoo v.looges the MOU wi.Uoo:nlinue to remain in full

-Co.roe and effect until such time as either oflilie parties decides the a.greement need~ to be revised. Eilcb year.

the MOU wiJt be reviewed fur substantive changes and updated as ne,oessar-y. Bn_nfug an subsrantiv,e changes, the MO w:ill r~ain ill effect. Signatory C-Ollfrrmation is not required.

} f you do not agree w.ith this re,. '.ew proctss or wish to make changes to the- MOU, pl~ contact Mr.

Michael .Bea,; of my staff at 614-799-3687. I f the proc*~ is .acceptable and you have o.o clumges, you need to do oolh:in~. PJease Jet us know if ycm have any ~uestions. in t.a1s regard. Thank you:.

Enclosure

C-15 DBNPS Emergency Plan Revision XX LEITER OF AGREEMENT' BETWEE lt1RST ENERGY . WCLEARQPERATING COMPANY

,-\ND TRE omo DEPARTMENT OF !PUBLIC SAFETY EMERGENCYMANAGEMENTAGENCY This Jett@r will serve as a written agreement tna,t the First Energy Nuciear Operating Cool.pally (Davis-BGBa~ Nnclear Power Station,.Perry no1ear Power Plant, and B,eaver Valley Power t-.ition) will pJXnide the Ohio D~aitment of Public Safety. Emergency Management Agency with the following !;<J.U(pm: e:m: at the locations iJ!dicatoo wnng ~ drill or eme1gency imohing a nuclear power plant.

LOCATION~ EOUIPMEJJ.I!

JI>IC: Te1epho:ru$, Facsimile l\lh.chin~ Copier, Typewritcw'Worcl Processor, W011k Space. Status Boards, Map-s. Admimsntive Support/SuppHes BCC/EO ; Tclepho-nes, Faesimile M;'.J:ohme, Copier, Wor Space, Sta.ms Boards, Maps, Adnunis:trati.ve Support/Supplies

, O'l'E: It is understood tht this Jisti1rnot aU inchu.ive, but is reprosentafrve offue level o support needed by resp mler-s to these fa:cilit:i$Ji:

A teclmfoa[ liaison v.i ll lre ilispartcb.ed by the FirstEnergy Nuclear Operating Company to fu.e S1atie Erott-gency Operatiotl$ Center {EOC) upon or l:le.fure the dBClaration of a Site Area Emergenoy at Davis~Besse Nuclem-Po,wer tat.ion,.:Perry Nuclear Pow.et Pla.II,t, or Beaver VaUey P,ower Srntion .3 $ deremuned by individual plant procedw;es. The State will pro ida mmilar eqltipment to the tec}micaJ Jiaifl'On to emw:-e ms/her dati,es may bEi perfonned. In the event of an incident where further degradation ofth,e pliWt appears likdy. fu.e Ohio Emergency Managei:ltent Agency may request that the teclmical Haia.on be dispatched to the State EOC prior to a Site Area Enrergency dieclaratiou. Th@ Ohio Emergency Manag:ement Age-ncy will dispatch a liaison ro the nu.clear power plant of ooncem at the Alert level.

T

is agl'eemmt slutU be i;eviewed annually .m.d updated. asS nece.s my. The llg[eement will 1:enurin in effect until terminated by eithor party thron.gh tbe submission of a sixty (60) da.ys

'WriUen notice.

SIGNED

.iFot flhe State o,f OM111 Eme1-gency For the irst Energy Nu.c[ear Management A.geu,cy Operating Compflny EXECUTrVE DIRECTOR CiHIEF OP UOO OF.iF'ICER ~ P.IUlOC:

DATE '

D-1 DBNPS Emergency Plan Revision 35 Appendix D Supporting Documents (Under Separate Cover)

EVACUATION TIME ESTIMATES OHIO RADIOLOGICAL EMERGENCY PREPAREDNESS PLAN OHIO RADIOLOGICAL EMERGENCY PREPAREDNESS (REP) OPERATIONS MANUAL OHIO EMERGENCY OPERATIONS PLAN, EMERGENCY SUPPORT FUNCTION #10, HAZARDOUS MATERIALS, TAB B - REP INCIDENT RESPONSE PLAN OTTAWA COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN LUCAS COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN

E-1 DBNPS Emergency Plan Revision XX Appendix E (Under Separate Cover)

DBRM-EMER-1500 A, Davis-Besse Emergency Action Level Basis Document

F-1 DBNPS Emergency Plan Revision XX Appendix F (Under Separate Cover)

