ML22269A358

Issuance of Amendment No. 305 Revising the Emergency Plan

ML22269A358
Person / Time
Site:	Davis Besse
Issue date:	11/15/2022
From:	Luke Haeg Plant Licensing Branch III
To:	Tony Brown Energy Harbor Nuclear Corp
Purnell B
References
EPID L-2022-LLA-0013
Download: ML22269A358 (30)

Text

November 15, 2022 Mr. Terry J. Brown Site Vice President Energy Harbor Nuclear Corp.

Mail Stop P-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 ISSUANCE OF AMENDMENT NO. 305 REVISING THE EMERGENCY PLAN (EPID L-2022-LLA-0013)

Dear Mr. Brown:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 305 to Renewed Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). The amendment is in response to Energy Harbor Nuclear Corp. application dated January 19, 2022 (Agencywide Documents Access and Management System Accession No. ML22019A236), as supplemented by letter dated July 5, 2022 (ML22186A121). The amendment revises the emergency plan for Davis-Besse by changing the emergency response organization staffing requirements.

A copy of the NRC staffs Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Lucas E. Haeg, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosures:

1. Amendment No. 305 to NPF-3

2. Safety Evaluation cc: Listserv

ENERGY HARBOR NUCLEAR CORP.

AND ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-346 Amendment No. 305 Renewed License No. NPF-3

1. The U.S. Nuclear Regulatory Commission (NRC or Commission) has found that:

A. The application for amendment filed by Energy Harbor Nuclear Corp. dated January 19, 2022, as supplemented by letter dated July 5, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, Renewed Facility Operating License No. NPF-3 is hereby amended to authorize revision of the emergency plan as set forth in the application dated January 19, 2022, as supplemented by letter dated July 5, 2022, and evaluated in the NRC staffs safety evaluation for this amendment.

3. This license amendment is effective as of the date of its issuance and shall be implemented on or before September 30, 2023.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Michael Michael King Date: 2022.11.15 King 07:28:05 -05'00' Andrea D. Veil, Director Office of Nuclear Reactor Regulation Date of Issuance: November 15, 2022

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 305 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-3 ENERGY HARBOR NUCLEAR CORP.

ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346

1.0 INTRODUCTION

By application dated January 19, 2022 (Agencywide Documents Access and Management System Accession No. ML22019A236), as supplemented by letter dated July 5, 2022 (ML22186A121), Energy Harbor Nuclear Corp. (EHNC, the licensee) submitted a license amendment request (LAR) for Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse).

The proposed amendment would revise the emergency plan for Davis-Besse by changing the emergency response organization (ERO) staffing requirements.

The proposed changes would revise the Davis-Besse emergency plan to reduce the number of on-shift staff positions, extend augmented ERO response times, and re-align augmented ERO response positions. The proposed changes also include:

Standardization of position titles and responsibilities; Redefining augmented response timeframes as being initiated from event classification rather than ERO notification; Extending certain augmented ERO response times; Separating the command-and-control functions between the technical support center (TSC) and emergency operations facility (EOF);

Removing references to the corporate assistance center and the radiological testing laboratory; and Revising figures delineating positions associated with facility activation.

The LAR included an evaluation of the proposed changes, a marked-up copy of the emergency plan showing the proposed changes (attachment 1), a clean copy of the proposed emergency plan (attachment 2), and a summary of the ERO changes (attachment 3). In addition, the LAR provided a chart (attachment 4) comparing the proposed ERO staffing requirements to the current emergency plan (revision 35), revision 4 of the emergency plan, and applicable NRC staff guidance.

Enclosure 2

The July 5, 2022, supplemental letter was in response to a U.S. Nuclear Regulatory Commission (NRC or Commission) staff request for additional information dated June 13, 2022 (ML22164A857). The supplemental letter provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on March 22, 2022 (87 FR 16252).

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements The planning standards in paragraph 50.47(b) of Title 10 of the Code of Federal Regulations (10 CFR) establish the requirements that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. In accordance with 10 CFR 50.47(b)(1), the primary responsibilities for emergency response by the nuclear facility licensee must have been assigned, and each principal response organization must have staff to respond and to augment its initial response on a continuous basis. The requirements for on-shift and augmented ERO staffing are addressed in 10 CFR 50.47(b)(2),

which states:

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.

In addition, section IV.A, Organization, of appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50 states, in part, that

[t]he organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization.

2.2 Guidance NRC Regulatory Guide 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors (ML090440294), provides guidance on methods acceptable to the NRC staff for implementing 10 CFR 50.47(b) and appendix E to 10 CFR Part 50. Revision 2 of Regulatory Guide 1.101 endorses Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ML040420012), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and to improve emergency preparedness.

Evaluation criteria II.B.1 and II.B.5 in NUREG-0654 address the planning standard in 10 CFR 50.47(b)(2). Evaluation criterion II.B.1 states that each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement. Evaluation criterion 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.

Interim staff guidance (ISG) regarding emergency planning requirements for nuclear power plants is provided in NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants, November 2011 (ML113010523), which was developed by the NRC Office of Nuclear Security and Incident Response. Specifically, NSIR/DPR-ISG-01 was developed to address the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions. The ISG endorsed the Nuclear Energy Institute (NEI) document NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, June 2011 (ML111751698), which was developed to establish a standard methodology for licensees to conduct analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency for an operating power reactor.

By letter dated June 12, 2018 (ML18022A352), the NRC staff provided alternative guidance related to evaluation criterion II.B.5 in NUREG-0654, Revision 1, for minimum ERO on-shift and augmentation staffing. The letter stated, in part:

The NRC has revised Section II.B, Table B-1 of NUREG-0654, based in part on comments received from the public on the draft Revision 2 of NUREG-0654, located at www.regulations.gov under Docket ID FEMA-2012-0026. The revised ERO staffing guidance has been finalized, and the NRC will include it when the entire NUREG-0654, Revision 2, is ready for issuance. Until then, the NRC staff is making available on an interim basis the ERO on-shift and augmentation staffing plan (attached). Regardless of whether a licensee chooses to use the guidance contained in Revision 1 of NUREG-0654, the attached, or an alternative approach, licensees are still required to adhere to 10 CFR 50.54(q) when revising their ERO staffing plans.

This alternative guidance was subsequently incorporated into NUREG-0654, Revision 2 (ML19347D139), when it was issued in December 2019. To simplify the discussion, the following terms are used in this safety evaluation (SE):

The original table B-1 refers to table B-1 in NUREG-0654, Revision 1.

