View source for L-22-152, Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan

{{Adams
| number = ML22186A121
| issue date = 07/05/2022
| title = Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan
| author name = Huey D
| author affiliation = Energy Harbor Nuclear Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000346
| license number = NPF-003
| contact person = 
| case reference number = EPID L-2022-LLA-0013, L-22-152
| document type = Letter type:L, Response to Request for Additional Information (RAI)
| page count = 4
| project = EPID:L-2022-LLA-0013
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:energy                                                       Energy Harbor Nuclear Corp.
Davis-Besse Nuclear Power Station harbor                                                                5501 N State Route 2 Oak Harbor, Ohio 43449 Douglas B. Huey                                                                         419-321-8300 General Plant Manager Nuclear July 5, 2022                                                                 10 CFR 50.90 L-22-152 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 Response to Request for Additional Information regarding a License Amendment Request that revises the Davis-Besse Nuclear Power Station Emergency Plan (EPID No. L-2022-LLA-0013)
By {{letter dated|date=January 19, 2022|text=letter dated January 19, 2022}} (Accession No. ML22019A236), Energy Harbor Nuclear Corp. requested Nuclear Regulatory Commission (NRC) approval for a license amendment request (LAR). The LAR revises the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse) emergency plan to eliminate on-shift staffing positions, increase emergency response facility (ERF) augmentation times, revise ERF staffing positions, revise facility position titles to be consistent with the Energy Harbor Nuclear Corp. fleet, and eliminate information from the emergency plan contained in implementing procedures and instructions. By email dated June 13, 2022, the NRC staff requested additional information regarding the Davis-Besse Emergency Plan LAR.
The Energy Harbor Nuclear Corp. response to the June 13, 2022, NRC request is attached.
There are no regulatory commitments contained in this submittal. 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 July-5", 2022.
Sincerely,

Davis-Besse Nuclear Power Station, Unit No. 1 L-22-152 Page2

==Attachment:==

Response to Request for Additional Information cc: NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board

Attachment L-22-152 Response to Request for Additional Information Page 1 of 2 By {{letter dated|date=January 19, 2022|text=letter dated January 19, 2022}}, Energy Harbor Nuclear Corp. submitted a license amendment request for Nuclear Regulatory Commission (NRC) review and approval.
By email dated June 13, 2022, NRC staff requested additional information to complete its review. The request for additional information is presented below in bold type and is followed by the Energy Harbor Nuclear Corp. response.

===Response===
A review of documentation was conducted to provide a technical justification of the Davis-Besse Nuclear Power Station (DBNPS) current requirement of three RMTs during a response following an Alert declaration or higher. Multiple documents were reviewed, including the Safety Evaluation Report (SER) version of the Emergency Plan, and its supporting documentation or correspondence, and reviews of regulatory correspondence to identify any finding, violation, or performance deficiency associated with offsite monitoring. No specific evidence of a deficiency was found.

Attachment L-22-152 Page 2 of 2 There are no special or unique features in either the topography in the area surrounding the DBNPS 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 DBNPS site is essentially flat, open farmland, with no distinctive terrain features or structures that would inhibit travel during an emergency response. The DBNPS 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.
A review was conducted of the SER version of the DBNPS Emergency Plan with supporting documentation from the time of development to determine if there were any unique reasons that three RMTs were selected as part of the DBNPS Emergency Response Organization staffing; however, there is no discussion contained within the documentation to explain why this number of RMTs was designated.
A review of regulatory correspondence from the period of submittal of the SER version of the DBNPS Emergency Plan did not identify any finding, violation, or performance deficiency associated with offsite monitoring.
While the current DBNPS Emergency Plan assigns sufficient qualified individuals to staff three RMTs following a declaration of an Alert or higher, Energy Harbor Nuclear Corp. has demonstrated that offsite survey tasks can be adequately performed by using two teams.
During implementation of the DBNPS emergency response drill and exercise program, there have been drills conducted utilizing two RMTs, versus three. Since the beginning of 2021 until present, there have been a total of six drills conducted, five in 2021 and one in 2022. Of these drills, two were conducted with three RMTs and four drills were conducted using two RMTs. Drills with two RMTs were conducted on February 23, 2021, August 24, 2021, October 5, 2021, and May 24, 2022. All drill objectives were repeatedly met when two RMTs were utilized, which further demonstrates that field monitoring team emergency response functions can be completed when two teams are utilized. Based on this demonstrated performance, Energy Harbor Nuclear Corp.
determined that all required survey tasks can be performed at DBNPS if the required number of RMTs is reduced from three to two.}}