Davis-Besse Nuclear Power Station (DBNPS) ERO On-Shift Staffing Analysis Report

Attachment 2 DBNPS Emergency Plan Affected Pages (Clean Copy)

(194 pages follow)

DBNPS Emergency Plan Revision XX DAVIS-BESSE NUCLEAR POWER STATION EMERGENCY PLAN

DBNPS Emergency Plan Revision XX FOREWORD In accordance with the conditions of the Nuclear Regulatory Commission operating license for the Davis-Besse Nuclear Power Station, the management of the Company recognizes its responsibility and authority to operate and maintain the Davis-Besse Nuclear Power Station in such a manner as to provide for the safety of the public. The importance of Emergency Preparedness and Response in contributing to this safety as well as contributing to Station reliability is also recognized.

In accordance with this philosophy, this Emergency Plan has been prepared. It establishes the procedures and practices for management control over unplanned or emergency events that may occur at the Davis-Besse Nuclear Power Station.

Revision 35 of the Emergency Plan meets the requirements of 10 CFR 50.54(q). Changes made in Revision 35 of the Emergency Plan do not decrease its effectiveness.

The issuance and control of this Emergency Plan and activities associated with Emergency Response at the Davis-Besse Nuclear Power Station are the responsibility of the Site Vice President, DB Nuclear. Additions, deletions, or modifications to the Emergency Plan shall be approved by the Manager, Regulatory Compliance and Emergency Response, the Director, Site Performance Improvement, and the General Plant Manager. It is intended that this Emergency Plan and the Emergency Plan Procedures be fully compatible with the applicable requirements for quality assurance set forth in the Nuclear Assurance Program Manual.

The Manager, Regulatory Compliance and Emergency Response is hereby assigned the responsibility for emergency preparedness operations with authority as established in this Emergency Plan and outlined above. Day-to-day maintenance and implementation of the Emergency Response Program is the responsibility of the Manager, Regulatory Compliance and Emergency Response and the Emergency Response Section.

Manager, Regulatory Compliance and Date Emergency Response Director, Site Performance Improvement Date General Plant Manager Date Site Vice President - DB Nuclear Date

-i-

DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes Revision 35 addresses routine updates to the DBNPS Emergency Plan and incorporates changes supporting changes to the station telephone communications, the company name, and removed reference to Company Nuclear Review Board (CNRB) in the Recovery Section of the plan.

Title change throughout Changed title of Emergency Response Manager to Manager, Regulatory Compliance Emergency Plan and Emergency Response Forward page Removed FENOC from the third paragraph Page xi Removed reference to FirstEnergy Corporation Section 2.2 Changed FENOC to Fleet Section 5.6 Removed the sentence The Emergency Public Information staff is activated by call tree notification, and operates the Joint Information Center (JIC).

Table 5-1 Moved NRC Liaison under Emergency Operations Facility from a 1-2 hours to a 60/60 time requirement in the Alert, Site Area Emergency, General Emergency column.

Table 5-1 Moved State/County Communicator under Emergency Operations Facility from a 1-2 hours to a 60/60 time requirement in the Alert, Site Area Emergency, General Emergency column.

Section 6.1 Removed the form number (Form 361) from the form name NRC Event Notification Worksheet.

Section 6.4.1.b Removed as described below. At other site locations (i.e., Davis-Besse Training Center, Davis-Besse Administration Building and Annex, Warehouse),

Section 7.6.1.a.1 Revised A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides six in/out bound offsite communications paths to A Private Branch Exchange (PBX) is used by the station for telephone communications. The PBX system provides in/out bound offsite communications paths Section 7.6.1.a.1, first Deleted first bullet 2 paths connect to the FirstEnergy company communications bullet system

- ii -

DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes (Cont)

Section 7.6.1.a.1, Revised 3 priority circuits travel to Toledo where then connect to the commercial second bullet telephone system to 2 priority circuits connect directly into the administration building PBX from the commercial telephone system Section 7.6.1.a.1, third Revised 1 priority circuit connects directly into the local commercial telephone bullet system to 1 priority circuit connects directly into the plant office building PBX from the commercial telephone system Section 7.6.1.b.1 Revised Voice over IP service from the Akron Ohio West Akron Campus to Voice over IP service delivered via Point to Point circuits Section 7.6.1.g Removed sentence The system is composed of a minimum of 26 phone lines Table 7-1, section A Added or Equivalent under Type of Detector for Neutron Figure 7-1 Revised Toledo Edison Plaza to 300 Madison Building LLC; revised FirstEnergy Corp. Facility to Corporate Facility; and removed reference to the Site Emergency Operations Center Section 8.3.2 Revised FENOC to Fleet Section 9.2 Deleted Following a SITE AREA or GENERAL EMERGENCY, the Company Nuclear Review Board (CNRB) will participate in the recovery planning effort to assure that all nuclear safety aspects of the recovery are satisfied. The CNRB will report their findings to the Recovery Director, who shall take the actions that he deems appropriate for safe recovery operations.