The revised table B-1 refers to table B-1 in the alternative guidance and NUREG-0654, Revision 2.

3.0 TECHNICAL EVALUATION

In accordance with the Davis-Besse emergency plan, the shift manager initially assumes responsibility as the emergency director during an emergency. Emergency response by on-shift staff is directed by the emergency director until relieved by augmenting staff with the activation of the emergency response facilities. The Davis-Besse emergency response facilities are the

TSC, the operations support center (OSC), and the EOF. The joint information center (JIC) is also housed at the EOF. The TSC, OSC, EOF, and JIC are all activated for an alert or higher classification. Additional corporate support is available from the corporate assistance center, which is notified at the alert or higher emergency classification.

The ERO staffing requirements for Davis-Besse are specified in the emergency plan. Table 5-1 of the emergency plan lists the minimum on-shift and augmented ERO staffing requirements.

Currently, the minimum on-shift staff are listed by major functional area of the emergency plan and the augmented ERO staff are listed by response location. Figures 5-1 and 5-2 of the emergency plan provide the organization charts for the on-shift emergency organization and the ERO, respectively. The emergency plan currently specifies the following categories of augmented response timeframes in table 5-1: 30-minute normal working hour response; 60-minute off-hour response; standard 60-minute response; and 1-2-hour response. These timeframes are measured from the time of ERO notification.

The licensee proposed to revise the ERO staffing requirements specified in the Davis-Besse emergency plan. Table 5-1 would be revised to list both the minimum on-shift and augmented ERO staffing requirements by major functional areas of the emergency plan. The licensee also proposed to change the categories of augmented response timeframes to 60 minutes and 90 minutes, which will be measured from the time the event is classified rather than the time the ERO is notified. The licensee states that a 60-minute response would be required for positions providing support to the on-shift staff and a 90-minute response would be required for positions providing relief to on-shift personnel performing emergency response functions. The licensee proposes to activate the TSC, OSC, and EOF within 60 minutes of declaring an alert or higher emergency classification. Thus, the minimum staff to activate these facilities would be required to respond within 60 minutes of the declaration. The licensee will continue to staff the JIC at the declaration of an alert or higher emergency classification.

The licensee proposed changes to the organization chart in figure 5-1. The organization charts in figure 5-2 would be deleted. The licensee would add new figures 5-2, 5-3, 5-4, and 5-5, that show the revised organization charts for the TSC, OSC, EOF, and JIC, respectively. The proposed charts for the TSC, OSC, and EOF show the minimum positions to activate the facility and the response time (60 or 90 minutes) for each ERO position, which includes positions not listed in the revised table 5-1. Consistent with the current emergency plan, there are no minimum staff positions or response times identified for the JIC.

The NRC staffs review of the proposed emergency plan changes is described below. As part of its review, the NRC staff compared the licensees proposed emergency plan changes to the revised table B-1. Section 3.1 of this SE provides a summary of the enhancements to equipment, procedures, training, and processes that have occurred since the 1980s, which the licensee used, in part, to justify the proposed changes to the emergency plan. Sections 3.2 and 3.3 of this SE describe the NRC staffs review of the proposed changes by major functional area of the emergency plan and ERO staff positions, respectively. Section 3.4 of this SE describes the NRC staffs review of some additional changes included in the LAR that are not addressed in the other sections.

3.1 Enhancements The licensees justification for the proposed changes to the Davis-Besse emergency plan relies, in part, on enhancements to equipment, procedures, training, and processes that have occurred since the 1980s. Based on these enhancements, the licensee 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. These enhancements are described in section 3.1 of the LAR and are summarized below.

Plant Computer System The licensee stated that in the 1980s, the plant computer systems were not integrated, so operators had to use 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. Additional displays were added, and the user interfaces were modified to increase the number of plant parameters that could be accessed through the integrated plant computer system. In addition, a site plant information system was installed to allow archiving and trending of plant data accessible to control room operators and all site personnel via the business network. As compared to the original computer systems, the licensee stated that the current computer systems have improved plant monitoring capabilities; improved graphical displays; real time, read-only plant data available on personal computers; and real time in-plant monitoring of conditions and trends.

Dose Assessment The LAR provides a summary of the dose assessment capabilities at Davis-Besse that existed prior to 2019. The LAR states that in 2019 the licensee implemented the unified radiological assessment system for consequence analysis interface (URI) dose assessment software. The LAR states, in part, that:

The [URI] 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.

Procedures The licensee stated that the Davis-Besse emergency action levels now incorporate guidance that has simplified the emergency classification process. This process includes the use of an overview matrix of emergency action level initiating conditions and threshold values, which streamlines the process of evaluating emergency action levels against plant conditions.

Additionally, the licensee stated that emergency operating procedures (EOPs) have been improved through internal operating experience and industry initiatives. The licensee stated, in part, that the 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 [safety parameter display system] and plant computer. Overall, the improvements made to procedures greatly reduce the operators reliance on the on-shift emergency response organization during the initial phase of the event.

Training The licensee stated that operations training is administered through the application of a Systematic Approach to Training (SAT) to ensure that all training is conducted to the industry-accepted standards required to achieve and maintain accreditation by the National Academy of Nuclear Training. The licensee also stated that a dynamic reference plant simulator is used during operations training to provide hands-on experience and practice in the operation of the plant from the control room during normal, abnormal, and emergency plant conditions. In addition, the LAR states that: 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.

3.2 Major Functional Areas The licensee stated that it performed a functional analysis of the revised augmented ERO positions based on the extended response times and completion of major tasks using NUREG-0654, Revision 1, and the revised table B-1. The results of this functional analysis are described in section 3.2 of the LAR. The licensee stated that the analysis demonstrates that no degradation or loss of function would occur as a result of the proposed changes. The major functional areas of the Davis-Besse emergency plan are currently consistent with the original table B-1:

1. Plant Operations and Assessment of Operational Aspects

2. Emergency Direction and Control

3. Notification/Communication

4. Radiological Accident Assessment and Support of Operational Accident Assessment

5. Plant System Engineering, Repair, and Corrective Action

6. Protective Actions (In-Plant)

7. Firefighting

8. Rescue Operations and First-Aid

9. Site Access Control and Personnel Accountability The revised table B-1 lists the following emergency preparedness functions instead of major functional areas of the emergency plan:

1. Command and Control

2. Communications

3. Radiation Protection

4. Supervision of Radiation Protection Staff and Site Radiation Protection

5. Dose Assessments/Projections

6. Emergency Classifications

7. Engineering

8. Security

9. Repair Team Activities

10. Supervision of Repair Team Activities

11. Field Monitoring Teams

12. Media Information

13. Information Technology of the LAR provides a comparison of the proposed minimum on-shift and augmented staffing levels to the current minimum staffing levels, the revised table B-1, and the original table B-1. The NRC staffs review of the proposed changes to the Davis-Besse emergency plan is described below by major functional area listed in the original table B-1.

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. The revised table B-1 focuses on the performance of emergency preparedness functions by plant operations personnel. The revised table B-1 incorporated the plant operations and assessment of operational aspects associated with emergency preparedness into the command and control and emergency classification functions.

The licensee stated that the staffing levels listed in the emergency plan for plant operations would be revised to reflect only those positions performing the following emergency preparedness functions: emergency classification, notification, protective actions, dose assessment, core damage assessment, and oversight of the on-shift ERO. The licensee also stated that the proposed change was evaluated in accordance with 10 CFR Part 50, appendix E, section IV.A.9. The evaluation did not reveal any conflicting duties for on-shift personnel as a result of the proposed change and plant operations staffing for emergency preparedness continues to meet NRC guidance.

Based on its review of the LAR, as supplemented, the NRC staff finds the proposed revisions to the Davis-Besse emergency plan related to plant operations staffing are consistent with the revised table B-1 and is acceptable because the emergency plan would continue to include the positions required to perform emergency preparedness functions. Therefore, the NRC staff has determined that the Davis-Besse emergency plan staffing levels will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to plant operations and assessment of operational aspects.

3.2.2 Emergency Direction and Control With the revision of table B-1, emergency direction and control was changed to command and control. The revised table B-1 specifies one on-shift individual (the operations shift manager) as responsible for command and control. The revised table B-1 specifies that the TSC should be staffed with an emergency coordinator to relieve the control room within 60 minutes following the declaration of an alert or higher emergency classification. Additionally, the EOF emergency director position should be staffed within 60 minutes of the declaration of a site area emergency or higher emergency classification to perform relief and assume command and control from the TSC.

Under the current Davis-Besse emergency plan, the emergency director is responsible for emergency direction and control. Upon initial classification of an emergency, the control room shift manager assumes the position of emergency director. The emergency plant manager or emergency assistant plant manager may assume the emergency director position upon their arrival in the control room. The emergency plant manager may also assume the emergency

director position from the TSC. The designated emergency director will assume this authority upon their arrival in the EOF or TSC. In table 5-1 of the emergency plan, the shift manager is identified as the minimum on-shift staff for this functional area, the emergency assistant plant manager and EOF emergency director are identified as augmented staff, and the emergency plant manager is not listed. The emergency assistant plant manager has a response time of 30 minutes during normal hours and 60 minutes during off hours. The EOF emergency director currently has a required response time of 1-2 hours.

With the proposed changes, the OSC, TSC, and EOF, would activate within 60 minutes of an alert or higher emergency classification. The licensee proposes to eliminate the emergency assistant plant manager position. For the control room shift manager, the licensee proposed to change the position title of emergency director to emergency coordinator. Emergency direction and control would transfer from the shift manager (emergency coordinator) to the TSC emergency coordinator and EOF emergency director upon activation of these facilities.

Specifically, the licensee stated that the command and control functions of emergency classification, federal notification, and emergency exposure authorization functions would be transferred to the TSC emergency coordinator, and the State/local notification, dose assessment, and protective action recommendation functions would be transferred to the EOF emergency director. The licensee stated that additional support for the shift manager will be provided, if needed, by duty operations personnel and will be managed through operations department procedures. The NRC staff found the proposed on-shift and augmented staff positions for emergency direction and control to be consistent with the revised table B-1 guidance for command and control.

The licensee proposes to revise the response times for the augmented ERO to be consistent with the 60-minute and 90-minute response times listed in the revised table B-1. With the proposed changes, the response times will be measured from event declaration rather than ERO notification. The licensee stated that this will result in the ability to transition command and control functions of classification from the control room to the applicable emergency response facilities earlier than is currently required for off-hour events. The proposed change does not extend the amount of time that the shift manager (emergency coordinator) maintains responsibility for emergency direction and control as the 60-minute TSC, OSC, and EOF activation criteria would ensure continued relief for on-shift personnel within the existing timeframe. The NRC staff found the proposed 60-minute response time for the TSC emergency coordinate and EOF emergency director to be consistent with the revised table B-1. However, the licensee proposes to staff the EOF emergency director position at an alert or higher emergency classification, while the revised table B-1 has this position staffing at a site area emergency or general emergency. The NRC staff considers this proposed change to be more conservative and timelier than the revised table B-1 because it will ensure that the EOF will be mobilized and available should an alert escalate to a site area emergency or general emergency.

The NRC staff reviewed the proposed changes related to emergency direction and control and found them acceptable based on the information discussed above. With the proposed changes, the Davis-Besse emergency plan will have staffing requirements that are consistent with the revised table B-1, except for the proposed staffing of the EOF emergency director position within 60 minutes of an alert. The NRC staff determined that staffing the EOF emergency director position within 60 minutes of an alert is acceptable because an alert is a lower emergency classification level than specified in the revised table B-1. Therefore, the NRC staff has determined that the Davis-Besse emergency plan will continue to meet the planning

standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to emergency direction and control.

3.2.3 Notification/Communication With the revision of table B-1, notification/communication was changed to communications.

The revised table B-1 specifies one on-shift individual to perform the communications function as a collateral duty. The revised table B-1 also states that the TSC should be staffed with two communicators within 60 minutes of the declaration of an alert or higher emergency classification and an additional communicator, as needed, within 90 minutes. In addition, the revised table B-1 recommends the staffing of one communicator in the EOF within 60 minutes of the declaration of a site area emergency or higher emergency classification.

The current Davis-Besse emergency plan assigns one on-shift individual as an on-shift communicator to perform the notification/communication function. This function is augmented by two additional communicators in the EOF available within 60 minutes of being notified of an alert or higher emergency classification.

Section 3.2.3 of the LAR states, in part, that: The proposed revision to the [emergency plan]

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 revised response times are from the declaration of an alert or higher emergency classification.