Section 9.2.3.a.3 Deleted Coordinate with the CNRB to ensure adequate review of engineering activities and proper review and approval of the recovery plan and implementing procedures. And renumbered subsequent steps.

Page A-2 Removed procedures: NOP-LP-5400, FENOC MIDAS Dose Assessment Software; NOP-LP-5402, Davis-Besse MIDAS Dose Assessment Software; NOP-LP-5412, DBNPS MIDAS Multiple Accident Dose Assessment Software; and added procedures: NOP-LP-5020, Unified Rascal Interface (URI) Dose Assessment Software General Administration; NOP-LP-5022, Davis-Besse Unified Rascal Interface (URI) Dose Assessment Software, and NOP-LP-5024, Unified Rascal Interface (URI) Dose Assessment Software

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DBNPS Emergency Plan Revision XX Davis-Besse Nuclear Power Station Emergency Plan Revision 35 Summary of Plan Changes (Cont)

Page A-2 Removed reference to RA-EP-02550, Offsite Personnel & Vehicle Monitoring &

Decontamination Page A-2 Removed FENOC from the title FENOC Field Monitoring Teams Radiation Monitoring Teams Field Surveys Page A-2, items 8 and 9 Revised 7.2 to 7.3 Page A-2, item 21 Revised 6.4.2 to 6.4.3 Page A-2, item 23 Revised 6.4.3 to 6.4 Page A-3, item 2, off- Added 6.5.3 normal Page A-3 Removed FENOC from the title FENOC Siren Testing And Maintenance Procedure Page A-4, item 1. Removed 4.3.3 and 5.5; and added 5.6 Public information Page A-4 Removed FENOC from the title Fleet Support of Emergency Plans at FENOC Nuclear Plants Appendix B Removed reference to FirstEnergy Corporation

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DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 1.0 DEFINITIONS ..........................................................................................................1-1 2.0 SCOPE AND APPLICABILITY ..............................................................................2-1 2.1 Site Description................................................................................................2-1 2.2 Population Distribution ....................................................................................2-2 2.3 Emergency Planning Zones ............................................................................2-3 2.4 Regulatory Requirements.................................................................................2-3 2.5 Objectives of Emergency Response.................................................................2-4 2.6 Emergency Plan Interrelationships ..................................................................2-4 2.7 Emergency Plan Procedures, Station Procedures and Fleet Business Practice ....................................................................................2-5 2.8 Participating Governmental Agencies .............................................................2-6 3.0

SUMMARY

OF THE EMERGENCY PLAN...........................................................3-1 3.1 Emergency Plan Steps .....................................................................................3-1 3.2 Emergency Organizations ................................................................................3-1 3.2.1 State of Ohio .......................................................................................3-2 3.2.2 Ottawa County, Ohio ..........................................................................3-2 3.2.3 Lucas County, Ohio ............................................................................3-3 3.2.4 Erie County, Ohio ...............................................................................3-3 3.2.5 Sandusky County, Ohio ......................................................................3-3 3.2.6 State of Michigan ................................................................................3-3 3.2.7 Federal Agencies.................................................................................3-4 3.3 Emergency Categories .....................................................................................3-4