The NRC staff finds the proposed augmentation times for the staffing of the State and local communicator in the EOF is more conservative than the guidance in the revised table B-1. The NRC staff determined that the proposed designation of an augmenting emergency notification system (ENS) communicator in the TSC and a State and local communicator in the EOF is acceptable because two notification/communications positions will continue to be staffed within 60 minutes of the declaration of an alert or higher emergency classification. In addition, this is consistent with the guidance in table B-1 insofar as it recommends staffing two communications positions within this timeframe. The NRC staff also finds it acceptable to eliminate the 30-minute augmented response position because the licensees staffing analysis demonstrated that the on-shift communicator is able to perform the notification task for an additional 30 minutes without conflicts.

As discussed above, the NRC staff reviewed the proposed changes to the Davis-Besse emergency plan related to the notification/communication function and found them acceptable.

Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the notification/communication function.

3.2.4 Radiological Accident Assessment and Support of Operational Accident Assessment For the major functional area of radiological accident assessment and support of operational accident assessment, the original table B-1 included the following major tasks: EOF director, offsite dose assessment, offsite surveys, onsite (out-of-plant) surveys, in-plant surveys, and chemistry/radiochemistry. Proposed changes related to the EOF director are encompassed in

section 3.2.2 of this SE. The licensee did not propose any changes related to the offsite dose assessment major task. The NRC staffs review of proposed changes associated with the other major tasks in this functional area is discussed below.

Offsite Surveys The revised table B-1 recommends one offsite field monitoring team (FMT) to be staffed within 60 minutes of the declaration of an alert or higher emergency classification. In addition, the revised table B-1 recommends an additional offsite FMT to be staffed within 90 minutes of the declaration of an alert or higher emergency classification.

The current Davis-Besse emergency plan requires three radiological monitoring teams (RMTs) respond within 30-60 minutes of notification of an alert or higher emergency classification. The licensee proposes to change the term RMT to FMT. The licensee stated that the dispatch of FMTs would occur at the declaration of an alert or higher emergency classification. However, the licensee proposes to reduce the number of FMTs from three to two with response times of 60 and 90 minutes.

In its July 5, 2022, letter, the licensee stated, in part, that:

There are no special or unique features in either the topography in the area surrounding [Davis-Besse] that would require three RMTs or in the duties assigned to the RMTs that would necessitate the staffing of three teams. The topography surrounding the [Davis-Besse] site is essentially flat, open farmland, with no distinctive terrain features or structures that would inhibit travel during an emergency response. The [Davis-Besse] site is adjacent to Lake Erie, and nearly half of the 10-mile Emergency Planning Zone is over the water, which is not surveyed by site personnel.

The July 5, 2022, letter, also states that emergency response drills at Davis-Besse have been conducted using two RMTs instead of three. The licensee identified four drills conducted between February 2021 and May 2022 where only two RMTs were used. The licensee stated that all drill objectives were met during these drills, which further demonstrates that field monitoring team emergency response functions can be completed when two teams are utilized.

Based on this demonstrated performance, the licensee determined that all required survey tasks can be performed at Davis-Besse if the required number of RMTs is reduced from three to two.

Based on the information discussed above, the NRC staff finds it acceptable to reduce the number of FMTs from three to two with response times of 60 and 90 minutes of an alert of higher emergency classification. Specifically, the NRC staff determined that this is consistent with the guidance provided in the revised table B-1. In addition, the licensee has demonstrated that it can perform offsite surveys using only two FMTs and the licensee has not identified any topographical features that would inhibit travel during an emergency response. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the offsite survey major task.

Onsite (Out-of-Plant) and In-Plant Surveys In the revised table B-1, the radiation protection (RP) function encompasses in-plant surveys and protective actions. The NRC staffs review of the staffing for in-plant protective actions is

discussed in section 3.2.6 of this SE. For the RP function, the revised table B-1 recommends having two RP personnel on-shift for single unit sites such as Davis-Besse. In addition, the revised table B-1 states that the OSC should be staffed with three more RP technicians within 60 minutes and another three RP technicians within 90 minutes of an alert or higher emergency classification. However, the revised table B-1 does not indicate how many RP personnel should be assigned specifically to in-plant surveys. The revised table B-1 also recommends having one FMT staffed within 60 minutes of an alert or higher emergency classification to perform onsite (out-of-plant) surveys. The revised table B-1 also allows augmenting personnel to be assigned to multiple functions provided they are capable of performing those functions at any given time.

The current Davis-Besse emergency plan has one RP technician on-shift to perform onsite and in-plant surveys, and one RP technician responding within 60 minutes of notification of an alert or higher emergency classification. The licensee proposes to require one additional RP technician responding within 90 minutes of an alert or higher emergency classification to perform onsite and in-plant surveys.

The licensee stated that the onsite area is small enough to allow a single individual to monitor the site without the use of a vehicle. The licensee noted that improvements in the plant computer systems, as it relates to the availability of plant data and trending analyses, has been extended to data associated with area radiation and plant process monitoring. The licensee stated, in part, that: 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.

Based on the information discussed above, the NRC staff finds that, with the proposed changes, the minimum on-shift and augmented staffing for onsite and in-plant surveys is acceptable.

Specifically, the augmentation by an RP technician within 90 minutes of an alert or higher emergency classification would enhance the licensees capability to perform onsite and in-plant surveys at Davis-Besse. In addition, the NRC staff finds that the improvements in the plant computer systems supports the augmentation of one RP technician within 60 minutes and one RP Technician within 90 minutes of an alert of higher emergency classification. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the onsite and in-plant survey functions.

Chemistry/Radiochemistry With the revision of table B-1, the chemistry/radiochemistry major task was removed from the NUREG-0654 guidance.

The current Davis-Besse emergency plan identifies the chemistry/radiochemistry tasks as being performed by the on-shift chemistry technician, which is augmented by another chemistry technician with a response time of 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of notification of an alert or higher emergency classification. The licensee proposes to eliminate the chemistry/radiochemistry function from the Davis-Besse emergency plan, including the listing of on-shift and augmented staff positions for this function.

The NRC staff determined that the proposed elimination of the chemistry/radiochemistry function from the Davis-Besse emergency plan is consistent with the revised table B-1. The

NRC staff finds that this change is acceptable because the need for immediate reactor sampling has been reduced due to the variety of plant indications of fuel damage available to plant personnel. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the chemistry/radiochemistry function.

3.2.5 Plant System Engineering, Repair, and Corrective Actions For the major functional area of plant system engineering, repair, and corrective actions, the original table B-1 lists (1) technical support and (2) repair and corrective actions as the major tasks.

Technical Support With the revision of table B-1, technical support falls under the engineering function. The revised table B-1 recommends one on-shift core/thermal hydraulics engineer to be augmented by one core/thermal hydraulics engineer, one electrical/instrument and controls (I&C) engineer, and one mechanical engineer within 60 minutes of the declaration of an alert or higher emergency classification. The revised table B-1 recommends additional staff to perform the engineering function, as needed, to respond within 90 minutes of the declaration of an alert or higher emergency classification.

The current Davis-Besse emergency plan identifies the shift technical advisor as the on-shift core/thermal hydraulics engineer. The emergency plan states that a TSC core/thermal hydraulic engineer and the TSC engineering manager would augment the response within 30 minutes (normal hours) or 60 minutes (off hours) of notification of an alert or higher emergency classification. Additionally, one I&C engineer, one mechanical engineer, and one electrical engineer would augment the response at the TSC within 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this notification.

The licensee did not propose any changes to the on-shift core/thermal hydraulics engineer position. The licensee proposed to change the response times for the augmenting core/thermal engineer, electrical engineer, and mechanical engineer to 60 minutes following the declaration of an alert or higher classification. The title of the TSC engineering manager would be changed to TSC engineering coordinator, with a response time of 90 minutes following the declaration of an alert or higher classification. The I&C engineering position would be removed from the emergency plan.

The licensee stated that overlapping expertise between the electrical and I&C engineer positions negates the need for the presence for both disciplines in the TSC. Therefore, the NRC staff determined that retaining one TSC electrical engineer position and eliminating the TSC instrumentation & control (I&C) engineer position is consistent with the revised table B-1 recommendation to have one augmenting TSC electrical/I&C engineer. The NRC staff finds that reducing the response time for the augmenting engineers to 60 minutes following the declaration of an alert or higher classification is an improvement over the 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> response time.

The revised table B-1 does not specify a TSC engineering coordinator, but it does recommend that additional staff to augment the engineering function to respond within 90 minutes of the declaration of an alert or higher emergency classification. Thus, the NRC staff finds that the

proposed response time for the TSC engineering coordinator to be consistent with the revised table B-1.

The licensee also stated that its 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. The NRC staff also determined that the capability of the shift technical advisor to monitor plant parameters has improved and the burden has been reduced over time due to the improvements to the plant computer system and other enhancements discussed in section 3.1 of this SE. The NRC staff finds that this supports the proposed changes related to the technical support task.

Based on the above, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the technical support function.

Repair and Corrective Actions The revised table B-1 specifies that the following supervisors and maintenance personnel should respond to the OSC to support repair team activities:

One lead OSC supervisor within 60 minutes of the declaration of an alert or higher emergency classification.

One electrical supervisor, one mechanical supervisor, and one I&C supervisor (may be combined with the electrical supervisor) within 90 minutes of the declaration of an alert or higher emergency classification.

One electrician and one mechanic within 60 minutes of the declaration of an alert or higher emergency classification to provide support for emergency core cooling system equipment (ECCS), event mitigation, and equipment repair.

One I&C technician within 90 minutes of the declaration of an alert or higher emergency classification to provide assistance with logic manipulation, support for event mitigation and equipment repair, and support of digital I&C, if applicable.

Additional I&C staff, electricians, and mechanics, as needed, within 90 minutes of the declaration of an alert or higher emergency classification.

The current Davis-Besse emergency plan specifies that the repair and corrective actions tasks are performed on-shift by a mechanic, an electrician, and an I&C technician. These positions are augmented at the OSC by an additional mechanic, electrician, and I&C technician within 30 minutes (normal hours) or 60 minutes (off normal hours) of the notification of an alert or higher emergency classification. The OSC manager is responsible for OSC personnel, including augmenting personnel to perform repairs and corrective actions, and has the same augmented response time.

The licensee proposes to eliminate the on-shift repair team staffing from the Davis-Besse emergency plan. The OSC manager position would be renamed as the OSC coordinator, and would direct repair and assessment personnel until the respective discipline supervisors arrive.

The licensee proposes to have the OSC coordinator, mechanic, and electrician respond within 60 minutes and the I&C technician respond within 90 minutes of the declaration of an alert or higher emergency classification. The licensee proposes to add the mechanical maintenance coordinator, electrical maintenance coordinator, and I&C coordinator positions to the emergency plan, which will staff the OSC within 90 minutes of the declaration of an alert or higher emergency classification.

The licensee stated that to support the objective of the single failure criterion, the Davis-Besse ECCS incorporates a diverse and redundant system design. The ECCS consists of a core flooding tank on both reactor coolant system 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.

The licensee stated that crediting the robust ECCS capability and protection against single point failures provides the basis for removal of maintenance personnel from on-shift and revising the response times for mechanical, electrical, and I&C personnel. The licensee determined that the proposed changes would not result in a reduction in response capability.

The NRC staff finds the availability of on-shift operators with the knowledge, skills, and abilities, to perform all tasks that may be required to implement the Davis-Besse abnormal operating procedures and emergency operating procedures, the redundant and diverse ECCS design, and the proposed augmenting maintenance personnel supports the proposed elimination of the on-shift repair team staffing and changes to the augmentation time for the OSC repair and corrective actions personnel. In addition, the NRC staff determined that with the proposed change the staffing requirements for the repair and corrective action personnel in the Davis-Besse emergency plan would be consistent with the guidance in the revised table B-1.

Based on the above, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the repair and corrective action function.

3.2.6 Protective Actions (In-Plant)

In the original table B-1, the in-plant protective actions functional area included the following tasks: access control; RP coverage for repair and corrective actions, search and rescue, first aid, and firefighting; personnel monitoring; and dosimetry. In the revised table B-1, in-plant surveys and protective actions were combined under the RP function. The NRC staffs review of the staffing for in-plant surveys is discussed in section 3.2.5 of this SE. For the RP function, the revised table B-1 recommends having two RP personnel on-shift for single unit sites such as Davis-Besse. In addition, the revised table B-1 states that the OSC should be staffed with three more RP technicians within 60 minutes and another three RP technicians within 90 minutes of an alert or higher emergency classification. However, the revised table B-1 does not indicate how many RP personnel should be assigned specifically to in-plant protective actions. The revised table B-1 also allows augmenting personnel to be assigned to multiple functions provided they are capable of performing those functions at any given time.