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DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 4.0 EMERGENCY CONDITIONS .................................................................................4-1 4.1 Emergency Classification Levels (ECLs) .......................................................4-1 4.1.1 GENERAL EMERGENCY ................................................................4-1 4.1.2 SITE AREA EMERGENCY ..............................................................4-1 4.1.3 ALERT ...............................................................................................4-1 4.1.4 UNUSUAL EVENT ...........................................................................4-1 4.1.5 RECOVERY .......................................................................................4-2 4.2 EMERGENCY CLASSIFICATION4-2 4.3 INITIATING CONDITION (ICs) ...................................................................4-2 4.3.1 Recognition Category Codes ..............................................................4-2 4.3.2 Emergency Classification Level (ECL) Codes ...................................4-2 4.4 EMERGENCY ACTION LEVELS (EALs) and Fission Product Barriers (FPBs)................................................................4-3 4.4.1 Barrier Abbreviation Codes ...............................................................4-3 4.4.2 Fission Product Barriers (FPBs) Recognition Categories Codes ........4-3 4.4.3 Operation Mode Applicability ...........................................................4-4 4.4.4 Treatment of Multiple Events and Classification Level Upgrading ...4-4 4.4.5 Emergency Classification Level Downgrading ..................................4-5 4.4.6 Classifying Transient Events ..............................................................4-5 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES .........................................5-1 5.1 DBNPS Organization .......................................................................................5-1 5.1.1 Plant Management and Administrative Organization .........................5-1 5.1.2 Onshift Operations Group ...................................................................5-2 5.1.3 Normal Plant Shift Staffing ................................................................5-2 vi

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 5.2 DBNPS Emergency Management....................................................................5-4 5.2.1 Emergency Director ............................................................................5-4 5.2.2 Emergency Offsite Manager ...............................................................5-5 5.2.3 Emergency Plant Manager ..................................................................5-5 5.2.4 Company Spokesperson......................................................................5-6 5.2.5 Emergency Director Advisor ..............................................................5-6 5.3 Onshift Emergency Response Organization ....................................................5-6 5.3.1 Shift Manager .....................................................................................5-6 5.3.2 Unit Supervisor ..................................................................................5-7 5.3.3 Shift Engineer (Shift Technical Advisor) ...........................................5-7 5.3.4 Security Shift Supervisor ....................................................................5-7 5.3.5 Onshift Maintenance Support .............................................................5-7 5.4 Onsite Emergency Response Organization ......................................................5-8 5.4.1 Overview.............................................................................................5-8 5.4.2 Direction and Coordination ................................................................5-9 5.4.3 Control Room .....................................................................................5-9 5.4.4 Technical Support Center (TSC) Organization...................................5-9 5.4.5 Operations Support Center (OSC) Organization ..............................5-12 5.5 Near Site Emergency Response Facility ........................................................5-15 5.5.1 Overview...........................................................................................5-15 5.5.2 Emergency Operations Facility (EOF) Organization........................5-16 5.6 Joint Information Center (JIC) .......................................................................5-18 8

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DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 5.7 Supporting Emergency Organizations ...........................................................5-19 5.7.1 Letters of Agreement ........................................................................5-19 5.7.2 Medical Emergency Response Organization ...................................5-19 5.7.3 Government Agency Support ...........................................................5-22 5.7.4 Other Support Organizations ............................................................5-28 6.0 EMERGENCY MEASURES ....................................................................................6-1 6.1 Activation of the Emergency Response Organizations....................................6-1 6.1.1 Shift Manager/Control Room Operations ..........................................6-2 6.1.2 Emergency Director ............................................................................6-4 6.1.3 Ottawa and Lucas County Sheriffs' Offices ........................................6-4 6.1.4 Ottawa County and Lucas County Emergency Management Agency Directors ..........................................................6-4 6.1.5 Ohio Emergency Management Agency (OEMA)...............................6-4 6.1.6 Federal Agencies (Other than NRC) ...................................................6-5 6.1.7 Ohio Department of Health.................................................................6-5 6.2 Assessment Actions .........................................................................................6-6 6.2.1 Assessment Actions for an UNUSUAL EVENT ................................6-6 6.2.2 Assessment Actions for an ALERT ....................................................6-6 6.2.3 Assessment Actions for a SITE AREA EMERGENCY .....................6-7 6.2.4 Assessment Actions for a GENERAL EMERGENCY ......................6-7 6.3 Mitigative Actions ...........................................................................................6-8 6.4 Protective Actions ............................................................................................6-8 6.4.1 Plant Site Protective Actions ..............................................................6-8 viii