Table 5-1 of the current Davis-Besse emergency plan requires two on-shift RP technicians for the in-plant protective actions functional area but allows these positions to be filled by someone who also fills another position. The licensee stated that it currently maintains one RP technician on-shift. The current emergency plan requires augmentation by one RP technician in the OSC within 30 minutes (normal hours) or 60 minutes (off normal hours) of the notification of an alert or higher emergency classification. In addition, the emergency plan requires augmentation by another three RP technicians in the OSC within 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the notification of an alert or higher emergency classification.

The licensee proposed to revise the Davis-Besse emergency plan to add one RP technician to the on-shift staff for the protective actions function. In addition, the protective actions function would be augmented by two RP technicians within 60 minutes and an additional two RP technicians within 90 minutes of the declaration of an alert or higher emergency classification.

These RP technician positions would continue to perform activities related to access control, dosimetry, job coverage for repair and corrective actions, and personnel monitoring.

The licensee stated, in part, that:

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 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.

Based on the technological improvements for access control and electronic area radiation monitoring implemented at Davis-Besse, the NRC staff finds that the licensees proposed changes to the emergency plan related to the protective action function would not result in a loss of function or impact to the timing of the performance of protective actions. The NRC staff also determined that the proposed changes related to the staffing requirements for in-plant surveys and protective actions are consistent with the guidance for the radiation protection function in the revised table B-1. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of

10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the protective actions (in-plant) function.

3.2.7 Firefighting With the revision of table B-1, the firefighting function was deleted. The current Davis-Besse emergency plan states that the responsibility for the firefighting function is assigned to the on-shift operations personnel who make up the station fire brigade, as well as offsite support as needed.

The licensee proposed to remove the firefighting function from the Davis-Besse emergency plan. The NRC staff finds this proposed change to be acceptable because it is consistent with the revised table B-1 and the firefighting function will continue to be maintained as part of the Davis-Besse fire protection plan.

3.2.8 Rescue Operations and First-Aid With the revision of table B-1, the rescue operations and first aid functional area was deleted.

The current Davis-Besse emergency plan states that one non-licensed operator will fulfill rescue operations and first aid as an ancillary duty.

The licensee proposed to remove the reference to rescue operations and first aid from table 5-1 of the Davis-Besse emergency plan. The NRC staff finds this proposed change to be acceptable because it is consistent with the revised table B-1 and the licensee will continue to retain the rescue operations and first aid function as an ancillary duty of the site fire brigade.

3.2.9 Site Access Control and Personnel Accountability The site access control and personnel accountability functions were included in NUREG-0654, Revision 1, but are not included in the revised table B-1. The current Davis-Besse emergency plan states that site access control and accountability function is staffed by the security shift supervisor and the central alarm station operator on shift, along with additional security personnel in accordance with the Davis-Besse physical security plan.

The licensee proposes to remove the site access control and personnel accountability function from the Davis-Besse emergency plan. The NRC staff finds this proposed change to be acceptable because it is consistent with the revised table B-1 and the licensee will continue to implement the site access control and personnel accountability function as part of the physical security plan. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the site access control and personnel accountability function.

3.3 ERO Position Changes A summary and evaluation of changes to the augmenting ERO by facility was provided in attachment 3 to the LAR. The NRC staffs evaluation of ERO position changes described in section 3.2 are not repeated here. The licensee stated that some positions proposed to be deleted from the Davis-Besse emergency plant would continue to be maintained in emergency plan implementing procedures (EPIPs).

3.3.1 EOF Position Changes EOF Position Changes Current Position Proposed Position Change Emergency Offsite EOF Manager Title change only Manager RMT Coordinator FMT Coordinator Title change only RMTs FMTs Title change only Technical Liaison(s) State Emergency Title change only Operations Center Liaison(s)

EOF Operations Advisor Operations Communicator Revised title and position NRC Liaison Offsite Agency Liaison Revised title and position None Health Physics Network New position (HPN) Communicator Emergency Director None Deleted position Advisor Emergency Planning None Deleted position Advisor Emergency Facility None Deleted position Services Manager Radiological Testing None Deleted position Laboratory Coordinator Assembly Area Coordinator None Deleted administrative position - maintained in EPIPs EOF Administrative None Deleted administrative Assistant position - maintained in EPIPs Maintenance Service None Deleted administrative Personnel position - maintained in EPIPs Log and Status Board None Deleted administrative Keeper position - maintained in EPIPs As discussed in section 3.2.2 of this SE, the licensee proposes to transfer the command and control functions from the control room to the TSC and EOF within 60 minutes of the declaration of an alert or higher emergency classification. The TSC would be responsible for onsite activities, and the EOF would be responsible for offsite activities.

Currently, the EOF operations advisor performs duties associated with event classification. The licensee stated that with the proposed changes the event classification function would be performed solely in the TSC, so there is no longer a need for the EOF operations advisor position. The licensee proposes to replace the EOF operations advisor position with the operations communicator position, which will be responsible for communication of plant status information between emergency response facilities. The NRC staff finds this change to be acceptable because it aligns with the changes to the TSC and EOF command and control responsibilities.

With the proposed changes, the NRC communications function will be transferred from the control room to the TSC. The licensee proposes to add the Health Physics Network (HPN) communicator position to the EOF to support site response to NRC questions regarding radiological conditions associated with the event. The HPN communicator position will be staffed within 90 minutes of the declaration of an alert or higher emergency classification. The NRC liaison position in the EOF will be replaced by the offsite agency liaison position to provide responses to questions from offsite agencies. The NRC staff finds these changes to be acceptable because they align with the changes to the TSC and EOF command and control responsibilities.

The licensee proposes to eliminate the emergency director advisor position in the EOF. The licensee stated that this position is not responsible for performance of any emergency preparedness or command and control functions. The licensee stated that this position was originally added to support the emergency director in an effort to improve overall facility performance. The licensee stated that the implementation of facility drills since this position was added has provided the EOF staff with the expertise required to perform their functions as described in the emergency plan. Therefore, the NRC staff finds it acceptable to delete this position from the emergency plan.