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 6.4.2 Offsite Protective Actions .................................................................6-10 6.4.3 Use of Onsite Protective Equipment and Supplies ...........................6-11 6.4.4 Contamination Control Measures .....................................................6-11 6.4.5 Ingestion Pathway Control Measures ...............................................6-11 6.5 Aid to Affected Personnel..............................................................................6-11 6.5.1 Emergency Personnel Exposure .......................................................6-11 6.5.2 Thyroid Blocking ..............................................................................6-12 6.5.3 Decontamination and First Aid .........................................................6-13 6.5.4 Medical Transportation .....................................................................6-14 6.5.5 Medical Treatment ............................................................................6-14 7.0 EMERGENCY FACILITIES AND EQUIPMENT ..................................................7-1 7.1 DBNPS In-Plant Emergency Facilities ............................................................7-1 7.2 Davis-Besse Administration Building (DBAB) Facilities ...............................7-2 7.3 Near Site Emergency Response Facility..........................................................7-5 7.4 Other Company Emergency Facilities .............................................................7-5 7.5 County and State Emergency Operations Centers ...........................................7-6 7.6 Communications Systems ................................................................................7-7 7.7 Alarms ........................................................................................................... 7-9 7.8 Prompt Notification System...........................................................................7-10 7.9 Assessment Facilities .....................................................................................7-11 7.10 Protective Facilities and Equipment ..............................................................7-17 7.11 First Aid and Medical Facilities.....................................................................7-18 7.12 Damage Control Equipment ..........................................................................7-18 ix

DBNPS Emergency Plan Revision XX TABLE OF CONTENTS Plan Section Topic Page 8.0 MAINTENANCE OF EMERGENCY PREPAREDNESS .......................................8-1 8.1 Organizational Preparedness............................................................................8-1 8.1.1 Training...............................................................................................8-1 8.1.2 Drills and Exercises ............................................................................8-3 8.1.3 Manager, Regulatory Compliance and Emergency Response ...........8-6 8.1.4 Ottawa County EMA and Lucas County EMA Directors....................................................................................8-7 8.2 Educational Information for the Public............................................................8-8 8.3 Review and Update of the Emergency Plan and Emergency Plan...................8-8 Procedures 8.4 Maintenance and Inventory of Emergency Equipment and Supplies ..............8-9 9.0 REENTRY AND RECOVERY.................................................................................9-1 9.1 Reentry ............................................................................................................9-1 9.2 Recovery ..........................................................................................................9-2 x

DBNPS Emergency Plan Revision XX APPENDICES Appendix Title A Emergency Plan Procedure and Related Document Index and Cross-Reference B Department of Energy Radiological Assistance Program (DOE O 153.1) for Davis-Besse Nuclear Power Station C Letters of Agreement D Supporting Documents (Under Separate Cover)

E DBRM-EMER-1500 A, Davis-Besse Nuclear Power Station Emergency Action Level Basis Document F. Davis-Besse Nuclear Power Station (DBNPS) ERO On-Shift Staffing Analysis Report xi

DBNPS Emergency Plan Revision XX LIST OF TABLES Plan Tables Title Page 1-1 Acronyms ............................................................................................................. 1-11 1-2 Communications Test Frequencies....................................................................... 1-15 2-1 Functional Interrelationships of Response Organizations .................................... 2-7 3-1 Emergency Categories and the Degree of Participation by Various Groups .......................................................................... 3-5 4-1 Operating Mode Applicability.............................................................................. 4-4 5-1 Manpower, Location, and Response Considerations for Emergencies ......................................................................................................... 5-31 6-1 PAGs for the Early Phase of a Nuclear Incident .................................................. 6-15 6-2 Recommended Protective Actions ....................................................................... 6-16 6-3 Representative Shielding Factors from Gamma Cloud Source ............................ 6-17 6-4 Selected Shielding Factors for Airborne Radionuclides....................................... 6-18 6-5 Representative Shielding Factors for Surface Deposited Radionuclides ....................................................................................................... 6-19 6-6 Guidelines for Protection Against Ingestion of Contamination ........................... 6-20 7-1 Radiation Monitoring Instruments and Equipment .............................................. 7-19 8-1 Periodic Training of Emergency Response Personnel ........................................ 8-10 xii

DBNPS Emergency Plan Revision XX LIST OF FIGURES Plan Figures Title Page 2-1 DBNPS General Site Location ............................................................................. 2-8 2-2 DBNPS Site Annual Wind Distributions at the 10 Meter Level .......................... 2-9 2-3 DBNPS 10-Mile Emergency Planning Zone ........................................................ 2-10 2-4 DBNPS 50-Mile Emergency Planning Zone ........................................................ 2-11 5-1 Onshift Emergency Organization ......................................................................... 5-33 5-2 Emergency Response Organization...................................................................... 5-34 6-1 Summary of Typical Emergency Measures ......................................................... 6-22 6-2 Emergency Notification ....................................................................................... 6-26 6-3 Offsite Emergency Evacuation Routes................................................................. 6-28 7-1 Emergency Facilities by General Location .......................................................... 7-21 9-1 Recovery Organization Framework ..................................................................... 9-7 xiii