The licensee proposes to eliminate the emergency planning advisor position, which is currently responsible for assessing facility readiness and providing oversight for the State/local communicator. The NRC staff finds this change acceptable because these responsibilities will be transferred to the EOF manager with the proposed changes.

The licensee proposes to eliminate the emergency facilities services manager and administrative positions listed in the table above. The emergency facilities services manager is responsible for procurement of personnel and equipment and provides oversight of the EOF administrative personnel. The EOF assembly area coordinator serves as the point of contact for the assembly area coordinators in the field. The licensee proposes to transfer the EOF assembly area coordinator responsibilities to the TSC security coordinator. For the other administrative positions, the licensee stated these support functions would be maintained in site EPIPs. The NRC staff finds these changes acceptable because the licensee has determined that these change to the emergency plan would not result in a reduction in capability for performance of onsite protective action functions.

The licensee proposes to eliminate the radiological testing laboratory coordinator position, which is responsible for performing habitability surveys of the Davis-Besse administration building and preliminary environmental sample analysis. The licensee stated that the duties associated with this position can be performed by the radiation monitoring technicians already performing habitability surveys in the Davis-Besse administration building. Supervisor functions related to protective actions in the building will be the responsibility of the OSC RP coordinator. Therefore, the NRC staff finds it acceptable to delete this position from the emergency plan.

Based on the above and the NRC staffs findings in section 3.2 of this SE, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to ERO positions in the EOF.

3.3.2 TSC Position Changes TSC Position Changes Current Position Proposed Position Change TSC Emergency Plant Emergency Coordinator Title change only Manger TSC Engineering Manager Engineering Coordinator Title change only TSC Assistant Emergency TSC Operations Coordinator Title change only Plant Manger Emergency RP Manager RP Coordinator Title change only Emergency Security TSC Security Coordinator Title change only Manager None ENS Communicator New position None TSC Operations New position Communicator None TSC Maintenance New position Coordinator None TSC Manager New position Operations and Severe None Deleted position Accident Management Engineers TSC Computer Technician None Deleted position TSC Engineering Lead None Deleted position TSC I&C Engineer None Deleted position The NRC staffs evaluation of the proposed new ENS communicator position is discussed in section 3.2.3 of this SE.

The licensee proposes to add the TSC operations communicator position. This position would be responsible for communications with counterparts located in the control room and EOF for the purpose of transmitting changes in plant status to the emergency response facilities. This position will be staffed within 90 minutes of the declaration of an alert or higher emergency classification. The NRC staff finds this change acceptable because it would enhance communications between the emergency response facilities.

The licensee proposes to add the TSC maintenance coordinator position which would serve as a liaison between the TSC and OSC for maintenance related activities. The maintenance manager will also be able to coordinate requisition of materials and supplies for the OSC as needed. The maintenance coordinator position will be staffed within 90 minutes of the declaration of an alert or higher emergency classification. The NRC staff finds this change acceptable because it would be an enhancement.

The licensee proposes to add the TSC manager position as a dedicated position responsible for oversight of the TSC, including ensuring positions are staffed, facility activation is completed and technical communications between the control room and other emergency response facilities is maintained. This position will be staffed within 90 minutes of the declaration of an alert or higher emergency classification. The NRC staff finds this change acceptable because it would be an enhancement.

The licensee proposes to eliminate the operations and severe accident management engineering positions in the TSC. Currently, these positions provide non-specific support to the engineering manager. The licensee also proposes to eliminate the I&C engineering position. In section 3.2.3 of this SE, the NRC staff found the proposed augmentation by the core/thermal hydraulic, electrical, and mechanical engineers was acceptable for the technical support function. The licensee stated that additional support personnel will be augmented on an as needed basis. Therefore, the NRC staff finds that it is acceptable to delete the TSC operations and severe accident management engineering positions and the TSC I&C engineering position from the emergency plan.

The licensee proposes to eliminate the TSC computer technician position. The licensee stated that the upgraded computer systems on site allow information regarding plant conditions to be readily available on computers in emergency response facilities and other key areas. Thus, the licensee determined that there is no longer a need for dedicated computer personnel to access plant status and relay the information manually. The site has also upgraded the Emergency Response Data System (ERDS) to allow for continuous access by the NRC. The action to verify the ERDS link upon facility staffing will be assigned to the ENS communicator, a position being added to the TSC. Therefore, the NRC staff finds it acceptable to delete the TSC computer technician position from the emergency plan.

The licensee proposes to eliminate the optional TSC engineering lead position, which is responsible for coordination of the core/thermal hydraulic, electrical, mechanical, and I&C engineer, and interfacing with the TSC operations lead. The licensee stated that with the transition of the TSC Operations Lead to the Operations Coordinator position, the TSC Engineering Manager will be able to provide the coordination function for the staff engineers in that facility and, as a result, the TSC Engineering Lead position can be eliminated. The NRC staff finds it acceptable to eliminate the TSC engineering lead position from the emergency plan because the licensee has determined that there would not be a loss in capability to perform the engineering coordination function.

Based on the above and the NRC staffs findings in section 3.2 of this SE, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to ERO positions in the TSC.

3.3.3 OSC Position Changes OSC Position Changes Current Position Proposed Position Change OSC Manager OSC Coordinator Title change only OSC RP Coordinator OSC Health Physics Title change only Manager None OSC Mechanical New position Maintenance Coordinator None OSC Electrical Maintenance New position Coordinator None OSC I&C Maintenance New position Coordinator OSC System Engineers None Deleted position Assistant OSC Manager None Deleted position

OSC Position Changes Current Position Proposed Position Change OSC Materials Manager None Deleted position The NRC staffs evaluation of the proposed OSC mechanical maintenance, electrical maintenance, and I&C maintenance coordinators is discussed in section 3.2.5 of this SE.

The licensee proposes to eliminate the OSC systems engineer positions, which provide non-specific support to the OSC manager. The licensee stated that with the proposed changes sufficient engineering expertise is provided by the TSC. In section 3.2.3 of this SE, the NRC staff found the proposed augmentation in the TSC by the core/thermal hydraulic, electrical, and mechanical engineers, was acceptable for the technical support function. The licensee stated that additional support personnel will be augmented on an as needed basis as deemed necessary by the TSC engineering coordinator. Therefore, the NRC staff finds the proposed change acceptable.

The licensee proposes to eliminate the assistant OSC manager position, which provides non-specific support to the OSC manager. The licensee stated that the proposed change provides for assistance to the OSC manager on an as-needed basis depending on the nature of the event and does not require this as a dedicated position for performance of OSC activities.

The licensee stated that this change is consistent with the standardized EHNC fleet OSC organizational structure. The NRC staff finds this change acceptable because the licensee has determined that there would not be a loss in capability to perform this function.

The licensee proposes to eliminate the OSC material manager position which provides non-specific support to the OSC manager. The NRC staff finds this change acceptable because the licensee stated it would maintain the available material management expertise in the EOF and TSC.

Based on the above and the NRC staffs findings in section 3.2 of this SE, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to ERO positions in the OSC.

3.3.4 JIC Position Changes The revised table B-1 recommends that JIC staff assigned to address media inquiries be capable of performing this function within 60 minutes of the declaration of an alert or higher emergency classification level, but notes that this function does not need to be performed at the TSC or OSC. The revised table B-1 further recommends additional staff to perform JIC functions be capable of performing their function within 60 minutes of the declaration of a site area emergency or general emergency. For the JIC, the revised table B-1 notes: Emergency response facility activation timing is not the concern; it is whether the facility staff is performing the stated function(s) within the time specified. The revised table B-1 does not specify an on-shift capability and does not identify specific staff positions for the augmenting minimum staff.

JIC Position Changes Current Position Proposed Position Change Audio/Visual Coordinator Media Relations Title change only Coordinator News Statement Information Coordinator Title change only Coordinator None Logistics Coordinator New position Public Relations Nuclear Communications Title change and combines the Communicator (EOF) Coordinator positions JIC Writer Technical Briefer Technical Advisor Title change and combines the JIC communicator positions Public Inquiry Hotline Media Monitor/Rumor Title Change and combines the Operator Control positions Media Assistant Public Affairs Duty Officer None Deleted position JIC Administrative None Deleted administrative position -

Assistant maintained in EPIPs The licensee will continue to staff the JIC at the declaration of an alert or higher emergency classification. The licensee proposes to add the JIC logistics coordinator position, which would be responsible for coordination of facility support activities and act as a liaison between State Public Information Officers and site personnel at the JIC.

The licensee proposes to combine the EOF public relations communicator and JIC writer positions into the nuclear communications coordinator at the JIC. Currently, the public relations communicator is responsible for provided updates from the EOF to the JIC writer. The licensee stated, in part, that:

The re-assignment of technical and plant support activities to the TSC reduces the need for EOF leadership to provide technical information to the JIC. As a result, the Nuclear Communications Coordinator is able to obtain needed information from the Technical Advisor in the JIC. Additionally, the Technical Advisor in the JIC will be in contact with the Operations Communicator in the EOF and will be able to obtain any needed technical or plant status information via that communications link.

These changes support continued performance of communications and public relations information and no longer require dedicated positions in the EOF for performance of these functions.

The licensee proposed to combine the JIC communicator and technical briefer functions into a single JIC technical advisor position. The technical advisor would have access to plant operations information via bridge line connected to other emergency response facilities.

With the proposed changes, response to media questions will be the responsibility of the media monitor/rumor control coordinator. The licensee stated, in part, that:

Improvements in JIC processes including the use of social media and internet capability for response to requests from the public have eliminated the need for dedicated Public Inquiry Hotline Operator and Audio/Visual Coordinator positions in the JIC. Using available internet resources, the Media Monitor/Rumor Control position is able to monitor social and news media and report rumors to JIC Management.

The licensee proposes to eliminate the public affairs duty officer position, which is responsible for keeping the public relations communicator in the EOF appraised of JIC activities and keeping the technical briefer appraised of plant status. The licensee stated that communications for assigned to this position would be maintained by the technical advisor under the proposed change. With the re-assignment of the public relations communicator duties to the nuclear communication coordinator, to the EOF, information regarding plant status will be communicated through periodic briefings in the EOF.

The licensee proposes to eliminate the administrative assistant position from the emergency plan. The licensee stated the administrative support function is not required for implementation of emergency plan requirements, but the function will be addressed in EPIPs.

Based on the above, the NRC staff determined that the proposed changes to the JIC staffing are consistent with the guidance in the revised table B-1, and the licensee would continue to have sufficient staff to address media inquiries within 60 minutes of the declaration of an alert or higher emergency classification level. Therefore, the NRC staff has determined that the proposed Davis-Besse emergency plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50, with respect to the for management and coordination of media information.

3.4 Additional Changes The licensee proposes to remove certain details regarding the vehicles used for the FMTs from the emergency plan. The NRC staff finds removal of these details is acceptable because these details are not required to be in the emergency plan.

The licensee proposes to remove references to the corporate assistance center and site emergency operations center from the emergency plan. The NRC staff finds these changes acceptable because these facilities do not have any responsibilities within the revised Davis-Besse emergency plan.

The licensee proposes to remove references to the radiological testing laboratory and dose assessment center from the emergency plan. The NRC staff finds this change acceptable because the radiological testing laboratory and dose assessment center are encompassed within the TSC and EOF, respectively.

The licensee proposes to remove references to chemistry procedures. The NRC staff finds this change acceptable because these procedures are implemented by licensing processes outside of the emergency plan.

The licensee proposed to revise the periodic training requirements listed in the emergency plan for emergency response personnel. The NRC staff found this to be acceptable because it is consistent with the changes made to the ERO staffing requirements.

3.5 Summary Based on its review of the proposed changes to the Davis-Besse emergency plan, the NRC staff finds that with the proposed changes, the Davis-Besse emergency plan (1) will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in section IV.A of appendix E to 10 CFR Part 50 and (2) will provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Ohio State official was notified on September 26, 2022, of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federal Register on July 21, 2022 (87 FR 43556).

Accordingly, based upon the environmental assessment, the Commission has determined that the issuance of this amendment will not have a significant effect on the quality of the human environment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Michael Norris, NSIR Date of issuance: November 15, 2022

ML22269A358 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NSIR/DPR/RLB/BC(A)

NAME BPurnell SRohrer FSacko DATE 10/20/22 9/29/22 9/8/22 OFFICE OGC (NLO) NRR/DORL/LPL3/BC NRR/DORL/DD NAME STurk NSalgado GSuber DATE 10/20/22 10/26/22 10/27/22 OFFICE NRR/D NRR/DORL/LPL2-2/PM NAME AVeil (MKing for) LHaeg DATE 11/15/22 11/15/22